Code of Conduct

Holmberg is committed to its social responsibility within the framework of its global business activities. Cooperation and exchange with our suppliers are very important to us in order to be able to meet future challenges together based on our guidelines described here.

1. General Obligation
This Code of Conduct sets out the minimum requirements for our suppliers and contractual partners, which we have also set for ourselves with regard to human rights, working conditions, environmental and climate protection, and ethical behavior.

Principles
The supplier undertakes to comply with all requirements of this Code and to obligate its own suppliers accordingly.
The supplier complies with all laws applicable to its company. The supplier supports the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights, and the 1998 International Labor Organization Declaration on Fundamental Principles and Rights at Work in accordance with national laws and customs.

This applies in particular to:

2. Human Rights and Working Conditions

Child Labor
The supplier does not employ children under the minimum legal age of employment. If no minimum age is set, the supplier does not employ children under 15 years of age.

Forced Labor, Slavery, and Human Trafficking
The supplier does not use any form of forced labor, debt bondage, or involuntary labor. The supplier is responsible for the payment of all legally binding levies that may arise in connection with its employees.

Remuneration and Working Hours
The supplier complies with all applicable national laws and binding industry standards regarding working hours, overtime, wages and salaries, as well as other employer benefits.

Freedom of Association and Collective Bargaining
The supplier recognizes and respects the right of employees to join a trade union/employee representation of their choice without threat or intimidation and to conduct collective bargaining within the framework of applicable laws.

Diversity
The supplier promotes a work environment that enables inclusion and in which the diversity of its employees is valued. The supplier shall not discriminate or tolerate such discrimination based on gender, race, religion, age, disability, sexual orientation, national origin, or other characteristics protected by law.

Occupational Health and Safety
The supplier complies with applicable occupational health and safety regulations and ensures a safe and healthy working environment to maintain the health of employees, protect third parties, and avoid accidents, injuries, and work-related illnesses.
The supplier has an emergency procedure and a system for reporting injuries and accidents.

3. Ethical Behavior

Bribery and Corruption
The supplier complies with all applicable national and international anti-corruption regulations, laws, rules, and standards. It does not offer or promise any advantages to improperly influence official or business actions.

Data Protection
The supplier ensures that confidential information and the intellectual property of third parties are protected.

Money Laundering and Financial Records
The supplier complies with all applicable laws and regulations regarding the fight against money laundering. The supplier maintains financial records and prepares reports in accordance with international laws and regulations.

Fair Competition
The supplier complies with applicable competition and antitrust laws.

Export Control
The supplier complies with all applicable trade and import regulations, including sanctions and embargoes applicable to its work.

4. Environmental Protection and Supply Chain

Environment
The supplier complies with all applicable and country-specific environmental laws, regulations, and standards and operates an efficient system for identifying and eliminating potential environmental hazards.

Reduction of Emissions, Waste, and Resource Consumption
The supplier implements appropriate measures for the continuous reduction of greenhouse gas emissions, waste generation, and consumption of natural resources such as water, energy, and raw materials.

Safe Handling of Hazardous Substances
The supplier undertakes to handle hazardous substances, chemicals, and waste in a responsible and legally compliant manner. This includes safe storage, labeling, transport, and disposal, as well as taking appropriate measures to prevent leaks, releases, or other forms of environmental pollution. Emergency plans for environmental incidents must be in place.

Promotion of Environmentally Friendly Technologies and Processes
The supplier actively strives to use or develop environmentally friendly technologies, production processes, and materials that minimize negative environmental impacts.

Compliance with Legal Substance Restrictions
The supplier undertakes to fully comply with the REACH Regulation (EC No. 1907/2006) for the Registration, Evaluation, Authorization and Restriction of Chemicals, the RoHS Directive (2011/65/EU) on the restriction of the use of certain hazardous substances in electrical and electronic equipment, and the POP Regulation (EC No. 2019/1021) on persistent organic pollutants, as well as all respective delegated directives and regulations.

The supplier ensures that no prohibited or restricted substances are contained in its products, or – if permitted – that these have been properly registered, communicated, and documented. Upon request, the supplier will provide corresponding declarations of conformity and safety data sheets.

The supplier undertakes to provide the necessary information upon request regarding legal substance restrictions in other countries or internationally.

Conflict Minerals
The supplier fulfills its due diligence obligations in the supply chain for minerals from conflict-affected and high-risk areas, in particular the obligations under EU Regulation 2017/821 of May 17, 2017 (concerning tin, tantalum, tungsten and their ores, as well as gold), and under the Dodd-Frank Wall Street Reform and Consumer Protection Act (currently concerning tin, tantalum, gold and tungsten from the Democratic Republic of the Congo and its neighboring countries), by using recycled materials, avoiding sources from conflict areas, or sourcing from and documenting validated smelters (e.g., via CMRT).

Compliance with CBAM (Carbon Border Adjustment Mechanism)
For the delivery of products from non-EU countries, the requirements of the EU Carbon Border Adjustment Mechanism (CBAM, Regulation (EU) 2023/956) must be complied with. This includes, in particular, the transparent provision of all required data on the direct and indirect CO₂ emissions generated during production, as well as the timely transmission of this information to the importer.

Management Systems
Suppliers should implement suitable management systems to:
– Ensure compliance with this Code of Conduct
– Identify risks and minimize them through appropriate measures
– Report violations and take corrective actions

Relationship with Sub-suppliers
The supplier shall work with its own sub-suppliers to ensure that they comply with this Code of Conduct for their deliveries and services to the supplier.

Holmberg GmbH & Co. KG
Code of Conduct
FL783 Revision

Confirmation by the Supplier

Compliance with the Code of Conduct

We reserve the right to verify compliance with this Code of Conduct upon reasonable notice. A violation of this Code of Conduct will be considered a material breach of contract on the part of the supplier.