Code of Conduct


Code of Conduct

content

 

1. Introduction

2. Working Conditions and Human Rights

2.1 Provisions for Upholding Human Rights 2.2 Working Conditions at Balzer & Co GmbH

3. Occupational Health and Safety

3.1 Workplace Conditions and Environment 3.2 Accident and Incident Management

4. Corporate Ethics

4.1 Interactions with Business Partners and Third Parties

4.2 Conflicts of Interest

4.3 Transparent Handling and Protection of Information

4.4 Plagiarism and Intellectual Property

5. Environmental Protection

5.1 Management of Natural Resources

5.2 Chemicals and Hazardous Substances

Scope and Implementation Preface from Management


Foreword by the management


At Balzer, we strive for exemplary quality in our products and processes, as well as in our behavior. Our corporate values form the foundation for this. We firmly believe that respecting and upholding our Balzer values will continue to be the basis for our success in the future. Committed to these Balzer business principles, we have established rules and procedures within our company to ensure that we can meet these high expectations we set for ourselves. These rules and procedures are continuously reviewed and adjusted to comply with current legal requirements. They are accessible to all employees.

These principles are thematically divided into:

- Policies on Working Conditions and Human Rights

- Policies on Occupational Health and Safety

- Policies on Corporate Ethics

- Policies on Environmental Protection 

These policies are summarized in our Code of Conduct, adherence to which we also require from all our business partners. The following policy on Working Conditions and Human Rights provides a detailed overview of the key principles for us regarding the adherence to human rights and working conditions at Balzer & Co GmbH. Strict compliance with these rules is fundamental to our principles of good corporate governance, and therefore, we commit ourselves and all our employees to uphold them.


Joachim Balzer

CEO

1 Introduction   

The trust of our customers, suppliers, business partners, and the public in our company significantly depends on the behavior of each individual employee. The foundation of this trust is the continuous respect for laws and regulations as well as all of our internal company rules. In return, we ask all business partners to comply with these rules as well. Balzer & Co GmbH is aware of its responsibility towards society and acts accordingly. We recognize the shared responsibility of the company and our employees for the common good. Therefore, this Code of Conduct summarizes the most important rules and continues the long-established culture of honesty and integrity. At the same time, it provides every employee with a guideline to support them in their responsible actions shaped by the interests of the company. This self-responsibility is both a right and a duty. Every employee is responsible for ensuring that their behavior always complies with the rules summarized here. We require our leaders, due to their exemplary role, not only to communicate these rules but also to embody them themselves and to enforce them among their employees. Our leaders are the first point of contact for their employees on all matters related to this Code of Conduct. As a general rule, we comply with the laws of the countries in which we operate. This aligns with our fundamental values and applies regardless of threatened penalties. Illegal actions are not in the interest of our company because they are unethical, lead to significant reputational loss, and may result in prosecution, compensation claims, and loss of contracts. Employees who act unlawfully must be aware that they themselves are at risk of prosecution. Therefore, compliant behavior serves to protect the employee themselves. Every employee is therefore obligated to inform themselves about the regulations applicable in their area of responsibility and to comply with them. In case of doubt, the supervisor should be consulted for clarification.


2. Working conditions and human rights   

Balzer & Co GmbH is aware of its responsibility towards society and acts accordingly. We recognize the shared responsibility of the company and our employees for the common good. For this reason, we commit ourselves to the Universal Declaration of Human Rights of the United Nations and actively advocate for their compliance. Balzer & Co GmbH maintains close contact with its suppliers on issues of adherence to and sustainability of human rights and working conditions, even in the countries of production. Due to the company size of under 50 employees and the always short pathways to management, the company has not yet established a documented procedure for violations concerning human rights and working conditions. However, Balzer & Co GmbH has proactively developed a complaint management procedure in anticipation of such incidents

2.1 Human Rights Compliance Provisions

We therefore maintain a zero-tolerance policy regarding the use of child labor, forced or compulsory labor, human trafficking, as well as harassment and discrimination. Should a violation of any of the following regulations become known by one of our employees or business partners, immediate and summary termination or dissolution of the employment or business relationship will follow. To ensure compliance with human rights, the following principles apply to us. 

2.1.1 Complaint Management Procedure   

Excerpt from our updated employment contracts, which guarantees every employee the opportunity to lodge a complaint without subsequent retaliation against the complainant: **§ 19 Company Complaint System

For general as well as individual complaints, such as:

- Constant time pressure

- Overload due to workload (many overtime hours)

- Rigid work schedule

- Poor work organization

- Shift work

- Conflicts with colleagues (bullying)

- Conflicts with superiors (bossing)

- Resulting psychological burdens

- Poor ergonomic conditions at the workplace

- Violations of human rights

- Violations of working conditions

Any employee can contact our Human Resources department. Balzer guarantees the strictest confidentiality and commits to complete abstention from retaliation against the complainant. Balzer & Co GmbH takes all anonymous complaints seriously in every case.

2.1.2 Child Labor and Young Workers  

Child labor is not tolerated by us. Any activity that could endanger the development of young employees is prohibited.

2.1.3  Forced or Compulsory Labor and Human Trafficking 

All activities in our work environment are carried out by our employees voluntarily and without coercion or threat of punishment. Forced labor, debt bondage, involuntary prison labor, slavery, or human trafficking should not be used by any company and are strictly condemned by us.

2.1.4 Harassment   

We respect and protect the dignity of our employees and treat them with respect. We advocate that all employees can work in an environment free from sexual, psychological, and physical harassment. 

2.1.5 Non-Discrimination 

We offer equal opportunities for all employees and fundamentally do not tolerate any form of discrimination based on ethnic origin, national and social origin, gender, religion or belief, political opinion, disability, age, sexual identity, or any other reasons.

2.2 Working conditions at Balzer & Co GmbH   

Productivity and humanity are together essential for sustainable corporate success. The economic success of Balzer can only be ensured by and with our employees. For this reason, the following regulations apply. 

2.2.1 Wages and benefits

Working hours, wages, salaries, social benefits, and other claims arising from the employment relationship will be settled by us in accordance with the legal regulations after the end of each pay period. The statutory minimum wage must never be undercut. All overtime is performed voluntarily by the employee and compensated accordingly. The weekly maximum working hours must be observed.

2.2.2 Freedom of Association and Assembly   

We respect our employees' right to freedom of association and collective bargaining, as well as the right to form interest groups. An employee must not suffer any disadvantages as a result of membership in a trade union.


3. Occupational health and safety   


The protection of our employees is our top priority. For this reason, we have established extensive regulations on occupational safety that are regularly trained. Every leader is responsible for knowing the safety regulations and for instructing their employees accordingly or ensuring their instruction by third parties. All employees are equally responsible for ensuring compliance. For more detailed information on occupational safety, please refer to the Occupational Health and Safety Policy.

3.1 Workplace Conditions and Environment

We ensure a safe and healthy working environment. This includes in particular the following fields of action.

3.1.1  Use of Operating Resources

As a precaution against workplace accidents, all operational facilities and equipment may only be used for the corresponding official purposes unless private use is expressly permitted. All facilities must be handled responsibly to protect material and immaterial assets and ensure their safety.   

3.1.2 Workplace ergonomics   

In addition, we set up all workplaces according to legal, safety and occupational health regulations, so that the work can be carried out accident-free and with little stress. 

3.1.3 Health Promotion   

We support this by providing ergonomic aids and protective equipment as well as preventive programs and health promotion measures that maintain and promote the health, performance and job satisfaction of our employees. 

3.2 Accident and Incident Management   

Our accident and incident management is primarily based on the principle of prevention. In addition to the aforementioned regulations for the direct occupational health and safety protection of our employees, this primarily includes protection against fire, accidents and toxic substances.

3.2.1 Emergency Preparedness

On the one hand, we achieve protection through preventive measures. This includes clear work instructions and regulations for accident prevention. These are supported by various technical facilities. On the other hand, we achieve this protection through regular emergency training as part of our annual occupational safety training, which all employees must attend. 

3.2.2 Accident Reporting   

Should an accident at work or other disruptions nevertheless occur, this must be reported and documented immediately. The accident report must contain the course of the accident, the consequences of the accident, the cause of the accident and the planned measures to avoid similar accidents in the future. These measures should be implemented as soon as possible. 

3.2.3 Fire safety 

Behavior in the event of a fire is also taken into account in the safety briefing. In addition, trained fire protection assistants are appointed to support our employees with questions. All of our facilities and systems are designed to minimize the risk of fire.

4. Business Ethics

In addition to the high quality of our products and services, a high level of professionalism and absolute integrity is a fundamental requirement. It is therefore of the utmost importance to us that business decisions are always based on objective criteria such as quality, reliability, competitiveness and taking into account recognized compliance standards and the meet the principles of good corporate governance.

4.1 Dealing with Business Partners and Third Parties
4.1.1 Corruption, Extortion and Bribery   We have zero tolerance for all forms of bribery, corruption, extortion and embezzlement that constitute an abuse of power for personal gain or to distort competition. 

4.1.2 Fair Competition   

We observe the rules of fair competition and support all efforts to enforce a free market and open competition nationally and internationally. We therefore refrain from any order that can only be obtained by violating laws or other relevant regulations. In particular, agreeing on prices and conditions, dividing up markets and regions, allocating customers and coordinating supply, development or production strategies and coordinated behavior are prohibited.
4.1.3 Money Laundering

We ensure that the applicable legal provisions against money laundering, i.e. the smuggling of illegally earned money or illegally acquired assets into the legal financial and economic cycle, are observed. 

4.1.4 Export Controls and Economic Sanctions 

We comply with all applicable import and export control laws, sanctions and embargoes that place restrictions on exporting or re-exporting to certain destination countries and prohibitions on transactions involving certain countries, regions, organizations and individuals.

4.2 Conflicts of Interest   

We strictly separate business and private interests. We make our decisions on the basis of a solid factual judgement, which is not clouded by favoritism resulting from personal relationships and opinions. Business partners must not be given preference in business decisions out of private interest. In addition, our employees do not use their work at Balzer to obtain private benefits. Secondary business activities require the prior approval of the management. 

4.3 Transparency in Handling and Protection of Information   

4.3.1 Financial Responsibility   

We document all essential business transactions in a comprehensible and timely manner. Financial records are to be prepared in accordance with applicable law and generally accepted principles of proper accounting. Internal and external reports must be correct and complete so that the recipient can get an accurate picture. Documents needed for internal investigations or government investigations may not be destroyed, removed, or altered. 

4.3.2 Disclosure of Information   

Accordingly, we disclose information in accordance with applicable regulations and standard industry practice. 
4.3.3 Privacy   

We only use the personal data of our employees and contractors for the purposes for which they were made available to us and treat them confidentially. We also appropriately use and protect non-personal data resulting from a business relationship. With our data protection guidelines, we also ensure that data worthy of protection is collected, processed, secured and deleted appropriately. Confidential content will under no circumstances be published without authorization, passed on to third parties or made available in any other form.

4.3.4 Preserving Identity and Protection Against Retaliation

We are also particularly committed to protecting against retaliation and protecting the identity of any employee, business partner or other third party who reports known or suspected misconduct or violations. The reporting of violations or suspected cases must under no circumstances result in negative or repressive measures for the reporting party. 

4.3.5 Patents and Trade Secrets   

The constant further development of our proprietary technologies and improvements in our know-how is of crucial importance for maintaining our competitiveness. No employee or business partner may therefore pass on new findings, confidential information or business secrets to third parties in any form. This also applies after the termination of the employment or business relationship. 

4.4 Counterfeiting and Intellectual Property   

The market success of our products and services is inextricably linked to their quality. Our motto "Quality is the basis of our success" places high demands on all employees in terms of creativity, diligence, orderliness and precision. We do not tolerate deliberate or negligent behavior that results in a reduction in our quality. For this reason, the use of Plagiarism or falsification of materials is prohibited.In addition, we respect intellectual property and will not make unauthorized use or disclosure of intellectual property, especially intellectual property protected by patents, copyrights or trademarks.


5. Environmental protection   

By environmental protection we understand the protection of all natural resources, such as water, air or energy. This includes the following principles, compliance with which is the central task of every employee. But we also demand compliance with these standards from our business partners: 

• Compliance with relevant environmental regulations, standards and threshold values, 

• protection of environmental elements from harmful effects, 

• Avoidance or prevention of environmental damage, 

• minimizing the amount and hazardousness of waste,

• Minimization of material and energy consumption. 

5.1 Management of natural resources   

5.1.1 Energy efficiency and resource consumption   

In all work and activities, we try to keep the consumption of energy and other resources as low as possible. This also applies to all external companies that work in our company. In particular, this applies to air pollution control, the minimization of greenhouse emissions and water protection. In order to rule out environmental pollution, all machines and vehicles are always kept in perfect technical condition. 

5.1.2 Waste prevention   

All processes are designed to waste as few resources as possible and thus keep waste to a minimum. We also use renewable energy and recycled resources, further reducing the waste generated by our operations.

5.2 Chemicals and Hazardous Substances   

Chemicals and hazardous materials that pose a hazard if released into the environment must be used responsibly and in compliance with applicable government regulations. Above all, this includes correct identification and ensuring the safety of employees and the environment in handling, storage, use, reuse and disposal. Employees who come into contact with chemicals or hazardous substances are therefore instructed accordingly. It is the duty of all employees and business partners to avoid any risk to the environment.


Scope and Implementation   

This code of conduct is binding for all employees of Balzer & Co GmbH. Our managers have a special responsibility. They are called upon to exemplify the rules of conduct and values of Balzer described in this code and are the first point of contact for questions from their employees about the correct behavior in individual cases. They are also responsible for ensuring compliance with this Code in their area of responsibility. We also require all business partners to comply with the Code. Questions about this code or correct behavior in individual cases will be answered by the respective superior or the management. Violations of this Code will not be tolerated and will result in disciplinary action. These range from warnings to termination of the employment or business relationship. All indications of such violations will be investigated. In the case of information given in good faith, confidential treatment of the person giving the information is promised.

Balzer & Co GmbH

Lower Meadows 1

D-76669 Bad Schoenborn

Phone: +49 7253 80294-10

Fax: +49 7253 32830

info@balzer-co.de

www.balzer-co.de

Status: 08/2022

* For reasons of better readability, the simultaneous use of the language forms male, female and diverse (m/f/d) in the text is avoided.

All personal designations apply equally to all genders.