General behavioural guidelines
for management and employees of the Bohle Group (‘Code of Conduct’)Contents
I. Preamble
For Bohle AG and its subsidiaries (hereinafter referred to as ‘Bohle’ or ‘Bohle Group’) as a family-owned company, the acceptance and observance of social and societal responsibility is of particular importance. The Supervisory Board, Management Board and management (hereinafter referred to collectively as ‘management’) recognise their social responsibility. The actions of the company, management and all employees (including all executives, temporary and permanent employees, full-time and part-time employees, trainees, regardless of whether they are female, male or diverse, hereinafter referred to collectively as ‘employees’) of the Bohle Group worldwide are guided in particular by the values of integrity, fairness, justice, sustainability and high ethical and moral standards. Mutual respect is the basis of our daily interaction. These principles are an expression of the company's responsibility towards society, the environment, business partners, employees and other stakeholders. Management has a particular responsibility in this respect, but these goals can only be achieved if all those involved work together. The Code of Conduct therefore formulates binding requirements for all employees.
For Bohle AG and its subsidiaries (hereinafter referred to as ‘Bohle’ or ‘Bohle Group’) as a family-owned company, the acceptance and observance of social and societal responsibility is of particular importance. The Supervisory Board, Management Board and management (hereinafter referred to collectively as ‘management’) recognise their social responsibility. The actions of the company, management and all employees (including all executives, temporary and permanent employees, full-time and part-time employees, trainees, regardless of whether they are female, male or diverse, hereinafter referred to collectively as ‘employees’) of the Bohle Group worldwide are guided in particular by the values of integrity, fairness, justice, sustainability and high ethical and moral standards. Mutual respect is the basis of our daily interaction. These principles are an expression of the company's responsibility towards society, the environment, business partners, employees and other stakeholders. Management has a particular responsibility in this respect, but these goals can only be achieved if all those involved work together. The Code of Conduct therefore formulates binding requirements for all employees.
II. General principles, law and order
Bohle Management undertakes to fulfil its social responsibility in all its business activities. In all business activities and decisions, the management undertakes to comply with the applicable national laws, international regulations and other relevant provisions of the countries in which it operates. Business partners, employees and all other stakeholders are to be treated fairly and respectfully. Contracts are honoured, taking into account changes in the framework conditions. These principles and obligations also apply directly to all employees of Bohle AG and all companies of the Bohle Group worldwide that are included in the Bohle consolidated financial statements
Bohle Management undertakes to fulfil its social responsibility in all its business activities. In all business activities and decisions, the management undertakes to comply with the applicable national laws, international regulations and other relevant provisions of the countries in which it operates. Business partners, employees and all other stakeholders are to be treated fairly and respectfully. Contracts are honoured, taking into account changes in the framework conditions. These principles and obligations also apply directly to all employees of Bohle AG and all companies of the Bohle Group worldwide that are included in the Bohle consolidated financial statements
III. Principles of corporate responsibility
a) No corruptionIn particular, all those involved in the procurement and sales process, as intermediaries between their own company and the respective suppliers and customers on the respective procurement and sales markets, bear responsibility towards their own company, towards customers and suppliers, towards the environment and towards society. When dealing with business partners (customers, suppliers) and state institutions, the interests of the company and the private interests of employees on both sides are strictly separated. Actions and (purchasing) decisions are made free of extraneous considerations and personal interests. The applicable criminal law on corruption must be observed. Among other things, the following must be observed:Offences in connection with public officials:The granting of personal benefits (in particular monetary benefits such as payments and loans, including the granting of small gifts over a longer period of time) by Bohle and its employees to public officials (such as civil servants or employees in the public sector) with the aim of obtaining benefits for Bohle or themselves or third parties is not permitted. Offences in business transactions:Personal benefits of monetary value in return for preferential treatment in business dealings may not be offered, promised, granted or approved. Similarly, personal advantages of value may neither be demanded nor accepted in dealings with business partners. Bohle hereby expressly requires its employees not to accept any promises of such advantages. Bohle employees may not offer, promise, demand, grant or accept any gifts, payments, invitations or services in business dealings that are granted with the intention of improperly influencing a business relationship or where there is a risk of jeopardising the professional independence of the business partner. This is generally not the case with gifts and invitations that are within the scope of customary business hospitality, custom and courtesy. Unless otherwise stipulated, the applicable tax regulations, such as the tax-free limit in Germany of EUR 50 net per year and person for gifts in kind, are the standard for this. If Bohle employees find themselves in a conflict of interest, or if they are unsure whether a conflict of interest exists or could arise, they can contact the legal department for advice at any time. b) Behaviour towards competitors (antitrust law) Bohle respects fair competition. Bohle therefore complies with the applicable laws that protect and promote competition, in particular the applicable antitrust laws and other laws and regulations governing competition. In dealings with competitors, these regulations prohibit in particular agreements and other activities that influence prices or conditions, allocate sales territories or customers, or improperly impede free and open competition. Furthermore, these regulations prohibit agreements between customers and suppliers that are intended to restrict customers in their freedom to determine their prices and other conditions for resale autonomously (price and condition fixing). In view of the fact that the distinction between prohibited cartels and authorised cooperation can be problematic, the legal department is available to Bohle employees and can be contacted in case of doubt.c) Conflicts of interest
In order to rule out potential conflicts of interest or the appearance of such between an employee's private and professional interests, employees are generally not permitted to do so: - To enter into or maintain financial interests in companies that may be affected by professional decisions of the employee or Bohle.
- Contracts may not be awarded to relatives, life partners or other related parties of employees. This also applies to transactions with companies in which relatives are directly or indirectly involved.
- No assumption of positions of entrepreneurial responsibility (e.g. board member, managing director, board of directors, supervisory board, advisory board) with customers, business partners or competitors.
The Executive Board decides on the approval of justified exceptions after consultation with the legal department. The perception of third parties is decisive. Even the appearance of a personal conflict of interest can be detrimental. Employees may also ask to be released from specific individual tasks that could lead to a conflict of interest if they have a legitimate interest. d) Donations and sponsoringBohle uses donations and sponsorship exclusively to support standard social projects and non-profit organisations, never for inappropriate purposes. Donations or sponsoring measures must comply with the recognised principles of corporate social responsibility. All donations made by the Bohle Group must be transparent. This applies in particular to the identity of the recipient and the planned use of the donation. The purpose and reason for the donation must be documented and legally justifiable.e) Customs and export control As a globally active company, Bohle complies with all customs and foreign trade regulations for the import and export of goods, services, information and technologies. This applies in particular to sanctions, embargoes and regulations concerning the transport of goods, technologies, services and information as well as the fight against terrorist financing. f) Business secrets Bohle obliges its employees to respect trade and business secrets. Confidential information and confidential documents may not be passed on to third parties without authorisation or made accessible in any other way, unless authorisation has been granted or the information in question is or has become publicly accessible. g) Intellectual property Bohle protects and defends the intellectual property of its own services and respects the intellectual property of third parties and expects all employees to observe the intellectual property rights of third parties. In the case of innovations, Bohle checks and secures the rights to the newly created intellectual property. Intellectual property is protected by laws such as copyright, trade mark, design and patent law. In addition, intellectual property can also be protected as a trade secret or as know-how.
- To enter into or maintain financial interests in companies that may be affected by professional decisions of the employee or Bohle.
- Contracts may not be awarded to relatives, life partners or other related parties of employees. This also applies to transactions with companies in which relatives are directly or indirectly involved.
- No assumption of positions of entrepreneurial responsibility (e.g. board member, managing director, board of directors, supervisory board, advisory board) with customers, business partners or competitors.
IV. Principles of social responsibility
a) Human rights Bohle respects and supports the observance of internationally recognised human rights and ensures that Bohle is not involved in any human rights violations. b) No discrimination Bohle respects the human rights, dignity, privacy and personal rights of every individual. A culture of respect determines the attitude towards all people. Bohle firmly condemns any form of disadvantage, discrimination and prejudice, as well as favouritism based on different gender and sexual identity, different ethnic, social or cultural backgrounds, different ages and different religious beliefs or world views, as well as disability. Bohle is committed to equal opportunities, equal rights and equal treatment and offers fair and appropriate employment conditions. Bohle undertakes to take a firm and clear stance against any form of discrimination such as disadvantage, humiliation, intimidation, oppression or offence within the framework of the applicable rights and laws. Bohle sees diversity as an enrichment that must be supported and actively promotes it within its own company and throughout the entire group of companies worldwide. The diversity of Bohle's employees is an essential pillar of Bohle's success, which must be preserved and expanded. c) Health protection Bohle guarantees a high standard of occupational health and safety in the workplace. The management supports continuous development to improve the working environment. As an employer, Bohle has a special responsibility to take preventative measures to protect employees from recognisable risks, even if these are associated with costs. d) Product safety The safety of the products developed, manufactured and sold by Bohle is a top priority for Bohle. Ensuring product safety means protection for Bohle's customers and their customers. In order to ensure the greatest possible safety of its products, Bohle is constantly working on improvements in terms of design, production and instruction. The general state of the art is not the goal for Bohle, but the minimum requirement. e) Fair working conditions Bohle respects the right to freedom of association and supports the company's social partnership. Bohle considers dialogue on an equal footing with employees and their representatives to be a critical success factor for the long-term successful development of the company. f) No forced labour Bohle rejects any form of forced labour. Bohle will not do business with companies that use, promote or support forced labour or derive economic benefits from it. g) No child labour Bohle respects and supports the regulations of the United Nations on human rights and children's rights. In particular, Bohle undertakes to comply with the Convention concerning the Minimum Age for Admission to Employment (Convention 138 of the International Labour Organisation) and the Convention concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour (Convention 182 of the International Labour Organisation). If a national regulation concerning child labour provides for stricter standards, these must be given priority. Bohle will not do business with companies that use, promote or support child labour or derive economic benefits from it. h) Environmental protection and sustainability Bohle is committed to the goal of protecting the environment for present and future generations. Laws enacted to protect the environment must be observed. Bohle supports environmentally conscious and sustainable behaviour by its employees. In its business activities, Bohle endeavours to keep the unavoidable ecological impact of resource consumption and emissions as low as possible and to continuously reduce it through the ongoing development of internal processes, operating resources and equipment as well as products. In their work, employees are required to protect natural resources and ensure that business activities minimise the environmental impact by saving materials, planning to save energy and reducing and recycling waste. When selecting suppliers, advertising materials or other external services, each responsible person should also take ecological and social criteria into account in addition to economic considerations.
V. Suppliers and service providers
The persons responsible for purchasing at Bohle are requested to communicate the principles of this Code of Conduct Sections III. and IV. to their direct suppliers, to promote compliance with the contents of the Bohle Code of Conduct Section III. among their suppliers to the best of their ability and to request them to also comply with the Bohle Code of Conduct Sections III. and IV. The purchasing managers at Bohle are also requested to recommend to their suppliers that they in turn request their suppliers to comply with the Bohle Code of Conduct.
The persons responsible for purchasing at Bohle are requested to communicate the principles of this Code of Conduct Sections III. and IV. to their direct suppliers, to promote compliance with the contents of the Bohle Code of Conduct Section III. among their suppliers to the best of their ability and to request them to also comply with the Bohle Code of Conduct Sections III. and IV. The purchasing managers at Bohle are also requested to recommend to their suppliers that they in turn request their suppliers to comply with the Bohle Code of Conduct.
VI. Compliance
Bohle undertakes to make its employees aware of the content of this Code of Conduct and the obligations arising from it. Bohle undertakes to work towards ensuring that Bohle always complies with the principles of this Code of Conduct, in particular by designing and, if necessary, adapting guidelines and processes. Bohle shall appoint a responsible contact person (currently the Head of the Legal Department) for the Bohle Code of Conduct vis-à-vis employees and business partners, who can provide binding information on compliance with the Bohle Code of Conduct - if necessary after external consultation. In addition, Bohle takes suitable organisational measures to ensure that the Code of Conduct is adhered to by management and employees. This is done in particular by introducing and maintaining appropriate controls and plausibility checks. Violations of this guideline can lead to direct measures under labour law.
Bohle undertakes to make its employees aware of the content of this Code of Conduct and the obligations arising from it. Bohle undertakes to work towards ensuring that Bohle always complies with the principles of this Code of Conduct, in particular by designing and, if necessary, adapting guidelines and processes. Bohle shall appoint a responsible contact person (currently the Head of the Legal Department) for the Bohle Code of Conduct vis-à-vis employees and business partners, who can provide binding information on compliance with the Bohle Code of Conduct - if necessary after external consultation. In addition, Bohle takes suitable organisational measures to ensure that the Code of Conduct is adhered to by management and employees. This is done in particular by introducing and maintaining appropriate controls and plausibility checks. Violations of this guideline can lead to direct measures under labour law.