CODE OF CONDUCT

Code of Conduct

1. Introduction

This Code of Conduct (CoC) provides the framework for our responsible and ethical conduct in all areas of our business activities. It serves as a guideline for the behavior of our employees as well as our business partners and establishes clear requirements for interaction with each other and with external stakeholders. Our goal is to contribute to a positive corporate culture and promote sustainable business practices through transparency, integrity, and respect.

1.1. Objectives

The objective of the Code of Conduct is to ensure responsible, legally compliant, and ethically sound behavior. It defines our core values and principles and helps to anchor them in the daily work environment. In doing so, we place the interests of our employees, customers, suppliers, as well as the environment and society at the center of our decisions, thereby creating the basis for successful and trust-based cooperation in the long term.

2. Fundamental Understanding of Corporate Conduct

For us, responsible corporate governance means taking responsibility for the consequences of our decisions and actions in economic, technological, social, and ecological terms and bringing about an appropriate balance of interests. We orient ourselves both by laws and regulations and by universally applicable ethical values and principles.

3. Social Engagement

We are actively involved in society and support social projects or associations in the regions where we operate. We promote the voluntary engagement of our employees and support their initiatives.

4. Scope of Application

This CoC applies to all employees. At the same time, we commit to promoting compliance with the contents of this CoC also among our suppliers and in the wider value chain within our respective possibilities and areas of action.

We expect our management to set an example by not only communicating these rules but also living them and requiring them from employees. They are the primary contacts for all questions concerning this Code of Conduct.

5. Integrity and Appreciation

We orient our actions toward universally applicable ethical values and principles, in particular integrity, mutual appreciation, righteousness, respect for human dignity, openness, and non-discrimination regarding religion, worldview, gender, and ethnicity.

5.1. Equal Opportunity and Diversity

We are committed to equal opportunity and do not tolerate discrimination. We promote diversity and inclusion in our company and respect the personal dignity, privacy, and personal rights of every individual.

5.2. Diversity and Inclusion

We value the diversity of our employees and create a work environment free from discrimination and harassment. We make personnel decisions exclusively based on qualification and performance.

6. Business Relationships with Customers and Suppliers

We are actively committed to ensuring that the following values and principles are observed and maintained in daily business transactions:

6.1. Antitrust and Competition Law

We commit to fair competition and comply with applicable antitrust regulations. We do not make arrangements or agreements that influence prices, conditions, strategies, or customer relationships. We do not discuss confidential topics such as prices, sales terms, or marketing plans with competitors.

6.2. Compliance with the Law

We comply with the applicable laws and other legal regulations of the countries in which we operate. We follow existing trade controls and comply with regulations on import and export controls as well as economic embargos.

6.3. Corruption

We reject corruption, bribery, and money laundering and promote transparency, integrity, and responsible leadership and control within the company.

In business decisions, we do not allow ourselves to be influenced by illicit advantages offered or promised to us, nor do we demand such from our business partners.

6.4. Fairness

We only use recognized business practices and pursue fair competition. We maintain a partnership-based and trustful relationship with supervisory authorities.

6.5. Consumer Interests

Insofar as consumer interests are affected, we adhere to consumer protection regulations and appropriate sales, marketing, and information practices.

6.6. Communication

We communicate openly and in a dialogue-oriented manner about the requirements of this Code of Conduct and its implementation toward all employees, customers, and suppliers. All documents and records are created dutifully, not unfairly altered or destroyed, and stored appropriately.

7. Handling Information

7.1. Data Protection and Data Security

Trade secrets and business information of our partners are treated sensitively and confidentially. We protect both corporate data and the personal data of customers and employees with all available means.

Specific behavioral guidelines apply to the handling of IT data, which all employees must obligatorily observe.

Monitoring and compliance with data protection guidelines are ensured by an external data protection officer.

7.2. Conflicts of Interest

No secondary activities may be carried out that conflict with our business interests. Business decisions may not be influenced by personal interests of employees.

Should grievances or risks occur despite all precautions, whistleblowers can contact the Managing Director listed below.

7.3. Protection of Intellectual Property

We respect intellectual property and protect confidential information. This includes trade secrets, patents, trademarks, and copyrights. We use such information exclusively for the legitimate business interests of Celltec Lehmann Schaumstofftechnik GmbH and protect it from unauthorized disclosure.

8. Human Rights

We are committed to respecting and promoting human rights. We respect the protection of privacy.

We protect our employees from corporal punishment and from physical, sexual, psychological, or verbal harassment or abuse.

We respect and protect the right to freedom of opinion and free expression. Particularly vulnerable groups such as youth, pregnant women, and people with disabilities enjoy special attention and rights.

9. Working Conditions

We attach great importance to fair and legally compliant working conditions. We do not employ workers under the age of 15 and strictly reject any form of child and forced labor. Our remuneration corresponds to the applicable laws and regulations.

We respect the right of our employees to freedom of association and assembly and maintain a partnership-based relationship with the works council. We comply with statutory working time regulations. We pay special attention to occupational health and safety by ensuring a safe and health-promoting work environment to avoid accidents and injuries. Our goal is fair, safe, and healthy working conditions for all employees.

We promote the personal and professional development of our employees through training opportunities and career prospects. We strive for a balanced work-life balance and offer flexible work models where possible.

10. Environmental Protection

We handle natural resources responsibly. We comply with the applicable regulations and standards for environmental protection (e.g., REACH regulation) and constantly strive to increase energy efficiency, including through the installation of combined heat and power plants and photovoltaic systems.

We involve our stakeholders in our sustainability efforts and promote dialogue with customers, suppliers, and the local community on environmental and social issues.

10.1. Sustainability

We commit to sustainable corporate management. This includes not only environmental protection but also social and economic aspects. We strive to continuously reduce our ecological footprint, produce in a resource-saving manner, and develop innovative, environmentally friendly solutions.

10.2. Product Responsibility and Safety

We place the safety and quality of our products at the center of our actions. We ensure that all our products and services are safe when used as intended. We comply with legal and regulatory requirements as well as our internal quality standards.

11. Implementation and Enforcement

We at Celltec Lehmann Schaumstofftechnik GmbH commit to compliance with this Code of Conduct. Violations of the code can lead to labor law consequences up to the termination of the employment relationship. Every employee is encouraged to report violations of the code. We do not tolerate any disadvantage for persons who express concerns in good faith.