Code of Conduct

concerning MILLIONS

Code of Conduct

We view it as our responsibility to ensure that defined social and environmental standards are met for the people who purchase our products and those that are part of production and distribution.

These standards are exactly defined in our Code of Conduct. The Code of Conduct is not negotiable and all of our suppliers and their sub-suppliers must adhere to it without exception. Important aspects included in the Code of Conduct are health and occupational safety, fair compensation and work times. We do not accept discrimination, child and forced labor. The AstorMueller group monitors the adherence of the requirements through systematic, unannounced inspections.

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1. Child labor

Child labor is any labor that is performed by a person under the age of 15, except if the local legislation requests a higher minimum age for the labor force or a longer duration of the compulsory school attendance. The higher age is applicable in this case. However, if the legal minimum age for exceptions specified in the ILO convention 138 for developing countries is 14 years, then the lower age is applicable. A "young worker" is any person who is older than a child in accordance with the definitions above and younger than 18 years.

a) The supplier is not permitted to use or tolerate child labor as defined above.

b) The supplier must implement, document and adhere to methods and procedures which are used to advance children (this includes: all required supportive actions and activities to guarantee the health, education and development of children who were victims of child labor in accordance with the above definition and who were released from it) who were in a work situation equivalent to the above definition of child labor and must communicate these to its personnel and other interested persons.

The supplier must permit such children an adequate support to attend school long enough so that they are no longer children in accordance with the above definition.

c) The supplier must implement, document and adhere to methods and procedures which advance the education of children and young workers affected by the ILO recommendation 146 who are subject to compulsory school attendance or who attend school and must communicate these to its personnel and other interested persons.  This includes measures that guarantee that no child or young worker is working during teaching time and that the total time spent daily for transport (trips from and to work and school), school and work does not exceed 10 hours daily.

d) The supplier must not subject young workers at or outside the work place to situations that are hazardous, unsafe or unhealthy.

2. Forced labor

Forced labor is any kind of work or service requested from a person under the threat of force and for which the person in question does not volunteer.

The supplier must not use or tolerate any forced labor including debt bondage and prison labor. When employees are hired, the supplier is not permitted to request a security deposit or request the handover of personal documents.

The supplier must not to exert bodily, sexual, psychological or verbal harassment or abuse or tolerate their existence.

3. Discrimination

The supplier must especially not discriminate against persons when hiring or for compensation, education, promotion, lay-off or retirement based on their race, social class, national origin, religion, disability, sexual orientation, membership in an association, political affiliation or their gender or to tolerate such a discrimination.

The supplier must not hinder the employees when exercising their rights, when following teachings or behaviors or when satisfying needs that are related to race, social class, national  origin, religion, disability, sexual orientation, membership in an association or political affiliation.

The supplier must not tolerate behavior including gestures, verbal expressions or physical contacts that imply sexual assault, threat, abuse or exploitation.

The agreed maternity protection before and after birth must be granted to female employees. Employees must not be laid off due to pregnancy. Pregnant employees must not be assigned to work in places that impact their health status.

4. Compensation

Employees have a right to a written contract of employment that regulates at a minimum the following items: start of the work, work hours, compensation, vacation entitlement, protection against unfair dismissal, maternity protection.

The supplier must guarantee that the wages paid for a standard work week are at least in accordance with the legal standards and that they are in all cases adequate to satisfy the basic needs of the personnel and that guarantee a certain disposable income.

The supplier must guarantee that wage deductions for disciplinary reasons are not possible and that the exact composition of wages and benefits are frequently explained in detail to the workers.

The supplier must also guarantee that the wages and benefits are paid in full compliance with all applicable laws and that the compensation is paid either in cash or through a check in a way that is favorable to the worker.

The supplier must guarantee that the sub-contracting of manpower or faked apprenticeship relationships are not used to circumvent the supplier's obligations against the personnel in accordance with the applicable law of the work and social security insurance legislation and respective regulations.

5. Work hours

The supplier must adhere to the applicable laws and industry standards with respect to work hours. Under no circumstances must the employees be asked to regularly work more than 48 hours per week. At least one free day must be granted for any 7 day period.

If the supplier requests overtime (more than the 48 hour standard work hours per week), then the supplier must ensure that these work hours are always compensated using a premium rate. Overtime must always be provided voluntarily by the employees.

6. Freedom of association / collective bargaining

The supplier must tolerate the right of all employees to establish employee associations of their choice, to join these and to perform collective bargaining.

In situations in which the right for freedom of association and collective bargaining is legally restricted, the supplier must enable the employees to find comparable ways to independent and free associations and negotiations.

The supplier must guarantee that the employee representatives are not discriminated against and that these employee representatives can contact their members at the work place.

7. Health and safety

The supplier must guarantee a safe, clean and healthy work environment assumed that the supplier best knows the industry and possible special risks. The supplier must take appropriate actions to prevent accidents or health related damages that are a result of the work, are in connection to the work or that occur during the work by minimizing the cause(s) of hazard(s) that are inherent in the work environment.

The supplier must assign a representative of the management board who is responsible for the health and safety of the entire personnel and who is responsible for the fulfillment of the health and safety elements of this directive.

The supplier must guarantee that the personnel will receive an approved and documented health and safety training and that this training will be repeated for all new and re-hired employees.

The supplier must provide for the entire personnel clean sanitary facilities, access to clean drinking water and possibly hygienic options for the storage of food.

The supplier must ensure that all sleeping accommodation, if these are made available to the personnel, are clean and safe and that they are in accordance with the basic needs of the personnel.

8. Environmental protection

The supplier must adhere to all applicable environmental laws and regulations of the country in which the supplier is active.

The supplier must run its business in such a way that natural resources are used as efficiently as possible.

Hazardous substances should, wherever possible, only be used in a restricted manner. They must only be used if they are used correctly and if the environment is not damaged due to their use.

The environmentally compatible disposal of waste and containers must be guaranteed and, on request, it must be possible to verify this. The entire waste generated during production must be disposed of in a correct manner.

9. Obligations of the supplier

The supplier must take clear actions to fulfill the requirements of this directive, to integrate the directive in all of its operational processes and to make it an integral part of its company philosophy and policy.

Within its organization, the supplier must assign the responsibilities for all matters that concern this Code of Conduct to a manager.

The company management of the supplier must review in frequent intervals the implementation of the requirements in this directive.

The supplier accepts the responsibility for the adherence to the requirements of this directive with respect to all salaried and hourly personnel for which it has a supervisory function and the supplier agrees

a) at each location that the supplier owns or manages, to assign the responsibility for the implementation of this directive to somebody

b) to ensure that all salaried and hourly employees know this directive by communicating the content in a comprehensible manner. Training about the Code of Conduct must be performed frequently

c) to forbear disciplinary measures, lay-offs or other discriminations of such employees who deliver information about the adherence to this directive.

Through appropriate reports, the supplier must provide proof that the supplier is in conformance with the requirements of this directive. The supplier must be in a position to provide access to the recordings and to provide adequate information to the parties assigned by the AstorMueller group, which must check the adherence to the requirements.

The supplier must make the adherence to this Code of Conduct a condition that is included in all agreements that will be established with sub-suppliers. These agreements must obligate the sub-suppliers to be in accordance with all requirements of this directive (including this clause) and on request to contribute to all control activities of the supplier.

10. Management systems / review and monitoring

We can assign independent reviewers, who conduct social and environmental reviews on behalf of the AstorMueller group, to assess the adherence to this Code of Conduct.

We have the right to monitor adherence to this Code of Conduct through systematic, unannounced inspections. The inspections will be performed by members of the AstorMueller group or independent reviewers.

The AstorMueller group's Code of Conduct sets the standards and we expect that our partners adhere to them when operating their factories. We are aware that some of these relatively high expectations cannot be fulfilled immediately.

In case of non-fulfillment, it is important for the AstorMueller group that the supplier takes all correcting steps necessary to improve the situation and to fulfill the requirements within an adequate time.

The time related postponement depends on the type of the correcting actions. We will be forced to terminate the cooperation with this supplier in case of repeated non-compliance without an effort by the supplier to implement corrective steps.