Code of Conduct

1. Preamble

For more than 10 years, CASCOO Europe GmbH is selling a wide range of castors and wheels and has built up a network with new warehouses and its own sales departments, among others, in Spain, BeNeLux, France, Slovenia and the UK, in recent years. As a growing, internationally operat-ing company, it is important to us to run the company in an ecologically and socially responsible manner. We expect the same behavior from our employees and our suppliers. Based on our com-pany's code of conduct for employees, we agree that the following regulations for a common code of conduct will apply to future cooperation between the contractual partners. The contractual part-ners undertake to comply with the principles and requirements of the code of conduct. The sup-plier undertakes to present this code of conduct to its subcontractors and to endeavor to contrac-tually oblige them to comply with the standards and regulations listed.

To make the Code of Conduct easier to read, we only use the masculine form, but hereby expressly point out that we explicitly address all genders when referring to persons.

2. Requirements for our suppliers

We base our requirements for our suppliers on the various conventions of the International Labor Organization (ILO) and in particular on the Supply Chain Law, which we consider important, even if it is not mandatory for us as a small company.

2.1 Social Responsibility

We believe that all people worldwide deserve an appropriate social standard and code of conduct. As an internationally active company, we take over responsibility towards our employees and soci-ety, which is why respect for human rights is of central importance to us. Our suppliers are also committed to recognizing human rights and assuming social responsibility.

Exclusion of forced labor, slavery and prohibition of child labor

Our suppliers prohibit any kind of slavery and forced labor (§ 2 sect. 2 no. 3 and 4 LkSG; ILO Con-vention 29 and 105) and ensure that there is no forced labor or child labor in the further supply chain. An employment relationship must always be established on a voluntary basis and the worker must be able to resign and leave the company at any time. In addition, there must be no unacceptable treatment of workers, such as psychological hardship, sexual harassment and humili-ation.

In addition, our suppliers do not accept the employment of children and young people outside the legal guidelines. If minors are employed in accordance with the law, care is taken to ensure that the activities are not harmful to their health or development and are in line with compulsory edu-cation, i.e. do not interfere with it. The minimum age here should be at least 15 years (ILO Conven-tion 138, §2 sect. 2 no. 1 and 2 LkSG).

No discrimination, harassment or bullying in the workplace

Our suppliers undertake to treat their employees and business partners equally and free from dis-crimination and racism. They do not tolerate harassment and/or discrimination based on gender, age, ethnic origin, citizenship, physical or mental disabilities, religious affiliation, sexual orientation or other legally protected characteristics (in accordance with Section 2 (2) no. 7 LkSG).

Health and safety at the workplace

Our suppliers ensure the health of their employees. Where necessary, employees are given access to safety clothing/protective clothing and are trained in the use of machines to keep the possibility of an accident at work as low as possible. Our suppliers comply with applicable laws and interna-tional standards for health and safety at work (ILO Convention 155).

Fair working hours and payment

Working hours must comply with applicable laws and industry standards. Employees must be given at least one day off after six consecutive working days. In addition, employees must be al-lowed to take appropriate rest breaks / break times (§2 sect. 2 no. 5c LkSG, ILO Convention 14, Art. 2). The salary must correspond to the national statutory minimum wage. Wage deductions as a pu-nitive measure are not permitted (§ 2 sect. 2 no. 8 LkSG).

2.2 Ecological responsibility

In our own interest, but also in the interest of future generations, we use natural resources spar-ingly and try to protect the environment whenever possible. We also expect this from our suppli-ers.

Treatment and discharge of industrial wastewater

If industrial waste water is produced during the production process, we expect the waste water to be discharged properly without endangering people or the environment (§2 sect. 2 no. 9 LkSG).

Handling of waste and hazardous substances

Our suppliers ensure that waste is separated and disposed of in accordance with at least the coun-try-specific requirements. Wherever possible, waste should be recycled. Hazardous waste materials must be disposed of separately without endangering people or the environment.

Consumption of raw materials and natural resources and energy

We expect our suppliers to use raw materials consciously and avoid unnecessary consumption of raw materials and energy. Work on site should be as energy efficient as possible and energy and water consumption should be reduced wherever possible.

2.3 Ethical business behavior

We base our requirements on the OECD Guidelines for Multinational Enterprises.

Fair competition

The standards of fair business activity, fair advertising and fair competition must be complied with.

Confidentiality / Data privacy

The supplier undertakes to comply with the laws on data protection and information security and to ensure the protection of the private information of clients, suppliers, customers, consumers and employees.

Integrity / bribery, taking advantage

The supplier must ensure compliance with anti-corruption laws and apply appropriate monitoring procedures. A zero-tolerance policy must be pursued with regard to the prohibition of bribery, corruption, extortion and embezzlement (OECD Guidelines for Multinational Enterprises Chapter IIV). All transactions must be in accordance with the statutory provisions. The supplier undertakes not to do business with persons, companies or organizations that are associated with terrorism or drug trafficking or whose funds originate from criminal activities.

3. Implementation of the requirements

The supplier or the management/executive board ensures that the code of conduct is actively communicated and implemented within the company.

We expect our suppliers to identify risks in the supply chain and take appropriate measures. In the event of suspected violations, the supplier informs us promptly and, if necessary, regularly about the identified violations and risks and the measures taken in relation to them. Should we discover a breach of the provisions of this Code of Conduct, we will inform the supplier immediately in order to give him the opportunity to bring his conduct into line with this codex within a reasonable grace period. If this does not happen within the specified period and we do not receive any feedback on the improvements sought, we reserve the right to terminate the busi-ness relationship, including the associated supply contracts.

Questions and complaints

The employees of the supplier must be given the opportunity to express concerns or questions re-garding their employer's business conduct. The first point of contact should be the direct supervi-sor. If this is not an option for whatever reason, employees can use the complaint system. If there is no separate portal for complaint management, the supplier undertakes to inform employees about our complaint system. The system can be accessed internally and externally via https://cascoo.eu/en/contact.

4. Acknowledgement and consent of the supplier

By signing this document, the supplier undertakes to act responsibly and to comply with the prin-ciples / requirements listed. The supplier undertakes to communicate the content of this code to employees, agents and subcontractors in a manner that they can understand and to take all neces-sary precautions to implement the requirements.