Code of Conduct

Preamble

Hailo-Werk Rudolf Loh GmbH & Co. KG and its affiliated subsidiaries (hereinafter individually referred to as “Company/Companies”) commit themselves to heir global social responsibility. In particular, the Companies bear responsibility within the scope of their business activities to their own company, to customers and suppliers in the value chain and to the environment.

The Hailo Code of Conduct is a voluntary code, which is recommended to the Companies. Upon signing the Code, the member company commits itself to comply with the following principles.

I. General Principles

Basic Understanding

The Company accepts its corporate and social responsibility and undertakes to live up to this responsibility in all its entrepreneurial activities.

Legal Rules and Regulations

The Company undertakes to comply with all relevant and applicable laws and other provisions of the countries in which it operates concerning all business activities and decisions. Business partners are to be treated fairly. Contracts are to be honored; in doing so, any changes of the framework conditions are taken into account. The Company complies with applicable laws that protect and promote competition, in particular any applicable antitrust laws and other laws on the regulation of competition.

Values and Principles

The Company’s actions are guided by Christian and generally accepted ethical values and principles, in particular integrity, virtue, respect for human dignity, candor and nondiscrimination based on religion, worldview, gender and ethics. The Company opposes corruption and bribery in terms of the respective UN Convention (from 2005). In an appropriate way, it promotes acting with integrity, transparency, responsible leadership and control in the Company.

II. Principles on Corporate and Social Responsibility

Human Rights

The Company respects and supports the compliance with internationally accepted human rights. In particular, it complies with the human rights pursuant to the UN Charter of Human Rights (Universal Declaration of Human Rights, resolution 217 A (III) of the General Assembly on December 10, 1948).

Principle of Non-Discrimination

Within the scope of the respective applicable legal rules and regulations, the Company opposes any form of discrimination. This applies in particular to discriminating employees due to race, ethnic origin and gender.

Occupational Health and Safety

The Company guarantees occupational safety and health at the workplace within the scope of national regulations. In order to prevent accidents and personal injuries, the employers provide secure and healthy working conditions that, as a minimum criterion, comply with the existing legal
regulations. The Company supports a continuous development to improve the working environment.

Working Hours

The Company observes the labor standards regarding the maximum admissible working hours and remuneration, especially with regard to the level of remuneration, pursuant to applicable laws and regulations.

Remuneration

Remuneration including wages, overtime and fringe benefits shall be at least in an amount determined in the effective legal rules and regulations or above this amount.

Harassment

Employees shall not be subjected to any corporal punishment or other physical, sexual, emotional or verbal abuse or harassment.

Child Labor and Forced Labor

The Company does not accept any form of forced labor or child labor.

Should forced or child labor be detected within a direct or indirect connection, e.g. at a supplier, the grievance must be reported and redressed.

Transparency and Consumer Dialogue

The Company acknowledges the consumers’ right to important product and process information that is required to make a qualified purchase decision. If possible, the company will specify the respective relevant information and make it publicly available.

Corporate Citizenship

The Company promotes civic involvement by making positive contributions to the communities in which it is active. At the same time, it expressly endorses any voluntary commitments of its senior management and its employees.

Environment

The Company is committed to the goal of sustainably protecting the natural fundamental resources for the current and future generations. The Company applies environmentally friendly practices that are continuously improved. It complies with the regulations and standards regarding environmental protection related to its operations and deals responsibly with natural resources.

Communication

Communication about this Code of Conduct and its implementation with employees, customers, suppliers and other stakeholders shall be done openly and with an emphasis on dialogue by the Company.

III. Principles of Fair Competition

Prohibition of Corruption

When dealing with business partners and government institutions, the Company’s interests and the private interests of employees are to be strictly separated from each other on both sides. Decisions shall be made free of irrelevant considerations and personal interests. The applicable criminal law of corruption must be complied with. The following, among other things, must be adhered to:

The Company's management and employees must not offer, promise, demand, grant or accept any presents, payments, invitations or services in the course of business, which have the intention to influence a business relationship in a dishonest way or which bear the threat to endanger the professional independence of the business partner. As a principle, this does not apply to presents and invitations that lie within the scope of usual hospitality, conventions and courtesy.

IV. Scope, Implementation, Supplier

Scope

This Code of Conduct applies to all branch offices and business units of Hailo-Werk Rudolf Loh GmbH & Co. KG.

Implementation and Compliance

The Company shall announce the content of this Code of Conduct and the ensuing responsibilities to its employees. It ensures compliance with the Code of Conduct by implementing suitable measures.

Suppliers

The Company shall see to it that the direct suppliers are aware of the principles of this Code of Conduct and it shall demand compliance with it from its suppliers.

Haiger, November 18, 2013

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