Code of Conduct for Business Partners


Strubl GmbH & Co. KG strives to achieve its business and strategic objectives in alignment with ethical standards and societal values.

In accordance with the GKV Code of Conduct for the Plastics Processing Industry, we aim for a long-term and conscientious leadership of our company. We expect an equal commitment to these principles from our partners in collaboration, including suppliers and service providers. The foundation of these core principles spans various domains, ranging from professional conduct in the business context to subjects such as human rights, labour standards, and environmental protection. The following Business Partner Code of Conduct elaborates on these fundamental values and their meaning for business practices.

We encourage our business collaborators, whether they are suppliers, service providers, or other entities, to embrace these fundamental principles and establish robust processes for their effective implementation.

The Code of Conduct is an indispensable guide, complemented and reinforced by applicable laws, internal policies, and instructions. It is binding for all business partners, including suppliers, service providers, and any others with whom a direct business relationship is established.

A. Business Environment

(1) Compliance with Laws and Regulations

The business partner commits to adhering to all relevant national and European laws and regulations, contractual agreements, and undertaken commitments.

(2) Corruption Prevention, Integrity, and Bribery

The business partner commits to strictly complying with international and local anti-corruption laws and maintaining high integrity standards in all business activities. Any form of bribery, corruption, extortion, or embezzlement is prohibited. Neither the business partner, its employees, nor third parties may be influenced by or attempt to influence others in a criminal manner, whether through gifts or other (material or non-material) benefits. Commissions and compensation for dealers, intermediaries, and advisors must be reasonable and tied to service or product delivery.

(3) Cartel and Competition Law

The business partner adheres to national and international cartel laws as well as laws against unfair competition. Agreements on prices or conditions, as well as other anticompetitive measures affecting prices or conditions, are prohibited.

(4) Money Laundering

The business partner is advised to verify the identity of its business partners to prevent involvement in money laundering. Transactions that could arouse suspicion of money laundering must be rejected.

(5) Confidentiality and Data Protection

The business partner complies with applicable data protection regulations. Personal data must be protected from unauthorized access and misuse.

(6) Protection of Trade Secrets and Intellectual Property

The business partner acknowledges the value of confidential information and trade secrets and commits to protecting them. These must not be disclosed to third parties. Information exchange takes place in accordance with ownership rights and confidentiality agreements.

(7) Recognition of Intellectual Property and Rights

The business partner respects intellectual property rights and protections of third parties, including competitors or business partners. Technology and knowledge transfers must respect intellectual property rights and protect customer information. Avoiding misuse of insider information is imperative in accordance with relevant legal provisions.

(8) Export and Import

The business partner declares its commitment to comply with applicable import and export control laws, especially regarding sanctions, embargoes, and regulations concerning the transfer or provision of goods and technology.

(9) Whistleblower Compliance

The business partner maintains effective communication channels for employees and others who may have knowledge of potential violations of protected legal positions. These channels allow reporting of possible unlawful actions.

B. People and Fundamental Rights

(10) Human Rights

The business partner recognises the protection of human rights as an essential part of its corporate responsibility. The business partner commits to respecting globally recognised human rights in its business activities and value chains. If local laws restrict international human rights standards, the business partner strives to promote international principles without conflicting with local laws. If local laws set stricter standards than international ones, the business partner will adhere to those.

(11) Prevention of Child Labour

The business partner unequivocally opposes the exploitation of children and adolescents. It is the responsibility of the business partner to ensure that no form of child labour (defined according to ILO core labour standards) is practiced within its company. If national regulations on child labour have stricter requirements, the business partner gives priority to these regulations.

(12) Prohibition of Forced Labour

The business partner unequivocally opposes any form of forced or compulsory labour. The business partner does not tolerate work performed under threat of punishment. This includes forced overtime, debt bondage, prison labour, slavery, and servitude.

(13) Freedom of Association and Collective Bargaining

The business partner respects the fundamental right to freedom of association, the right to union membership, access to employee representation, membership in works councils, and the right to collective bargaining, according to applicable local laws.

(14) Prohibition of Discrimination and Fair Treatment

The business partner ensures that its employees and partners are treated with dignity and respect. Any form of discrimination based on ethnicity, nationality, skin colour, gender, age, religion, political activity, membership in employee representation, disability, sexual orientation, or other personal characteristics is prohibited. Individual rights and dignity are respected, while equal treatment of all employees and the promotion of equal opportunities in the workplace are supported.

C. Labour Standards

(15) Safety and Health at the Workplace

The business partner is committed to creating a safe, hygienic, and health-promoting work environment through consistent and demanding standards. International recognised occupational safety standards are implemented. Additionally, the business partner promotes continuous improvements in working conditions and regularly trains its employees on applicable health and safety norms and measures.

(16) Working Hours

Working hours adhere to applicable national regulations, industry norms, and relevant ILO conventions. The business partner documents working hours in accordance with national legal requirements.

(17) Compensation and Social Benefits

The business partner ensures that employee compensation meets at least the locally applicable legal standards or industry minimum wages. If legal minimum wages are inadequate, the business partner is obligated to offer compensation that covers employees' basic needs. Overtime is compensated according to legal requirements, including corresponding surcharges or at least at the legally established regular hourly rate if no other legal provisions exist. Social benefits are provided in accordance with applicable national or local standards.

D. Environmental Protection

(18) Environmental Awareness and Climate Responsibility

The business partner actively strives to minimise environmental impacts and strictly adheres to international standards and legal requirements for environmental and climate protection. These efforts are continually expanded, including measures to reduce emissions, effective waste prevention, and resource-efficient practices. The development, production, packaging, and transportation of products are carried out safely and environmentally responsibly in compliance with applicable standards.

(19) Waste Management and Emission Control

The business partner establishes procedures and systems to ensure the safe handling, transportation, storage, recycling, reuse, and management of raw materials, materials, and waste. The business partner ensures that the creation or disposal of waste and the release of substances into the air or water, which could potentially harm human health and the environment, are minimized and effectively managed prior to entering the environment. If relevant, the prohibition of the export of hazardous waste is considered according to the Basel Convention of March 22, 1989, as amended. Suitable procedures, systems, and processes aim to prevent or minimise unintended or diffuse leakage or release of pollutants into the environment. The business partner minimises the consumption of resources such as energy, water, and raw materials wherever possible.

(20) Process Safety and Safety Standards

The business partner employs an efficient management system (e.g., ISO 9001) to control work processes in compliance with recognized safety standards. Specific risk analyses for facilities are conducted where necessary. Measures are taken to prevent incidents such as chemical leaks or explosions in relation to all facilities. This includes preventive measures to ensure process safety.

E. Product Responsibility

(21) Product Safety and Quality Focus

The business partner ensures compliance with relevant national and European laws and regulations. The following regulations are of high relevance: Regulation (EC) No. 1907/2006 of the European Parliament and of the Council of December 18, 2006 (REACH), Regulation (EC) No. 1272/2008 of the European Parliament and of the Council of December 16, 2008 (CLP), and Regulation (EC) No. 1935/2004 of the European Parliament and of the Council of October 27, 2004, concerning materials and articles intended to come into contact with food. Ongoing product safety reviews regarding health and environmental risks ensure suitability for intended uses. It is of paramount importance that the business partner's products meet high sustainability standards, and that potentially harmful ingredients are either avoided or, where possible, replaced with environmentally friendly alternatives.

(22) Commitment to Global Environmental Agreements

The business partner strictly adheres to international environmental agreements, as relevant.

(23) Responsibility Regarding Conflict Minerals

The business partner acts decisively to prevent the supply of products that contain conflict materials to Strubl Gmbh & Co. KG. Compliance with the EU Regulation 2017/821 for establishing due diligence in the supply chain is essential in this regard.

F. Implementation of Fundamental Principles

The strict compliance and enforcement of these fundamental principles by business partners are achieved through either their individual code of conduct or an internal company policy that is equivalent to the "Code of Conduct for Business Partners of Strubl GmbH & Co. KG." If no corresponding standard is established, we kindly request our business partners to commit to these fundamental principles according to this code of conduct. In this case, the mentioned code of conduct or company policy should be attached and submitted to Strubl GmbH & Co. KG. We kindly ask our business partner to inform Strubl GmbH & Co. KG about violations of the fundamental principles.