Code of Conduct for business partners of

Brandenburgische Kondensatoren Technologie GmbH

0 Preamble

Brandenburgische Kondensatoren Technologie GmbH (BKT) considers itself as part of an internationally integrated economy and is part of the civil society as a company at its location in Prenzlau. BKT complies with national and international laws and acts as a company according to the basic understanding of the honourable businessman and is committed to its economical, ecological and social responsibility.

BKT monitors the direct and indirect effects of its business activities on the environment and on society and endeavours to achieve an appropriate balance between economic, ecological and social concerns.
BKT acts in accordance with generally accepted values and principles, complies with the law and especially observes internationally recognised human rights and labour standards.
BKT stands for the objectives and contents of the Code of Conduct and will make all appropriate and reasonable efforts within the scope of its respective legal and actual possibilities to fulfil the voluntary commitment on an ongoing basis at all its company locations.

If existing national regulations contradict the contents of the Code of Conduct or if the national context makes it impossible to comply with them without restriction, BKT will look for ways to fulfil the requirements of the Code of Conduct as far as possible.

1 Scope of application

This Code of Conduct for business partners is an important part of the business relationship with BKT. It applies to all business partners, in particular suppliers, service providers and customers. For the sake of simplicity, the collective term “business partner” is used in this document. BKT expects its business partners to implement the requirements of this Code of Conduct in their own supply chain.

2 Corporate understanding

2.1 Moral commitment and integrity

BKT pursues only lawful business objectives and practices and maintains business relationships only with reputable partners. BKT behaves fairly and respectfully towards business partners. BKT respects different legal, economic, social and cultural backgrounds and the special circumstances of the countries and regions in which BKT operates. BKT respects the laws of the countries and regions in which business activities take place. BKT always bases its business activities on universal ethical values and principles, including integrity and respect for human dignity. BKT builds on free and fair world trade.

2.2 Corruption, trade control, money laundering

BKT rejects all forms of bribery and corruption. Thus, BKT avoids even the appearance of such behaviour – be it in the form of granting or accepting unfair advantages. BKT acts in accordance with the applicable import and export control regulations and complies with the legal requirements for the prevention of money laundering and terrorist financing.

2.3 Fair competition

BKT advocates free and fair competition. BKT does not tolerate any anti-competitive agreements and ensures that the company acts in accordance with the applicable antitrust laws. BKT rejects competitive advantages through unfair business practices.

2.4 Handling of personal data, Protection of confidential information and intellectual property

BKT respects the personal rights of its employees and business partners and complies with the applicable legal and regulatory requirements for the processing of personal data and information security when handling personal information. BKT protects entrusted business secrets and other confidential information of its business partners from unauthorised acquisition, use and disclosure, at the minimum in accordance with the relevant statutory provisions for the protection of business secrets. BKT respects the intellectual property of its business partners and other third parties and ensures that sufficient precautions are taken to protect intellectual property rights when exchanging know-how and technologies.

2.5 Ecological responsibility and obligation

The protection and preservation of the natural foundations of life concerns and obliges us all. Thus, BKT conducts its business activities in an ecologically responsible manner and is committed to the goal of a climate-neutral future.

2.6 Protection of the environment and climate

BKT fulfils its ecological responsibility by applying the applicable legal requirements and recognised standards for the protection of the environment and climate. BKT works in accordance with the ISO 14001 environmental management system to continuously reduce the negative impact of its business activities on the environment and climate. BKT applies applicable law and takes appropriate measures that are based on statutory internationally recognised standards and cover the following topics, among others:

proper and professional handling of hazardous substances, chemicals and waste, including their disposal
measures to reduce or avoid waste
minimising emissions through operational processes
conserving natural ressources, for example through measures to save water, chemicals and other raw materials, an promoting the circular economy
use of climate and environmentally friendly technologies, processes, raw materials and products
measures to increase energy efficiency and the proportion of renewable energies in energy consumption at the company locations

2.7 Animal and species protection

BKT observes the principles for the protection of biological diversity and aligns its corporate actions accordingly. The Washington Convention on International Trade in Endangered Species of Wild Fauna and Flora serves as a guideline here.

2.8 Human rights and labour standards

Human dignity is inviolable. BKT therefore respects the internationally recognised human rights set out in the United Nations Universal Declaration of Human Rights. BKT is guided by the internationally recognised labour standards of the International Labour Organisation, as set out below in this Code of Conduct. In all its business activities, BKT endeavours to neither cause nor contribute to human rights violations. BKT expects the same from its business partners. Where necessary and possible, BKT supports its business partners in this endeavour.

2.9 Employment relationships

BKT treats its employees with respect. BKT rejects any form of unlawful punishment, abuse, harassment, intimidation or other unworthy treatment of employees. BKT applies the applicable labour law to all employment relationships and expects the same from its business partners. At the beginning of the employment relationship, employees must be provided with comprehensible information about the essential working conditions, including their rights and obligations, working hours, remuneration as well as payment and accounting modalities. BKT respects and protects the right of employees to terminate their employment relationship in compliance with the relevant notice period.

2.10 Rejection of child labour and protection of young workers

BKT does not tolerate child labour and observes the applicable legal minimum age for employment. In any case, BKT does not employ persons under the age at which compulsory education ends according to the law of the place of employment, and under the age of 15. Internships are organised in accordance with legal requirements. BKT expects its business partners to have appropriate means of determining age to prevent child labour. If child labour is detected, all necessary measures must be taken immediately to focus on the welfare, protection and development of the child. In case of persons under the age of 18, the rights of young workers must be observed.

2.11 Rejection of forced labour

BKT rejects forced or compulsory labour in any form. This also applies to any form of debt bondage, serfdom, slavery or slavery-like practices, human trafficking and extends to all forms of involuntary labour and services that are incompatible with internationally recognised labour and social standards.

2.12 Principles of remuneration

BKT ensures that the applicable industry standard wage is paid to all employees of the company. Legally unauthorised wage deductions, including wage deductions as a disciplinary measure, will not be tolerated by BKT.

2.13 Working hours

BKT applies the statutory or applicable collective labour agreement provisions on working hours, including overtime, rest breaks and holidays. BKT ensures that the regular weekly working hours plus maximum possible overtime are not exceeded and that the working time regulations are complied with.

2.14 Diversity and inclusion, Non-discimination

BKT values the diversity of its employees and promotes a working environment that enables inclusion. BKT is therefore committed to equal opportunities and rejects any form of discrimination and unequal treatment based on national and ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion or ideology. BKT lives by the principle of equal pay for male and female workers for work of equal value.

2.15 Health and safety in the workplace

BKT complies with national and international occupational health and safety standards. BKT ensures a safe and healthy working environment (avoiding accidents, injuries and work-related illnesses) to maintain the safety and health of its employees and third parties.

3 Compliance with and implementation of expectations

This Code of Conduct for business partners is of central importance to BKT. Compliance with its provisions is considered essential for business relationships. BKT’s business partners recognise the expectations set out in this document and undertake to comply with them.

The business partners must endeavour to ensure that their subcontractors and sub-suppliers are also aware of the contents of this Code of Conduct, apply it to their respective companies or comply with corresponding behavioural guidelines. In order to preventively ensure compliance with our expectations and obligations, we require the active participation of our business partners, for example by providing all information that is relevant for the risk assessment of the relationship between BKT and the business partner concerned.

If the risk analysis carried out by BKT shows that the business partner concerned must take preventive measures (e. g. training, adjustment of procurement strategies, obtaining contractual assurances or controls) or remedial measures regarding our expectations and obligations, the business partners must implement such preventive or remedial measures deemed necessary by BKT in an appropriate manner immediately upon request by BKT.

BKT reserves the right to review compliance with the above expectations of its business partners and its human rights and environmental obligations on a regular basis, but not more frequently than once a year, and also on an ad hoc basis by means of audits and/or other appropriate measures. The review itself may be carried out by employees of BKT or by authorised third parties. BKT will carry out each audit with due notice and during the business hours of the business partners. Business partners are expected to grant access to all required areas, documents and data records. If a business partner violates the described expectations or obligations, BKT may set a reasonable deadline for the business partner to end the violation and/or otherwise remedy the situation. The period shall be at least four weeks, unless a shorter period is required to protect the life, body or health of a person.

After unsuccessful expiry of the deadline, BKT may terminate individual or all contracts with the business partner concerned.

Training and well-established internal processes are essential for compliance with the expectations set out above. The business partner is responsible for training measures. The business partner warrants that its business activities are in accordance with the statutory and other legal provisions applicable to it and with the contractual agreements made with BKT. The business partner also warrants that it has taken sufficient organisational measures in its company to ensure compliance with the expections and obligations described here.

This Code of Conduct for business partners is subject to German law. The United Nations Convention on Contracts for the International Sale of Goods (CISG) is hereby excluded.