TRICOR Code of Conduct for Suppliers

I. Introduction & Requirements for Suppliers

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The scope of the CoC extends to TRICOR Packaging & Logistics AG, TRICOR Packaging Systems GmbH 
and their affiliated companies within the meaning of Section 15 of the German Stock Corporation Act (AktG) (hereinafter referred to as ‘TRICOR’). TRICOR is committed to environmentally and socially responsible corporate governance. We expect the same behaviour from all our suppliers. We also require our employees to observe the principles of ecological, social and ethical behaviour and to integrate them into the corporate culture.Furthermore, we strive to continuously optimise our business activities and products in terms of sustainability and encourage our suppliers to contribute to this in the spirit of a holistic approach. For future cooperation, the contracting parties agree to the validity of the following regulations for a joint code of conduct. This agreement serves as the basis for all future deliveries. The contracting parties undertake to comply with the principles and requirements of the code of conduct and to endeavour to contractually oblige their subcontractors to comply with the standards and regulations set out in this document . This agreement shall enter into force upon signature. A violation of this code of conduct may ultimately be grounds and cause for TRICOR to terminate the business relationship, including all associated supply contracts. The Code of Conduct is based on national laws and regulations, such as the Supply Chain Due Diligence Act (LkSG), as well as international agreements such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children's Rights and Business, the United Nations Guidelines on Business and Human Rights, the International Labour Standards, and the International Labour Organisation's Global Compact. EU directives must be taken into account and complied with. General export controls and any economic sanctions are also applicable. of the International Labour Organisation and the United Nations Global Compact. EU directives must be taken into account and complied with. General export controls and any economic sanctions must also be taken into account by the supplier.

1. Bribery and corruption

TRICOR is against corruption and bribery and requires its suppliers to comply with the legal provisions for combating corruption. Suppliers assure that they do not offer, promise or grant any improper advantages to TRICOR or persons associated with it. The same applies to anyone acting  on the instructions of the suppliers. The supplier bears full financial responsibility and keeps accurate records of the use of funds.

2. Antitrust and competition law

All applicable domestic, EU and relevant foreign antitrust laws as well as laws against unfair competition are complied with. This is expected of all suppliers. Price or condition agreements with competitors are therefore to be avoided, as are other agreements that restrict competition, including, in particular, agreements with competitors for the purpose of market or customer sharing. The supplier undertakes to disclose relevant information to the extent necessary to prevent conflicts of interest. 

3. Occupational safety and health

Suppliers are required to ensure a safe, healthy and hygienic working environment and to take the necessary measures to prevent accidents and damage to health that may arise in connection with their activities.In doing so, they must ensure that occupational safety standards are complied with. To this end, suppliers shall take appropriate and verifiable measures and operate systems (e.g. based on ISO 45001 or comparable systems) to identify and prevent potential risks to the health and safety of their employees. In addition, wherever relevant, supplementary regulations of the companies and locations, for example on occupational health and safety and hygiene, as well as other relevant regulations, must be observed. 

4. Working hours

Working hours must be set in accordance with local laws and industry standards. Regular working hours may not exceed 48 hours per week. Overtime of up to 12 hours per week is only permitted if the average working time over a period of four months does not exceed 48 hours. Overtime requires remuneration agreed in accordance with legal regulations. Furthermore, care must be taken to ensure that overtime is only worked on a voluntary basis, is remunerated accordingly or is compensated by equivalent time off, unless exceptions are permitted under collective agreements or similar contracts. As a general rule, one day off must be granted after a working week of six consecutive days. It is mandatory to comply with national legal regulations regarding working hours, in particular rest periods and Sundays and public holidays. General principles and the rights of employees are observed. 

5. Remuneration

All suppliers shall ensure that the wages paid to employees are at least equal to the statutory minimum wage. The applicable minimum wage laws shall be complied with. Illegal and unauthorised wage deductions, in particular those in the form of direct or indirect disciplinary measures, are prohibited. Wages shall be paid in a manner that is convenient for the employee. Employees must be informed regularly and in detail about the composition of their remuneration in a comprehensible form. 

6. Freedom of association

The right of employees to form and join organisations of their choice, to engage in collective bargaining and to strike must be respected. In cases where freedom of association and the right to collective bargaining are restricted by law, alternative means of independent and free association of employees for the purpose of collective bargaining must be provided. Employee representatives shall be protected from discrimination. Employees shall not be discriminated against on the basis of forming, joining or being a member of such an organisation. Their employee representatives shall be granted free access to their colleagues' workplaces to ensure that they can exercise their rights in a lawful and peaceful manner.

7. Prohibition of child labour 

Child labour must not be used at any stage of production. Suppliers undertake to comply with applicable laws regarding minimum age and to follow the recommendations of the ILO conventions. The legal regulations of the respective country in which the place of employment is located must always be complied with. It is prohibited to hire employees who are below the age at which compulsory schooling ends. Under no circumstances may the age of employment be below 15 years. If children are found working, remedial and preventive measures must be documented and taken immediately to terminate and prevent the child's employment. In addition, the child must be given the opportunity to receive school education from then on. Children who have not yet reached the minimum age of 15 and other persons subject to full-time compulsory schooling may only be employed in a permissible manner and within the framework of school or work experience placements, provided that these support the child's development and are undertaken with the child's consent. Permissibility is governed by the provisions of the Youth Employment Protection Act. 

8. Protection of young workers

When employing young people, particular attention must be paid to compliance with the statutory regulations on working hours, in particular the prohibition of shift work, night work and overtime, rest breaks and hazardous work. In addition to the Youth Employment Protection Act, the provisions of the Vocational Training Act must also be observed and implemented. Under no circumstances may young employees be required to perform work that could be harmful to their health or that is harmful to the safety and morality of minors. From the age of 18, instruction must be provided on the possible effects and consequences. Furthermore, the local safety regulations must also be observed. Care must also be taken to ensure that the mental health and development of young people is not endangered. Compliance with the standards of the International Labour Organisation and commitment to the guiding principles of the UN Convention on the Rights of the Child are required. 

9. Inappropriate treatment

No forced labour, slave labour or similar forms of labour may be used. All work must be voluntary and carried out without threat of punishment. Employees must be able to terminate their work or employment relationship at any time. Furthermore, no unacceptable treatment of workers, such as psychological hardship, sexual and personal harassment and humiliation, may take place. The commissioning or use of private or public security forces must be refrained from if, during their deployment, persons are treated in an inhumane or degrading manner or injured, or if freedom of association is impaired. 

10. Modern slavery

All forms of modern slavery are expressly prohibited. Any form of forced labour or comparable labour performed under duress is not permitted. In particular, serfdom, debt bondage, servitude, any form of human trafficking, compulsory labour and all forms of oppression or exploitation that restrict a person's freedom in order to exploit them for personal or commercial purposes are strictly prohibited. The employment relationship must be voluntary and in compliance with legal regulations. Unacceptable treatment of workers, such as through the use of 
psychological violence, sexual and personal harassment or humiliation, is prohibited. Care must be taken to ensure that human rights are respected in accordance with generally accepted standards, both now and in the future. All employment relationships must be reviewed for ethical correctness. Furthermore, there is an obligation to report cases of human trafficking or other human rights violations immediately. It is mandatory to comply with the standards of the International Human Rights Charter and to implement and prevent them through effective means. Checks must also be carried out to identify possible human rights violations. Violations must be tackled with a zero-tolerance approach. In order to prevent and effectively combat modern slavery, transparency must be ensured with regard to the supply chain and one's own business area. The disclosure obligations in accordance with the legal regulations of the respective countries must always be complied with.

11. Discrimination

Discrimination and unequal treatment of employees in the employment relationship or within the framework of the recruitment process is prohibited in any form, unless it is justified by the requirements of the job. Unequal treatment of any kind is prohibited. Discrimination, harassment, exclusion or bullying, as well as other forms of unequal treatment, are strictly prohibited and must be reported immediately. Equal treatment and tolerance of all employees must be ensured in all cases, regardless of the following aspects:

• Ethnic, national and social origin
• Physical or mental disability
• Belonging to ethnic minorities or indigenous peoples 
• Skin colour
• Gender
• Gender identity
• Marital status
• Sexual orientation
• Age
• Pregnancy
• Nationality
• Creed and world view
• Political opinion
• Membership in an employee organisation
• Personal characteristics of any kind

12. Complaint mechanisms

The supplier must pass on information received from TRICOR regarding the availability, responsibility and implementation of a complaints procedure to its employees in an appropriate manner within the framework of whistleblowing legislation. The complaint procedure must be accessible to employees while maintaining the confidentiality of their identity and providing effective protection against discrimination. If no information is provided, the supplier is responsible at the operational level for establishing an effective complaint mechanism for individuals and communities who may be affected by negative impacts.

13. Intellectual property

Intellectual property rights must be respected; technology and know-how transfer must be carried out in such a way that intellectual property rights and customer information are protected and no plagiarism is circulated.

14. Environmental responsibility

14.1. Environmental protection

All processes are implemented in an environmentally conscious manner. Applicable laws and minimum regulations on climate and environmental protection must be observed. All suppliers are expected to comply with legal requirements and to operate in an environmentally conscious manner, i.e.: 

• Managing resources efficiently and sustainably (energy, water, raw materials, auxiliary and operating materials)
• Where possible, use environmentally friendly materials and renewable energies.
• Avoiding, reducing or recycling emissions and waste
• Making logistics processes environmentally friendly 
• Avoid negative impacts on soil quality.

Suppliers are expected to take appropriate and traceable measures and operate recognised systems to ensure environmental protection. These include, for example, management systems in accordance with DIN ISO 14001, DIN ISO 50001 or comparable systems. Great importance is attached to a transparent wood and paper supply chain, and all wood and paper suppliers are expected to be certified according to the FSC®/PEFC standard and to strictly comply with the applicable EU regulation on the prevention of deforestation. Suppliers undertake to support responsible forestry and, among other things, not to use illegally harvested wood or wood products from opaque sources. 

14.2 Handling waste and hazardous substances

A systematic approach is followed to identify, manage, reduce and responsibly dispose of or recycle solid waste. The prohibitions on the export of hazardous waste in the Basel Convention of 22 March 1989, as amended, must be observed. Chemicals or other materials that 
pose a risk when released into the environment must be identified and handled in such a way that safety is ensured during handling, transport, storage, use, recycling or reuse, and disposal. Mercury must be used in accordance with the prohibitions of the Minamata Convention Mercury must be used in accordance with the prohibitions of the Minamata Convention of 10 October 2013, and persistent organic pollutants must be used in accordance with the Stockholm Convention of 23 May 2001, as amended. 

14.3 Dealing with air emissions

General emissions from operational processes (air and noise emissions) and greenhouse gas emissions must be classified, routinely monitored, checked and, if necessary, treated before they are released. The supplier is also responsible for monitoring its exhaust gas purification systems and is required to find economical solutions to minimise all emissions. 

15. Protection of natural resources

The supplier must not deprive people of land, forests or water resources that are essential to their livelihoods in violation of legitimate rights. The supplier is expected to refrain from harmful soil changes, water and air pollution, noise emissions and excessive water consumption if 
this endangers human health, significantly impairs the natural basis for food production or prevents people from accessing clean drinking water or sanitary facilities.

16. Confidentiality and data protection

All suppliers undertake to meet the reasonable expectations of their clients, suppliers, customers, consumers and employees with regard to the protection of private information. The supplier must observe the laws on data protection and information security and the official regulations when collecting, storing, processing, transmitting and passing on personal information. 

II. Implementation of requirements

The supplier undertakes to comply with the above principles. Compliance with the specified environmental and social standards must be documented in a verifiable manner. It is recommended that a suitable system (definition and documentation of responsibilities, procedures, objectives and measures) be used to enable continuous improvement. All suppliers undertake to impose these minimum standards on their direct suppliers and service providers through appropriate (contractual) arrangements and to regularly review compliance. It is expected that suppliers will analyse risks within their supply chain and take appropriate measures where necessary. Compliance with environmental and social standards must be verifiably documented. It is recommended that a suitable system (definition and documentation of responsibilities, procedures, objectives and measures) be used to enable continuous improvement. 

1. Information and communication

The supplier is required to make the provisions of this Code of Conduct available to all employees. It is also possible to communicate a corresponding set of rules to its employees. In addition, the supplier shall also pass on the requirements specified in the CoC or similar standards to its Tier 1 suppliers along its supply chain, provided that this set of rules contains all minimum standards. Of this Code of Conduct for Suppliers and require compliance to at least the same extent from its suppliers.

2. Compliance review

The supplier agrees that compliance with the above requirements may be verified, after reasonable prior notice, either by TRICOR itself or by an independent third party commissioned by TRICOR. The results of the verification will be made available to the supplier under review. The supplier agrees that the client is entitled to conduct such audits once a year or for specific reasons to verify compliance with the code at the supplier's premises during normal business hours after giving reasonable advance notice, by persons commissioned by the client. The supplier may object to individual audit measures if these would violate mandatory data protection regulations. If a violation of the provisions of this Code of Conduct is detected, TRICOR shall immediately notify the supplier in writing within one month and set a reasonable grace period for the supplier to bring its conduct into line with these provisions. If a remedy is not possible in the foreseeable future, the supplier must notify TRICOR immediately and work with TRICOR to develop a plan with a timetable for ending or minimising the violation. If such a breach was culpable, the grace period expires without result, or the implementation of the measures contained in the plan termination is unreasonable for the client and no less severe means are available, the business relationship may be terminated by giving notice within the grace period set. Any legal right to extraordinary termination without setting a grace period, in particular in the case of breaches deemed to be very serious, as well as the right to compensation for damages, shall remain unaffected. 

3. Acknowledgement and consent

By signing this document, the supplier undertakes to act responsibly and to comply with the principles/requirements listed. The supplier undertakes to communicate the content of this code to employees, agents and subcontractors in a manner that is understandable to them and to take all necessary precautions to implement the requirements. 

4. Contact

In special cases and if you have information about actions that violate this code of conduct, you can contact us at the following email address: [email protected] or use our publicly accessible whistleblower reporting system, whereby the regulations for the protection of whistleblowers under the German Whistleblower Protection Act (HinSchG), in particular those in Sections 33ff. HinSchG, apply. 
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