alupak Code of Conduct

a. Lawful Conduct

Obeying the law is paramount to alupak. Each employee must comply with the legal requirements of the jurisdiction in which he or she is acting. Violations of the law must be avoided at all costs.

Every employee must expect disciplinary consequences in the event of a violation – irrespective of the sanctions provided for in the law – because of the violation of his or her duties under the employment contract.

b. Mutual respect, honesty and integrity, working conditions.

We respect the personal dignity, privacy and personal rights of each individual. We work together with employees and external business partners of different nationalities, ethnic origins, skin color, cultures, religions and world views. We do not tolerate discrimination, whether on these grounds or on the basis of gender, sexual identity, age or disability. We do not tolerate corporal punishment or personal insults, nor do we tolerate physical, sexual, psychological or verbal harassment or abuse.

We are open and honest and stand by our responsibilities. We are reliable partners and only make commitments we can keep. We expect our employees to behave honestly.

We offer fair employment conditions, pay appropriate compensation and consider the needs of employees when taking operational measures. We do not accept any form of child or forced labor.

c. Responsibility for the reputation of alupak

The reputation of alupak is significantly affected by the appearance, actions and behavior of each individual in our workforce. Unlawful or inappropriate conduct by even one employee can cause significant damage to the company. Every employee is required to pay attention to, maintain and promote the reputation of alupak.

d. Leadership, responsibility, supervision

Integrity and compliance with the law and alupak’s internal regulations begin in the management of the company. Each manager is responsible for his or her employees. She must earn recognition through exemplary personal conduct, performance, openness, reliability and social competence. This also means that the manager must always address and emphasize the importance of correct behavior in everyday business and set an example himself/herself with integrity and in compliance with the rules.

Leaders set clear, ambitious, and realistic goals and hold themselves to them by example. They lead by trust and give their employees as much personal responsibility and freedom of action as possible. They challenge and encourage their employees. At the same time, they make it clear to their employees that compliance with alupak laws and guidelines has top priority under all circumstances and at all times. Managers are also responsive to their employees in the event of any ambiguity regarding legal compliance, questions, or professional or personal concerns. However, the manager’s responsibility does not relieve employees of their own responsibilities.

We commit to:

• To treat each other with respect
• To reliability and sincerity
• On openness and critical faculties
• To a cooperative leadership style
• To clear, quick decisions within the given framework

This creates the basis for personal responsibility, initiative, commitment and joint entrepreneurial success!

Every manager has organizational and supervisory duties to fulfill. He or she is responsible for ensuring that no violations of laws, internal guidelines or this alupak Code of Conduct occur in the respective area of responsibility that could have been prevented or made more difficult by appropriate supervision.

Even if individual tasks are delegated, the manager retains responsibility.

a. Observance of competition and antitrust law

The state protects fair competition through competition and antitrust laws. Violations of these regulations are subject to severe penalties. They also affect the employee who violates these laws. Every employee is therefore obliged to comply with all rules of fair competition and cartel avoidance. Any form of collusion with competitors that distorts competition, for example with regard to prices and capacities, is prohibited. The same applies, of course, to agreements with competitors not to compete, to submit sham bids, etc.

b. Offering and granting advantages

We win contracts fairly through the quality and price of our products and services and not by offering undue advantages to others.
No employee may offer or grant – directly or indirectly – unauthorized advantages of any kind to public officials or business partners in connection with business activities. No payments of money or other benefits may be made to influence decisions or to obtain an unjustified advantage. Any gratuity must comply with applicable laws and internal policies.
Promotional gifts to employees of business partners must be selected to avoid any appearance of dishonesty or impropriety on the part of the recipient. They must not be given if they can be understood as an attempt to influence a public official or a business partner in order to gain advantages for alupak.

c. Requesting and accepting benefits

No employee may use his or her official position to demand, accept, obtain or be told that he or she will receive benefits. This does not include accepting occasional gifts of symbolic value or invitations to dinners or events if the occasion and extent of the invitation are appropriate and refusing the invitation would be contrary to the requirements of courtesy.

Employees may not accept gifts or other benefits from companies or persons with whom they have a business relationship, the value of which exceeds customary minor attentions.

d. Special rules for the awarding of contracts

Anyone who applies for a contract expects us to review their bid fairly and without bias. Suppliers are to be selected solely on a competitive basis after comparing the quality, performance, price and suitability of the products and services offered.

e. Donations

As a responsible member of society, alupak grants donations in cash and in kind for education and science, culture as well as charitable and social projects. Donations to individuals, for-profit organizations, and organizations whose goals are incompatible with those of alupak are not permitted. Donations to private accounts are not permitted.

Donations must be transparent, i.e. the recipient of the donation and the specific use by the recipient must be known. Donations should be tax deductible. Requests for donations are generally subject to the decision of the management.

It is alupak’s declared goal to only maintain business relationships with reputable customers, consultants and business partners whose business activities are in accordance with legal regulations and whose financial resources are of legitimate origin. All employees are required to strictly comply with anti-money laundering laws. Suspicious behavior by customers, consultants or business partners must be reported. All applicable record-keeping and accounting requirements for cash and other transactions and contracts shall be followed.

alupak will comply with all export control and customs laws and regulations applicable in the respective countries in which we operate. Such regulations may apply in connection with direct or indirect exports or imports from or into sanctioned countries, or in connection with third parties against whom, for example, there are suspicions with regard to national security or who are involved in criminal activities. Violations of these regulations and laws can result in drastic penalties, up to and including exclusion from simplified import and export procedures, i.e. disruption of the seamless supply chain.

All employees involved in the import and export of goods and services are required to comply with all applicable economic sanctions, export control and import laws and regulations, as well as all policies and processes imposed by their business activities.

All employees are required to make business decisions in the best interest of alupak and not based on personal interests. The following rules apply to avoid conflicts of interest or loyalty:

a. Duty of disclosure

Each employee shall disclose to his or her manager any personal interest (including family members or close personal friends) that may exist in connection with the performance of his or her official duties. Attempts by business partners to influence alupak employees, their family members or close personal friends by making contributions to them must be reported immediately.

b. Transparent awarding of contracts

No employee shall place or cause to be placed an order with family members or close personal friends without the prior written approval of the appropriate manager.

c. Private contracting with alupak’s business partners.

No employee may have private orders carried out by companies with which he/she has to deal in his/her business activities for alupak if this could give him/her advantages that are not customary in the market. a direct or indirect influence on the commissioning of the company by alupak or if he/she is involved with the processing of orders by this company in an official capacity.

d. Use of alupak employees for private purposes

It is impermissible for managers to use the work performance of employees for private purposes in abuse of their authority to issue directives.

e. Non-compete clause

An employee may not manage or work for a company that competes in whole or in part with alupak. He/she may not engage in activities that compete with alupak.

f. Participation in third party companies

It is also not permitted to directly or indirectly participate in a non-listed company that competes with alupak in whole or in part.

Prior written permission is required in case of participation in a company that is a business partner of alupak. Permission is granted by management and documented in the personnel file. Permission is not granted or can be withdrawn again if the employee is involved with the respective company on official business.

Participation by close relatives in a competitor company or any other of the prescribed companies must be notified in writing by the employee to the Human Resources Department if interests of the company may be affected thereby and must be documented in the personnel file.

Exempt from the above regulations are shareholdings in listed companies as well as in the form of equity funds or similar investments, where the investor is usually not even informed about the individual shareholdings.

a. Records and reports

Open and effective collaboration includes accurate and truthful reporting. This applies equally to relationships with management, employees, customers, business partners, as well as the public and government agencies.

All records and reports made internally or given externally must be accurate and truthful. In accordance with generally accepted accounting principles, data entries and other records must always be complete, accurate, timely and in accordance with the system. The requirement for truthful information also applies to expense and travel expense reports.

b. Confidentiality

Each employee shall maintain confidentiality about internal company matters that have not been publicly disclosed. This includes, for example, details concerning the organization of the company and its facilities, as well as business, manufacturing and development processes, projects and internal reporting figures.

Non-public information from or about suppliers, customers, employees, consultants, agents and other third parties must also be protected in accordance with legal and contractual requirements. In particular, no employee is permitted to make any recordings, files, images, sounds or reproductions without the consent of his or her manager, unless it is directly related to the job.

The obligation to maintain confidentiality shall continue to apply after termination of employment.

c. Data protection and data security

Access to the intranet and Internet, worldwide electronic information exchange and dialog, and electronic business transactions are critical to the effectiveness of each of us and to business success as a whole. However, the benefits of electronic communication come with risks to privacy and data security. Taking effective precautions against these risks is an important part of IT management, leadership and also the behavior of each individual.

Personal data may only be collected, processed or used insofar as this is necessary for defined, clear and lawful purposes. In addition, personal data must be kept secure and may only be transferred using the necessary precautions. A high standard of data quality and technical protection against unauthorized access must be ensured. The use of data must be transparent for the data subjects, and their rights to information and correction and, if applicable, to objection, blocking and deletion must be safeguarded.

alupak has numerous facilities and equipment such as computers, copiers, software, machines, tools and other work equipment in its offices and operating facilities. These may only be used for company purposes and not for personal benefit. Exceptions require management approval.

The protection of the environment, the conservation of its natural resources, the efficient use of energy as well as occupational safety and health protection are corporate goals of high priority for us. An integrated management system sets high standards for this and ensures compliance with the law.

Environmentally friendly design and technical safety are fixed targets right from the development stage of our products. Every employee must contribute to an exemplary performance in the field of environmental protection and occupational safety. In particular, employees are encouraged to exploit all reasonable opportunities for process optimization, thereby reducing the consumption of energy and raw materials in production while limiting emissions. Developing and promoting a sense of responsibility for the environment, energy use and occupational safety at all levels is an ongoing management task. Each individual has a shared responsibility to support alupak in its efforts to create safe working conditions. The working environment must meet the requirements of a health-oriented design. Every employee must pay constant attention to occupational safety.

Every employee has the right to make a personal complaint to his or her manager, the Human Resources Department or the management, or to point out circumstances that indicate a violation of the Code of Conduct; this may also be done anonymously. The matter will be thoroughly investigated. Appropriate action will be taken as necessary. Any tip-off will be treated confidentially within the framework of legal regulations. Whistleblowers must not suffer any unjustified disadvantages because of their information.

On the other hand, communications made with the intent to falsely accuse colleagues or managers will not be tolerated. Such conduct is also a serious violation of this Code of Conduct.

In the event of violations of this Code of Conduct, the Company will take action and take appropriate measures for proper resolution. As a matter of priority, the company will attempt to resolve the matter by explaining the importance of the values to affected employees in order to encourage them to change their behavior. However, it is also possible to implement labor or disciplinary measures within the framework of the applicable regulations in the event of violations of this Code of Conduct.

The management ensures the functioning of this Code of Conduct by creating the necessary framework conditions as well as providing the necessary resources.

The management actively promotes the broad communication of the Code of Conduct and ensures its sustainable implementation. Compliance with the law and observance of the Code of Conduct shall be regularly monitored in all organizational units of alupak.