1.       Compliance with laws and regulations

We expect our suppliers to comply with all applicable laws, rules and regulations and to take appropriate measures to ensure compliance with these laws, rules and regulations.

This Code of Conduct is based in particular on national laws and regulations, such as the Supply Chain Duty of Care Act (LkSG) and international conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines on the Rights of the Child and Business Conduct, the United Nations Guiding Principles on Business and Human Rights, the international labour standards of the International Labour Organization and the United Nations Global Compact.

The principles contained therein represent minimum standards. The national and other relevant laws and regulations that apply in the countries in which business activities take place and the principles contained in this Code of Conduct must be complied with. Of all applicable regulations, the most suitable for realising the purpose of protection is always decisive.

2.       Respect for human rights and working conditions

a.         Prohibition of forced labour

Any form of forced labour, servitude, involuntary prison labour or human trafficking is unacceptable. Workers are free to leave their employer after reasonable notice.

Employees must be able to leave work or employment at any time. Furthermore, there must be no unacceptable treatment of workers, such as psychological hardship, sexual and personal harassment and humiliation.

The hiring or use of security personnel must be prohibited if persons are treated in an inhumane or degrading manner or are injured during their deployment or if freedom of association is impaired.

b.         Prohibition of child labour

There is no use of child labour as defined by ILO and UN conventions and/or national law.

The minimum age for the employment of minors is not below the applicable age of compulsory schooling and is at least 15 years, unless ILO exceptions apply. The right of children to education is respected.

Children and young people under the age of 18 are not employed at night or under dangerous conditions.

c.         Fair remuneration

Wages shall be paid on time, regularly and in full. Deductions from wages as a disciplinary measure will not be permitted, nor will deductions be made from wages that are not authorised by national legislation without the express consent of the worker concerned.

All disciplinary measures shall be recorded.

The respective supplier shall ensure that workers receive clear, detailed and regular written information on the composition of their remuneration.

d.         Faire Arbeitszeit

Die Arbeitszeiten müssen den geltenden Gesetzen oder den Branchenstandards entsprechen. Überstunden sind nur zulässig, wenn sie auf freiwilliger Basis erbracht werden und 12 Stunden pro Woche nicht übersteigen, während den Beschäftigten nach sechs aufeinanderfolgenden Arbeitstagen mindestens ein freier Tag einzuräumen ist. Die wöchentliche Arbeitszeit darf 48 Stunden nicht regelmäßig überschreiten.

e.         Freedom of association

Without exception, workers have the right to organise and form a trade union of their own choosing and to bargain collectively. Workers‘ representatives shall not be discriminated against and shall have the opportunity to carry out their representative functions in the workplace.

In cases where freedom of association and the right to collective bargaining are restricted by law, alternative means of independent and free association of workers for the purpose of collective bargaining shall be provided.

Their employee representatives must be granted free access to the workplaces of their colleagues in order to ensure that they can exercise their rights in a lawful and peaceful manner.

f.           Prohibition of discrimination

Discrimination Unequal treatment of employees in any form is prohibited unless it is justified by the requirements of employment.

There is no discrimination in recruitment, remuneration, admission to training, promotion, termination of employment or retirement on the basis of race, caste, nationality, religion, age, disability, gender, marital status, sexual orientation, trade union membership or political affiliation.

The personal dignity, privacy and personal rights of each individual are respected.

g.         Health and safety at work

The supplier is responsible for a safe and healthy working environment. The necessary precautionary measures against accidents and damage to health that may arise in connection with the work shall be taken by setting up and applying appropriate occupational safety systems.

Suitable measures must be taken to prevent excessive physical or mental fatigue. In addition, employees are regularly informed and trained on applicable health and safety standards and measures.

Employees are provided with access to sufficient quantities of drinking water and access to clean sanitary facilities.

3.       Ethical business practices

a.         Prohibition of corruption and bribery

Any form of corruption or bribery will not be tolerated. The respective supplier must ensure that its employees do not obtain or accept any unauthorised personal benefits in connection with their business activities. Only gifts below a de minimis limit of 20 euros are permitted. Cash payments to our employees are prohibited without exception. Invitations to our employees to business trips, works trips, leisure events or other events must be approved in advance by the management of the individual companies in our group of companies or their authorised representatives. Invitations to business meals are exempt from the authorisation requirement, provided that they serve a legitimate business purpose and the nature and extent of the expenses are reasonable.

b.         Avoidance of conflicts of interest

As a supplier to KOLB Group companies, we must avoid situations in which our own interests conflict with the business interests of the respective supplier. The respective KOLB Group company must be informed immediately if a conflict of interest becomes known.  

c.         Fair competition, compliance with competition and antitrust law and intellectual property

The KOLB Group and its companies comply with the applicable rules of competition and antitrust law as well as the principle of fair competition and expect the same from all business partners. When dealing with competitors, the applicable antitrust laws prohibit in particular agreements and other activities that influence prices or conditions as well as agreements between customers and suppliers that are intended to restrict customers in their freedom to determine their prices and other conditions for resale. We disapprove of such practices and expect the same from our business partners. In addition, suppliers to the KOLB Group undertake to respect intellectual property rights.

d.         Export controls and economic sanctions

The supplier of the KOLB Group strictly observes compliance with all applicable regulations and laws for the import and export of goods, services and information as well as payment transactions. In its business activities, existing sanctions and embargoes are observed within the framework of the laws and regulations.

e.         Prevention of money laundering and terrorist financing

The respective supplier of the KOLB Group undertakes to fulfil its legal obligations to prevent money laundering and terrorist financing within the framework of the applicable legal provisions and not to promote these either directly or indirectly.

4.       Environmental protection and sustainability

a.         Environmental protection laws

The supplier shall comply with the relevant environmental protection laws and regulations. Its operations fulfil the requirements of waste legislation as well as immission and water protection.

All regulations regarding hazardous substances are complied with by the business partner. This applies in particular to the storage, handling and disposal of hazardous substances. Employees must be instructed on the handling of hazardous materials and substances.

b.         Treatment and discharge of industrial waste water

Wastewater from operational procedures, production processes and sanitary facilities must be standardised, monitored, checked and treated if necessary before discharge or disposal. In addition, measures should be introduced to reduce the generation of wastewater.

c.         Dealing with air emissions

General emissions from operations (air and noise emissions) and greenhouse gas emissions shall be standardised, routinely monitored, verified and treated as necessary prior to release.

The supplier is also responsible for monitoring its emission control systems and is required to find cost-effective solutions to minimise any emissions.

d.         Handling of waste and hazardous substances

The respective supplier shall follow a systematic approach to identify, handle, reduce and responsibly dispose of or recycle solid waste.

The prohibitions on the export of hazardous waste in the Basel Convention of 22 March 1989, as amended, must be observed. Chemicals or other materials that pose a risk when released into the environment must be identified and handled in such a way that safety is ensured when handling, transporting, storing, using, recycling or reusing and disposing of these substances.

Where required, mercury shall be used in accordance with the prohibitions of the Minamata Convention of 10 October 2013 and persistent organic pollutants in accordance with the Stockholm Convention of 23 May 2001, as amended.

e.         Reduce consumption of raw materials and natural resources

The use and consumption of resources during production and the generation of all types of waste, including water and energy, must be reduced or avoided.

This is done either directly at the point of origin or through procedures and measures, e.g. by changing production and maintenance processes or procedures in the company, by using alternative materials, by saving, by recycling or by reusing materials.

f.           Dealing with energy consumption/efficiency

Energy consumption must be monitored and documented. Economic solutions must be found to improve energy efficiency and minimise energy consumption.  

g.         Animal welfare

When using animals that are also indirectly related to the production of the goods supplied, attention must be paid to species-appropriate husbandry and compliance with the applicable animal welfare regulations. Measures that cause unnecessary suffering and pain to animals must be avoided as far as possible.

5.       Conflict minerals

a.         Dealing with conflict minerals

For the conflict minerals tin, tungsten, tantalum and gold, as well as for other raw materials such as cobalt, suppliers implement processes to ensure compliance with the due diligence obligation to promote responsible supply chains for minerals from conflict and high-risk areas in accordance with the guidelines of the Organization for Economic Co-operation and Development (OECD). The respective supplier also expects this from its business partners.

6.       Data protection

a.         Compliance with data protection and confidentiality

The business partners undertake to meet the reasonable expectations of the KOLB Group and its employees with regard to the protection of confidential information. The business partners will work together with the responsible persons of the KOLB Group to conclude appropriate confidentiality agreements and to ensure adequate protection of confidential information received. Business partners must comply with the laws on data protection (GDPR) and information security and the official regulations when collecting, storing, processing, transmitting and passing on confidential information.