Petrofer Group Code of Conduct
Content Foreword 1. Responsibility towards Employees and Society 1.1 Responsibility and cooperation 1.2 Human rights and discrimination 2. Employment Law, Plant Security and Employee Health and Safety 3. Environmental Protection and Sustainability 4. Behaviour of our employees 4.1 Public appearance 4.2 Avoiding conflicts of interest 4.3 Confidentiality of information 4.4 Dealing with company property 5. Conduct towards business partners and third parties 5.1 Corruption 5.1.1 Conduct towards officials 5.1.2 Conduct towards business partners and customers 5.1.2.1 Relationship rules 5.1.2.2 Demanding and accepting benefits 5.1.2.3 Offering and granting of benefits 6. Competition and anti-trust 6.1 Expectations of business partners 6.2 Consultants, dealers and intermediaries 6.3 Political parties 7. Compliance with the Code of Conduct Page 2 of 8
Foreword Petrofer has successfully developed, produced and distributed worldwide for many decades, quality chemical products for production and manufacturing processes in the automotive and automotive supplier industry, as well as for use in many other industrial applications and markets. We place the highest value on the consistent quality and performance of our products and service. Our goal is to be the preferred supplier to both national and international customers. We firmly believe that our business can only be successful if we take our corporate responsibility seriously and align our actions on legal and ethical principles. With this Code of Conduct, we have our standards laid down in terms of our appearance, cooperation and behavior, with the aim to make all our company activities exercised within a legal, moral and ethical framework. The Management, all Executives and Employees are committed to these principles worldwide. Petrofer Group Executive Committee May 2015 Page 3 of 8
1. Responsibility towards Employees and Society The application of social and corporate responsibility is an essential part of the valueorientated corporate management of Petrofer. 1.1 Responsibility and cooperation The staff are crucial to the success of Petrofer Group. For this reason, Petrofer acknowledges its responsibility to its employees, to promote and develop their skills. Our internal company cooperation is characterised by mutual respect, and a spirit of partnership. Any form of discrimination, violence, physical abuse or sexual harassment will not be tolerated. We are committed within the scope of the statutory provisions to the principle of equal opportunities in recruitment and development of our employees. We welcome and support the voluntary work of our employees, and thus taking part in responsibility for their community. As a member of the VCI, and as a responsible chemical company, we are committed to the idea of Responsible Care and the necessary responsible behavior at the site in Hildesheim, and our sites and customers worldwide. 1.2 Human rights and discrimination Petrofer respects internationally recognised human rights and supports their compliance. Any form of child or forced labour throughout Petrofer Group will not be tolerated. Petrofer will not tolerate discrimination of people because of their nationality, gender, creed, religion, disability or other personal characteristics. 2. Employment Law, Plant Security and Employee Health and Safety Petrofer agrees to comply with, and implement, all relevant laws and regulations in the areas of employment, work practices, plant and equipment along with ensuring the Health and Safety of all employees throughout Petrofer Group. Through preventative safety measures, regular training, detailed procedures and management we will avoid risks to people. Through the service, maintenance and periodic inspections of our facilities and equipment we ensure a high process efficiency and a safe working-environment. Through these and other measures we contribute to the health and safety of all our employees and visitors. Page 4 of 8
Importantly all employees of Petrofer contribute, as part of their responsibility, to avoid hazards for themselves and colleagues, giving heed to any possible hazards of their work and working-environment. Their direct manager must be informed of deficiencies in occupational safety and hazards immediately, and we openly encourage employees to raise issues and identify potential improvements to working practices. 3. Environmental Protection and Sustainability Petrofer is committed to complying with the laws and regulations, whether regional, national or international on environmental protection. The business processes of Petrofer are focused on the principle of sustainability. We support sustainable corporate activity on economic, ecological and social levels. The Petrofer staff contribute to the practical implementation of sustainability principles at work, and deal responsibly with energy, water and raw materials etc. Petrofer and each employee at their workplace are committed to work towards the achievement of the following environmental objectives: Protection of natural resources Prevention of pollution Use of safer, environmentally and energy efficient production Improvement of environmental awareness Supplier evaluation taking into account quality and environmental aspects Information to the interested public (if required) 4. Behaviour of our employees 4.1 Public appearance Every employee is an ambassador for Petrofer and its public image, and must at all times present the company in a responsible and professional way. Every employee is required to communicate with our customers, colleagues and business partners in a professional, courteous and service orientated manner. 4.2 Avoiding conflicts of interest Every employee is required to make business decisions solely in the interests of Petrofer. Any conflict of interest between Petrofer and our business partners through personal, tangible or intangible interests is to be avoided, and must be reported immediately to senior management or the Executive Committee. Page 5 of 8
Any kind of secondary employment in companies that are competing with Petrofer, as an employee, consultant or any other way is prohibited. The direct or indirect involvement (e.g. by close family members) with competitors, business partners or other competing activities and relationships are prohibited. Any actual or perceived conflict of interest is to be communicated to the Executive Committee. 4.3 Confidentiality of information Every employee is required to keep Petrofers business and trade secrets entrusted to him confidential and secret. This includes, for all employees, operational activities, commercial, technical and intellectual property or other items as they become known. All must remain retained within the company environment and secret. All information or documents about business activities that were not published by Petrofer will be treated confidentially. Any contact with the press through written, televised or internet approaches must be approved by the Executive. Posting any corporate information or any communication on company matters through Social Media is forbidden unless prior approval from the Executive is obtained. 4.4 Dealing with company property All company property, premises, work equipment, (e.g. communications and IT equipment, office supplies, vehicles, safety equipment) and including intangible assets such as intellectual know-how may only be used in the interests of Petrofer business. All corporate possessions in our Employees ownership have to be dealt with responsibly and protected against damage, loss and theft. The company's property may not be used for other business purposes, sold or lent, regardless of its condition or its value, without the express permission of the Company through the relevant Senior Manager. 5. Conduct towards business partners and third parties 5.1 Corruption The Petrofer Group does not tolerate corruption, illegal or unfair business conduct and corrupt practices of its employees or business partners. Page 6 of 8
5.1.1 Conduct towards officials Donations of any kind to public officials, civil servants, politicians and other employees or representatives of state bodies and their family members are prohibited. Invitations to purely technical events may be accepted if the event has no significant "recreational aspects" (such as entertainment, social program, etc.). 5.1.2 Conduct towards business partners and customers Employees must not allow themselves or willingly put themselves, into a position where they or the Company may be compromised including commercially, environmentally, sexually, morally, politically, legally, emotionally or financially. 5.1.2.1 Demanding and accepting benefits Employees may not ask or demand, for themselves or for others, benefits of any kind from business partners and customers. Donations from business partners and customers, which can influence the business decisions of employees, or may give the impression of influence, may not be accepted. The acceptance of advertising, occasional gifts or meals and event invitations may be accepted to a reasonable small value. This is provided that the applicable laws and internal Petrofer corporate directives are complied with. 5.1.2.2 Offering and granting of benefits All kind of donations to business partners and customers with the intent to receive orders or an unfair advantage are not allowed. Advertising and occasional small gifts to business partners, customers or their employees including invitations to business meals or events are generally allowed when the applicable laws and internal Petrofer company policy is followed. Page 7 of 8
6. Competition and anti-trust Petrofer agrees to comply with all applicable competition laws. Every employee is obliged to observe the local and International rules of fair competition. Any agreements or arrangements made that affect the prices, trading conditions or restrict fair competition in any other way are prohibited. 6.1 Expectations of business partners We expect all our business partners to align their business protocol with ours and follow the principles set out in this Code of Conduct. 6.2 Consultants, dealers and intermediaries Petrofer will take all the necessary steps to ensure that the consultants, dealers and agents appointed by us comply with the law and this Code of Conduct. Petrofer will not tolerate and be involved with illegal business and sales practices, and will terminate any agreement immediately. 6.3 Political parties Donations of any kind to political parties, political organizations and their representatives, and to potential candidates for political office are prohibited. 7. Compliance with the Code of Conduct Petrofer will implement the principles laid down in the Code of Conduct within all companies of the Petrofer Group. All subsidiaries and employees of the Petrofer Group are required to comply with the Code of Conduct and to behave accordingly. The Executive Committee have a particular responsibility for the implementation, monitoring and enforcement of compliance with this Code of Conduct. Every employee is encouraged to report promptly, any potential, imminent or actual violations of the applicable law, this Code of Conduct or other internal Petrofer policies to their Manager and subsequently the Executive Committee. Violations of the Code of Conduct or other Petrofer policies and regulations will result in disciplinary proceedings. Petrofer Executive Committee May 2015 Page 8 of 8