Compliance

Code of Conduct

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Our Code of Conduct forms the basis for responsible and ethical conduct at aixFOAM. It describes the values, principles and guidelines that shape our daily cooperation as well as our interactions with customers, business partners and employees.

Compliance with all applicable laws and legal regulations is an essential foundation of all activities carried out by SH.

This Code of Conduct cannot cover every legal requirement that applies to SH's management bodies and employees. It sets out the key principles for responsible conduct by SH, its employees and its management.

All employees and members of the management are required to familiarize themselves with the legal regulations relevant to their area of responsibility and to seek legal advice from the appropriate internal contacts at SH whenever in doubt.
It is SH's policy to promote fair competition. The company competes through performance, customer focus and product quality. SH complies with all applicable antitrust laws, intellectual property laws, particularly those protecting third-party rights, as well as laws against unfair competition. SH expects the same commitment from its competitors, customers and suppliers.

Every employee and member of the management must understand that violations of competition law are never in SH's interest and are therefore strictly prohibited. The same applies to compliance with intellectual property laws, especially the protection of third-party rights.
SH strictly rejects corruption in all business activities. This applies both to dealings with public officials, political representatives and judicial authorities, as well as with representatives and employees of other companies. No personal benefits may be offered or granted to public officials or employees of other companies in exchange for preferential treatment.

Employees and members of SH's management must not accept bribes or derive any personal benefit from their work beyond their company remuneration. They must not accept gifts (other than customary promotional items), invitations exceeding normal business practice (e.g. vacation trips) or any other direct or indirect benefits. Likewise, they must not offer such benefits to competitors, consultants, customers, suppliers, service providers or other business partners of SH.
All SH employees and members of its governing bodies are required to avoid conflicts of interest between their private interests (whether direct, indirect, or involving related persons or companies) and the interests of SH.

Avoiding conflicts of interest also means ensuring that business relationships with competitors, consultants, customers, suppliers, service providers, and other business partners do not create even the appearance of preferential treatment due to personal relationships.

In cases of doubt, employees must consult their supervisor or disclose any potential conflict of interest and seek guidance from the management or its representatives. The interests of SH always take precedence.
SH complies with all legal requirements governing international trade that apply to its products and services. The company observes all applicable national and international export and import restrictions as well as licensing requirements.
SH's business success depends largely on its employees. The company is committed to social responsibility and therefore promotes fair working conditions throughout the organization.

Fair working conditions include equal treatment of all employees, regardless of gender, sexual orientation, origin, skin color, or any other personal characteristic.

SH considers it its responsibility to be a socially responsible employer and to treat its employees with respect and fairness. This includes complying with all occupational health and safety regulations to ensure a safe workplace. SH also expects employees to treat one another with respect. Personal insults and sexual harassment will not be tolerated.
Honest and transparent reporting, both within the company and to the public, is essential for SH. All governing bodies and employees of SH are therefore required to report conscientiously, truthfully, loyally and in a timely manner within the company. Governing bodies and employees of SH who report to third parties, such as authorities or the press, must follow the same principles. This is essential for SH's credibility in relation to authorities, business partners and other business and social contexts.
As management and employees, we are responsible for ensuring a safe and healthy working environment. Strict compliance with applicable safety regulations and practices is essential. Employees are required to report any violations of these principles immediately. Any deficiencies must be remedied without delay.

SH continuously strives to develop innovative and high-quality products for its customers. Product safety is a top priority in this process.

SH supports all efforts relating to sustainability and works closely with customers and suppliers in this regard. This applies in particular to the production of raw materials and the use of our products.
The knowledge and information acquired by employees and governing bodies at SH or in connection with their work for SH are an essential element of the company's business success. SH invests substantial personnel and financial resources in the development of innovative products and in the expertise of its employees and suppliers. Protecting these innovations secures SH's competitive success and is therefore of particular importance.

All employees and governing bodies of SH are required to prevent such knowledge and information, which may constitute trade or business secrets, from becoming known outside SH, for example through the unauthorized disclosure of sensitive data in conversation. In addition, anyone handling such knowledge and information should determine whether industrial property rights may be obtained for them.

Trade and business secrets of SH's business partners must also be protected against unauthorized disclosure.
Respect for the personality and privacy of our employees includes the protection of their personal data. SH therefore complies with all applicable data protection regulations and expects its employees to do the same.
Managers are expected to actively promote the implementation of this Code of Conduct. This includes ensuring that all employees under their responsibility are familiar with the Code and are able to apply and comply with it in their daily work. Managers must also continuously monitor compliance with the Code and its implementation throughout the company.

All SH employees must understand that violations of the Code of Conduct will not be tolerated under any circumstances and may result in disciplinary or employment-related consequences, depending on the severity of the violation.

If an employee becomes aware of a possible violation of the Code of Conduct, whether involving themselves or another employee, the matter should first be addressed within the relevant working environment.

If this is not possible or appears inappropriate, any employee may contact the Compliance Officer responsible for monitoring the principles set out in this Code of Conduct. All questions, reports and suggestions will be treated with strict confidentiality and handled according to the nature of the matter. Upon request, employees will be informed about how their report has been handled and which measures have been taken.

No employee will suffer any disadvantage for contacting their local representative or the central Human Resources department in good faith.

Supplier Code of Conduct

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A trustworthy partnership is based on shared standards. Our Supplier Code of Conduct defines the requirements for quality, integrity, sustainability, and compliance with legal and ethical standards throughout our supply chain.

SH expects its suppliers to uphold the highest standards of legality and integrity. This includes strict compliance with all applicable laws, regulations, standards, and contractual obligations, while avoiding violations, circumvention, or deceptive practices.

a) Compliance with Applicable Law as a Minimum Standard

We expect our suppliers to comply with all applicable laws and relevant regulations in the countries where they operate. If products or services are intended for export, they must also comply with the legal requirements of the destination country.

b) Anti-Corruption (Public and Private Sector)

We expect our suppliers to neither participate in nor tolerate corruption. They must actively implement anti-corruption measures and consistently address any identified cases of corruption. This also applies to any actions intended to conceal corruption or circumvent anti-corruption regulations.

We expect our suppliers to manage the interests of SH, their own organization, and the employees involved responsibly and to keep these interests appropriately separated.

We expect our suppliers and their employees to act with integrity, make business decisions solely on objective criteria, and not allow themselves to be influenced by benefits or incentives offered by business partners or third parties.

We expect our suppliers to exercise the utmost restraint when granting financial or non-financial personal benefits to business partners or public officials. Under no circumstances may benefits be offered, promised, or granted in exchange for official or business decisions or with the expectation of preferential treatment. Benefits may only be offered in exceptional cases if they are appropriate, socially acceptable, customary in business practice, and of low value. All applicable criminal and tax laws must be observed.

c) Antitrust Law

We expect our suppliers to compete fairly and refrain from engaging in unfair competition. In particular, suppliers must comply with all applicable national and international antitrust laws and other regulations governing competition. Illegal anti-competitive agreements, abuse of a dominant market position, and the unlawful exchange of competition-sensitive information are strictly prohibited.

d) Export Controls

We expect our suppliers to comply with all applicable national and international export control and foreign trade regulations when importing or exporting goods or services. They must not engage in any violations, circumvention, or deceptive practices.

We expect our suppliers to maintain transparent and traceable records of all import and export activities. Furthermore, suppliers must not make facilitation payments to public officials.

e) Anti-Money Laundering

We expect our suppliers to comply with all applicable national and international anti-money laundering laws in all transactions and business relationships.

f) Confidentiality and Data Protection

We expect our suppliers to respect the trade secrets, business information, and intellectual property rights of third parties and to treat all exchanged documents, data, quotations, and pricing information as confidential.

We expect our suppliers to carefully protect confidential business-related and personal data that is not publicly available, in accordance with national and international regulations governing trade secrets, while also complying with all applicable data protection laws.
SH expects its suppliers to respect universal human rights and fundamental rights, particularly in the workplace. SH recognizes the principles of the International Labour Organization (ILO), as well as the UN International Covenant on Civil and Political Rights and the UN International Covenant on Economic, Social and Cultural Rights, as global minimum standards. We expect our suppliers to comply with these principles.

a) Freedom of Association

We expect our suppliers to respect their employees' rights to freedom of expression and freedom of association in accordance with the laws applicable at their place of business and employment. Employees must not suffer disadvantages for forming or joining trade unions, employee representative bodies, or for advocating their rights or improved working conditions.

b) Working Hours

We expect our suppliers to comply with all applicable laws governing working hours at their place of business and employment, including maximum daily and weekly working hours. This also includes compliance with applicable collective bargaining agreements. Employees must be provided with sufficient rest periods and days off.

c) Wages

We expect our suppliers to provide fair and adequate compensation to their employees while complying with all applicable minimum wage regulations, remuneration requirements, employment laws, and collective bargaining agreements.

d) No Child Labour

We expect our suppliers to comply with the United Nations' principles on human rights and children's rights. SH has zero tolerance for child labour. Under no circumstances may children of compulsory school age or children under the age of 15 be employed. Where national laws impose stricter requirements regarding child labour or the minimum working age, those provisions shall take precedence.

e) No Slavery or Forced Labour

We expect our suppliers not to engage in, benefit from or tolerate any form of slavery, slavery-like practices or forced labour. Forced labour includes any work or service performed involuntarily under threat of punishment, including prison labour. It also includes any compulsory retraining, education or other measures imposed by governments or local authorities that require individuals or groups to perform work against their will under conditions comparable to imprisonment, detention or institutional confinement.

f) Non-Discrimination

We expect our suppliers to treat all people, especially their employees, with respect, fairness and without discrimination. Any form of discrimination or unequal treatment based on national or ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion or belief is unacceptable. Applicable anti-discrimination laws must be observed.

g) Protection of Natural Resources and Human Rights

We expect our suppliers to respect and preserve the natural resources on which people depend. Harmful soil, water or air pollution, excessive noise emissions or water consumption that jeopardise food production, access to clean drinking water or adequate sanitation must be avoided. No person may be unlawfully deprived of access to land, forests or water that are essential to their livelihood. The inappropriate use of private or public security forces to unlawfully enforce business interests is strictly prohibited.

h) Responsible Sourcing of Raw Materials

We expect our suppliers to implement processes for the responsible sourcing of conflict minerals such as tin, tungsten, tantalum and gold, and where applicable other raw materials such as cobalt, in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
At SH, we expect our suppliers to ensure that people can perform their work safely and without suffering permanent physical harm.

a) Safe and Healthy Working Environment

We expect our suppliers to provide a safe and healthy working environment for their employees. They must identify and minimise risks to employees' health and physical well-being. Appropriate occupational health and safety management systems should be in place, and all applicable occupational safety and health regulations must be observed.

b) Accident Prevention

We expect our suppliers to organise work processes, product design and the provision of services in a way that prevents accidents wherever reasonably possible and minimises the consequences should accidents occur.
SH expects its suppliers to minimize their environmental impact and actively contribute to protecting the environment and preserving natural resources. In particular, SH regards compliance with the Minamata Convention, the Stockholm Convention on Persistent Organic Pollutants (POPs) and the Basel Convention as global minimum standards and expects its suppliers to adhere to them.

a) Environmental regulations

We expect our suppliers to act responsibly in protecting the environment and conserving limited natural resources, implement responsible chemical management, support animal welfare and biodiversity, prevent deforestation, and fully comply with all applicable environmental and animal protection laws.

We also encourage our suppliers to support environmental protection beyond legal requirements and to propose environmentally friendly products, production methods, works and services wherever possible.

b) Sustainability

We expect our suppliers to use natural resources responsibly so that future generations are not negatively affected by today's consumption.

Suppliers are expected to consistently follow the principles of sustainability and the circular economy. The use of non-renewable resources should be continuously reduced in favour of renewable or recyclable alternatives, and waste should be avoided wherever possible.

c) Energy

We expect our suppliers to continuously reduce their energy consumption and make the greatest possible use of carbon-neutral energy sources.

d) Climate protection

We expect our suppliers to align their production, development and services with the objectives of sustainable climate protection. Through continuous dialogue, we aim to work together towards carbon neutrality and the reduction of harmful emissions.
SH conducts both internal and external audits to continuously improve and sustainably safeguard its supply chain. We expect our suppliers to cooperate appropriately in these activities. We also welcome suppliers who certify their management systems and can provide corresponding evidence to SH.

We expect our suppliers to ensure that their employees, subcontractors and sub-suppliers are made aware of, committed to and, where necessary, trained in the requirements of this Supplier Code of Conduct. Suppliers should also ensure that these requirements are communicated throughout their supply chain.

Any violation of the principles set out in this Supplier Code of Conduct is regarded by SH as a significant breach of the contractual relationship. If there are indications that these principles have not been complied with (e.g. through media reports), SH reserves the right, without prejudice to any further legal rights, to request information regarding the relevant circumstances.

SH also reserves the right to carry out random inspections and audits at suppliers in order to verify compliance with this Supplier Code of Conduct.

Important: In the event of serious or repeated violations, the contractual relationship may be terminated. Suppliers will be given an appropriate period of time to remedy any non-compliance or deficiencies.
The primary contacts for our suppliers and their employees are their existing business contacts within SH.

In addition, suppliers, their employees, downstream suppliers, their employees and other affected parties may contact SH's Compliance Department confidentially to report legal violations or other circumstances that may harm people, the environment or SH, lead to unfair disadvantages, or unlawfully impair natural resources in connection with the business activities of SH or one of its suppliers.