Code of Conduct of Etengo AG and its Suppliers

Etengo AG is committed to corporate social and environmental responsibility. We expect our employees to comply with the principles of social, ethical and environmentally friendly behaviour, and to integrate them into the corporate culture. We also strive to continuously optimise our corporate activities and our services in terms of sustainability, and expect the same of our suppliers, to engage in a combined effort.

Our code of conduct is based on international conventions including

• the United Nations Universal Declaration of Human Rights,
• the UNICEF guidelines on Children’s Rights and Business Principles,

• the United Nations Guiding Principles on Business and Human Rights,
• the International Labour Organization (ILO) International Labour Standards and
• the United Nations Global Compact,

as well as national laws and regulations such as

• the German Supply Chain Due Diligence Act (LkSG).

For future collaboration, Etengo AG shall require its contractors to comply with the following provisions in terms of a joint code of conduct. In addition to complying with the listed principles and requirements, contractors shall also endeavour to encourage their own subcontractors to comply. A breach of this code of conduct may ultimately be grounds and cause for Etengo AG to terminate the business relationship including all associated supply contracts.

Remuneration

Remuneration shall be fair and to market standard.
It shall take into account both the national minimum wage and the minimum industry standards. In addition, the remuneration shall be sufficient to cover normal cost-of-living expenses and permit a minimum of savings. Workers shall receive all the benefits required by law, as well as clear, detailed and regular pay slips.

Working time

Working times shall be fair.
They shall comply with applicable laws and the industry standards. Overtime shall only be permitted if it is voluntary.

Forced labour

All work shall be voluntary.
It shall be done without threat of punishment. Employees shall be free to terminate work or employment at any time with reasonable notice. Unacceptable treatment of workers, such as psychological hardship, sexual and personal harassment and humiliation, shall not be tolerated.

Child labour

There shall be no child labour.
There shall be no child labour at any stage of service provision or production. The recommendation on the minimum age of employees pursuant to the ILO conventions shall be respected.

Discrimination

There shall be no discrimination.
Discrimination on the basis of a difference in gender, national, ethnic or social origin, skin colour, disability, state of health, political conviction, ideology, religion, age, pregnancy or sexual orientation shall not be permitted. In particular, employees shall not be discriminated against on the grounds of establishment of, affiliation with or membership of a trade union. The personal dignity, privacy and personal rights of each individual shall be respected.

Safety in the workplace

Safety in the workplace shall be ensured.
The employer shall be responsible for providing a safe and healthy working environment. By setting up and implementing appropriate occupational safety systems, the employer shall meet the requirements for precautions to prevent any accidents and injuries that may arise in connection with the activity. The employer shall also implement appropriate measures to prevent excessive physical or mental fatigue. In addition, employees shall be regularly informed about applicable health and safety standards and safety measures, and trained in their application.

Natural resources¹

Natural resources shall be protected.
Soil, water and air pollution, and noise emissions, shall be refrained from, as shall water overuse if it has a negative impact on people’s health, significantly impairs the natural basis for the production of food or prevents people’s access to safe drinking water or sanitary facilities. Land, forests or waters that people depend on to secure their livelihood shall only be appropriated if no legitimate rights are violated.

Industrial waste water¹

Industrial waste water shall be managed responsibly.
Waste water resulting from industrial activity, manufacturing processes and sanitary facilities shall be typed, monitored, screened and, if necessary, treated prior to discharge or disposal. In addition, effort shall be made to reduce waste water generation.

Air pollution¹

Air pollution shall be managed responsibly.
General emissions resulting from industrial activity (air and noise pollutants) as well as greenhouse gas emissions shall be typed, routinely monitored, screened and, if necessary, treated prior to emission. In addition, the functionality of exhaust gas purification systems shall be regularly ensured and effort made to minimise any emissions.

Waste and hazardous substances¹

Waste and hazardous substances shall be managed responsibly.
Solid waste shall be systematically identified, managed, reduced and responsibly disposed of or recycled. The prohibitions on the export of hazardous waste specified in the Basel Convention of 22 March 1989 as amended shall be complied with. Chemicals or other materials whose discharge to the environment pose a hazard shall be identified and managed in a safe manner when being handled, transported, stored, used, recycled or reused, and disposed of. Mercury and persistent organic pollutants shall only be used in accordance with the prohibitions of the Minamata Convention on Mercury of 10 October 2013 and in accordance with the Stockholm Convention of 23 May 2001.

Raw materials and natural resources¹

Raw materials and natural resources shall be used responsibly.
The use and consumption of resources during production and the generation of waste of any kind, including water and energy, shall be avoided or reduced. This shall be done either directly at the point of origin or by implementing specific processes and measures such as adapting production and maintenance processes or corporate procedures, using alternative materials, economising, recycling or reusing materials.

Energy

Energy shall be used efficiently.

Energy consumption shall be monitored and documented. Economical solutions shall be sought and implemented to improve energy efficiency and minimise energy consumption.

[1] Not relevant for Etengo AG

Competition

Competition shall be fair.
The standards of fair trade, fair advertising and fair competition shall be complied with. In addition, applicable antitrust laws shall be applied, in particular those that prohibit collusion and other activities that influence prices or conditions when dealing with competitors, customers and suppliers.

Privacy and confidentiality

Privacy and confidentiality shall be respected.
Reasonable expectations of suppliers, customers, consumers and employees with regard to the protection of private information shall be met. Personal information shall be collected, stored, processed, transmitted and disclosed in compliance with data protection and information security laws, and regulations issued by the authorities.

Intellectual property

Intellectual property rights shall be respected.
Intellectual property rights and customer information shall be protected when transferring technology and expertise.

Integrity, bribery and conflicts of interest

The highest standards of integrity shall be applied in all business activities.
A zero-tolerance policy shall be exercised in prohibiting all forms of bribery, corruption, extortion, embezzlement and money laundering.

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Last updated: 01/01/2023