ZVEI Code of Conduct

The German Electrical and Electronic Manufacturers’ Association (ZVEI) represents the economic, technological and environmental interests of the German electrical industry. (ZVEI) represents the economic, technological and environmental interests of the medium-sized German electrical industry.

SEPA EUROPE GmbH is committed to its social responsibility and has signed the ZVEI Code of Conduct on Social Responsibility.

The ZVEI Code of Conduct is an expression of the common values of the ZVEI. It is based on internationally established standards and covers all relevant topics.

Further information can be found on the ZVEI homepage at: www.zvei.org.

ZVEI Code of Conduct

on social responsibility

Preamble

The ZVEI – Zentralverband Elektrotechnik- und Elektronikindustrie e. V. (German Electrical and Electronic Manufacturers’ Association) and its member companies are committed to their corporate social responsibility worldwide (internationally usually referred to as ‘CSR’). This ‘ZVEI Code of Conduct on Social Responsibility’ (hereinafter referred to as ‘CoC’) is an industry guideline that defines what this means in particular with regard to working conditions, social and environmental compatibility as well as transparency, trusting cooperation and dialogue. The contents of this CoC, which were developed and agreed upon by the ZVEI together with member companies, are an expression of the ZVEI’s shared value base, as defined in the ZVEI’s vision and mission and set out in particular in the commitment to the social market economy. The application of this CoC is recommended to member companies by the ZVEI. It is designed as a voluntary commitment that can be signed by member companies. By providing this CoC, the ZVEI supports them in responding to the different framework conditions in a global market and in facing the challenges and societal expectations that follow from the increasingly networked cooperation in value chains.

1. basic understanding of socially responsible corporate governance

This CoC is based on a common basic understanding of socially responsible corporate governance. For the undersigned company, this means that it assumes responsibility by considering the consequences of its business decisions and actions in economic, technological as well as social and ecological terms and by achieving an appropriate balance of interests. The undersigned company voluntarily contributes to the well-being and sustainable development of the global society at the locations where it operates within the scope of its respective possibilities and scope for action. It is guided by universally accepted ethical values and principles, in particular integrity and probity and respect for human dignity.

2. scope of application

2.1 This CoC applies to all branches and business units of the undersigned company worldwide.

2.2 The undersigned company undertakes to promote compliance with the contents of this CoC also among its suppliers and in the further value chain within the scope of its respective possibilities and scope for action.

3. cornerstones of socially responsible corporate governance

The undersigned company actively works to ensure that the values and principles set out below are observed and complied with on a sustainable basis.

3.1 Compliance with the law

The undersigned company complies with the applicable laws and regulations of the countries in which it operates. For countries with weak institutional frameworks, it carefully considers what good corporate governance practices from its own home country should be applied in a supportive manner.

3.2 Integrity and Organizational Governance

3.2.1 The undersigned company orients its actions to universally valid ethical values and principles, in particular integrity, integrity, respect for human dignity, openness and non-discrimination of religion, ideology, gender and ethnicity.

3.2.2 The undersigned company rejects corruption and bribery as defined in the relevant UN Convention. It promotes transparency, integrity and responsible management and control in the company in an appropriate manner.

3.2.3 The undersigned company follows clean and accepted business practices and fair competition. In competition, it is oriented towards professional conduct and quality work. It maintains a cooperative and trusting relationship with the supervisory authorities. It also adheres to the requirements of the ‘Guidelines for our Association’s Work – Instructions for Acting in Conformity with Antitrust Law in the ZVEI’.

3.3 Consumer interests:

As far as consumer interests are concerned, the undersigned company complies with consumer protection regulations as well as with appropriate sales, marketing and information practices. Particular attention is paid to vulnerable groups (e.g. youth protection).

3.4 Communication

The signatory company communicates openly and in a dialogue-oriented manner about the requirements of this CoC and about its implementation to employees, customers, suppliers and other interest and stakeholder groups. All documents and records are dutifully prepared, not unfairly altered or destroyed, and properly stored. Trade secrets and business information of the partners are treated sensitively and confidentially.

3.5 Human rights

The undersigned company is committed to promoting human rights. It respects human rights in accordance with the UN Charter on Human Rights3 , in particular those listed below:

3.5.1 Privacy

Privacy protection.

3.5.2 Health and safety

Maintaining health and safety at work, in particular ensuring a safe and healthy working environment to prevent accidents and injuries.

3.5.3 Harassment

Protect employees from physical punishment and from physical, sexual, psychological or verbal harassment or abuse.

3.5.4 Freedom of expression

Protect and ensure the right to freedom of opinion and expression.

3.6 Working conditions

The undersigned company complies with the following ILO4 core labour standards:

3.6.1 Child labour

The prohibition of child labour, i.e. the employment of persons younger than 15 years of age, unless local legislation sets higher age limits and unless exceptions are permitted.

3.6.2 Forced labour

The prohibition of forced labour of any kind.6 3.6.3 Remuneration The labour standards regarding remuneration, in particular the level of remuneration in accordance with the laws and regulations in force.

3.6.4 Employee rights

Respect for the right of workers to freedom of association, freedom of assembly and collective bargaining, to the extent permitted and possible by law in the country concerned.

3.6.5 Prohibition of discrimination

Non-discriminatory treatment of all employees.

3.7 Working time

The undersigned company complies with the labour standards regarding the maximum permissible working hours.

3.8 Environmental protection

The undersigned company complies with the regulations and standards on environmental protection that affect its respective operations and acts in an environmentally conscious manner at all of its sites. It also uses natural resources responsibly in accordance with the principles of the Rio Declaration.

3.9 Civic engagement

The undersigned company contributes to the social and economic development of the country and region in which it operates and promotes corresponding voluntary activities by its employees.

4. implementation and enforcement

The undersigned company shall make all appropriate and reasonable efforts to continuously implement and apply the principles and values described in this CoC. Contractual partners should be informed of the essential measures upon request and within the framework of reciprocity, so that it becomes comprehensible how their compliance is fundamentally ensured. There is no entitlement to the disclosure of trade and business secrets, information relating to competition or other information worthy of protection.

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