Foreword
Strubl GmbH & Co. KG strives to achieve its corporate and strategic goals in accordance with ethical standards and social values.
In line with the GKV Code of Conduct for the Plastics Processing Industry, we strive to manage our company conscientiously and with a long-term perspective. We expect the same level of commitment from our cooperation partners, including suppliers and service providers. These core principles cover a wide range of areas, from professional conduct in a business context to issues such as human rights, labor standards, and environmental protection. These fundamental values are explained in detail in the following Code of Conduct for Business Partners.
We expect our business partners, whether suppliers, service providers, or others, to share these fundamental principles and to develop and implement robust processes for their implementation.
The Code of Conduct is an indispensable guide and is supplemented and reinforced by applicable legislation and internal guidelines and instructions. It is binding for all business partners, including suppliers, service providers, and any others with whom we have a direct business relationship.
A. Conduct in a business environment
(1) Compliance with laws and regulations
The business partner undertakes to comply with all national and European laws and regulations relevant to it, its contractual agreements, and any voluntary commitments it has entered into.
(2) Prevention of corruption, integrity, and bribery
The business partner undertakes to strictly comply with international and local anti-corruption laws and standards. The highest standards of integrity must be maintained in all business activities. Any form of taking advantage, bribery, corruption, extortion, and embezzlement is prohibited. Neither the business partner itself, its employees, nor any third parties commissioned by it may allow themselves to be influenced by business partners in Germany or abroad, nor may they attempt to influence business partners in a criminal manner, whether through gifts or other (material) benefits. Commissions and remuneration for dealers, intermediaries, and consultants must always be appropriate and linked to performance.
(3) Antitrust and competition law
The business partner shall comply with national and international antitrust laws and laws against unfair competition. Agreements on prices or terms with competitors are prohibited, as are other measures that restrict competition and influence prices or terms.
(4) Money laundering
The business partner is required to regularly verify the identity of its business partners in order to prevent any involvement in money laundering. Transactions that could give rise to suspicion of money laundering must be rejected.
(5) Confidentiality and data protection
The business partner shall comply with the applicable data protection regulations (BDSG, GDPR). Personal data must be protected against unauthorized access and misuse.
(6) Protection of trade secrets and intellectual property
The business partner is aware that confidential information and trade secrets are of particular value and must therefore be protected appropriately. These may not be disclosed or made accessible to third parties. Information may only be exchanged in accordance with property rights and, where applicable, through confidentiality agreements.
(7) Recognition of intellectual property and property rights
The business partner shall respect the intellectual property rights and property rights of third parties, such as competitors or business partners. Technology and knowledge transfers must be carried out within the framework of intellectual property rights and protect customer information. Misuse of insider information shall be avoided in accordance with the applicable legal provisions.
(8) Export and Import
The business partner declares its obligation to comply with applicable import and export control laws, specifically with regard to sanctions, embargoes, and other regulations concerning the transfer or provision of goods and technology.
(9) Whistleblower compliance
The business partner maintains effective communication channels for employees and other persons who may have knowledge of potential violations of protected legal positions. These channels should enable the reporting of possible illegal activities.
B. Human beings and fundamental rights
(10) Respect for human rights
The business partner recognizes the protection of human rights as an essential part of its corporate responsibility. The business partner is committed to respecting internationally recognized human rights and to taking them into account in its business activities and value chains. Where local laws restrict international human rights standards, the business partner shall strive to promote the principles of international standards without, however, coming into conflict with local laws. If local laws provide for stricter standards than international standards, the business partner shall comply with them.
(11) Prevent child labor
The exploitation of children and young people is categorically rejected. It is the responsibility of the business partner to ensure that no form of child labor (as defined by the ILO core labor standards) is practiced within their company. If national regulations regarding child labor contain stricter requirements, the business partner shall give priority to these regulations.
(12) Prohibition of forced labor
Any form of forced or compulsory labor is strictly prohibited. The business partner does not tolerate any work that has been forced under threat of punishment. This includes forced overtime, debt bondage, prison labor, slavery, and serfdom.
(13) Freedom of association and collective bargaining
The business partner respects the fundamental right to freedom of association, the right to join a union, access to employee representation, membership in works councils, and the right to collective bargaining, in accordance with applicable local laws.
(14) Prohibition of discrimination and fair treatment
The business partner guarantees that its employees and business partners will be treated with appropriate appreciation and respect. Any form of discrimination, whether based on ethnicity, nationality, skin color, gender, age, religion, political activity, membership in an employee representative body, disability, sexual orientation, or other personal characteristics, is rejected. The personal rights and dignity of each individual are respected; at the same time, the business partner supports the equal treatment of all employees and the promotion of equal opportunities in the employment environment.
C. Labor standards
(15) Occupational health and safety
The business partner is committed to creating a safe, hygienic, and healthy working environment by establishing consistent and demanding standards. Necessary steps are taken to prevent accidents and health impairments in connection with the activities. Internationally recognized occupational safety standards are decisive in this regard. In addition, the business partner promotes continuous improvements in working conditions and regularly trains its employees on applicable health and safety standards and measures.
(16) Working hours
Working hours are organized in accordance with the applicable national regulations, industry standards, and relevant ILO conventions. Legal regulations on working time recording are followed.
(17) Remuneration and social benefits
The business partner guarantees that the remuneration of employees is at least in line with the minimum wages applicable under local law or customary in the industry. If the statutory minimum wage is insufficient, the business partner is obliged to offer remuneration that covers the basic needs of employees. In addition to regular remuneration, overtime shall be compensated in accordance with legal requirements, including the corresponding surcharges or at least the regular hourly wage stipulated by law, unless other legal provisions apply. Social benefits shall be provided in accordance with applicable national or local standards.
D. Environmental protection
(18) Environmental awareness and climate responsibility
The business partner actively strives to minimize environmental impact and strictly complies with international standards and legal requirements for environmental and climate protection. These efforts are continuously being expanded. Measures include reducing emissions, effective waste prevention, and resource-efficient working practices. The development, manufacture, packaging, and transport of products are carried out safely and in an environmentally friendly manner in compliance with applicable standards.
(19) Waste management and emission control
The business partner shall establish procedures and systems to ensure the safe handling, transport, storage, recycling, reuse, and management of raw materials, materials, and waste. Any generation or disposal of waste, as well as the release of substances into the air or water that could have a negative impact on humans and the environment, shall be reduced as far as possible and handled appropriately before it enters the environment. Where relevant, the ban on the export of hazardous waste in accordance with the Basel Convention of March 22, 1989, in its current version, is taken into account. Appropriate procedures, systems, and processes are used to prevent or minimize unintentional or diffuse leaks or releases of pollutants into the environment. The business partner shall optimize the consumption of relevant resources such as energy, water, and raw materials in a sustainable manner.
(20) Process reliability and safety standards
The business partner uses an efficient management system (e.g., ISO 9001) to control work processes in compliance with recognized safety standards. Where necessary, specific risk analyses are carried out for facilities. Measures are taken for all facilities to prevent incidents such as chemical leaks or explosions. This also includes preventive measures to ensure process safety.
E. Product responsibility
(21) Focus on product safety and quality
The business partner shall ensure compliance with the relevant national and European laws and legal regulations. The following regulations play a particularly important role in this regard: 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 on materials and articles intended to come into contact with food. Continuous review of product safety with regard to health and environmental risks ensures their suitability for intended uses. It is of utmost importance that the business partner's products meet high sustainability standards, are environmentally friendly, and that potentially harmful ingredients are either avoided or, where possible, replaced with environmentally friendly alternatives.
(22) Commitment to global environmental protection agreements
The business partner strictly complies with international environmental protection agreements, where relevant.
(23) Responsibility for conflict minerals
To ensure that no products containing metals (such as tin, tungsten, tantalum, and gold) or other raw materials such as cobalt are supplied to Strubl GmbH & Co. KG whose source minerals or derivatives originate from conflict and high-risk areas where they may contribute to the financing or support of armed groups, the business partner acts decisively. Compliance with EU Regulation 2017/821 establishing due diligence obligations in the supply chain is essential for him.
F. Implementation of the basic principles
Strict compliance with and enforcement of these basic principles is ensured by business partners either through their individual code of conduct or through an internal company policy that is equivalent to the “Code of Conduct for Business Partners of Strubl GmbH & Co. KG.” If no corresponding standard has been established, we ask our business partners to commit to these basic principles in accordance with this code of conduct. In this case, the code of conduct or company policy in question must be attached as an appendix and sent to Strubl GmbH & Co. KG.
We ask our business partner Strubl GmbH & Co. KG to inform us of any violations of the basic principles.
Please send any queries regarding sustainability, human rights, or the code of conduct to esg@strubl.de