Code of Conduct by BUCHLER GmbH a Member of the FAGUS Group

Code of Conduct

The reputation of Buchler GmbH is built on trust and respect. Our customers, shareholders and partners expect that our products are sourced and / or manufactured in a fair, ethical and environmentally responsible way. In our international business environment, certain differences in laws, customs and standards affecting business practices are unavoidable. However commonly shared values must govern the way international business is conducted. Such common values are amongst others the United Nations Declaration of Human Rights and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. We are therefore committed to the standards outlined below which reflect our internal guidelines. We require our suppliers and business partners to conduct their operations in accordance with those standards at a minimum:

1. Laws and Regulations

In general our suppliers and business partners must follow all local laws, rules, regulations and requirements applicable to their operations (hereinafter referred to as “Applicable Local Laws and Regulations” or “ALLR”).

2. Standards of Employment

Standards of employment shall be in accordance with ALLR. As an absolute minimum the following standards must be respected:

(1) Employment is freely chosen. There is no forced labor and workers are free to leave their employer with reasonable notice. In particular no forced, bonded or prison, military or compulsory labor or any form of human trafficking is allowed.

(2) Freedom of association and the right to collective bargaining are respected. Workers have the right to join or form trade unions of their own choosing and to bargain collectively. The employer adopts an open attitude towards the activities of trade unions and their organizations.

(3) Working conditions are safe and hygienic. A safe and hygienic working environment shall be provided with workers to receive regular and recorded health and safety training as far as required by ALLR. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

(4) Child labor shall not be used. No recruitment or employment of any person less than the minimum age defined in the ALLR shall take place. If the ALLR sets the minimum age at 14 years of age (in full accordance with the exceptions for developing countries under the International Labor Organization (ILO) Convention No. 138), then no recruitment or employment of any persons less than 16 years of age shall take place. No young person under the age of 18 shall work in hazardous condi[1]tions.

(5) Living Wages are paid. Wages and benefits paid for a standard working week meet at minimum national legal standards or local industry standards (whichever is higher). All workers shall be provided with written and understandable information about their employment conditions and their wages.

(6) Working hours are not excessive. Working hours must comply with ALLR. They should not exceed 48 hours in a seven day period and shall be defined by contract. Overtime shall be voluntary. Working hours and overtime may exceed 60 hours in any seven day period (provided it is allowed by ALLR) only in exceptional circumstances e.g. production peaks. Workers shall be provided with at least one day off in every seven days.

(7) No discrimination is practiced. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

(8) No harsh or inhumane treatment is allowed. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

(9) Health and Safety. Best efforts must be used to provide a secure, safe and healthy workplace and to minimize the risks of accidents, injury and expo[1]sure to health risks. The standards required by ALLR have to be fulfilled.

3. Business Integrity, Bribery and Corruption

We require our suppliers and business partners to conduct their business with integrity and in full compliance with ALLR. This applies in particular for relations with public officials. In this respect as an absolute minimum none of our suppliers and business partners shall offer, promise or give any undue pecuniary or other advantage, whether directly or through intermediaries, to a public official for that official or for a third party in order to obtain or retain business or other improper and undue advantages.

4. Environmental Management Systems

The activities are to be conducted in ways which protect and preserve the environment while meeting the ALLR. Resources such as water and energy have to be used responsibly. If relevant and / or requested by the ALLR, a management system for the prevention, immediate minimization of pollution events, monitoring and control of Emissions shall be implemented and maintained.

Braunschweig, dated 9th Feburary 2024.