Niedax Group

Code of Conduct

Version 10/2023
(Rev. 3)

Code of Conduct – Niedax Group (Version 10/2023 – Rev. 3) Page 1 of 10

TABLE OF CONTENTS
Preamble ............................................................................................................................... 3
1. Scope of Application....................................................................................................... 4
2. Basic understanding ....................................................................................................... 4
3. Compliance with legislation ............................................................................................ 4
4. Integrity and Compliance ................................................................................................ 5
4.1 Corruption ............................................................................................................... 5
4.2 Fair Competition ...................................................................................................... 5
4.3 Prevention of money laundering .............................................................................. 5
4.4 Protection of information and intellectual property ................................................... 5
4.5 Data protection ........................................................................................................ 5
4.6 Export Controls ....................................................................................................... 5
4.7 Avoidance of conflicts of interest ............................................................................. 6
5. Health and safety ........................................................................................................... 6
6. Remuneration and hours of work.................................................................................... 6
7. Observance of human rights .......................................................................................... 6
7.1 Prohibition of child labour ............................................................................................. 7
7.2 Prohibition of forced labour .......................................................................................... 7
7.3 Freedom of association and collective bargaining ........................................................ 7
7.4 Promotion of diversity, equal opportunities ................................................................... 7
8. Environment, energy and climate protection ................................................................... 7
9. Dealing with conflict minerals ......................................................................................... 8
10. Supply chain ............................................................................................................... 8
11. Consumer interests..................................................................................................... 8
12. Execution and implementation .................................................................................... 8
12.1 Communication ....................................................................................................... 8
12.2 Information on infringements ................................................................................... 8
13. Signature .................................................................................................................... 9
Committment to comply with the Code of Conduct of Niedax Group.....................................10

Code of Conduct – Niedax Group (Version 10/2023 – Rev. 3) Page 2 of 10

PREAMBLE
Niedax Group is a group of renowned and legally independent companies that are among the
world's leading manufacturers in the field of electrical installation and cable trray systems.
In view of the challenges of the future in a global market, the aim of the Niedax Group
companies is to continue to grow organically and through acquisitions and to secure its position
as the global market leader in the field of metal cable support systems.
Mindful of the fact that partnership-based, ethical and legally compliant behaviour will lead to
the desired success, the Niedax Group companies1 are committed to their social responsibility
in the context of global corporate activity (internationally usually referred to as Corporate Social
Responsibility or CSR) in accordance with the "ZVEI-VDMA Code of Conduct"2.
The Code of Conduct of Niedax Group (hereinafter referred to as 'Code of Conduct') sets out
as a guideline what this means in particular with regard to working conditions, social and
environmental compatibility as well as transparency, trusting cooperation and dialogue. The
contents of this Code of Conduct, which was developed and harmonised for the Niedax Group
companies, are an expression of the shared values within Niedax Group, as defined in the
vision and mission.

1 Scope of application see point 1

2 Version 01/2022

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1. SCOPE OF APPLICATION
With regard to this Code of Conduct, the term 'Niedax Group companies' refers to the following
companies:
Niedax GmbH & Co. KG, Niedax Infrastruktur GmbH, Rico GmbH & Co. KG, Rico Engineering
GmbH, Hermann Kleinhuis GmbH + Co. KG, Niedergesäß GmbH & Co. KG, Fintech GmbH
and Niedax Galvanik GmbH with their locations in the Federal Republic of Germany.

2. BASIC UNDERSTANDING
This Code of Conduct is based on a shared conception of socially responsible company
management as defined by the following guiding principles.
We, the Niedax Group companies, accept responsibility for the consequences of our business
decisions and activities in respect of the legal, economic, technical, social and environmental
implications as far as possible within our available scope of action. We thus contribute to the
societal and economic development of the countries and regions in which we operate.
Our actions are consistent with the relevant legal regulations. We are guided by ethical values
and principles, in particular integrity and honesty, as well as respect for the dignity of human
beings as set out in the principles of the Universal Declaration of Human Rights of the United
Nations, the OECD Guidelines for Multinational Enterprises, the Core Labour Standards of the
International Labour Organisation and the United Nations Guiding Principles on Business and
Human Rights.
This Code of Conduct defines the basic principles of our actions, and we actively demand that
it is observed by our employees worldwide. Its standards apply in all branch offices and
business units within our company.
We expect the same basic understanding from our business partners. It is not intended to
constitute a basis for third-party rights.

3. COMPLIANCE WITH LEGISLATION

It is a matter of course for us that we will comply with current laws and other legal requirements
in the countries in which we operate. In cases where local laws and regulations are less
restrictive, our actions are guided by the principles of this Code of Conduct. Where there is a
direct conflict between mandatory local law and the principles contained in this Code of
Conduct, the local laws shall take precedence. Nevertheless, we endeavour to comply with the
content of this Code of Conduct.

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4. INTEGRITY AND COMPLIANCE
We have implemented suitable compliance measures3 so that the following areas are covered
appropriately:

4.1 Corruption
We do not tolerate corruption, bribery or blackmail; they impede fair competitive conditions.
Gifts made with the intention of influencing business decisions or which could give the
appearance of doing so or to obtain some other undue advantage are neither promised,
offered, granted, requested nor accepted in our business relationships. Nor do we allow these
to be promised to us. Especially strict standards must be applied when dealing with people for
whom particular rules apply under criminal and liability law (e.g. public officials).

4.2 Fair Competition

We operate in compliance with national and international competition and anti-trust legislation
and do not participate in price agreements, sharing markets or collusion in respect of
customers, markets and bids.

4.3 Prevention of money laundering

Money laundering is the term used for bringing money obtained illegally or from illegally
acquired assets into the legal financial and economic system. We comply with our legal
obligations to prevent money laundering and do not participate in transactions that serve to
disguise or integrate criminal or illegally acquired assets.

4.4 Protection of information and intellectual property

We protect confidential information and respect intellectual property; transfers of technology
and know-how must be made in a way that protects intellectual property rights, customer
information, business secrets and information that is not in the public domain. We observe the
current laws to protect business secrets and treat our business partners’ confidential
information accordingly.

4.5 Data protection

We process, store and protect personal data in compliance with statutory regulations. Personal
data is therefore treated confidentially and only collected for legal, previously defined purposes
in a transparent manner. We only process personal data if it is protected against loss,
modification and unauthorised use or disclosure using appropriate technical and organisational
measures.

4.6 Export Controls

We undertake to comply with legal standards relevant to export controls – including but not
limited to approval requirements, export bans and support bans – in the course of shipping
and exporting our goods.

3Compliance refers to observance of legal regulations, regulatory standards, voluntary self-imposed

commitments and internal guidelines.

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4.7 Avoidance of conflicts of interest
We avoid internal and external conflicts of interest which could illegitimately influence business
relationships. Where this is not successful, we disclose these conflicts.

5. HEALTH AND SAFETY

We protect our employees’ health by taking suitable measures in relation to health and safety
at work (e.g. the implementation of a company health and occupational safety management
system) that provide appropriate cover in the following areas:
• Compliance with current laws and guidance set out in international standards
relating to health and safety at work 4;
• Suitable workplace design, safety regulations and provision of suitable personal
protective equipment;
• Implementation of preventive checks, emergency measures, an accident reporting
system and further suitable measures for continuous improvement;
• Provision of access to adequate quantities of drinking water and access to clean
sanitary facilities for employees.
We ensure that our employees have received adequate instruction.

6. REMUNERATION AND HOURS OF WORK

Remuneration is based on current laws and, if applicable, current binding collective
agreements and is supplemented by the relevant national legislation on minimum wages.
Employees are given clear, detailed and regular information on the composition of their
remuneration. We comply with current laws and (international) working standards5 in respect
of the maximum permissible working hours and ensure that
• working time, including overtime, does not exceed the relevant legally permissible
maximum limits;
• the hours worked per week, including overtime, do not exceed 60 hours per week,
even in exceptional circumstances and even if no such stipulations exist;
• employees have at least one full day per calendar week free.

7. OBSERVANCE OF HUMAN RIGHTS

We pay attention to and support compliance with internationally recognised human rights and

• respect the personal dignity, privacy and personal rights of each individual;
• protect and uphold the right to freedom of speech and freedom of expression;
• do not tolerate unacceptable treatment of employees such as physical and
psychological hardship, sexual and personal harassment or discrimination.

4 See ILO work and social standards (ILO Guidelines on Occupational Safety and Health); SA 8000
Social Accountability or ISO 45001 Occupational Health and Safety Management, etc.
5 ILO Convention No. 1 (Hours of Work (Industry) Convention), 1919)

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7.1 Prohibition of child labour
We do not tolerate any child labour6. We do not employ any employees who cannot prove that
they are at least 15 years old, and we require proof of age to be submitted. For countries which
fall within the exception for developing countries according to ILO Convention No. 138, the
minimum age can be reduced to 14 years. We do not hire employees for dangerous work who,
according to ILO Convention No. 182, cannot prove that they are at least 18 years old

7.2 Prohibition of forced labour

Forced labour, modern slavery or comparable acts that involve the deprivation of liberty are
forbidden.7 All work must be voluntary, and it must be possible to end the employment
relationship.

7.3 Freedom of association and collective bargaining

We respect the right of employees to freedom of association, freedom of assembly and to
engage in collective bargaining and pay negotiations8, providing this is legally permissible and
possible in the relevant country in which we are operating. If this is not permissible, we look
for appropriate compromises for our employees.

7.4 Promotion of diversity, equal opportunities

We encourage equal opportunities and do not tolerate discrimination.9 We treat all people
equally regardless of gender, age, skin colour, ethnic origin, sexual identity and orientation,
disability, religious affiliation, worldview or other personal attributes.

8. ENVIRONMENT, ENERGY AND CLIMATE PROTECTION

We act in compliance with current legislation and are guided by international standards10 in
order to minimise negative impacts on the environment and continuously improve our activities
in respect of environment and climate protection.
All employees are made aware of environmental issues and the necessary training is offered.
We have implemented appropriate environmental protection measures (e.g. the
implementation of a company environmental management system) that cover the following
topics appropriately:
• Setting objectives, defining and implementing measures and ensuring the
continuous improvement of these;
• Environmental aspects such as the reduction of CO2 emissions, increasing energy
efficiency, using renewable forms of energy, safeguarding the quality of water and
reducing water consumption, safeguarding air quality, encouraging resource
efficiency, reducing waste and disposing of waste in the proper way and responsibly
handling substances that are dangerous to human beings and the environment.

6 ILO Convention Nos. 79, 138, 142 and 182

7 ILO Convention Nos. 29 and 105
8 ILO Convention Nos. 87, 135 and 154
9 ILO Convention No. 111
10 ISO 14001 and Standards of OECD Guidelines/COP21

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9. DEALING WITH CONFLICT MINERALS
We exercise the necessary care to take measures to avoid using conflict minerals in our
products in order to prevent human rights violations, corruption and financing armed groups or
similar via this route.

10. SUPPLY CHAIN

We expect our suppliers to comply with the principles of this Code of Conduct or to apply
comparable codes of conduct. Furthermore, we encourage them to implement the criteria in
this Code of Conduct in their own supply chains.
We reserve the right to systematically apply this Code of Conduct with our suppliers and to
carry out checks as warranted. This may take the form of questionnaires, assessments or
audits.
Should this cause doubts as to whether this Code of Conduct is being followed, the supplier is
requested to take suitable measures to counter this and to notify its contact in our company of
the course of action. If required, the cooperation arrangement will be ended.

11. CONSUMER INTERESTS

Where the interests of consumers are affected, we follow consumer protection provisions and
appropriate sales, marketing and information practices. Special attention is paid to groups that
require particular protection (e.g. young people or pregnant women).

12. EXECUTION AND IMPLEMENTATION

We make suitable and reasonable efforts to continuously implement, document and apply the
principles and values in the Code of Conduct. All employees are made aware of what this Code
of Conduct contains and receive training on relevant topics as required. Violations of the Code
of Conduct are not tolerated and can have consequences under employment law.

12.1 Communication
We communicate openly in dialogue with employees, customers, suppliers and other interest
and stakeholder groups regarding the requirements of this Code of Conduct and its
implementation.

12.2 Information on infringements

We offer our employees and business partners access to a protected mechanism that will allow
them to confidentially report possible violations of the principles of this Code of Conduct.
If you would like to pass on any information, please contact the following person/office directly
or anonymously:
Name of contact/office: Lars Ziegenhagen
Contact details: Phone: +49 2644 5606 777
E-Mail: [email protected]
Address: Asbacher Straße 141, 53545 Linz am Rhein, Germany

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13. SIGNATURE
For the the Niedax Group Companies according to point 1:

Linz am Rhein, 09.10.2023

sign.Bruno Reufels sign. Alexander Horn

Chairman of the Management Board / CEO Technical Managing Director

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 COMMITTMENT TO COMPLY WITH THE
CODE OF CONDUCT OF NIEDAX GROUP

I, the undersigned
(name, surname)

confirm in my function as
(function in the company)

and as a representative of the company

(company with company suffix)

with the following official business address

(P.O. Box / street and house number)

(postcode, town)

(country)

that I have taken note of the Code of Conduct of the Niedax Group (as of 10/2023, Rev. 3) and
undertake to comply with all provisions.

(Place, Date) (company stamp and signature)

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