BUSINESS PARTNERS

COMMITMENT TO ETHICAL BEHAVIOR

Your obligations during the period of cooperation with GTH Group companies

1. INTRODUCTION

The GTH Group is fully aware of its social responsibility. In its business, the GTH Group is guided by ethical standards including responsible behavior towards employees, society and the environment, which are captured in the GTH Group Code of Ethics and which the GTH Group continuously adapts to its knowledge and current best practice in these areas. In accordance with these values, the GTH Group also ensures that the selected ethical and legal standards are adhered to not only by individuals and companies within the GTH Group, but also by partner entities.

The GTH Group's commitment to ethical behavior reflects the applicable and effective legislation, EU regulations, international treaties and regulatory rules supplemented by up-to-date recommendations, expert group methods and best practice in the field of legal and ethical regulation.

 

2. GOALS AND EXPECTATIONS

When working with GTH Group, you are required to maintain a similar level of integrity as GTH Group requires of its own companies and their employees in its dealings with third parties. This document informs you about the basic ethical principles of the GTH Group and lists the rules that support its adherence.

GTH Group reserves the right to monitor and verify the Supplier's (business partner's) compliance with the rules set forth in this Ethical Conduct Commitment, in particular through a business partner questionnaire, survey or external verification. By entering a contractual relationship, the Suppliers undertake to comply with this Commitment to Ethical Conduct and to provide the GTH Group with all necessary cooperation to verify compliance with this commitment.

 

3. BASIC RESPONSIBILITIES

a) Business ethics and competition

• comply with all applicable and effective laws, EU regulations, international treaties and regulatory rules
• properly fulfill your obligations to contractual partners, the state or other public institutions, and always act honestly in a business relationship
• fulfil your obligation to provide information arising from valid and effective legal regulations in relation to public registers of legal and natural persons, the register of beneficial owners, the register of contracts, the register of public procurement, etc.
• keep accurate and transparent accounting records of all your financial transactions
• do not tolerate or encourage human rights violations, fraudulent practices, corruption, violations of competition rules, discrimination or other illegal or unethical practices
• never negotiate with competing companies about prices, your business practices or market sharing, and do not negotiate with them during tenders
• follow the current recommendations of expert groups and best practices in the field of legal and ethical regulation
• be mindful of protecting your business reputation
• do not contribute, directly or indirectly, in any form to support non-state armed groups
• pay attention to the prevention of unlawful conduct of natural persons that could give rise to criminal liability of a legal entity (Compliance program)

b) Occupational health and safety

• comply with all legal regulations relating to traffic safety, health protection, occupational health and safety
• create and maintain a safe working environment and prevent workplace accidents
• reduce risks and set up the best possible preventive measures against accidents and occupational diseases
• ensure that employees have access to first aid stations, clean sanitary facilities and drinking water in the workplace
• provide your employees with suitable and effective personal protective equipment free of charge
• provide your employees with free training appropriate to their job title and at least to the minimum legislative extent
• do not tolerate violations of labor legislation

c) Respect for human rights and protection of employees

• treat each individual with respect and decency and respect human rights in accordance with relevant laws, EU regulations, international treaties
• always treat employees and colleagues regardless of their race, ethnicity, nationality, gender, sexual orientation, age, health, religion, belief or world view, or other criteria that are prohibited by applicable law
• do not tolerate harassment of any nature, intimidation or hostile environment (e.g. ridicule, slander, etc.) and corporal punishment in the work environment as part of disciplinary proceedings
• do not use child labor and comply with all applicable legislation on the minimum age for employment
• refrain from using any form of forced or compulsory labor
• do not require deposits or financial guarantees from employees, and do not withhold their identity documents
• avoid using any form of tied labor and do not allow or encourage employees to go into debt through recruitment fees, fines, or other charges
• respect the right of employees to leave the workplace after a shift
• ensure that the recruitment process is carried out independently, without any prejudice, and is always based on objective criteria and conducted in accordance with equal opportunities practices
• respect the right of employees to terminate their employment within a contractual or statutory notice period
• hand over the employment contract or agreement on work performed outside the employment relationship to the new employee no later than on the day of starting work and in a language that the employee understands
• pay wages and other contributions at least to the extent stipulated by applicable legislation and collective agreements, on time, in full and directly to the employee
• comply with all applicable laws, regulations, and collective agreements regarding working hours
• ensure that overtime work is carried out in accordance with applicable legislation and only when absolutely necessary
• do not interfere with the rights of employees to form unions and join unions or other associations of their choice, and do not discourage them from joining such associations
• ensure that employee representatives are not subjected to discrimination and have access to employees in the workplace
• recognize elected workers' representatives, employees' right to collective bargaining, and employees' right to strike
• if necessary, use private or public security forces to prevent any human rights violations
• respect the right of local communities and vulnerable groups to decent living conditions, education, employment and social activities
• avoid the forced eviction and expropriation of land, forests and waters during their acquisition, development and use

d) Environmental protection

• comply with all legal regulations relating to environmental protection.
• minimize the burden on the environment and continuously improve environmental protection
• prevent your business activities from causing soil contamination, water and air pollution beyond legal limits, and causing excessive industrial noise
• take appropriate measures to reduce greenhouse gas emissions and dependence on fossil fuels in your business activities
• strive for efficient use of energy and prefer the use of renewable energy sources
• conserve natural resources and optimize the consumption of raw materials
• avoid using raw materials from conflict areas (conflict minerals) and from deep seabed mining in your activities
• optimize water consumption and take measures to reduce wastewater
• support biodiversity and protect rare species of plants and animals and their occurrence in the natural environment
• ensure animal welfare and treat them in an ethical and humane manner
• approach deforestation and landscape transformation are always in accordance with the law
• limit or completely eliminate the use of chemicals and mixtures that pose a risk to the environment and health (substances classified as mutagenic, teratogenic and carcinogenic)
• actively reduce waste production, e.g. by preventing waste generation, and prioritize its reuse and recycling
• prefer to work with suppliers who strive to source the raw materials and materials used in their products in an ethical and sustainable way

e) Impermissible payments and donations

• never offer, promise, pay or approve any gift with the intention of obtaining or retaining an undue advantage or a gift that would appear improper under the circumstances
• never offer business attention (e.g., a gift, a post, or an experience) if it could be perceived as corruption or a conflict of interest under the circumstances

f) Relationships with suppliers (business partners), clients and customers

• strive to ensure fair treatment of all business partners
• in all relationships with business partners, clients or customers, always act lawfully, purposefully and honestly
• the GTH Group only works with trusted partners, so you should also choose entities with a good reputation to work with

g) Regulation of international trade

• if your activities for the GTH Group involve international business activities, please comply with the applicable laws governing international trade
• do not engage in transactions that do not comply with applicable laws and rules that restrict transactions with certain (sanctioned) countries and persons and are carried out in prohibited ways

h) Prevention of money laundering

• comply with relevant laws that prohibit money laundering, support and terrorist financing, and that require you to report cash or suspicious transactions
• do not use payments in cash or through monetary instruments that have no connection with the customer or have been revealed to be used for money laundering
• follow the "know your customer" principle and check their credibility

ch) Cooperation with public authorities (public authorities) and other institutions

• observe the highest possible level of correctness and transparency in your dealings with representatives of public authorities and other institutions, respecting the roles that both parties represent
• comply with the relevant legislation when cooperating with public authorities and other institutions

i) Protection of persons and property

• follow the rules of each GTH Group facility and workplace for entering and leaving buildings and other areas, including carrying the appropriate identification card (if required)
• prevent unauthorized persons from accessing GTH Group equipment
• protect GTH Group company assets from theft or misuse
• point out any shortcomings in measures to protect people and property

j) Privacy and data protection

• process personal data only for legitimate purposes, resulting from valid and effective legislation and contractual relationships, or on the basis of the consent of the personal data subject. Make personal information available only to people who need it for legitimate purposes. Disclose personal data only with the consent of the person to whom it relates, if such consent is required by law
• take care to prevent unauthorized access to the personal data you process, their accidental loss or destruction
• follow the rules of each GTH Group facility and site for the handling and handling of GTH Group data
• please report any deficiencies in the data protection measures of the GTH Group

k) Intellectual Property

• protect the intellectual property of GTH Group companies and third parties, even after the termination of the contractual relationship
• please note that information, ideas or inventions that have been implemented or created in connection with your work for the GTH Group may, in certain circumstances, be the property of the GTH Group. Respect the trade secrets of the GTH Group company and third parties, even after the termination of the contractual relationship
• do not disclose or release internal or confidential information and/or data of GTH Group or other entities that GTH Group is required to keep confidential without the written consent of the relevant entity concerned, even after the termination of the contractual relationship

l) Prevention of conflicts of interest

• avoid or appear to be in conflict with your obligations to perform tasks for the GTH Group company
• use GTH Group company resources and resources solely for the performance of tasks for the GTH Group company
• if you are a member of the statutory body of a company outside the GTH Group and if you could influence the business and dealings of the GTH Group with that company, please notify your contact in the GTH Group company without delay
• if you have a potential conflict of interest, please notify your contact at the GTH Group company in writing without delay

 

4. HOW TO PROCEED IN CASE OF DOUBT

If you encounter a situation that indicates serious misconduct, violations of legal regulations or ethical rules:

• formulate information that defines your doubt (who, what, when and where)
• report your suspected contact with a GTH Group company, or use the GTH Group Whistleblowing System/Ethics Line
• the GTH Group undertakes to refrain from any retaliation against a whistleblower who made a report in good faith

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If you have any questions or doubts about any of the rules, please contact your contact person at the GTH Group company.