Code of Conduct

1 Our responsibility / our principles

We champion sustainable business practices on a daily basis by carefully managing our resources, passionately combining proven expertise and innovative ideas to incorporate them seamlessly into our day-to-day business together with our local, national and international business partners, with a view to creating a better, cleaner and more sustainable world for both ourselves and the generations to come. Fundamental principles such as fairness, safety and respect are at the heart of our actions and characterize our day-to-day business life, which is always focused on people. We attach great importance to long-term partnerships, sustainable cooperation and responsible action and conduct, underpinned by the core values of business ethics, integrity and safety, as well as compliance with legal requirements and environmental standards.

2 Principles of cooperation

2.1 Unifying values

The RONDO values form the basis for our cooperation. We create a working environment that is characterised by mutual respect, professionalism, honesty and fairness. Mutual trust is the basis of our cooperation. We put the issue front and centre. We hold discussions in a committed, constructive and respectful manner. Communication is always based on facts, we do not spread rumours. RONDO employees take responsibility for their actions.

2.2 Diversity, equal opportunities and inclusion

RONDO is committed to ensuring equal employment opportunities and does not tolerate discrimination against its employees. No one should be disadvantaged, favoured or harassed on the basis of characteristics such as gender, skin colour, religion, nationality, political or other convictions, ethnic origin, disability, age or sexual orientation.

2.3 Teamwork and personal development

RONDO promotes teamwork in a multicultural, welcoming and partnership-based environment and relies on highly motivated, well-qualified employees who are willing to learn. We value the individual strengths and expertise of our employees. We support the professional and personal development and vocational success of our employees and encourage individuals to strive for excellence and engage in lifelong learning.

3 Working conditions and human rights

3.1 Human rights

We consider it our duty to prevent human rights violations of any kind in the course of our business activities. At RONDO, we are guided by the following international regulations in this regard:

• The United Nations Universal Declaration of Human Rights
• The UN Convention on the Rights of the Child
• The fundamental conventions and international labour standards of the ILO (International Labour Organization)
• The principles of the United Nations Global Compact
• The applicable national regulations and sanction provisions

3.2 Child labour, forced labour and modern slavery

RONDO is committed to ensuring fair working conditions and does not accept any form of child labour, forced labour or modern slavery. Child labour includes any form of employment of children below the legal minimum age that impairs their physical, mental or social development. This includes activities that expose children to dangerous working conditions, prevent them from attending school or are contrary to international standards such as ILO Conventions 138 and 182 and the UN Convention on the Rights of the Child. Such work is strictly prohibited under international and 
national legislation. Forced labour and modern slavery are defined as work or activities that are performed involuntarily under threat of punishment, including unlawfully enforced overtime, human trafficking, debt bondage, forced prison labour, slavery or peonage.

3.3 Wages and social security benefits

We are fully committed to providing RONDO employees with a safe and stimulating working environment that enables them to carry out their work under fair conditions and for competitive remuneration. We ensure that employees are included in social security programmes and that the locally applicable industry tariffs or statutory minimum wages are adhered to.

3.4 Health and safety regulations

RONDO commits to safeguarding the health and safety of its employees by providing a safe and risk-free work environment for its employees. We comply with local and national laws and regulations and safety laws and regulations in order to prevent accidents. We hold all of the necessary legal permits, licenses and approvals.

3.5 Working hours and workplace health promotion

RONDO complies with the applicable national regulations on working hours and rest periods, time off and holidays. The manner in which the workplace, working hours and breaks are organised takes into account both operational requirements and the individual health considerations of employees. At RONDO, we encourage a favourable work-life balance. We offer our employees flexible working time models 
within the scope of operational feasibility.

4 Cooperation with customers, suppliers and partners

Our company plays an active role in shaping a fair and sustainable future; one in which respect, justice, economic stability, ecological action and social responsibility are promoted, strived for and continuously pursued. We are committed to protecting the environment both for ourselves and the generations to come. Our actions are reflected in this Code of Conduct. We expect the same from our customers, partners and suppliers in exchange for long-term cooperation and the opportunity to shape a sustainable future as one. For a detailed description of the expectations we have of our suppliers and partners, please refer to the Supplier Code of Conduct.

4.1 Selection of business partners

We exercise care in selecting our suppliers, distributors and other business partners on the basis of qualifications, experience, sustainability and other legitimate business interests. The selection process is not influenced by personal relationships or motives. Collaboration with customers, suppliers and other third parties whose standards are incompatible with our Code of Conduct must be avoided.

4.2 Bribery and corruption

We are committed to ensuring that our employees comply rigorously with the prohibition of corruption and bribery. Our employees must not bribe third parties or government officials or accept unjustified benefits from anyone. They must not directly or indirectly offer, acquire or solicit unauthorised financial benefits or other privileges.

4.3 Gifts and benefits

Business courtesies, gifts, benefits and hospitality that are ‘reasonable’ and do not exceed the (monetary) value of customary local business standards and are in accordance with local laws and regulations are exempt from the regulations on bribery.

4.4 Fair competition

RONDO is an active supporter of a free market economy and fair competition. With this in mind, we undertake not to enter into any agreements or arrangements with competitors that influence market prices or the availability of products and services. Any sharing of confidential information with competitors must be prevented.

4.5 Export controls and economic sanctions

RONDO respects the statutory import and export regulations of each country as well as applicable sanctions and embargoes.

4.6 Patents and intellectual property

We respect the intellectual property rights (intellectual property protected by patent, copyright and trade mark law) of our business partners and competitors.

4.7 Conflicts of interest

To protect the interests of the company and employees in equal measure, we ensure that no conflicts of interest arise between the private interests of employees and those of the company. Our employees disclose their own conflicts of interest arising from connections to competitors, customers, suppliers and service providers and consult their superiors in cases of doubt.

5 Quality, sustainability and environmental protection

We are guided by the three pillars of sustainability: Economy, ecology and social responsibility. We attach equal importance to these factors, thereby assuming responsibility towards future generations.

5.1 Quality

Products and services from RONDO are of outstanding quality and our business practices and the technologies we use are geared to the highest standards.

5.2 Resource management

We strive to continuously improve our products and services by optimising our processes, methods and use of materials. A reduction in waste and emissions (air, water, soil) and an improvement in energy efficiency are among our explicit corporate goals.

RONDO reviews its due diligence and reporting obligations regarding the use of minerals and metals from conflict and high-risk areas as well as child labour on an annual basis.

5.3 Environmental protection

We are committed to protecting and preserving the environment. We endeavour to sustainably reduce our environmental impact and actively promote environmental protection, fire prevention, and occupational health and safety. This is how we do our bit for our customers, employees, fellow citizens and future generations.

6 Governance – Compliance with principles and guidelines

6.1 Compliance with internal policies and laws

In addition to the principles set out in this Code of Conduct, RONDO has clearly defined accountability 
and signature regulations as well as target agreements. We also adhere to national and international laws, regulations and directives concerning our business activities.

6.2 Financial integrity

All business transactions must be recorded in the accounting system. Discounts and commission may only be granted within the framework of customary national conditions. We provide complete, accurate, timely and understandable information in all our financial reports. These comply with the applicable national and international regulations, laws and standards.

6.3 Data protection & information security

We exercise the utmost care and strict confidentiality when collecting, storing, processing or transmitting the personal data of employees, customers and other third parties. In the context of information security, information is used exclusively for the purpose of performing tasks related to service provision and is protected against internal and external misuse. Employees receive regular training on how to handle company data carefully and confidentially and on the current risks involved. We see this as an important contribution to maintaining business operations (business continuity management).

7 Reporting breaches

All employees are encouraged to proactively contact their line manager, the HR department or the company management if they are unsure or unclear about how to comply with these rules. Obvious breaches of this Code of Conduct must also be reported to line managers, the HR department or the company management. Our employees are aware that breaches of this global Code of Conduct and any internal regulations may result in disciplinary action, including termination of employment.

8 Enforcement of the global Code of Conduct

This global Code of Conduct has been issued by the Board of Directors. It is an integral element of the employment relationship and has been incorporated into all employee guidelines. The policy is published on the company website and is publicly accessible. Line managers are responsible for monitoring whether employees are behaving correctly and for addressing misconduct without delay. They act as role models in practising the values and principles of this Code of Conduct. The companies of the RONDO Group shall communicate the content of the global Code of Conduct to employees, contractual partners and third parties.