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Supplier Code of Conduct

(Version 1.0)

Hako GmbH
Hamburger Straße 209-239
23843 Bad Oldesloe

Table of Contents
I. Preambel
II. Social Responsibility
III. Climate and Environmental Protection
IV. Ethics
V. Governance


I. Preambel
Hako is committed to ecologically and socially responsible corporate governance. We take responsibility
for our decisions, for our actions, for our products and services. We expect the same behaviour and
sense of responsibility from our suppliers. We also expect our own employees1 to observe the principles
of ecological, social and ethical conduct and to integrate them into our corporate culture. We strive to
continuously improve our business activities as well as our products and services in terms of
We can only fulfill our responsibility together with our business partners. We therefore expect our
suppliers to also accept this responsibility and to implement this commitment upstream in the supply
chain. In this context, we must accept that not all suppliers can directly and/or fully comply with our
supplier Code of Conduct. This applies in particular to those suppliers in the supply chain who are based
in countries in which compliance with individual requirements (e.g. freedom of association) is not
permitted by law. Irrespective of this, we work to ensure that the respective legal minimum standards
are complied with. We do not exclude the termination of a business relationship as the last possible
This Supplier Code of Conduct is based on national laws and regulations such as the German
Lieferkettensorgfaltspflichtengesetz (LkSG) as well as international conventions such as the Universal
Declaration of Human Rights of the United Nations and the International Labour Standards of the
International Labour Organization (ILO).
The Hako Supplier Code of Conduct subsequently defines the minimum requirements that must be met
in order to comply with our standards.

II. Social Responsibility
Suppliers shall respect the human rights of their employees, local communities and vulnerable people
and treat them with dignity and respect. They shall take reasonable precautions for the health and safety
of their employees, customers, visitors, contractors and others who may be affected by their operations.
This includes the following:
II.1 Exclusion of Forced Labour
Hako has a zero tolerance policy towards any form of modern slavery, servitude or bonded labour, and
forced or compulsory labour, as well as any form of human trafficking in its supply chain. All work must
be voluntary and without threat of punishment. Employees must be able to leave work or employment
at any time. There must be no unacceptable treatment of workers, such as psychological hardship,
sexual and personal harassment and humiliation. The hiring or use of security guards shall be refrained
from if, in the course of their employment, persons are treated or injured in an inhumane or degrading
manner or if freedom of association is impaired.
1 We understand employees to be all personnel employed by or deployed by a supplier.
II.2 Prohibition of Child Labour
Hako does not tolerate child labour in its supply chain. Suppliers are required to prevent any kind of
child labour as defined in the core labour standards of the International Labour Organization in their
operational work processes. In cases where young workers are employed, they must not perform
activities that are mentally, physically, socially or morally harmful or that interfere with their schooling.
II.3 Working Hours, Wages and other Benefits
The working hours of the suppliers' employees should not exceed the maximum working hours
according to the applicable laws and ILO standards. Overtime shall be worked on a voluntary basis.
Suppliers shall respect the right of their employees to rest and leisure time to balance their professional
and private lives.
Compensation must be paid regularly, on time, and in full in accordance with national law. Deductions
from wages as punitive measures are not permitted. Compensation and other benefits should be fair, in
line with market conditions, and equal for all employees, and should provide employees and their
families with an adequate standard of living.
II.4 Freedom of Association
In accordance with local laws, suppliers must respect the right of employees to associate freely, form
and join trade unions, appoint employee representation, form a works council and actively participate in
collective bargaining. Employees shall not be discriminated against on the basis of forming, joining or
being a member of such an organization.
II.5 Prohibition of Discrimination
Equal treatment of all employees must be a fundamental principle of the suppliers' corporate policy. Any
kind of discrimination is prohibited unless it is justified in the requirements of employment. This applies,
for example, to discrimination based on gender, age, ethical origin, skin colour, disability, origin and
ideology, religion, pregnancy or sexual origin or on other criteria that are unlawful under applicable law.
II.6 Health and Safety
Suppliers are responsible for a safe and healthy working environment. By implementing appropriate
occupational safety systems, necessary precautionary measures are taken against accidents and
damage to health that may arise in connection with the activity. Physically demanding activities and
conditions in the workplace, as well as risks arising from the use of the infrastructure available in the
workplace, must be managed in such a way that employees are protected from hazards.
Safety information about identified workplace risks or hazardous materials including components in
intermediates must be provided to employees for awareness, training, and protection from hazards.
Minimum requirements for a safe and healthy work environment include the provision of potable water,
adequate lighting, appropriate room temperature, good ventilation and sanitation.
II.7 Preservation of the Natural Foundation of Live
Suppliers shall not deprive land, forests or waters, the use of which secures the livelihood of persons,
in violation of legitimate rights. Harmful soil alteration, water and air pollution, noise emissions and
excessive water consumption shall be refrained from if this damages the health of persons, significantly
impairs the natural basis for the production of food or prevents the access of persons to clean drinking
water or to proper sanitary facilities.
II.8 Complaint Mechanism
Hako has implemented a complaints procedure. Suppliers shall inform their employees about the
existence of this grievance procedure in an appropriate manner and provide them with unrestricted
access to the procedure. To the extent that no notice is given, the supplier itself is responsible at the
plant level for establishing an effective grievance mechanism for individuals and communities that may
be affected by negative impacts.
II.9 Dealing with Confilct Minerals
For the conflict materials tin, tungsten, tantalum and gold, as well as for other raw materials such as
cobalt, the supplier shall establish processes in accordance with the Organization for Economic
Cooperation and Development (OECD) guiding principles on due diligence to promote ressponsible
supply chains for minerals from conflict and high-risk areas. Smelters and refiners without adequate,
audited due diligence processes shall be avoided.

III. Climate and Environmental Protection
Suppliers shall act in an ecologically responsible and resource-efficient manner. This comprises the
following aspects:
III.1 Careful Use of Ressources
Suppliers preserve and protect natural resources, e.g. energy sources, water, forests, soil and raw
materials. They prevent the exploitation, destruction or neglect of natural resources. Likewise, suppliers
shall make commercially reasonable efforts to minimize the generation of exhaust gases, wastewater,
waste, noise and light pollution.
Suppliers shall use their best efforts to ensure that their business activities do not impact natural
resources in a way that significantly affects food production, deprives people of access to clean drinking
water, or harms human health.
III.2 Energy Consumption and Renewable Energy
Suppliers shall make reasonable efforts to meet their purchased energy needs from renewable energy
sources whenever possible. They shall use their best efforts to increase the overall use of renewable
energy from year to year.
Suppliers shall make reasonable efforts to improve energy efficiency in their operations and reduce
energy consumption through appropriate management systems.
III.3 Water Use
Suppliers shall make reasonable efforts to reduce water consumption in their own operations and in
their value chain.
Suppliers shall make reasonable efforts to monitor the use, quality and discharge of water at their sites.
They shall use their best efforts to continuously improve water reuse, water treatment, water use
reduction and wastewater treatment.
III.4 Waste, Waste Water, Local Air Emissions, Noise and Light Pollution
Pollution of soil, air and water as well as noise and light pollution shall be avoided. Suppliers shall use
their best efforts to ensure that the handling, storage, transportation, reuse, recycling and disposal of all
types of waste and waste water are carried out safely and in accordance with regulations.
Suppliers shall pay special attention to the handling of substances containing mercury or which are
persistent organic pollutants (POP`s), as well as to the handling of waste, waste gas and waste water
which may contain mercury or POP`s. Suppliers shall handle these substances in accordance with the
provisions of the Minamata Convention on Mercury and the Stockholm Convention on POP`s.
Suppliers shall ensure that the management of waste from their operations complies with regulatory
requirements and the requirements of the Basel Convention, in particular in the case of transboundary
transport or trade thereof.

IV. Ethics
To fulfill social responsibility, all suppliers are expected to act ethically and with integrity and to comply
with all applicable laws and regulations. The ethical requirements include the following aspects:
IV.1 Fair Competition
Suppliers shall conduct themselves fairly in competition and comply with all applicable anti-trust laws.
IV.2 International Trade Controls
Suppliers must comply with export control regulations applicable to their business and provide accurate
and truthful information about them to customs and other authorities as required.
IV.3 Business Integrity
Suppliers must apply the highest standards of integrity in all business activities. Suppliers must prohibit
and neither practice nor tolerate corruption, extortion, embezzlement, misappropriation and money
laundering in any form. Suppliers must not offer or accept bribes or other unlawful payments in business
dealings with business partners or public officials. Suppliers must not offer Hako employees gifts or
other benefits for personal gain that could be considered as a bribe.
IV.4 Privacy
Suppliers shall comply with the reasonable expectations of its clients, suppliers, customers, consumers
and employees regarding the protection of private information. Suppliers shall comply with data privacy
and information security laws and government regulations in the collection, storage, processing, transfer
and disclosure of personal information.
IV.5 Intellectual Property
Intellectual property rights must be respected. Technology and know-how transfers must be carried out
in such a way that intellectual property rights and customer information are protected.

V. Governance
Suppliers shall implement a governance structure that supports compliance with applicable laws and
regulations in their businesses and promotes continuous improvement with respect to the expectations
set forth in this Supplier Code of Conduct. Specifically, these are:
V.1 Legal and other Requirements
Suppliers must be aware of and comply with all applicable international, national and local laws and
regulations, contractual agreements and internationally recognized standards and conventions.
V.2 Passing on of Hako´s Supplier Code of Conduct in the Supply Chain
Suppliers shall implement the principles set forth in this Supplier Code of Conduct in their upstream
supply chain as well, if possible.
V.3 Commitment and Responsibility
Suppliers shall comply with the principles set forth in this Supplier Code of Conduct. Suppliers should
integrate all applicable aspects of the Supplier Code of Conduct in their management systems.
V.4 Right to Evaluation and Control
Suppliers shall grant Hako the right to evaluate and control their performance after reasonable
advance notice in order to determine the Supplier's compliance with the principles set forth in this
Supplier Code of Conduct. The evaluations and controls will be carried out directly by Hako or by a
qualified external service provider, e.g. in the form of an assessment or audit.

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