Waldaschaff Group Code of Conduct

1). Preamble

The Waldaschaff Group Code of Conduct sets our the standards on which our ethical behaviour is based. Our intention is to ensure mutual respect, honesty and fairness when dealing with fellows and business partners.

This Code shall apply to all business activities of the Waldaschaff Group worldwide. It takes account of the cultural diversity and values of our employees all over the world and is our commitment to the social responsibility or our global enterprise.

To maintain the high reputation our Company enjoys with customers, business partners and the public, the compliant and responsible conduct of each employee is essential.

The Waldaschaff Group Code of Conduct is binding for all employees at all Company locations.

<br/> Management board

2). Compliance with legislation, regulations and internal policies

The relevant applicable statutory regulations, current states of technology, the International Bill of Human Rights, the UN Convention against Corruption, the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work, as well as all internal policies and rules shall be observed.

3). No active or passive corruption

The Waldaschaff Group employees shall not tolerate any form of corruption and firmly refuse any kind of bribery. The Company management, executives and employees shall be prohibited from offering, promising or granting business partners, their employees or agencies, officials, politicians or any relatives of the said group of persons any benefits in return for being preferred in the procurement of goods, services or official acts, irrespective of whether or not an entitlement to the service/act exists in each individual case. In this context, the Waldaschaff Group is subject to the ICC Rules on Combating Corruption, the provisions of the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, as well as the “Anti Unfair Competition Law of the People‘s Republic of China”.

Should an employee become aware of cases of corruption and/or bribery, he/she must immediately contact the person of trust responsible for the relevant location and report the situation.

4). Confidentiality of information and data privacy

All information relating to the Waldaschaff Group and their business partners shall be treated as confidential and must not be disclosed to third parties unless such information has previously been publicly known or accessible in a permissible manner. The disclosure of information due to requests for information by public authorities as well as in course of the performance of business matters shall be exempt from this provision. This obligation to keep secrecy shall survive the termination of any employment relationship.

5). Sustainability and environmental compatibility

The Waldaschaff Group adheres to the principles of sustainability and environmental compatibility as well as energy efficiency and occupational safety. Compliance with all relevant environmental protection, energy and occupational safety regulations including the specific rules of the countries where the Waldaschaff Group is active is an obvious commitment of the Company management, the executives and each individual employee. Compliance with these regulations also applies to the manufacturing process and the life cycle of our products. In the development, selection of materials and suppliers, as well as in the manufacturing processes already, we set high standards in consideration of economical, ecological, environmentally compatible, energy-related and occupational safety aspects.

6). Tolerance and equal opportunities

As a global enterprise, the Waldaschaff Groups works with employees and business partners of different nationalities, cultures, religions and philosophies of life. Personal interaction shall be characterised by respect, tolerance, appreciation, fairness and openness.

The Waldaschaff Group invariably disapproves discrimination, harassment, disadvantage, any form of disparagement, but also the preferential treatment of employees or business partners due to their ethnic origin, sex, religion, ideology, political conviction, disability, age, sexual identity or other ethical, social and legally protected characteristics. Any form of harassment at work, especially sexual harassment of any kind whatsoever is generally prohibited. In this respect it is negligibly whether or not the person concerned could evade from such harassment or the trespasser considers his/her behaviour as acceptable.

7). Management culture

The Waldaschaff Group consider their employees as their number one asset. They invest in the qualification and skills of their employees; commitment and good performance are enhanced and rewarded.

All executives are requested to act as role models and in compliance with this Code of Conduct, especially to behave in an appreciating, reliably and responsible manner to their direct reports. They shall acquire and maintain their appreciation by their exemplary personal behaviour, performance, approachability and social skills.

8). Fair and safe working conditions

The Waldaschaff Group strive at providing their employees with safe and fair working conditions meeting all relevant statutory and national requirements in every country.

Regarding their international representation, the Waldaschaff Group shall also observe the ILO (International Labour Organisation) Declaration on Fundamental Principles and Rights at Work and disapprove any form of forced or child labour among other things.

Waldaschaff Automotive GmbH and WA Production GmbH tolerate and respect the freedom of association, the membership or affiliation of their employees in associations accepted under constitutional law, e.g. properly established trade unions.