Code of Conduct

for Suppliers and Business Partners

Preamble

PWA ELECTRONIC GmbH is an internationally operating company. As such a company, PWA ELECTRONIC GmbH bears corporate responsibility towards customers, employees, investors and the public, as well as towards the environment.

PWA ELECTRONIC GmbH sees itself as obligated to act economically, socially and environmentally responsibly. PWA ELECTRONIC GmbH is committed to always complying with applicable law in all its business activities, respecting ethical principles and acting sustainably.

Against this background, we, PWA ELECTRONIC GmbH, have created this Code of Conduct for Suppliers and Business Partners. PWA ELECTRONIC GmbH expects its suppliers and business partners, as well as their employees, to act responsibly, comply with this Code of Conduct for Suppliers and Business Partners and work according to the guiding principles and principles contained therein. Should suppliers or business partners engage third parties (e.g. subcontractors) in the course of their business relationship with PWA ELECTRONIC GmbH, PWA ELECTRONIC GmbH expects these third parties to likewise commit to the fundamental principles set out in this Code of Conduct for Suppliers and Business Partners. PWA ELECTRONIC GmbH reserves the right to verify compliance with the defined requirements at the supplier or business partner independently or through an external partner after prior notice and in the presence of a representative of the supplier or business partner on site.

1.) Social (Corporate) Responsibility

  • Human Rights
    We expect our suppliers and business partners to comply with and protect internationally applicable provisions for the protection of human rights as general and universally valid requirements. This includes in particular that our suppliers and business partners do not use forced or child labor and comply with the provisions set out in ILO Conventions 138 and 182 regarding the statutory minimum age for the employment of children. Our suppliers and business partners are responsible for ensuring that unacceptable treatment of workers, such as psychological hardship, sexual and/or personal harassment, does not occur.
  • Equal Opportunity and Non-Discrimination (Equal Treatment and Prohibition of Discrimination)We expect our suppliers and business partners not to discriminate against anyone on the basis of ethnic origin, nationality, skin color, gender, religion, ideology, age, disability, sexual orientation, political views or other legally protected characteristics.
  • Freedom of AssociationWe expect our suppliers and business partners to recognize the fundamental right of all employees to form and join trade unions and employee representatives. If this right is restricted due to local laws, alternative, legitimate opportunities for employee representation shall be promoted.
  • Workplace Safety and Working HoursWe expect our suppliers and business partners to comply with the applicable legal requirements for occupational safety and health protection in order to protect the health and safety of their employees. They support the further development and improvement of working conditions. Working hours comply at a minimum with the respective national legal requirements or the minimum standards of the respective national business sectors.
  • Minimum WageWe expect our suppliers and business partners to ensure fair remuneration of their employees that meets at least the legally valid and guaranteed minimum. Where statutory or collective bargaining agreements do not exist, remuneration is based on industry-specific, locally customary collective agreement wages and benefits that ensure employees and their families an adequate standard of living.

2.) Environmental Responsibility

  • Environmental ProtectionWe expect our suppliers and business partners to implement measures for responsible environmental stewardship and to comply with applicable environmental laws, regulations and standards. Our suppliers and business partners take into account the minimization of greenhouse gas emissions, the use of renewable resources and the minimization of environmental and health damage in the development, manufacture and use phase of products as well as in other activities.
  • Energy and Resource EfficiencyWe expect our suppliers and business partners to use natural resources sparingly and to reduce environmental pollution in air, land and water. They contribute to reducing energy consumption and greenhouse gas emissions.
  • Waste and RecyclingWe expect our suppliers and business partners to take into account the avoidance of waste, reuse, recycling as well as safe and environmentally friendly disposal of residual waste in their production processes, for the use phase of products and other activities.
  • Conflict MineralsWe expect our suppliers and business partners both not to finance and support armed groups that violate human rights in any way, as well as to ensure that they do not use and/or process raw materials in their products that are extracted and mined in conflict regions and/or high-risk areas.
  • ChemicalsWe expect our suppliers and business partners to comply with all applicable environmental laws and regulations and with their products to comply with the applicable REACH Regulation (EC) No. 1907/2006 and the valid RoHS Directive 2011/65/EU and corresponding subsequent regulations.

3.) Transparent Business Relationships

  • Avoidance of Conflicts of InterestWe expect our suppliers and business partners to make their decisions only on the basis of objective criteria and not to be influenced by personal interests and relationships.
  • CorruptionWe expect our suppliers and business partners to strictly reject any form of bribery, corruption, extortion and embezzlement and to respect, support and comply with the observance of anti-corruption laws. They ensure that their employees, subcontractors or representatives do not grant, offer or accept any bribes, kickbacks, unlawful donations or other unlawful payments or benefits to customers, public officials or other third parties.
  • BriberyOur suppliers and business partners do not offer PWA employees or third parties inappropriate benefits in the form of gifts, entertainment or invitations to unlawful influence in any way. Likewise, our suppliers and business partners do not request or accept such inappropriate benefits.
  • Government as Customer and Dealings with AuthoritiesWe expect our suppliers and business partners to adhere to strict legal requirements in their dealings with governments, authorities and public institutions. They comply with and adhere to the respective legal regulations in their participation in public tenders as well as the rules of free and fair competition.
  • Consultants and IntermediariesWe expect our suppliers and business partners to engage consultants or intermediaries only in compliance with applicable laws. They pay special attention to ensuring that compensation paid to consultants or intermediaries is only paid for consulting or brokerage services actually performed and is in reasonable proportion to the services rendered.

4.) Fair Market Conduct

  • Free CompetitionWe expect our suppliers and business partners to comply with applicable antitrust laws and in particular not to enter into anti-competitive agreements with competitors, suppliers or customers. Our suppliers and business partners do not abuse any dominant market position that may exist.
  • Import & Export ControlWe expect our suppliers and business partners to ensure compliance with all applicable laws and regulations for the import and export of goods, services and information, and to respect applicable trade restrictions, embargoes and other restrictions.
  • Money LaunderingWe expect our suppliers and business partners to only conduct business relationships with business partners of whose integrity they are convinced. They ensure that the respective applicable legal provisions against money laundering are not violated.
  • Business InformationWe expect our suppliers and business partners to disclose their business data and to report truthfully and in accordance with applicable laws on their business activities.

5.) Protection of Data, Trade Secrets and Company Assets

  • Data ProtectionWe expect our suppliers and business partners to comply with and observe the applicable laws protecting personal data of employees, suppliers, customers and other affected parties.
  • Protection of Know-how, Patents, Trade and Business SecretsWe expect our suppliers and business partners to respect the know-how, patents, trade and business secrets of PWA and third parties and not to disclose such information to third parties without prior express written consent from PWA or in any other unlawful manner.
  • Handling of Company AssetsWe expect our suppliers and business partners to respect the tangible and intangible assets of PWA and not to use them for unlawful or non-business purposes. They ensure that their employees and any third parties (subcontractors or representatives) engaged by them in the context of the business relationship neither damage PWA's assets nor misuse them, i.e. contrary to PWA's interests.
  • Security of the International Supply ChainWe expect our suppliers and business partners to ensure that the operating facilities and transshipment points where goods intended for PWA are produced, processed, stored, loaded and transported are protected from unauthorized third-party access within the framework of a secure supply chain and that the personnel deployed is reliable.

6.) Consequences of Violations

In the event of violations of this Code of Conduct, the supplier or business partner must notify PWA ELECTRONIC GmbH. If a supplier or business partner does not comply with the fundamental principles defined in this Code of Conduct, PWA ELECTRONIC GmbH is entitled to terminate the business relationship with this supplier or business partner by extraordinary termination.

Code of Conduct, 22.12.2022