GKV Code of Conduct

for the Plastics Processing Industry

Preamble

As an umbrella organisation bringing together the member organisations AVK, FSK, IK and pro-K, the GKV represents a large section of the plastics converting industry in Germany.The member companies are committed to their social responsibility within the framework of their entrepreneurial activity (Corporate Social Responsibility). The present GKV code of conduct (CoC) is a voluntary agreement, through which member companies wish to guarantee particularly the observance of global demands on ethical and moral actions as well as the standards of proper conduct in the areas of competition and antitrust law (compliance). This also means promoting fair and sustainable standards dealing with suppliers and customers as well as own company personnel. The companies recognising the code of conduct regularly inform company members on the ethical goals and behaviour principles of this code of conduct. Moreover, they aim for suppliers to also accept the guidelines. The GKV code of conduct is designed as a negotiated agreement. The certification of participating companies is carried out by the GVK or its member associations.

I. General regulations

1. Validity

This code of conduct is valid for all branches and production sites of the company.

2. Laws, standards and ethic behaviour

The company adheres to the valid laws and standards of the respective countries it is active in. It takes guidance from the general ethic values and principles, especially integrity, righteousness as well as human dignity.

3. Business partners, authorities and consumers

The company practices according to the generally recognised business practices of fairness and honesty. It deals truthfully with authorities. Standards protecting consumers are adhered to. The company avoids conflicts of interest, whether internal or external, if they can influence the
business relationship in an unobjective way. Unavoidable conflicts are disclosed to the business partner without being asked.

4. Trade secrets

Trade secrets of business partners will be treated strictly confidentially by companies and their members. Passing on confidential information to third parties or making this information publicly available is forbidden. This continues to be the case for company members even after the employment has been terminated.

5. Reporting and transparency

Internal and external reports and documents of the company, in particular also financial information, represent complete, appropriate and timely as well as comprehensible representations about the company. They are prepared in accordance with recognised accounting principles as well as appropriately recognised control systems.

6. Responsibility in the supply chain

The company is aware that responsible behaviour is becoming increasingly important within supply chains. The selection of our suppliers takes into account, as far as possible, whether they are also committed to acting responsibly and apply either this or an equivalent code of conduct.

II. Antitrust and competition law guidelines

1. Antitrust law

The company is committed to a fair competition. Laws protecting fair competition, particularly antitrust law and other competition regulating laws, are adhered to. Collusion on prices or other conditions, sales areas or customers as well as misuse of market power contradict the principles of the company.

2. Bribery, bribability and corruption

The company opposes bribery and corruption and does not tolerate such behaviour. The employees are to take care not to create personal dependencies or obligations towards customers or suppliers. In particular, employees are not allowed to accept or make gifts which, under reasonable contemplation, could influence business decisions. In case gifts are part of a country’s custom, it is important to note that no binding dependencies are created and local legal standards are adhered to. Contravention will routinely have legal consequences.

3. Money laundering

The company complies with the legal obligations to prevent money laundering and does not participate in transactions that serve to conceal criminal or illegally acquired assets. Before entering into business relationships, the company checks the identity and seriousness of its business partners. When making payments to or from business partners, it looks for warning signs of money laundering. Business processes are dutifully documented.

III. Global guidelines

1. Human Rights

Internationally recognised human rights1 are supported explicitly and consistently. Equally, in the case of disciplinary measures, all company personnel are to be treated with dignity and respect. Such measures must only take place in accordance with the current national and international standards and internationally recognised human rights.

2. Child Labour

Child labour and any kind of exploitation of children and adolescents is rejected. The corresponding laws are adhered to.

3. Forced labour

Any kind of forced labour, debt bondage, slave work or slavery or similar situations are rejected. Company members must not be forced to work through means of violence or intimidation, neither directly nor indirectly.

4. Wages

All employees in full time employment shall receive a fair salary covering at least their basic needs. The wages are to be paid in a practical way (cash, cheque, bank transfer) and payroll accounting has to be made available to a reasonable extent.3 The right of employees to freedom of association, freedom of assembly and collective bargaining in as far as this is legally admissible and possible in the respective country, shall be respected.

5. Working hours

Working hours correspond to valid national laws, industry standards or relevant ILO conventions. Extra work has to be done on a voluntarily basis.

6. Health and employment protection

The national and international regulations for securing health and safety at work are adhered to. Relevant systems to avoid risks for health and safety are to be set up.

7. Environmental protection

The company adheres to the goals of sustainable environmental protection. Environmentally friendly production methods are aimed for in this context. In accordance with the principles of the Rio Declaration on Environment and Development of the United Nations7, the company deals responsibly with natural resources.

IV. Ethical and social principles

1. Non-discrimination

The company opposes discrimination on employment or occupation, in particular a discrimination because of race, ethic or national origins, colour of skin, gender, or mental and physical disability, age, creed, membership of a trade union or any other personal traits.

2. Molestation

The company disapproves of physical, psychological or sexual violence.

3. Freedom of opinion

The right to freedom of opinion and free expression of opinion is warranted.

4. Privacy

Privacy is respected.

V. Observance of the code of conduct

1. Measures

The company presents the code of conduct to company members in a suitable form and given intervals, and ensures that it is adhered to.

2. Certification

A requirement for the certification is a regular survey of members taken every two years within the framework of self-disclosure. The certified companies can be made public in an appropriate way through the GKV and its member associations. The participating companies acquire the right to use the GKV logo for the Code of Conduct. If the companies do not fulfil or cease to fulfil the certification requirements, membership within the compliance initiative will be withdrawn.

July 1st, 2023