Compliance

Code of Conduct

Guiding principles of the Schunk Group

Schunk is a globally active technology group. Our expertise in the fields of materials and mechanical engineering
provides a major boost for industries around the world. Schunk pursues profitable growth as well
as independence and thinks long-term. We are characterized by diversity and mutual respect: As a team,
we succeed.

 

Preamble
¬ This Code of Conduct sets out fundamental principles of behavior which determine the actions of
the management and all employees of the Schunk Group in our day-to-day business as a company.
¬ The trust that our business partners – including customers, suppliers, visitors, government authorities
and the public – place in us is paramount to the Schunk Group. That’s why a sense of
responsibility, legal compliance, and moral integrity run through all of Schunk’s actions.

A. Validity
¬ In addition to and independently of this guideline, the business activities of the Schunk Group and
the conduct of all employees are subject to the applicable local laws and regulations.
¬ Where additional rules of conduct are set down for individual companies, organizational units, or
groups of people in separate guidelines (such as corporate standards), these guidelines apply
without limitation alongside with this Code of Conduct.

B. Compliance with laws and regulations
1. Compliance with applicable law
¬ Observing all applicable laws and regulations is an essential basis of all actions of the Schunk Group.
¬ All employees and corporate bodies of the Schunk Group are obligated to obtain information on
the laws and regulations that apply to their areas of responsibility within the company and, in
case of doubt, to consult the responsible bodies within the Schunk Group for advice.
¬ Schunk complies with its statutory obligations to prevent money laundering and does not participate
in any money laundering activities. All employees are required to report unusual financial transactions, particularly those involving cash or cash equivalents, that could give rise to a suspicion of money laundering to the relevant finance department.
¬ Schunk does not give any financial benefits or perquisites, particularly donations or sponsoring,
to political parties, affiliated or similar organizations, individual public officials, or candidates for political office.

2. Fair competition
¬ Rules to protect fair competition are an essential element of a free market economy. These rules
concern the following in particular:

• prohibition of agreements between competitors regarding prices, terms, division of territory, customer groups, or production volumes,

• prohibited price maintenance or price fixing involving our sales partners,

• prohibition of abuse of a dominant position, and

• control of corporate mergers

in order to prevent dominant positions from arising.
¬ Promoting fair competition is in line with the Schunk Group’s business policies. For this reason,
Schunk observes all applicable antitrust laws.
¬ Agreements between market participants with the aim of restricting competition are prohibited
in particular.
¬ Informal discussions or understandings or even concerted practices are also prohibited where
these express agreement on, or the intention to implement, a measure restricting competition.
¬ Confidential information regarding prices and/or upcoming price changes or customer/supplier
relationships must not be shared during any discussion with competitors.

3. Corruption/granting and accepting benefits and perquisites
¬ All Schunk employees pledge to do everything in their power to prevent corruption within their
sphere of influence. Corruption means offering, giving, or accepting a gift, loan, commission, reward,
or any other benefit or perquisite to or from a person or entity as an incentive to do something
that is dishonest or illegal or represents a breach of trust.
¬ Personal benefits or perquisites must not be requested, accepted, offered, or granted in exchange
for preferential treatment during preparations for, awarding of, or execution of a contract.
¬ The distribution or acceptance of gifts is not allowed in principle. The only exceptions are customary
token or promotional gifts or gifts that are in keeping with customary practice and rules of
courtesy in a certain country and are compatible with the relevant statutory provisions.
¬ Providing or accepting products or other objects on loan for an indefinite period can also take on
the nature of a prohibited gift or acceptance or granting of a benefit or perquisite and is therefore
also prohibited.

4. International trade
¬ Schunk is a global company, and in its worldwide business activities, it is obliged to observe rules
and regulations that restrict the free movement of goods.
¬ With this in mind, the companies of the Schunk Group observe all export and/or import bans, export controls, economic sanctions, embargoes, and reservations of government approval that apply based on national or international law.
¬ Various national and international laws and embargoes restrict or prohibit the import or export
of, or domestic trade in, goods with regard to products, technologies, and software, provision of
technical support, and intermediary actions, as well as movements of capital and monetary transactions
involving certain countries, persons, and/or organizations. These restrictions and prohibitions
may be based on the particular nature of the goods in question, the intended purpose, the
country of origin or destination country, or the person of the other party to the transaction.
¬ The national and international export control regulations are of particular importance.
¬ All employees are required to comply with these control provisions whenever goods or services
are purchased, brokered, produced, or put into circulation or technologies are transferred or received.
¬ Whether government authorization is required must be reviewed accordingly before any such
action is taken. All companies of the Schunk Group must take the necessary organizational precautions
and designate responsible persons who ensure that the aforementioned rules are observed.

C. Prevention of conflicts of interest
¬ All of the corporate bodies and employees of the Schunk Group are required, as part of their
affiliation with the company, to prevent any conflicts between their personal interests (direct or
indirect, through related persons or companies) and those of the Schunk Group.
¬ To prevent conflicts of interest, employees must report any intention to

• accept a role or position at another enterprise,

• begin any secondary employment or similar activity, paid or unpaid, or

• begin any entrepreneurial activity

to their relevant supervisor or the responsible Human Resource department and obtain this person
or body’s approval.

D. Respect for human rights; prohibition of discrimination
1. Fair working conditions
¬ Schunk pledges to uphold the principles of social responsibility. For this reason, it is in the company’s
interest for fair working conditions to apply worldwide throughout the Schunk Group.
¬ Compliance with all local legislation concerning minimum wages, social benefits, overtime, working
hours, and working conditions is mandatory for Schunk.
¬ The requirement of fair working conditions includes zero tolerance for forced labor or any form
of modern slavery or human trafficking and rules out any and all forms of discrimination against
employees. In particular, the rights of indigenous peoples and local communities should be respected, promoted and protected throughout the supply chain.
¬ The Schunk Group believes it goes without saying to treat its employees with respect all over the
world, in compliance with all locally applicable labor, employment, and human rights standards
and laws.
¬ The Schunk Group recognizes its employees’ freedom of association and assembly and their right
to join unions or associations of employees.
¬ Schunk will not hire or use private or public security forces if, in the use of these security forces
a) the prohibition of torture and cruel, inhuman or humiliating treatment is disregarded,
b) injury to life or limb; or
c) the freedom of association and freedom of organization are impaired.
¬ The Schunk Group also expects its employees to treat each other, and of course also customers
and suppliers, with respect. Other colleagues’ privacy must be respected. We have zero tolerance
for any and all forms of harassment, especially sexual harassment and bullying.

2. Child labor
The Schunk Group rejects all forms of child labor, including among its business partners, customers, and
suppliers. The minimum age for employment within the Schunk Group is observed at all times, in keeping
with the relevant local regulations.
3. Prohibition of discrimination
¬ All employees of the Schunk Group and all business partners have a right to fair, polite, and respectful
treatment from managing directors, executives, other employees, and colleagues.
¬ The Schunk Group does not tolerate harassment or discrimination targeting anyone based on ethnic
origin, skin color, nationality, descent, sex or gender, sexual or gender identity, beliefs or religious
affiliation, world view, political views, age, physical constitution, appearance, or any other
personal characteristic.

E. Occupational safety and health; environmental protection
1. Occupational safety and health
¬ Safety in the workplace and the safety of our products are elementary principles for us.
¬ All processes, production sites and offices, and operating materials must be in keeping with the
applicable laws and with internal rules and regulations on occupational safety and health and on
fire protection and the environment.
¬ All employees are expected to observe the relevant safety rules and demonstrate risk awareness
and initiative in case of all safety-related activities. This applies to any and all risks or hazards that
could arise at the Schunk workplace, on customer or supplier premises, or when our products are
used.
¬ Recognized accidents or potential hazards and near misses must be reported to the responsible
manager immediately. All managers are responsible for protecting their employees and must instruct,
train, and supervise them accordingly.
¬ Ensuring a safe, healthy, and ergonomic workplace and providing suitable personal protective
equipment for all employees goes without saying for the Schunk Group.
¬ We are committed to achieving continuous improvement in occupational safety and health, based
on both our own experiences and ongoing advances in science and research.

2. Environmental protection
¬ Schunk is committed to protecting our environment as one of the company’s core objectives and
has stated that producing our products with minimum resource use is an important goal.
¬ An indispensable part of environmental protection is compliance with legal regulations. This in-volves taking into account the prohibition of unlawful eviction and the prohibition of unlawful deprivation of land, forests and waters in the acquisition, construction or other use of land, forests and waters, the use of which secures the livelihood of a person.
¬ The following guiding principles on environmental protection, ecological sustainability, and maintaining
the natural basis for life apply:

• We protect our environment, use all natural resources sparingly, and minimize the impact of our activities on people and the environment.

• We take the aspect of preserving the natural environment into account during development and design, manufacturing, packaging, and shipping of our products and when improving procedures and introducing new facilities, equipment, and products.

¬ Should any incident that could result in environmental impact occur, the appropriate bodies
within the company must be notified right away and in detail and must, for their own part, cause
the reports required by law to be made to the authorities.
¬ All employees are tasked with preventing risks to people and the environment, minimizing environmental
impact, and using resources sparingly.
¬ We are committed to an integrated and forward-looking environmental protection and to the
continuous improvement of our environmental and energy management system, environmental
and energy-related performance, and energy efficiency.

F. Data protection, confidential information, plagiarism and intellectual property
1. Protecting business and trade secrets
¬ Our inventions, products, and know-how are crucial to our company’s long-term success.
¬ This means promoting the creative and innovative expertise of our employees is of strategic importance,
as is protecting our intellectual property against third parties becoming aware of it or
gaining access to it without authorization.
¬ All employees are therefore required to observe reasonable and necessary security standards,
both in personal contact and in their electronic communications with third parties. The same applies
to confidential information that is made accessible to us by third parties.
¬ All security guidelines issued by the central Schunk IT department must be observed.
¬ Without approval employees are not permitted to participate in public discussions (such as
presentation events, Internet forums, etc.) or to make company-related information public (on
the Internet, for example) in their function as persons associated with Schunk.

2. Handling of company property
¬ Employees are obligated to treat company equipment, such as machines, tools, and information
and communication systems, with care and to use these items only as intended.
¬ Company property must not be used for personal purposes or removed from company premises
without the express consent of the appropriate body within the company.

3. Obligation of confidentiality
¬ The knowledge and information gained within the Schunk Group is a significant element of our
business success. The Schunk Group invests significant personnel and financial resources in developing
innovative products and services. Protecting the innovations developed in this way safeguards
the Schunk Group’s success as a competitor, which is why this represents an asset that
merits particular protection.
¬ All employees and corporate bodies of the Schunk Group are therefore obligated to prevent any
knowledge and information constituting business or trade secrets from becoming known outside
the Schunk Group, for example through unauthorized dissemination of sensitive information
through discussions with third parties, in trade journals, or on the Internet.
¬ Furthermore, all employees who deal with knowledge and information of this type are obligated
to obtain information on the extent to which obtaining industrial property rights for this
knowledge and information enters into consideration.
¬ Business and trade secrets of business partners of the Schunk Group must also be protected
against becoming known without authorization.

4. Plagiarism
¬ The Schunk Group does not approve the use, further processing or marketing of counterfeit products. In the unlikely event that such counterfeits should occur in the company despite quality assurance measures, they will be isolated immediately. Furthermore, any plagiarism detected by Schunk will not be put into circulation, but will be reported to the responsible law enforcement authorities.

5. Personal data protection
¬ Respect for the individuality and privacy of the employees of the Schunk Group includes protecting
their personal data.
¬ The Schunk Group takes care to ensure compliance with the applicable laws and regulations on
data protection and privacy and requires its employees, customers, and suppliers to do the same.

 

G. Compliance with the Code of Conduct and monitoring
¬ All companies and organizational units of the Schunk Group are individually responsible for compliance
with the rules set down in this Code of Conduct and with further rules and regulations
stipulated internally within their own areas of responsibility.
¬ This Code of Conduct is accessible to all employees and other stakeholders of the Schunk Group
at all times on the intranet and on the Schunk Group website.
¬ Every manager is required to advise his or her employees of the existence of this Code of Conduct
and to explain its content to them. Every Schunk employee is called upon to review his or her own
conduct based on the standards and actions outlined in this document and to take corrective
action whenever it is necessary.
¬ Managers have a special obligation to act as role models, actively demonstrate integrity in their
day-to-day business, and inform employees within their own areas of responsibility of the content
of this Code of Conduct.
¬ Violations of this Code of Conduct will not be tolerated and may bring consequences under civil
or criminal law and disciplinary consequences with regard to employees’ employment.
¬ If any employee receives an offer or request for a personal benefit or perquisite, he or she must
report the matter to the appropriate specialized department or the executive management.
¬ All employees are, in general, called upon to consult their manager, the appropriate specialized
department, or the executive management for advice and assistance if they have any legal doubts
concerning their own behavior or there are any indications of dubious matters in their work environment.

 

H. Whistleblower system and point of contact for misconduct
1. Internal reporting channels
¬ Anyone who is aware of a violation of this Code of Conduct can contact the relevant manager,
Head of Personnel, Global Human Resources, or the Head of the Internal Audit department of the
Schunk Group. Reports will be treated as strictly confidential.

2. External reporting channel: The Schunk Group ombudsman
¬ The Schunk Group has established an external whistleblower system by appointing an external
lawyer as an ombudsman (lawyer of confidence).
¬ Any employee or other internal or external stakeholder is free to contact the ombudsman as a
point of contact, free of charge, at any time to make a confidential report of suspected criminal
activity or similarly severe irregularities relating to the Schunk Group.
¬ Due to attorney-client privilege, it is ensured that the identity of whistleblowers will be reliably
protected and not disclosed to the Schunk Group.

¬ Contact details for the Schunk ombudsman:

• Address: Dr. Rainer Buchert, Buchert Jacob Partner Partnerschaftsgesellschaft mbB
• Kaiserstraße 22, 60311 Frankfurt am Main/ Germany
• Phone: +49 69 710 333 30
• E-mail: [email protected]
   

Reports can also be submitted using a contact form on the website of Buchert Jacob Partner:
www.ombudsperson-frankfurt.de/en

Heuchelheim, April 1, 2023

Schunk GmbH