Company Code of Conduct

1. Observance of the applicable law

Compliance with all applicable laws and regulations is an indispensable basis for all actions of the PONGS Group. This Codex sets forth some of the key principles for the conduct of the PONGS Group, including its employees and officers. However, it can not handle all of the legal regulations that must be observed by the corporate bodies, executives and employees of the PONGS Group worldwide. All employees and corporate bodies of the PONGS Group are required to obtain information about the legal provisions applicable to their area of ​​responsibility within the company and, in case of doubt, to seek legal advice from the competent authorities in the PONGS Group.

2. Fair competition

It is in line with the business policy of the PONGS Group to promote fair competition. The PONGS Group complies with all applicable domestic and foreign antitrust laws and the law against unfair competition. Price or condition agreements with competitors are therefore just as inadmissible as agreements with competitors for the purpose of market distribution. Unlawful agreements may not be replaced by concerted practices with competitors or by coordination within associations. Unfair competition practices are rejected by the PONGS Group. If PONGS Group companies hold a dominant position, they must not be misused in relation to customers and competitors. It must be clear to every employee and all bodies that violations of competition law regulations are under no circumstances in the interest of the PONGS Group and must therefore be avoided without exception.

3. Corruption

All employees undertake to do everything in their power to prevent corruption. Corruption is the offering, giving, or acceptance of a gift, loan, commission, reward, or any other benefit to or from any person as an incentive to do something that is dishonest, illegal, or a breach of trust.

4. Conflicts of interest

It is a duty of all PONGS Group officers and employees to avoid conflicts of interest between their private interests (directly or indirectly, or by related parties or companies) and the interests of the PONGS Group.

5. International trade

For the PONGS Group, the legislation governing international trade in their products and services is binding. All companies of the PONGS Group therefore comply with export or import bans and regulatory approval requirements due to national or international legal regulations.

6. Fair working conditions

The business success of the PONGS Group depends to a large extent on its employees. The company is therefore committed to the principles of social responsibility. Therefore, it is in the company’s interest that the PONGS Group has fair working conditions worldwide. Compliance with all local labor and social laws is a matter of course for the PONGS Group. The requirement of fair working conditions excludes any form of discrimination against employees based on their gender, sexual orientation, origin, color or other personal characteristics. The PONGS Group considers it its duty to be an employer around the world who respectfully and fairly deals with its employees. The PONGS Group therefore expects their employees to treat each other with respect. Discrimination or harassment will not be tolerated.

7. Child labor

The PONGS Group rejects child labor, even among its business partners. The minimum age for admission to employment in the PONGS Group in accordance with the relevant state regulation is observed.

8. Occupational safety, health, fire and environmental protection

It is the task of all employees to avoid hazards to people and the environment, to minimize the impact on the environment and to use resources sparingly. Processes, facilities and equipment must comply with the applicable statutory and internal requirements for occupational safety as well as health, fire and environmental protection.

9. Confidentiality

The knowledge and information acquired in the PONGS Group is an essential element for their business success. The PONGS Group invests substantial human and financial resources in the development of innovative products and services. The protection of innovations thus developed ensures the PONGS Group’s success in competition; It is therefore a special asset. All employees and corporate bodies of the PONGS Group are obliged to prevent this knowledge and information, insofar as they constitute trade or business secrets, from becoming known outside the PONGS Group, eg. by unauthorized dissemination of sensitive data in conversation with third parties, in professional journals or on the internet. In addition, any employee with such knowledge and information is required to know the extent to which obtaining intellectual property rights for such knowledge and information may be considered. Business or business secrets of business partners of the PONGS Group must also be protected against unauthorized disclosure.

10. Privacy

Respecting the personality of our employees includes the protection of their personal information. The PONGS Group therefore ensures compliance with the applicable data protection regulations and requires this from its employees.

11. Internal organization to comply with this behavioral code

Each organizational unit is responsible for complying with the regulations contained in this Code of Conduct as well as other internal rules within its area of ​​responsibility.

Supplier Code of Conduct

1. Our understanding of sustainability in supplier management

The PONGS Group together with its affiliates (hereafter: PONGS) understands sustainability as an integral part of our business processes. As a technology group with a high level of materials expertise, we source raw materials, goods and services from suppliers worldwide to ensure the sustainable success of our customers with innovative product and service solutions. The basis for this is responsible corporate management geared to long-term value creation. For this reason, we integrate suppliers directly into our sustainability strategy. In addition to procedural, economic and technical criteria, our procurement activities also pay attention to social and ecological aspects such as human rights, working conditions, corruption prevention and environmental protection. In the field of tension between product / service, market, region and process, cost, quality, reliability, innovation and sustainability are key factors for supplier selection and evaluation. PONGS expects its suppliers to comply in their activities with applicable national laws and this PONGS Supplier Code of Conduct. Furthermore, they are expected to implement appropriate processes that support compliance with applicable laws in their companies and promote continuous improvement in the principles and requirements of the PONGS Supplier Code of Conduct. In addition, PONGS expects its suppliers to ensure that their affiliates also comply with and adhere to all of the policies and requirements described here. This Code of Conduct is valid for all companies of the PONGS Group worldwide.

2. Dealing with employees

PONGS expects its suppliers to comply with the fundamental labor laws of the applicable national legislation.

3. Child labor

PONGS expects its suppliers to prohibit and refrain from any kind of child labor in their companies.

4. Discrimination

PONGS expects its suppliers to promote equal opportunities and equal treatment and to prevent discrimination in the recruitment of workers and in the promotion or provision of education and training. No employee may be discriminated against on grounds of sex, age, skin color, culture, ethnic origin, sexual identity, disability, religious affiliation or beliefs.

5. Forced labor

PONGS expects that its suppliers will not allow forced labor in their companies.

6. Remuneration and working hours

PONGS expects its suppliers to comply with applicable national legislation on working hours. It is also expected that the suppliers’ employees will receive compensation in accordance with the applicable national laws.

7. Health protection and occupational safety

PONGS expects its suppliers to comply with applicable national health and safety legislation. In addition, suppliers are expected to build and apply appropriate occupational safety management (for example, in accordance with ISO 45001). This includes on the one hand the containment of actual and potential occupational safety risks and on the other hand the training of employees in order to prevent accidents and occupational diseases in the best possible way.

8. Environmental protection

PONGS expects its suppliers to comply with applicable national environmental laws, regulations and standards. Suppliers are also expected to build and apply an appropriate environmental management system (for example, in accordance with ISO 14001) to minimize environmental impact and hazards, and to improve environmental protection in day-to-day operations.

9. Behavior in the business environment

Ban on corruption and bribery

PONGS expects its suppliers to not tolerate corruption. In particular, they ensure that their employees, subcontractors or agents do not offer, promise or promise any benefit to PONGS employees or related parties with the aim of obtaining an assignment or other preference in the course of business.

Invitations and gifts

PONGS does not expect its suppliers to abuse invitations and gifts to influence them. Invitations and gifts to PONGS employees or related parties are only granted if the occasion and scope are reasonable, i.e. they are of low value and can be considered as an expression of locally accepted business practice. Likewise, the suppliers of PONGS employees do not demand undue benefits.

Avoidance of conflicts of interest

PONGS expects its suppliers to make decisions based on their business with PONGS based solely on objective criteria. Conflicts of interest with private interests or other economic or other activities, even of relatives or other related persons or organizations, are avoided right from the start.

10. Free competition

PONGS expects its suppliers to compete fairly and to comply with applicable antitrust laws. Suppliers neither participate in anti-competitive agreements with competitors nor misuse any potential dominant position.

11. Money laundering

PONGS expects its suppliers to comply with relevant anti-money laundering legislation and not participate in money laundering activities.

12. Supplier relationships

The supplier undertakes to comply with all statutory provisions and ordinances, in particular also the Anti-Terror Ordinance, the REACH and RoHS Ordinance and declares with regard to metals that the regulations on “Conflict Minerals”, such as “Conflict Minerals”. the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502, or similar EU directives or regulations or national legislation. PONGS expects its suppliers to communicate and take into account all the principles and requirements described here for their subcontractors and suppliers. Suppliers encourage their subcontractors and suppliers to adhere to the described standards of human rights, working conditions, corruption prevention and environmental protection in the fulfillment of their contractual obligations. Any breach of the principles and requirements set forth in the PONGS Supplier Code of Conduct will be considered as materially affecting the contractual relationship on the part of suppliers. In the event of suspicion of non-compliance with the described principles and requirements of the PONGS Supplier Code of Conduct (eg negative media reports), PONGS reserves the right to request information about the relevant facts.

PONGS further has the right to terminate any or all contractual relationships with suppliers who demonstrably fail to comply with the PONGS Supplier Code of Conduct, or who seek and implement any improvement measures after having been given a reasonable period of grace by PONGS.