Gebrüder Schulte GmbH & Co. KG

Code of conduct / sustainability guidelines for suppliers, partners and employees

 

1. Introduction/preamble

 

Sustainability is a long-term strategic success factor for Gebrüder Schulte GmbH & Co. KG and its suppliers.


Gebrüder Schulte GmbH & Co. KG is aware of its social, ecological and corporate responsibility. As a company, Gebrüder Schulte GmbH & Co. KG (hereinafter referred to as "Gebrüder Schulte") is committed to complying with the Supply Chain Act and doing its part to uphold human rights and environmental standards in its supply chain. With our sustainability guideline for suppliers, we actively promote sustainable business practices.

We also expect our employees to observe the principles of ecological, social and ethical behavior and to integrate them into our corporate culture. We also strive to continuously optimize our business activities and our products and services in terms of sustainability.

This document, Code of Conduct, summarizes the basic principles and standards of Gebrüder Schulte GmbH & Co. KG for its suppliers of production-related and non-production-related goods and services, based on globally recognized guidelines and principles. The Code of Conduct is based on national laws and regulations as well as international agreements such as the United Nations Universal Declaration of Human Rights, the international labor standards of the International Labor Organization and the United Nations Global Compact.

For future cooperation, the contracting parties agree to the validity of the following regulations for a joint code of conduct. This agreement shall form the basis for all future deliveries. The contracting parties undertake to comply with the principles and requirements of the Code of Conduct and to endeavor to contractually oblige their subcontractors to comply with the standards and regulations set out in this document.
This agreement comes into force upon signing. A breach of this Code of Conduct may be reason and cause for the company to terminate the business relationship, including all associated supply contracts. The supplier assures to establish a complaint procedure regarding the mentioned points and to protect all parties involved from possible retaliation.

Der Lieferant sichert zu ein Beschwerdeverfahren hinsichtlich der genannten Punkte zu etablieren und alle Beteiligten vor möglichen Vergeltungsmaßnahmen zu schützen.

These principles include, but are not limited to

 

2 Social responsibility

2.1.1 Human and employee rights

The company respects human rights and works with its partners to ensure that they are observed in our supply chain. We are committed to avoiding discrimination, forced labor and child labor in any form.
The ban on child labor must be observed. In the context of youth work, the relevant statutory protective regulations must be observed. The supplier must advocate the abolition of child labor. Any kind of promotion and implementation of forced labor and slavery is prohibited.The supplier must advocate the elimination of all forms of forced labor.
We ensure that our suppliers and partners comply with international labor standards as set out in the ILO core labor standards.

 

2.1.2 Prohibition of forced labor / slavery
No forced labor, slave labor or comparable work may be used. Employment in forced labor is prohibited. This includes any work or service that is required of a person under threat of punishment (whether physical, mental, financial or otherwise) and for which that person has not volunteered. Also prohibited are all forms of slavery, slavery-like practices, servitude or other forms of domination or oppression in the workplace, such as extreme economic or sexual exploitation and humiliation.

All employees are granted the right to terminate their employment relationship subject to the contractually agreed or statutory notice period. It is prohibited to withhold identification documents from employees. Employees, especially migrant workers and migrants, are not allowed to make unlawful payments or deposits to get their jobs. If there are legitimate payments for job placement or for obtaining documents necessary for employment, such as work permits, visas or health checks, these are borne by the employer.

Special care is taken when using employment agencies, both directly and indirectly. Only legal and responsible employment agencies are used. Certified employment agencies are used wherever possible.

 

2.1.3 Prohibition of child labor
Our suppliers only employ employees who have reached the minimum age required to perform work in accordance with the applicable national legislation. Our suppliers will observe and respect the rights of children.

The minimum age of a child for admission to employment must be above the age at which compulsory schooling ends under German law, whereby the employment age of 15 years is not undercut under any circumstances, unless one of the exceptions recognized by the ILO applies (see ILO Convention No. 138). However, these exceptions are only relevant if German law also provides for them.

In order to ensure the above, reliable mechanisms for determining age are used when hiring employees, but under no circumstances do they lead to degrading or undignified treatment of employees or applicants.

 

2.1.4 Protection for young employees
The worst forms of child labor are always prohibited for employees under the age of 18 (in accordance with ILO Convention No. 182). These include, but are not limited to, all forms of slavery and practices similar to slavery, the use of children for illicit activities and any work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children or young people.

If employees under the age of 18 are employed, their working hours will not interfere with their participation in vocational training programs recognized by competent authorities.


2.1.5 Fair remuneration
The remuneration for regular working hours and overtime must correspond to the national statutory minimum wage or the minimum standards customary in the industry, whichever is higher. If the remuneration is not sufficient to cover the costs of normal living expenses and to build up a minimum level of reserves, the supplier is obliged to increase the remuneration accordingly. Employees shall be granted all legally prescribed benefits. Deductions from wages as a punitive measure are not permitted The supplier must ensure that employees receive clear, detailed and regular written information on the composition of their remuneration.

Our suppliers pay remuneration and social benefits that at least comply with national and local legal standards, regulations or agreements. The applicable regulations on working hours and vacation are complied with.

The remuneration paid to employees must comply with all applicable laws on remuneration, including laws on minimum wage, overtime and statutory social benefits. Deductions from wages as a disciplinary measure are not permitted. The basis on which workers are to be remunerated will be made known to employees in a timely manner in the form of a payslip or similar document.

2.1.6 Fair working conditions
All employees are informed about their rights and the conditions of their employment (such as remuneration, working time regulations and vacation entitlements) in a comprehensible manner and have a written employment contract.

All employees have the right to appropriate remuneration that is sufficient to enable them and their families to live in dignity. The statutory social benefits are granted. Remuneration is paid on time, regularly and in full.

The applicable statutory regulations on working hours (in particular with regard to overtime, breaks and rest periods) as well as vacation, paid sick days and parental leave are always complied with. The use of overtime is voluntary or regulated by contract.

Care is taken to ensure that employees are not subjected to inhuman or degrading treatment, physical punishment, sexual harassment, psychological or physical coercion, abuse or verbal abuse in the workplace.

Disciplinary measures that violate applicable law will not be taken. Permitted disciplinary measures will only be taken if they are set out in writing in the employment contract or in work regulations published in advance. The relevant regulations will be explained to employees beforehand in clear and understandable terms.


2.1.7 Freedom of association and collective bargaining
Our suppliers respect the freedom of association and the right to form interest groups. They grant their employees the right to defend their interests on the basis of national legislation.

The right of employees to form and join organizations of their choice and to engage in collective bargaining must be respected. In cases where freedom of association and the right to collective bargaining are restricted by law, alternative possibilities for independent and free association of employees for the purpose of collective bargaining must be granted. Employee representatives must be protected from discrimination. They must be granted free access to the workplaces of their colleagues to ensure that they can exercise their rights in a lawful and peaceful manner.

Open communication and direct dialog between workers and management is the best way to resolve workplace issues and compensation-related disputes. Business partners shall respect the right of workers to freedom of association, to join or refrain from joining trade unions, to appeal to workers' representatives, to join works councils in accordance with local laws. Workers must be able to communicate openly with management without fear of reprisal, intimidation or harassment.

2.1.8 Prohibition of discrimination
Any form of discrimination against employees must be avoided and actively prevented. In particular, no one may be discriminated against on the basis of skin color, gender, age, religion or ideology, social background, health, ethnic origin, nationality, membership in employee organizations, political membership or political opinion or sexual identity. This applies in particular to the recruitment of employees and in relation to their further training, promotion and remuneration.

2.1.9 Occupational health and safety
The occupational health and safety obligations applicable under the law of the place of employment are always complied with. Gebrüder Schulte ensures that appropriate systems are in place to identify, assess, prevent and control potential health and safety hazards. Effective measures are taken to prevent accidents at work or work-related health hazards, in particular through

  • adequate safety standards in the provision and maintenance of the workplace, the workplace and the work equipment,
  • suitable protective measures to avoid the effects of chemical, physical or biological substances,
  • measures to prevent excessive physical and mental fatigue, in particular through appropriate work organization in terms of working hours and rest breaks, and
  • appropriate training and instruction of employees and the documentation of these measures.

The minimum requirements also include adequate lighting, temperature control and ventilation, the provision of drinking water, adequate sanitary facilities and the provision of occupational health care.

All employees have the right to leave the company premises in dangerous situations without having to ask for permission.

2.1.10 Preserving natural resources and safeguarding basic human needs
The preservation of natural resources is observed and safeguarded. In particular, care must be taken to ensure that harmful soil changes, groundwater contamination, air pollution, harmful noise emissions or excessive water consumption are avoided in the course of business activities.

  • significantly impair the natural basis for the preservation and production of food,
  • deny a person access to safe drinking water,
  • impede or destroy a person's access to sanitary facilities or
  • damage a person's health.


2.1.11 Complaints mechanisms / whistleblowing and protection against retaliation
The supplier is responsible at the factory level for establishing an effective grievance mechanism for individuals and communities that may be affected by adverse impacts, including in the supply chain. Even where legal systems are effective and well resourced, grievance mechanisms can offer particular benefits, such as rapid access and redress, reduced costs and transnational reach. Employees who raise a grievance for violations of this Code of Conduct or relevant laws shall not be subject to any form of disciplinary action.

2.1.12 Dealing with conflict minerals
For the conflict minerals tin, tungsten, tantalum and gold, as well as for other raw materials such as cobalt, the company establishes processes in accordance with the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and expects its suppliers to do the same. Smelters and refineries without appropriate, audited due diligence processes should be avoided. Where relevant, a separate capital should be formulated due to the great importance of the topic in many sectors. A reference to current OECD standards and guidelines is useful.

2.1.13 Local land, forest and water rights / forced eviction
Local, national, international and traditional land, water and resource rights are respected, especially those of indigenous communities. The free and informed consent of affected communities is obtained before legally permitted land use changes are implemented or water or resources of local communities are consumed or impacted. The consent process is documented. It is ensured that no unlawful evictions take place.

2.1.14 Deployment of private and public security forces
It is prohibited to commission or use private or public security forces to protect a company project if, due to a lack of instruction or control on the part of the company when deploying the security forces

  • the prohibition of torture and cruel, inhuman or degrading treatment is disregarded,
  • life or limb are injured
  • the freedom of association and unionization are impaired.


2.1.15 Diversity and inclusion (minorities)
The diversity of people and thinking is valued and cultural differences are recognized. Different ideas, cultures and perspectives overcome unconscious barriers and help to build higher performing teams of well-trained employees. Inclusion is a reflection of a corporate culture in which every individual feels valued, respected and supported. The willingness and ability to recognize, understand, respect and then fully leverage the unique contributions of each individual will help everyone reach their highest potential. Inclusion is one of the prerequisites for innovation and success because it fosters the right conditions for optimal performance. This is expressed through active and explicit support for specific groups and issues, such as early career professionals, gender equality, etc.
As far as possible, people with disabilities or special needs and minorities are integrated into the company.


2.2 Environmental permits
All necessary environmental permits and approvals must be obtained, kept up to date at all times and complied with.

2.2.1 Climate protection
Gebrüder Schulte expects appropriate measures to be taken at all stages of the supply chain to reduce the carbon footprint and thus contribute to achieving the targets agreed at the UN Climate Change Conference in Paris and the 1.5 degree target of the Intergovernmental Panel on Climate Change (IPCC). All suppliers and their subcontractors are encouraged to find cost-effective solutions to improve energy efficiency and minimize energy consumption and greenhouse gas emissions.

2.2.2 Ecological responsibility
The supplier follows a systematic approach in order to fulfill its ecological responsibility. The core topics of the EMAS Regulation (No. 1221/2009) and ISO 14001:2015 are the following environmental aspects: Emissions to the atmosphere, discharges to water, contamination of soil, consumption of raw materials and natural resources, energy consumption/efficiency, release of energy (in the form of heat, radiation, light, noise), generation of waste, land use / biodiversity.

These should be taken into account in the supplier's environmental management system. We encourage the introduction of an environmental management system in accordance with EMAS or ISO 14001 or the supplier should focus on the topics covered by these two (or similar) standards.


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

2.2.4 Dealing with air emissions
General emissions from operations (air and noise emissions) and greenhouse gas emissions shall be typified, 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 minimize any emissions.

2.2.5 Handling waste and hazardous substances
Appropriate measures shall be taken to ensure that waste containing persistent organic pollutants (as defined in the Stockholm Convention of May 23, 2001 (POPs Convention) and the applicable legislation adopted on the basis thereof) is handled, collected, transported and stored in an environmentally sound manner. Such waste may only be disposed of in such a way that the specified pollutants are destroyed or irreversibly transformed (so that they no longer exhibit the characteristics of persistent organic pollutants) or disposed of in another environmentally sound manner; the latter can only be considered if destruction or irreversible transformation is not the environmentally preferable option or if the content of persistent organic pollutants is low.

The export of hazardous and other waste within the meaning of the Basel Convention of March 22, 1989 and within the meaning of Regulation (EC) No. 1013/2006 is prohibited if the importing state is not a party to the Basel Convention, the importing state has not given its written consent to the specific import or has even prohibited this import, or it can be assumed that the waste will not be treated in an environmentally sound manner in the importing state or elsewhere.
It is also prohibited to export hazardous waste (as defined above) from countries listed in Annex VII of the Basel Convention to countries not listed therein, and to import hazardous waste and other waste (as defined above) from a country that is not a party to the Basel Convention.


2.2.6 Reduce consumption of raw materials and natural resources
In addition to the applicable local environmental laws, all internationally recognized environmental standards must also be complied with.

Throughout the entire supply chain, the aim is to avoid or continuously reduce the environmental impact of resource and energy consumption, emissions of greenhouse gases and air pollutants, water consumption, soil and water pollution and waste as far as possible, to preserve biodiversity and to promote a circular economy. This applies to both goods and packaging.


2.2.7 Dealing with energy consumption/efficiency
In your apartment or house, you probably make sure that every form of energy, whether for heating or lighting, is used sparingly. Please do the same in our company. Wasting energy not only costs a lot of money, it also has a negative impact on the environment. Please also make sure that there is no unnecessary waste in your work area - what is not produced in the first place cannot pollute the environment.

2.2.8 Environmentally friendly production
Responsible use of raw materials and natural resources is ensured in all phases of production. The supplier is requested to give preference to the use of renewable energies and to ensure that energy is consumed sparingly. During product development, attention is paid to the principle of recyclability and the return of products to natural cycles.

2.2.9 Hazardous substances and product safety
Hazardous materials, chemicals and substances must be labeled and their safe handling, movement, storage, recycling, reuse and disposal must be ensured. Strictly comply with all applicable laws and regulations regarding hazardous materials, chemicals and substances. Applicable substance restrictions and product safety requirements must be complied with. Employees in key positions must be informed and regularly trained in this regard.

The following are prohibited

  • the manufacture, import and export of products containing mercury,
  • the use of mercury and mercury compounds in manufacturing processes within the meaning of Art. 5 para. 2 and Annex B Part I of the Minamata Convention of October 10, 2013 from the phase-out date specified therein,
  • the treatment of mercury waste contrary to Art. 11 para. 3 of the Minamata Convention.



2.2.10 More environmentally friendly packaging
Efforts must always be made to ensure that more environmentally friendly packaging is used. To this end, packaging should be avoided where possible, reduced or improved in terms of its environmental effects. These principles are to be applied in the order of priority indicated here - the best packaging in environmental terms is the one that can be completely avoided. Packaging is considered more environmentally friendly if it is reusable, uses as little material as possible, is recyclable or consists of secondary raw materials, alternative materials or certified paper.

2.2.11 Decarbonization
The aim is to make an active contribution to the decarbonization of the industrial market. The focus is on efficient management, energy modernization and sustainably operated and managed investments.

2.2.12 Biodiversity / animal welfare
Site-specific biodiversity must not be restricted. The principles of animal welfare are observed in business activities. The Washington Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) is recognized and business activities are aligned accordingly.

2.2.13 Renewable energies
Care must be taken to avoid negative impacts on the environment as far as this is within the company's sphere of influence. This includes the reduction of pollutants, emissions, waste water, waste, odors, noise, energy consumption (especially fossil fuels) in the manufacture and use of products and services.

Non-renewable raw materials and energy sources must be replaced by renewable ones as soon as the company becomes aware of the possibility. A review must be carried out at regular intervals to determine the extent to which it is possible to replace non-renewable raw materials and energy sources with renewable energy sources.


2.3 Ethical business conduct
For the individual areas, we refer to the OECD Guidelines for Multinational Enterprises and the Global Compact.

2.3.1 Competitive behavior
The applicable national and international competition laws must be complied with. In particular, reference is made to the principles of fair competition and the prohibition of agreements that distort competition.

The company is committed to being transparent and reporting regularly on our progress with regard to compliance with the Supply Chain Act and our Code of Conduct. We expect our suppliers and partners to inform us about their progress with regard to the compliance with the Supply Chain Act and their own rules of conduct and standards.


2.3.2 Confidentiality / data protection
The Supplier undertakes to meet the reasonable expectations of the Client, suppliers, customers, consumers and employees with regard to the protection of private information. The Supplier shall comply with data protection and information security laws and regulatory requirements when collecting, storing, processing, transferring and disclosing personal information.

2.3.3 Intellectual property / plagiarism
Intellectual property rights and product rights must be respected; technology and know-how must be transferred in such a way that intellectual property rights and customer information are protected. The use, application or utilization of counterfeit parts is expressly prohibited and will be severely punished. The use, further processing or marketing of counterfeit parts is not permitted. The publication of information must be approved in advance or be mandatory due to laws or regulations.

2.3.4 Integrity, bribery, taking advantage
The company is committed to acting ethically and with integrity. We expect our employees, suppliers and partners to adhere to high ethical standards, including the avoidance of bribery, corruption and other unethical practices. In accordance with the United Nations (UN) Convention against Corruption and applicable national regulations, it must be ensured that all forms of corruption are refrained from and prevented. Invitations and gifts are only permitted to an appropriate extent and must not influence the business relationship. Any kind of conflict of interest must be avoided.
The supplier must take a stand against all forms of corruption, including extortion and bribery. We ensure that our suppliers and partners adhere to the same high standards as we do.


2.3.5 Avoiding conflicts of interest
Our suppliers make decisions on the basis of objective considerations and are not unduly guided by personal interests.

2.3.6 Money laundering
Our suppliers comply with the relevant statutory provisions on the prevention of money laundering.

2.3.7 Export controls and economic sanctions
Numerous countries such as Great Britain, France, Germany and the USA have passed laws on the export control of strategic products, technology and software. Gebrüder Schulte, suppliers and partners are bound by these laws and regulations. The corporate policy of Gebrüder Schulte expressly requires compliance with all applicable export control regulations.
Failure to comply may result in civil or criminal penalties, including fines, imprisonment, loss of export licenses, debarment, revocation of previously issued licenses, seizure and confiscation of goods. Such sanctions may be imposed on Gebrüder Schulte, individual employees and/or persons otherwise associated with Gebrüder Schulte.
Due to the enormous importance of compliance with all applicable export control regulations, employees or Gebrüder Schulte who knowingly violate such controls or the Compliance Policy will be subject to appropriate disciplinary action.

Gebrüder Schulte encourages partners and employees to report actions that may violate laws or other regulations and guidelines of Gebrüder Schulte. Gebrüder Schulte, in turn, is obliged to investigate reported incidents and take appropriate action.

Gebrüder Schulte does not take action against individuals who raise questions, point out compliance issues or report possible misconduct. The proper application and handling of export control measures underscore Gebrüder Schulte's commitment to ethical business conduct and compliance with applicable laws and regulations.


2.3.8 Financial responsibility
Financial responsibility and compliance with the legal requirements of proper accounting and disclosure regulations are a matter of course for Gebrüder Schulte.

All reporting and disclosure in the form of financial statements, reports, records and announcements is truthful, generally accepted accounting principles, comprehensive and understandable.


2.3.9 Ethical recruitment
All policies and laws related to recruitment, selection and other aspects of employment such as promotion, demotion, transfer, layoff, termination, compensation, education, training and disciplinary action must be considered.

2.3.10 Disclosure of information
Our suppliers are expected to cooperate fully with investigating authorities to the extent permitted by law. If a supplier becomes aware of credible evidence of non-compliance with this Supplier Code or any other violation of applicable law, the supplier must promptly disclose such evidence to the appropriate investigating authorities and, if necessary, to the employees required to fully investigate the suspected misconduct.

If statutory provisions require the disclosure of information anyway, this obligation must be fulfilled independently.



3. Compliance with the Code of Conduct

 

Gebrüder Schulte will not tolerate violations of our Code of Conduct and will take appropriate measures to ensure that it is complied with. We expect our suppliers and partners to report violations of our Code of Conduct and to work with us to ensure compliance.

Gebrüder Schulte undertakes to implement this Code of Conduct in the supply chain and to ensure that our employees, suppliers and partners comply with its standards. If a breach of the provisions of this Code of Conduct is identified, the client shall notify the supplier in writing within one month and set a reasonable grace period for the supplier to bring its conduct into line with these provisions.

 

3.1 Implementation of the requirement

3.1.1 Comminication
Our suppliers communicate this Code of Conduct to third parties who are used to fulfill the relationship with Gebrüder Schulte, take the Code of Conduct into account when selecting them and endeavor to oblige them to comply with it and to check this regularly.

A breach of this Code of Conduct constitutes an impairment of the business relationship between Gebrüder Schulte and our supplier. Without prejudice to further rights, Gebrüder Schulte reserves the right in this case to demand clarification of the facts and the initiation of countermeasures from its supplier. If the supplier demonstrably fails to initiate suitable improvement measures within a reasonable period of time or if a breach is so serious that a continuation of the business relationship becomes unreasonable for Gebrüder Schulte, Gebrüder Schulte reserves the right to terminate the contractual relationship concerned without prejudice to further rights.

 

3.1.2 Monitoring and obligation to provide evidence
Upon request, the supplier shall provide Gebrüder Schulte with all necessary information for an initial assessment correctly and comprehensively as part of a self-assessment. In addition, the supplier shall provide other information that demonstrates compliance with the guideline. Gebrüder Schulte shall monitor the implementation of this guideline. The supplier shall inform Gebrüder Schulte of any events that conflict with the principles of the guideline.

 

3.1.3 Referencing:
 

 

Status: 01.06.2024

Andrea Schulte

CEO