Code of Conduct

Code of Conduct of Wirthwein AG and its subsidiaries

Assumption

Wirthwein AG with its subsidiaries is a leading global manufacturer of top-quality and complex plastic parts and mold construction. Moreover, with its company Winkler Design the group of companies does business in the field of interior fittings. By means of our guidelines we commit ourselves to act responsibly and according to law towards our employees, customers, business partners and the general public.

The business principles at hand are a worldwide binding system of rules for us to act sustainably and responsibly in the business organization in addition to statutory regulations and internal agreements.

Area of validity

These guiding principles are binding for all employees of Wirthwein AG and its subsidiaries as well as for suppliers, service providers and other partners worldwide and can be considered as a standard internal system of rules how to treat staff and partners.

Laws and provisions

The relevant legal provisions of the respective countries Wirthwein is active in are the superior framework of any activity and binding for all employees.

Protection of intellectual property

Protection of intellectual property is ensured with patents, copyrights and protected trademarks, as well as responsible handling of these in the supply chain.

Financial responsibility

We comply with our company's accountability obligations regarding business documentation and accounting policies. We are responsible for accurately and transparently recording, maintaining and reporting on all financial activities.

Corruption and bribery

Open competition is crucial for our liberal basic order and market economy and has to be protected and preserved by our entrepreneurial activities. Any influence of the competition in the form of corruption or bribery has to be disapproved and refrained from at any time.

We exclusively choose our suppliers on the basis of quality, delivery reliability, price and extraordinary problem-solving skills. On the other hand, we acquire our orders by our top-quality products, cost awareness and innovative strength.

Neither may our employees grant any unlawful advantages (active bribery) to third parties nor accept such (passive bribery). Among others, this implies monetary payments and any other services which influence free decision-making for one’s own or any external advantage.

Any action that influences competition infringes our guidelines and will be taken sanctions against. This also includes self-dealing, unless the company has granted an exemption from the ban on self-dealing.

Antitrust law

The Management Board of Wirthwein AG explicitly admits to corporate governance in compliance with antitrust law. With regard to an antitrust code of conduct for employees, we refer to the “Code of conduct with respect to competitors” published by the German Association of Materials Management, Purchasing and Logistics (BME). All employees have to consider and comply with both the rules and standards at hand and the applicable antitrust regulations.

Forced labor

Forced labor is the severest form of compulsory work. It contradicts our liberal thinking according to which staff can independently and without any compulsion decide whether they want to close an employment contract within the Wirthwein Group based on contractually agreed upon employment obligations. We reject any form of forced labor. We guarantee our employees fair working conditions in accordance with the respective national standards in order to create optimum conditions for a motivated and efficient workforce to realize our business objectives.

Freedom of assembly and association

We recognize our employees‘ right of assembly and association, which we respect in terms of our free basic order that we feel very strongly committed to.

Child labor

In order to meet our social awareness and responsibility at all sites of Wirthwein, we regard it as our duty to particularly protect children against excessive workload and perils within the framework of an employment relationship.

This is the reason why we reject any form of child labor as long as children are in compulsory school age still or have not reached the age of 15 yet. Moreover, employees under the age of 18 may not perform any hazardous work and are allowed to perform night-shift work to a limited extent only and with regard to the vocational training requirements. This rule only applies if the national legal provisions do not define any higher age regulations.

Harassment

The free basic human rights are of paramount importance and have to be protected at all sites of Wirthwein by any means. In this context, personal dignity, privacy and personal rights of each individual have to be protected and respected in particular. This is why we refrain from any form of harassment, be it of physical, sexual, psychological or also verbal nature. We pursue a fair cooperation based on mutual respect.

Working time

Our working time regulations comply with the national legal provisions to meet our social responsibility towards our employees.

Payment

Apart from job security, fair payment of our employees is of top priority. The remuneration we pay for the service our employees provide conforms at least to the national legal standards and regulations.

Nondiscrimination rule

Through its international orientation as well as its global and sustainable growth strategy, Wirthwein AG takes social and cultural responsibility in particular resulting from its cooperation with employees and business partners of different origin, religion, skin color and ideology. Therefore we cultivate a relationship with foreign cultures which is based on respect and dignity. We refrain from any form of discrimination.

Apart from that, we guarantee equal opportunities and equal treatment of all employees, regardless of gender, age, sexual orientation or handicap. Employment, further development and payment of our employees depend on their own skills and personal qualifications only.

Each individual employee is committed to refrain from any form of discrimination in order to provide for a fair cooperation which is based on respect both inside the organization as well as for business partners.

Physical health and safety

We feel particularly committed to protecting our employees against work-related hazards and caring for their well-being, which are the key aspects of our internal safety and health care policy.

Within the framework of our duty of care, we take all necessary measures to ensure our employees‘ safety and health at work according to national provisions. By means of this, we want to create a safe and healthy workplace environment as well as care for satisfied and high-performing employees.

Apart from that, each individual employee is committed to substantially contribute to safety at work and health protection. This particularly implies the respective behavior at the workplace which fulfils all the relevant provisions to avoid accidents and any work-related health risks.

Dealing with resources and environmental protection

Due to our sites in ecologically valuable areas we commit ourselves to feel particularly responsible for nature and environment. This is the reason why we abide by national provisions and agreed environmental protection standards. Continuous review and constant improvement is at the core of our business processes and is expressed in our practiced environmental management system. Within the framework of our production processes we particularly see to it that our products are manufactured in a resource-conserving way by applying environmentally efficient, energy efficient and innovative technologies. We are setting further standards in this respect with our energy management system.

The focus here is on a sustainable reduction in our greenhouse gas emissions, increased use of renewable energies, and careful use of water resources. Withdrawal volumes, water consumption and water quality are complied with and successively improved in accordance with official permits and legal requirements.

We already include all energy and environmentally relevant aspects in the development process in order to minimize the use of natural resources, to reduce the burden on the environment to the lowest possible level, also with a view to minimizing greenhouse gas emissions in our value chain, and as a result to contribute to improved air quality.

We are also pushing for a reduction in all types of waste and chemicals used in the company. Responsible waste and chemical management, which we are constantly expanding, helps us to achieve this.

Each employee is requested to contribute to our environmental and energy policy objectives within the bounds of his or her possibilities and to continuously improve them.

Supply chain

We hereby request our suppliers, service providers and other partners to comply with these guidelines of Wirthwein AG with its subsidiaries and to act accordingly.

The risk of using and placing counterfeit products on the market should also be minimized by our suppliers, service providers and other partners by implementing appropriate processes.

In addition, a process should be implemented to ensure compliance with applicable export restrictions and economic sanctions and to make it transparent.

We are happy to support our partners in advancing in the area of sustainability, compliance, energy and the environment. This can be done through training and interpretation aids of the requirements placed on and by us. We also provide on-site support should the need arise.

Responsible for the implementation

Management Board and Human Resource/Compliance Management of Wirthwein AG are responsible for publishing and implementing the guidelines at hand. Each manager has to make sure that all employees will observe and actively support the principles of action in these guidelines. Each individual employee has to observe both the relevant legal provisions and the principles of action determined in the guidelines and act accordingly.

Infringement on the guidelines at hand can be reported to both managers and the responsible Local Compliance Officer of the respective site and can lead to respective consequences within the framework of in-house and legal provisions. Information from employees who report such a violation will be treated confidentially and the employee will not suffer any detriment whatsoever.

 

Creglingen, November 2021

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