Code of Conduct
pewag group
Code of Conduct 2024
Publisher: pewag AG
Version: 5
58-GM.05.03.02/E-MD, EN
Issue Date: May 2024
Before printing, please consider the environment.
Foreword
Combining entrepreneurial action with ethical principles is a long tradition for the pewag group and one of the essential factors for long-term success.
We are convinced that ethical and economic values are interdependent and that, as members of the business community, we must strive to treat each other fairly and operate within established norms.
Our claim is to live up to our corporate responsibility towards people and the environment.
This Code of Conduct defines the necessary minimum requirements for corporate, social and environmentally conscious behavior, which we expect our group companies, employees, customers, suppliers and partners to comply with.
By complying with applicable laws, adhering to the ethical principles summarized here, and applying best practices within our industry, we can achieve excellent performance in a transparent and sustainable manner.
Ägyd Pengg CEO
2.2.6
2.2.7
2.2.8
2.2.9
2.2.10
2.3.5
2.3.6
2.3.7
2.3.8
3.1.9
We take responsibility for: Governance
1 Governance
1.1 Management commitment
We adhere to the highest standards of integrity and act honestly and fairly throughout the value chain, in compliance with applicable laws and regulations, international standards and industryspecific guidelines, such as the Automotive Sustainability Guiding Principles 4.0 (AIAG / drive sustainability).
Starting with top management, we take on the commitment at all levels to ensure the principles of economic, social and environmental responsibility and sustainability. In particular, we are bound to accountability, transparency, ethical behavior, respect for the interests of stakeholders, respect for the rule of law, respect for international standards of conduct, and respect for and demand of human rights.
1.2 Certification
The pewag group is certified in accordance with the scope defined in the management manual according to internationally recognized standards, including:
• ISO 9001 Quality Management Systems
• ISO 14001 Environmental Management Systems
• ISO 45001 Occupational Health and Safety Management Systems
• ISO 50001 Energy Management Systems
1.3 Business Ethics
1.3.1 No corruption, extortion, bribery or money laundering
Employees shall not participate in or endorse corrupt practices in whatever form, including offering or accepting bribes, excessive gifts or hospitality or facilitation payments. Employees shall not facilitate or support money laundering and shall report any suspicious transactions and be alert for signs of money laundering.
Zero tolerance policy
We have a zero tolerance policy for all forms of bribery, corruption, extortion and embezzlement. We comply with anti-corruption laws that apply to our business activities and to the countries in which we operate.
Dealing with our customers
Employees may not offer, promise, grant or accept unfair advantages in connection with a business activity (money, gifts or other favors or services). The employees of the sales department or the management are entitled to grant advantages to maintain customer relations. If invitations are extended to business partners, the management of the invited persons shall also be informed in advance as far as possible.
Financial contributions to government officials, representatives of public institutions, employees or representatives of companies that are majorityowned by the state, provincial, municipal or parties,
or to political parties and their representatives, are strictly prohibited.
Dealing with our suppliers
Employees may not use their position or influence within the pewag group to seek, obtain, accept or agree to personal benefits.
We require our suppliers and partners to adhere to a minimum set of ethical standards in their business activities. For this reason, we publish guidelines that we expect our partners to uphold and cascade them throughout their supply chain.
Gift acceptance
Gifts and invitations as well as other benefits that exceed a symbolic value or industry standards must be politely but firmly declined. Invitations from suppliers or customers to employees of the pewag group must not exceed the industry standard scale with regard to their equivalent value. Any gifts that are nevertheless received shall be collected and raffled off among all employees at the respective location on special events.
1.3.2 Data protection and data security
Employees shall respect privacy and civil liberties in respect of the collection, retention, use or dissemination, as well as any other processing of personal data.
Protection of personal data
The protection of the personal data of our employees, customers and suppliers, as well as the respect of national and international data protection regulations are self-evident for us.
We align our security standards and our actions to protect personal data from access and unlawful use by unauthorized persons. Our business partners are also obliged to handle data carefully and in compliance with the law.
Data security and trade secrets
Successful business activity requires that all relevant information reaches only the required group of addressees. An unsystematic scattering of information, on the other hand, can lead to unsolicited disruptions.
All employees are therefore called upon to carefully decide who needs to be provided with what information in order to be able to make the necessary decisions quickly and on a secure information basis.
When passing on information, care must be taken to ensure compliance with adequate security standards, particularly with regard to cyber security. Every employee must be aware
of the degree of confidentiality when passing on information.
Business secrets and other sensitive information have to be treated confidentially and protected from disclosure to unauthorized persons. Employees who have access to business secrets and confidential information may only use these for the business purposes of the pewag group and may not pass them on to third parties (this also includes family members and friends), unless an appropriate confidentiality agreement relating to this transfer has been concluded in connection with a business purpose of the pewag group.
1.3.3 Financial responsibility / Accurate Records
The pewag group conducts its business dealings in a transparent manner and accurately reflects them in the company‘s financial reports and filings. An adequate financial reporting system control is in place.
All relevant facts relating to business and financial activities and transactions have to be documented accurately, systematically, reproducibly, and in accordance with applicable laws, local accounting principles and tax requirements, and IFRS accounting standards. The statutory retention periods and internal guidelines for documentation must be observed. Corresponding guidelines are made available in our management system.
1.3.4 Disclosure of financial and nonfinancial information
Financial and non-financial information is disclosed in accordance with applicable regulations and prevailing industry standards.
When it comes to disclosing information on sustainability, the pewag group strives to be a pioneer within the industry.
1.3.5 Fair competition and antitrust law
All employees are obliged to comply with the rules of fair and equitable competition. Our business is conducted exclusively in accordance with applicable anti-trust laws and guidelines.
In particular, no agreements restricting competition (price agreements, tendering agreements, agreements relating to production limits or the division of markets according to customers, suppliers, regions or industries) may be entered into. This policy applies to all meetings or other contacts with competitors.
The exchange (i.e. both the provision and receipt) of sensitive information, such as prices, production and distribution costs, production or delivery capacities, capacity utilization or other relevant
information about the future competitiveness, with competitors of the pewag group is strictly prohibited without exception.
It happens from time to time that we produce products for our competitors. We also purchase products from our competitors - for capacity reasons, for example, but also for other reasons. Under no circumstances may such customersupplier relationships lead to uniform pricing on the market and under no circumstances may these relationships reach a significant share. We refrain from and under no circumstances authorize the disparagement of our competitors, their products or their employees.
1.3.6
Avoidance of conflicts of interest
Employees shall avoid and disclose situations in which their financial or other interests conflict with their job responsibilities or situations giving any appearance of impropriety.
Decisions are made on the basis of sound business judgment that is not clouded by favoritism based on personal relationships and opinions.
Private activity
Every employee must immediately inform his or her own manager or the person responsible for human resources of his or her intention to accept a position in another company, to take up paid secondary employment or to actively engage in entrepreneurial activities.
This applies not only to the assumption of functions in or for a company with which the pewag group has or could have a business relationship or is in competition, but also to capital and profit participations in such a company.
Conflicts of interest between the official duties of an employee and his or her personal interests must be avoided. This applies in particular in connection with the processing of contracts and procurements. Conflicts of interest must always be disclosed. This also applies to the employee‘s business relationships.
Behavior that could affect the interests of the pewag group should also be avoided in the private sphere.
Social networks
When using the Internet privately, employees must be aware of the potential conflicts that can arise. There should be a clear separation between „pewag“ pages and „private“ pages.
On social networking sites, our employees should take care that the information they disclose does not discredit the pewag group. If employees make political statements, they always have to ensure that these statements are not associated with the pewag group.
It is not always desirable to share pewag-related photos, comments, and videos. Offensive comments towards colleagues of the pewag group have to be avoided.
Employees may respond to legitimate criticism of the pewag group but may not remove it. Blogs and other personal websites that do not identify the author as a pewag employee and that do not concern the pewag group are purely personal and are therefore not subject to this Code of Conduct.
1.3.7 Protection of intellectual property
The pewag group respects valid intellectual property rights.
Employees are responsible for the preservation of intellectual property of the pewag group, such as patents, trademarks, brands or know-how, and have to do everything necessary to protect it. This also includes refraining from behavior that could impair the reputation and value – in particular the brands - of the pewag group.
1.3.8
Dealing with counterfeit parts
The pewag group minimizes the risk of introducing counterfeit and/or diverted parts and materials into deliverable products and adhere to relevant technical regulations in the product design process.
In the event of a plagiarism discovery, affected parts or materials are to be quarantined and the original manufacturer, the customer and/or the relevant authorities to be notified.
1.3.9 Export controls, trade, and economic sanctions
We comply with applicable restrictions on the export or re-export of goods, software, services and technology, as well as with applicable restrictions on trade involving certain countries, regions, companies or entities and individuals.
We have adequate policies and procedures in place to ensure compliance with applicable export control and economic sanctions laws and -regulations of all relevant countries.
1.3.10 Elimination of defects
The pewag group provides for or cooperates in remediation through legitimate processes when its business activities cause or contribute to adverse environment or social impacts.
1.3.11 Protection against retaliation
The pewag group avoids any form of threats, intimidation, and physical or legal attacks against stakeholders, including those exercising their legal rights to freedom of expression, association, peaceful assembly and protest against its business activities.
1.4
1.4.1
Consideration of stakeholders
Consumer concerns
Our goal is customer satisfaction.
To achieve this goal, we strive to offer the best solutions on the market as well as to exceed our customers‘ expectations and are committed to the principles and values of this Code of Conduct.
1.4.2 Responsible supply chain and due diligence
We expect compliance with minimum ethical requirements not only within the pewag group, but also from our suppliers, customers and other contractual partners along our supply chain.
We promote transparency and traceability and use best efforts to implement ESG standards and minimum ethical requirements further along the supply chain.
These minimum ethical requirements are set out in a separate Code of Conduct for suppliers. Self-report questionnaires and audits are also used to ensure compliance with these minimum requirements.
1.4.3 Involvement and development of society
Within the scope of our possibilities, we try to contribute to the sustainable development of society, especially in the following areas: job creation and professional qualification; health and well-being; wealth and income creation; gender equality; investment for the common good; community involvement.
We take responsibility for:
2 Social
Social
2.1 Compliance with legal requirements
Each employee has to observe and comply with all laws and regulations applicable in his or her work environment.
2.2 Human rights and working conditions
We respect and promote the human rights of workers, local communities and other relevant stakeholders, and prevent and address adverse human rights impacts linked to our business activities, in accordance with the UN Guiding Principles on Business and Human Rights.
2.2.1 Protection against child labor and for young workers
The pewag group observes the minimum employment age in its business activities and throughout its supply chain in accordance with the ILO Minimum Age Convention and ensures that child labor is not tolerated in any form.
We are committed to the prohibition of child labor and neither employ nor tolerate the employment of workers who do not have a minimum age of 15 years or who work in countries with an exemption according to ILO Convention 138.
Young employees under the age of 18 are only employed if the work is not dangerous, if they have reached the minimum age for employment applicable in the respective country, and if they are no longer of compulsory school age.
2.2.2
Wages and benefits
The pewag group provides its employees with remuneration in accordance with applicable regulations and prevailing industry practices. This remuneration is adequate to cover basic needs and enables a decent standard of living for employees and their families, which includes respecting minimum wages, overtime compensation, medical leave and governmentmandated benefits.
All employees receive fair, equitable, living, and comprehensible wages and salaries that are in accordance with applicable legal regulations at the respective location, and with other legally binding instruments (e.g. collective bargaining agreements). For this the general wage level, the cost of living, social benefits and the relative standard of living of other social groups, among other things, form the orientation framework.
2.2.3 Working hours and employment conditions
The pewag group complies with local laws and collective bargaining agreements regarding working hours or comply with the ILO Standards on Working Time in the absence of relevant local regulations.
We offer our employees flexible working time models within the scope of operational possibilities, taking into account a balanced relationship between work and private life (e.g. home office, educational leave, change to part-time and back to full-time) and are committed to appropriate working conditions with regard to remuneration, working hours, weekly rest, vacation, overtime, health and safety, and maternity protection.
2.2.4 Protection against modern slavery
The pewag group is committed to the prohibition of any form of forced, bonded compulsory labor, including human trafficking.
2.2.5
Ethical recruiting
pewag group agrees not to mislead or defraud potential employees about the nature of the work, ask employees to pay recruitment fees, and/or confiscate, destroy, conceal and/or deny access to employees‘ passports and other governmentissued identification documents.
Employees receive a written contract or employment notification at the start of their recruitment in a language well understood by them stating in a truthful, clearly manner their rights and responsibilities.
2.2.6 Freedom of association and collective bargaining
The pewag group allows employees to communicate openly with management regarding working conditions and management practices without fear of reprisals, intimidation or harassment.
We respect employer rights to associate freely, to join or not join labour unions, bargain collectively, seek representation and join workers’ councils.
Employee representatives are given sufficient time and access to facilities such as meeting rooms to perform their duties, in accordance with local law.
2.2.7
Non-discrimination, protection against harassment and interaction with each other
The pewag group does not tolerate any form of discrimination or harassment in respect of employment and occupation and provides equal employment opportunities, regardless of employer or applicant‘s characteristics, such as age, gender, sexual orientation, gender identity, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union association, veteran status, genetic information, or marital status.
Harassment in any form, unwanted physical contact, and bullying are absolutely undesirable and prohibited.
All employees have the right to fair, polite and respectful treatment. We are all obliged to respect the personal dignity of all employees and to deal with them in a fair, open, appropriate, and helpful manner in order to ensure a trustful working atmosphere.
2.2.8 Problem-solving culture
Problems are to be described in such a way that they are well understood by the author and can also be understood and solved by other employees.
Criticism is made in a factual and constructive manner, not looking for someone to blame but for causes that lead to a solution.
We see this as an opportunity for personal development as well as an improvement of the entire organization.
2.2.9 Equality
The pewag group provides equal opportunity in employment and commits to equal pay for equal work.
2.2.10 Diversity, equity, and inclusion
The pewag group develops and promotes inclusive cultures at all levels, where diversity is valued and celebrated, and everyone is able to contribute fully and reach its full potential.
2.2.11
Land rights and forced eviction
The pewag group supports the avoidance of forced evictions and the deprivation of land, forests and waters in the acquisition, development or other use of land, forests and waters.
2.2.12 Private or public security forces
The pewag group does not commission private or public security forces to protect the business project if, due to a lack of training or control on the part of the company, the deployment of the security forces may lead to violations of human rights.
2.3 Occupational health and safety
The pewag group provides its employees a safe and healthy working environment that meets or exceeds applicable local laws and industry standards for safety and occupational health.
Safety at work, safe production processes, as well as safe products are fundamental for us.
All employees are expected to comply with safety regulations, to be aware of hazards and to pay appropriate attention during all activities. This applies to all hazards that may arise at work or during the use of our products.
2.3.1
Workspace and ergonomics
The pewag group provides a working environment that meets or exceeds local and national safety, occupational health, and fire legislation, in addition to encouraging remote workers to understand and apply best practices.
Workplaces are designed and adapted according to the results of the respective local health and safety risk assessment to minimize physical stress.
2.3.6 Emergency Preparedness
The pewag group strives to minimize the risk of occupational hazards and develops relevant plans for emergency preparedness and response.
Health and safety information, such as emergency procedures and potential safety risks, is clearly communicated to employees and posted.
2.3.2
Personal protective equipment
Where applicable, we provide our workforce with necessary Personal Protective Equipment (PPE) and ensure that they understand how and when it needs to be applied.
All affected employees have knowledge and understanding of what protective equipment is required for what activity and how to use it, including its possible limitations and proper care and maintenance.
2.3.3 Handling of chemicals
All processes for handling chemicals and other hazardous substances are carried out in compliance with applicable laws and regulations as well as internal guidelines. All employees concerned have knowledge and understanding of safe and proper chemical handling.
2.3.4 Machine
safety
All applicable laws on machine safety are to be complied with, including relevant safety devices as well as regular and documented maintenance. Affected employees receive appropriate training or follow-up training to ensure knowledge and understanding of safe and proper machine operation.
2.3.5 Fire protection
All local fire safety laws shall be complied with. Emergency exits, as well as fire detection, alarm and extinguishing systems are provided and have to be kept ready for use at all times. Regular training, fire and evacuation drills have to be conducted in accordance with local laws.
2.3.7
We ensure that all locally required permits, licenses, inspection, and testing reports are in place, up to date and available in accordance with local regulations.
Incident and accident management
The pewag group implements hazard and risk analyse systems to minimize the potential for incidents or accidents at the workplace. Incident and accident investigations aim to determine the root cause, and to take corrective actions to minimize the chance of a recurrence.
Accidents or risks, potential hazards and nearaccidents have to be reported immediately to the responsible manager.
Managers are responsible for the protection of their employees and have to instruct, train and supervise them accordingly. Managers are obliged to carry out risk assessments to identify and assess possible risks and potential hazards for persons, and to carry out investigations in the event of accidents and near-accidents to minimize the cause sustainably.
The respective top management is responsible for establishing a safe organization and monitoring it. This also includes the organization of occupational health examinations.
2.3.8 Contractors
The pewag group also addresses occupational safety and health protection to its suppliers. We coordinate the procurement process in an appropriate manner to identify hazards and to assess and control risks arising from business activities with the supplier and which affect the supplier‘s employees.
We take responsibility for:
Environment
3 Environment
We take our responsibility for the environment very seriously.
We apply environmental protection practices, conserve natural resources, and reduce the overall environmental footprint of production, goods, and services throughout their life cycle.
We are committed to complying with all local energy and environmental regulations and to continuously improving our performance. Where we cannot avoid environmental pollution, we set ourselves the goal of continuously reducing the use of energy, polluting emissions of all kinds and the volume of waste. By systematically monitoring and reviewing our environmentally relevant activities, we are able to identify deviations and weak points and initiate appropriate corrective measures.
We are striving for a transition to a circular economy.
The pewag group is certified according to ISO 14001 (requirements for environmental management systems) and ISO 50001 (requirements for energy management systems).
3.1.1 Carbon neutrality, energy efficiency and renewable energies
We set science-based and time-bound emission reduction goals and renewable energy objectives that are aligned with the Paris Agreement and put in place measures that drive forward the decarbonization of the value chain.
We implement a comprehensive strategy to save energy and increase the use of renewable energy. We monitor and document energy consumption and greenhouse gas emissions and strive to reduce them in a cost- and energy-efficient
3.1.2
manner from raw material extraction, through product manufacture and transport, to the end of the product life cycle.
Water quality, consumption and management
We minimize water consumption, effectively reuse and recycle water with responsible treatment of wastewater discharges, and prevent potential impacts from flooding as a consequence of rainwater run-off, as required by and in accordance with applicable law.
Based on a water balance appropriate corrective and improvement measures are derived.
3.1.3 Air quality
We routinely monitor, appropriately control, minimize, and to the extent possible, eliminate emissions contributing to air pollution, as required by and in accordance with applicable law.
3.1.4 Responsible chemical management
We identify, minimize, or eliminate the use of restricted substances in manufacturing processes and finished products to ensure regulatory compliance. We are aware of the use of restricted substances in processes and finished products and actively investigate suitable substitutes to maintain product and environmental stewardship.
3.1.5 Circular economy, sustainable resource management and waste reduction
We promote closed loop systems by supporting the use of sustainable, renewable natural resources, while reducing waste and increasing reuse and recycling.
Consequently, we are constantly developing our products to achieve an increasingly higher loadbearing capacity and safety for our customers with a long service life and low weight.
We set goals for waste reduction according to the prioritization of prevention, reduction, reuse, recovery, recycling, removal and finally disposal of waste through safe and responsible methods to protect the environment and the health and safety of employees and local communities.
3.1.6 Biodiversity, land use and deforestation
We protect ecosystems, especially key biodiversity areas, impacted by our operations, and avoid illegal deforestation in accordance with international biodiversity regulations, including the IUCN Resolutions and Recommendations on Biodiversity.
3.1.7 Soil quality
Where appropriate, we monitor and control our impact on soil quality to prevent soil erosion, nutrient degradation, subsidence and contamination.
3.1.8 Noise emissions
Where appropriate, we monitor and control the level of industrial noise to avoid noise pollution.
3.1.9 Responsible sourcing of raw materials and minerals
We responsibly source raw materials and minerals used in our products by promoting supply chain traceability and transparency, and by implementing appropriate due diligence measures for minerals from conflict-affected and high-risk areas.
4 Final provisions
4.1 Scope
The regulations of this Code of Conduct apply to all employees of the pewag group, regardless of their hierarchical integration or function, as well as to our group companies, not only literally, but also in the sense. So far as codes of conduct for individual areas of activity or companies are laid down in separate guidelines, these guidelines apply without restriction in addition to this Code of Conduct. In case of doubt, the stricter rule shall be observed.
Violation of the Code of Conduct may lead for all employees, including managers, to disciplinary action and ultimately to the legal measures and consequences provided for in the applicable laws.
The top management of the pewag group ensures that the principles and ethical values of this code of conduct are brought to attention to all employees of the group company in an appropriate manner and on a regular basis.
All managers with disciplinary responsibility have, in addition to their role model function, the responsibility to ensure that the employees in their own area of responsibility understand and follow the rules of this Code of Conduct. Managers will be asked at regular intervals to confirm that they have understood and complied with the rules of the Code of Conduct, have reported any violations of which they have become aware, and are aware of their responsibility to ensure that their employees comply with the rules of the Code of Conduct.
The legal department of the pewag group will monitor compliance with this Code of Conduct by recording all reported violations and all legal countermeasures.
4.2 Grievance mechanism
Concerns related to business ethics, human rights or other compliance issues can be raised at the following address:
Compliance Contact
compliance@pewag-group.com
The persons entrusted with the task of compliance contact are obligated to treat complaints confidentially in accordance with the applicable laws.
Employees and business partners will not be terminated, threatened, harassed, or otherwise discriminated against for reporting a complaint. Retaliation is not permitted and is a disciplinary violation.
Internal grievance
Every employee is entitled and required to report violations of this Code of Conduct or the guidelines applicable in the pewag group to the manager or the compliance contact. The pewag group and the group companies undertake not to hold any employee responsible if he or she brings a violation or suspected violation of this Code of Conduct or other applicable guidelines to the attention of the company management, a manager or the legal department.
External grievance
Complaints of any kind from our external contractual partners are to be regularly submitted to the responsible contact persons in contractual partner support procedures (e.g. supplier, customer service) and, if no remedy is found, to our compliance contact. For interested parties, whose rights are affected by the business operations of the pewag group and our group companies, are also granted access to this grievance mechanisms.
4.3 Reporting
The pewag group carefully monitors both business operations and extensive sustainability aspects in accordance with legal requirements and strategic specifications. The pewag group regularly publishes a sustainability report for the pewag group based on the principles of the globally recognized SDGs and the applicable European directives. We are thus setting a further milestone on our path towards corporate responsibility and social and ecological sustainability.
pewag AG
A-9020 Klagenfurt, Schleppe-Platz 8, Phone: +43 (0) 50 50 11-0, office@pewag.com
