Supplier Code of Conduct for Oeltechnik Group of Companies Version 10/2022

This Supplier Code of Conduct applies for all vendors/suppliers of Gesellschaft fuer
Oeltechnik mbH, Oeltechnik Services GmbH and TubeTech GmbH and Oeltechnik France
(together hereinafter referred to as “OELTECHNIK”).

1.  Our Principles

1.1  At OELTECHNIK we are committed to the highest standards of labour, human rights, environmental
and ethical conduct. To ensure that these standards are not only met within the organisation, but
wherever our activities have an impact, we actively work with our business partners along the entire
value chain to further develop their sustainability performance.

As part of these efforts, we expect all our suppliers to adhere to our Supplier Code of Conduct, which is
based on the ten principles of the UN Global Compact and derived from the Universal Declaration of
Human Rights, the International Labour Organisation's Declaration on Fundamental Principles and
Rights at Work, the Rio Declaration on Environment and Development, and the United Nations
Convention against Corruption.


2.  Code Implementation

2.1   At OELTECHNIK, we want to ensure compliance with our Code of Conduct throughout our entire value
chain. To this end, we closely collaborate with our suppliers, and reserve the right to verify compliance
with the Code, as well as the information provided to us by our suppliers, through assessments and
audits. To ensure compliance at the lower tiers of our value chain, all our direct suppliers are
responsible for ensuring that this Code is adhered to by all their direct suppliers, vendors, agents, and

In case there are indications that a Supplier does not comply with this Code of Conduct, we shall work
with that Supplier to agree on a corrective action plan with a reasonable timeline that enables the
Supplier to reach full compliance with the Code of Conduct. If a Supplier has intentionally provided
false or falsified information or cannot implement the required improvements, we reserve the right to
terminate our business relationship, in which case the Supplier shall not be entitled to compensation.
All costs arising from the Supplier's compliance with this Code of Conduct shall be borne solely by the
Supplier. The Code may be revised by OELTECHNIK with due notice to Suppliers.

In this Code of Conduct, references to:

  • Export Control Laws are to all export control laws and regulations in Relevant States;
  • Relevant States include the countries of the European Union, the United States of America and
    any other countries with jurisdiction over OELTECHNIK;
  • Restricted Party List are those lists published by the Relevant States of individuals or companies
    who have breached or are of concern in relation to Sanctions;
  • Restricted List States are to such countries as from time to time appear on restricted lists
    published by the Relevant States;
  • Sanctions are to all economic, trade and financial sanctions laws, regulations, embargoes, or
    restrictive measures of any Relevant States; and
  • Supplier shall, where relevant, also include all officers and employees of the Supplier.


3.  Human and Labour Rights

3.1  At OELTECHNIK we are committed to upholding the highest standards of human and labour rights and
want to ensure that all workers in our supply chain have a fair and ethical workplace. Suppliers should
have in place a policy recognising, respecting, and protecting the human rights of their employees,
those of their own suppliers and business partners and the communities affected by their operations.
Areas covered by their policy are as follows:

  • Fair terms of employment. All workers should be provided with simple, written contracts which
    must detail the terms and conditions of their employment. Work carried out should be based on
    the applicable local recognised employment law and practice.
  • Working hours. Working hours for all workers should not be excessive and must comply with
    relevant national laws. Overtime should be voluntary. OELTECHNIK supports the requirements of
    the International Labour Organisation (ILO) and we encourage our suppliers to adhere to and
    respect the relevant ILO standards on working time.
  • Anti-discrimination. Suppliers must seek to eliminate discrimination in access to employment,
    training and working conditions, on grounds of age, disability, ethnicity, gender, marital status,
    national origin, political affiliation, race, religion, sexual orientation, gender identity, union
    membership, or any other status protected by applicable national or local law and to promote
    equality of opportunity and treatment.
  • Fair compensation. Wages and benefits should meet national standards or collective labour
    agreements, where applicable. Workers should be provided with clear written information on their
    pay and conditions and excessive deductions on wages should not be permitted as a disciplinary
    measure. All use of temporary and outsourced labour shall be within the limits of the local law. In
    case suppliers are using any third-party employment agencies they are to ensure that these are
    compliant with the provisions of this Code and the law
  • Prevention of forced labour and human trafficking. Suppliers shall comply with all applicable
    anti-slavery and human trafficking laws. Suppliers must ensure they have taken steps to ensure
    their business operations do not make use of any form of force, bonded, involuntary labour and are
    free from any kind of slavery and human trafficking practices, both, internally / within their supply
    chains and other external business relationships.
  • Prevention of underage labour. Suppliers shall not employ workers under the age of 15 years,
    the applicable minimum legal age for employment, or the applicable age for completion of
    compulsory education, whichever is highest.
  • Protection of juvenile workers. Suppliers should observe the provisions of the UN International
    Labour Organisation such that any young persons under the age of 18 should not be employed to
    work at night or for any hazardous work and their employment should not harm the young person’s
    education, health or physical, mental, moral or social development.
  • Grievance mechanisms. Suppliers must establish effective grievance reporting mechanisms that
    allow for open communication on grievances and facilitate the exchange between management and
    workers without jeopardising the worker's employment.


4.  Health and Safety

OELTECHNIK places high priority ensuring a safe and healthy work environment for all workers in the
supply chain. Our Suppliers must create and maintain a safe work environment and incorporate sound
health and safety management practices into their business, as well as giving their workers the right to
refuse unsafe work and report unhealthy working conditions.

  • Working environment. A healthy and safe working environment should be provided for all
    employees and visitors in accordance with applicable international standards and national laws.
  • Occupational health and safety management. Suppliers shall identify, evaluate, and eliminate
    potential occupational health and safety hazards through a prioritised management process of
    hazard elimination, substitution, engineering controls, administrative controls and/or personal
    protective equipment. Adequate policies and management procedures relating to health and safety
    should be in place, which are either provided to, or accessible by employees.
  • Health and safety training. Suppliers shall provide appropriate training on workplace health and
    safety to their employees.


5.  Environment

OELTECHNIK is committed to protecting the environment and promoting environmental responsibility
together with our business partners. We expect our Suppliers to develop, implement, and maintain
environmentally friendly business practices to minimise the negative impact on the environment and
natural resources.

  • Environmental Impact. Suppliers must continuously strive to identify and reduce negative
    impacts of their operations on the environment.
  • Environmental regulations and permits. Suppliers shall comply with all applicable local and
    national laws and regulations relating to the protection of the environment and shall further obtain
    and comply with all required environmental permits.
  • Resource management. Suppliers shall quantify, set targets, monitor progress, and reduce their
    consumption of fossil fuels, water, and other manufacturing and/or office materials wherever possible. To reduce their consumption of virgin materials and close resource loops, Suppliers shall also aim to increase the proportion of recycled and recyclable materials in the manufacturing of
    their products.
  • Greenhouse Gas Emissions management. Suppliers shall quantify and reduce their emissions of
    greenhouse gases through conservation, use of green energy or other measures, wherever possible.

6.  Ethics and Legal Requirements

We expect that our Suppliers operate under a code of business ethics or a similar policy that adheres
to industry best practice standards. All applicable laws, rules and regulations must be complied with,
and business should be carried out in an ethical, transparent, responsible, and respectful manner and
in a way which adheres to the highest standards of ethical conduct.

  • Anti-bribery and corruption. Suppliers must comply with all applicable anti-bribery and anticorruption laws. Suppliers must establish and maintain procedures to prevent:
    1) any offer, promise, gift, or solicitation of an advantage as an inducement or reward to a person
    for the improper performance of that person’s position or as an attempt to influence a person in
    that person’s capacity as a public official; and
    2) participation in any other form of corrupt practice (such as theft, fraud, blackmail, participation
    in a criminal organisation and money laundering) under any circumstances.
  • Responsible sourcing of conflict minerals. Suppliers which are sourcing conflict minerals shall
    develop specific due diligence processes in accordance with the OECD Due Diligence Guidance for
    Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Due diligence
    must be conducted at the material processing level to determine whether conflict materials
    originate from high-risk regions, which include areas with conflict, worst forms of child labour,
    forced labour and human trafficking, severe human rights violations, or other objectively high-risk
    activities, including severe security risks, as well as negative environmental impacts.
  • Fair trading and competition. Suppliers must comply with all applicable advertising, fair trading,
    and competition laws.
  • Disclosure of Information. Suppliers must not make any false representations or provide false
    information or data to OELTECHNIK or in connection with any transaction or work involving
    OELTECHNIK or its customers.
  • Personal Information. Suppliers must commit to protecting the reasonable privacy expectations
    in relation to the personal information of their clients, suppliers, and employees. Suppliers must
    comply with all applicable privacy and information security laws and regulatory requirements when
    personal information is collected, stored, processed, transmitted, or shared.
  • Confidentiality. Suppliers must ensure that confidential information and trade secrets obtained
    by them during business activities with OELTECHNIK are treated in strict confidentiality and are not
    disclosed to third parties.
  • Intellectual Property. Suppliers are obliged to protect OELTECHNIK’s intellectual property rights
    and not to use them for any purposes other than as authorised by OELTECHNIK during its business
    activities with the Supplier.
  • Security. Suppliers must implement and maintain security safeguards, including administrative,
    physical, and technical safeguards designed to protect its information systems from unauthorised
    access, and shall promptly inform OELTECHNIK if it believes its systems have been compromised in a
    manner that could result in any damage to OELTECHNIK.


7.  Compliance

The Supplier shall, in relation to its business with OELTECHNIK:

  • not do anything which may cause OELTECHNIK to breach Export Control Laws or Sanctions;
  • comply with all Export Control Laws and Sanctions, including clearly indicating on all delivery
    notices the relevant export control classification and export licence numbers;
  • not carry out any activities from a Restricted List State or sub-contract to any entity from a
    Restricted List State or on a Restricted Party List;
  • keep OELTECHNIK informed at all times of such information as OELTECHNIK may require
    complying with Export Control Laws and Sanctions, including details and copies of applicable
    restrictions and export classification numbers, export licences or equivalent documentation,
    exemptions or exception and conditions relating to export, transfer, or use, and provide
    OELTECHNIK with such assistance as OELTECHNIK may reasonably request in this respect; and
  • keep OELTECHNIK informed at all times of all relevant information on: (i) any changes in
    circumstances relevant to compliance with Export Control Laws and Sanctions; (ii) actual or
    potential breaches of Supplier’s obligations in relation to Export Control and Sanctions; (iii) loss,
    suspension or invalidation of any relevant licence, authorisation, approval or export control
    privileges, including by being placed on a Restricted Party List; or (iv) it becoming aware that any
    relevant authority has initiated or will initiate any investigation or proceedings against the Supplier
    relating to an actual or potential breach of any Export Control Laws or Sanctions.