Code of Conduct

Foreword

For ALBROMET, putting responsibility into practice has always been the foundation of our corporate culture.

Putting responsibility into practice creates trust. A trustworthy, respectful relationship with all stakeholders is the basis for our success – and has been for more than 26 years. Compliance management represents an important aspect of our company alongside quality management and occupational health and safety management as well as environmental protection.

This Code of Conduct aims to establish rules to ensure that our actions are irreproachable, correct and exemplary at all times. In addition to the Code of Conduct, our actions are determined and our corporate culture is shaped by the ALBROMET self-image and our approach to leadership – for the benefit of our employees, our company and all business partners.

ALBROMET GmbH

Managing Director

Andrea Bäring

Scope

This Code of Conduct applies to ALBROMET GmbH.

For us, compliance with the law in our business activities goes without saying. Violations, on the other hand, are not compatible with our values, because they damage the reputation of our company and can also have legal consequences.

Statutory provisions and ethics

As a company that operates throughout Europe, ALBROMET is obliged to observe a wide range of social, political and legal operating conditions at home and abroad. For us, it is a matter of course to conduct our business in compliance with applicable laws and regulations in all of the countries in which we operate.

ALBROMET undertakes to adhere to fair, ethical and transparent business practices. We do not buy in materials and services that fail to comply with national or international laws and conventions. At the same time, we are committed to using raw materials that have a legal and sustainable origin. For example, we do not knowingly source raw materials from conflict regions (“conflict minerals”).

ALBROMET attaches particular importance to compliance with the legal regulations governing the employment of staff and does not tolerate illegal employment or moonlighting.

Responsibility

ALBROMET gives its employees as much personal responsibility as possible. At the same time, we are committed to statutory compliance and are guided by dream company principles.

One of the functions of our managers is to act as contact persons for employees: for questions of any kind, for professional and personal concerns, for issues concerning compliance with legal provisions.

Cooperation

Our employees are always selected and promoted on the basis of their qualifications and skills. We condemn all forms of discrimination, for example through disadvantaging, harassment, bullying, defamation – including in social networks – and promote respectful cooperation in a spirit of partnership.

We ensure equal opportunities and equal treatment, regardless of ethnic origin, skin colour, gender, disability, weltanschauung, religion, nationality, sexual orientation or social origin. This also applies to political attitudes, insofar as these are based on democratic principles and tolerance towards those with different views. The rights and duties of employees are based on jointly established company rules.

Conflicts of interest

ALBROMET avoids conflicts of interest whenever possible. By the same token, we also actively seek to resolve any conflicts of interest that are identified. This applies to conflicts of interest within the company as well as to conflicts of interest vis-à-vis customers, suppliers and competitors. We expect our employees to devote their entire working capacity to ALBROMET and to engage in sideline activities only to the extent permitted by law or stipulated in their employment contracts.

Competition

There can only be stable business cooperation for the benefit of all if there is fair competition and strict compliance with the legal system. For this reason ALBROMET undertakes to respect and comply with national and international rules of fair competition and not to take any actions that violate antitrust law. We do not submit sham offers, do not conduct discussions with competitors about prices, capacities or non-competition, nor do we make agreements to share customers, territories or production programmes.

Our agreements with customers and suppliers are comprehensive and unambiguous, and subsequent changes and additions are documented. This also applies to arrangements governing the payment of bonuses, credit notices and commissions. We select our suppliers solely on a competitive basis after comparing price, quality, reliability, performance and suitability of the products or services offered.

Avoidance of corruption

We condemn all active and passive bribery and the attempt thereof. Gifts, favours, hospitality, entertainment and other benefits are given or accepted only if they remain within the bounds of what is permitted by law or if they do not exceed the scope of business customs in the region concerned, and at the same time do not have an unreasonably high value and do not constitute a bribe.

Customs and foreign trade

When purchasing, manufacturing or marketing goods or when transferring or acquiring technologies, all control regulations of ALBROMET are adhered to. Prior to any shipment or export, the necessary permits are obtained from the competent authorities and all end-use declarations required by law are be made or voluntarily provided by ALBROMET.

ALBROMET complies with all applicable foreign trade and customs regulations.

Environmental protection and sustainability

ALBROMET aims to continuously improve the environmental performance of its business operations, using raw materials and the environment in a careful and responsible manner. For ALBROMET, it goes without saying that it complies with or exceeds national and international legal regulations and standards on environmental protection. We support environmentally-friendly activities by our employees. An efficient recycling system as well as authorised waste disposal companies and a modern, energy-saving machine park are prerequisites for environmentally friendly and sustainable business.

Confidentiality and data protection

Confidential information means all information that is not in the public domain. This information constitutes company assets and therefore any unauthorised disclosure could harm the interests of ALBROMET or third parties working for us. In the same way that we treat non-public data as confidential, we respect and protect the confidential information of our clients as well as of third parties.

ALBROMET is committed to handling all personal data responsibly, with due care and in compliance with applicable data protection regulations. The direct or indirect use of confidential business information during and after termination of the employment relationship for personal benefit, for the benefit of third parties or to the detriment of ALBROMET and its customers is prohibited.

The procedure is covered in the ALBROMET Privacy Policy (www.albromet.de/de/datenschutz)

Breach of the Code

ALBROMET reserves the right to investigate violations of this Code and to issue punishments with appropriate consequences within the context of company and legal regulations.

Whistleblower system

ALBROMET enables its employees to address concerns of any kind to the assigned line manager, openly or anonymously, in person, electronically, in writing or by telephone.

Note: In the interest of readability, we have not distinguished between genders in this publication.