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Supplier Code of Conduct

With this Supplier Code of Conduct, ALMEX GmbH commits to the highest ethical and social principles. ALMEX expects all ALMEX suppliers and their own suppliers to acknowledge and commit to this Code of Conduct. Suppliers are expected to comply with all applicable laws, including all anti-corruption laws worldwide; to promote diversity and corporate social responsibility; to meet environmental, health, and safety standards; to respect human rights; to support a sustainable and transparent supply chain, including responsible raw material sourcing measures; and to apply management systems necessary to comply with this Code.

Failure by the supplier to comply with the provisions of this Code may lead to a termination of the business relationship.

1

EMPLOYEE AND HUMAN RIGHTS

  • The supplier must treat its employees, partners, and workers with dignity and respect.
  • The supplier must not engage in human trafficking, slavery, child labor, or any other form of involuntary labor.
  • The supplier must neither permit nor engage in unlawful discrimination or harassment in the workplace.
    ALMEX does not tolerate behavior that interferes with another person’s ability to work in a harassing, disruptive, or detrimental manner.
  • Employees, partners, and workers of the supplier are not permitted to possess, consume, distribute, or sell drugs on ALMEX premises, nor to perform their work under the influence of alcohol or drugs.
2

SUPPLY CHAIN DUE DILIGENCE ACT (LkSG)

We point out that the Supply Chain Due Diligence Act is an integral part of our CoC and require our suppliers to comply with it regarding the following topics:

  1. the prohibition of employing a child
  2. the prohibition of the worst forms of child labor
  3. the prohibition of employing persons in forced labor
  4. the prohibition of all forms of slavery
  5. the prohibition of disregarding occupational safety obligations under the law of the place of employment
  6. the prohibition of disregarding freedom of association
  7. the prohibition of unequal treatment
  8. the prohibition of withholding adequate wages
  9. the prohibition of causing harmful soil alteration, water pollution, air pollution, harmful noise emissions, or excessive water consumption
  10. the prohibition of unlawful forced eviction and the prohibition of unlawful deprivation of land, forests, and waters
  11. the prohibition of commissioning or using private or public security forces to protect the corporate project if, due to insufficient instruction or control by the company, rights are violated during the deployment of security forces
  12. the prohibition of any act or omission beyond numbers 1 to 11 that is directly capable of severely impairing a protected legal position and whose unlawfulness is obvious upon a reasonable assessment of all relevant circumstances
3

ENVIRONMENT, HEALTH AND SAFETY

  • The supplier must conduct its activities with the objective of waste reduction, pollution prevention, recycling promotion, and resource conservation.
  • The supplier must provide safe and healthy working conditions for all employees, partners, and workers, including, but not limited to, emergency preparedness, industrial hygiene, and machine safety.
  • The supplier must comply with all applicable environmental, health, and safety laws.
4

CONFLICT MINERALS

  • Conflict minerals are defined as coltan (tantalum ore), cassiterite (tin ore), gold, wolframite (tungsten ore), or their derivatives (tantalum, tin, tungsten, and gold).
  • ALMEX aims to remove conflict minerals from its supply chain that directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or an adjoining country. ALMEX expects the supplier to share this objective.
  • ALMEX conducts due diligence reviews of its supply chain as needed to increase transparency and identify the countries, smelters, and refineries from which conflict minerals potentially used in its products originate. The supplier must cooperate with ALMEX’s due diligence processes and provide complete and accurate information upon request. The supplier is encouraged to conduct similar due diligence reviews of its own supply chain as needed.
5

ANTI-CORRUPTION

  • The supplier must not, directly or indirectly, pay anything of value to natural or legal persons, government officials, government agencies, or other third parties in order to
  • obtain or retain business or to improperly influence an act or decision, or
  • obtain an improper business advantage.
  • The supplier must avoid corrupt practices and comply with all applicable anti-corruption laws, particularly the U.S. Foreign Corrupt Practices Act (“FCPA”).
  • The supplier must ensure that all invoices and other financial statements submitted to ALMEX are accurate and transparent. The supplier must not misrepresent, falsify, or attempt to conceal, cover up, or otherwise obscure transactions or payment requests.
6

CONFLICTS OF INTEREST

  • A conflict of interest arises when personal interests or activities conflict or appear to conflict with the legitimate concerns of ALMEX or the supplier in their capacity as organizations.
  • The supplier must disclose to ALMEX all apparent or actual conflicts of interest related to its relationship with ALMEX. If ALMEX’s management approves an apparent or actual conflict of interest, the approval decision must be documented in writing.
7

GIFTS AND HOSPITALITY

  • Occasionally, ALMEX employees may accept gifts, simple hospitality, or other courtesies in business dealings, but only if there is a legitimate business purpose.

  • The following situations do not constitute a legitimate business purpose and are expressly prohibited:

  • providing gifts, hospitality, or preferential treatment with the intent to influence the objectivity of decisions made by an ALMEX employee, partner, or worker,

  • offers of gifts, hospitality, or preferential treatment while involved in a current purchasing or contractual decision with ALMEX (e.g., requests for information, price requests, bid requests, performance requests),

  • monetary gifts, including gift vouchers,

  • offers of extravagant or lavish recreational outings, travel, or accommodation. ALMEX employees are not permitted to solicit gifts, hospitality, or other benefits from suppliers.

  • The supplier must not offer ALMEX employees products, services, or financial interests for purchase whose terms are not available to all ALMEX employees.

  • Suppliers must not offer gifts, hospitality, or travel on behalf of ALMEX in connection with obtaining or retaining business for ALMEX.

8

DATA PROTECTION

  • The supplier must comply with applicable data protection laws and regulations when processing personal data of individuals with whom it conducts business, including customers, consumers, and employees.
  • In particular, the supplier may only process the minimum amount of personal data required to fulfill its obligations to ALMEX, and solely for the purposes specified in its agreement with ALMEX. The supplier must keep personal data confidential and secure at all times.
9

ACCURACY OF BUSINESS RECORDS

  • The supplier is obliged to maintain accurate books and records that reflect actual and permissible business transactions and payments. The creation of falsified, inaccurate, incomplete, or misleading documents is strictly prohibited.
  • All accounting documents and records must comply with generally accepted accounting principles.
  • Records must be legible and understandable.
10

COMPETITION, INTELLECTUAL PROPERTY AND CONFIDENTIAL INFORMATION

  • The supplier must comply with all applicable competition and antitrust laws.
  • The exchange of confidential information must take place based on a written and signed confidentiality agreement between ALMEX and the supplier. Any exchange of confidential information must be limited to the purpose of fulfilling contractual performance requirements.
  • The supplier must not disclose or reveal to third parties any intellectual property, confidential, or other proprietary information of ALMEX that becomes known to it (including information developed by the supplier and information about products, customers, pricing, costs, expertise, strategies, programs, procedures, and practices).
11

TRADE,
IMPORT AND EXPORT

  • The supplier must comply with the letter and spirit of applicable import, export, customs, sanctions, embargo, boycott, and other trade laws.
12

CONTACTS
AT ALMEX

  • The supplier may contact their responsible ALMEX procurement manager or ALMEX management for further information or to report a possible violation of the Code.

12.1 COMPLAINT PORTAL for Supply Chain and Human Rights

A complaint portal, including a description of the complaint process, can be found on the homepage.https://almex.de/lksg/

A complaint will be forwarded directly to our partner BDO Legal Rechtsanwaltsgesellschaft mbH, an impartial, independent company for reviewing reports by trained lawyers.