OBO Code of Conduct for social responsibility

Preamble

We, the OBO Bettermann group of companies, acknowledge our social responsibility in the framework of our corporate activities (internationally termed as "corporate social responsibility"). This "OBO Code of Conduct for social responsibility" (hereinafter termed "CoC") lays down what this means, in particular with regard to workplace conditions, social and environmental compatibility, as well as transparency, trusting cooperation and dialogue. The contents of this CoC are the expression of our shared value basis at OBO Bettermann, as defined in our policy and, in particular, in our acknowledgement of the social market economy.

The CoC is designed as a self-obligation and supports us in realising the different general conditions in a global market and meeting the challenges and social expectations resulting from the increasingly networked cooperation in the added value chains.

1. Basic understanding of socially responsible company management

This CoC is based on a shared basic understanding of socially responsible company management. For OBO Bettermann, this means that we accept responsibility by reconsidering the consequences of our corporate decisions and actions in an economic, technological and social and ecological regard and integrating a reasonable compensation of interests. We contribute, in the scope of our abilities and freedom of action, voluntarily to the well-being and sustainable development of society in the locations in which we are active. In so doing, we orientate ourselves in accordance with the generally valid ethical values and principles, particularly with regard to integrity and probity and respect for human dignity.

2. Scope of validity

2.1 This CoC applies to all the branch offices and business units of our corporate group around the world.

2.2 We oblige ourselves to promote compliance with the content of this CoC, also with our suppliers and in the further added value chain in the scope of our abilities and areas of action.

3. Cornerstones of socially responsible company management

We, OBO Bettermann, are actively working to ensure that the values and basic principles named below are observed and complied with in a sustainable manner.

3.1 Compliance with laws

We comply with the applicable laws and other legal requirements of the countries in which we are active. In countries with a weak institutional framework, we check carefully which good business practices from our home country should be used to support responsible company management.

3.2 Integrity and organisational governance

3.2.1 We, OBO Bettermann, orientate our actions in accordance with the generally valid ethical values and principles, particularly with regard to integrity and probity, respect for human dignity, openness and non-discrimination against religion, world view, gender and ethics.

3.2.2 We reject corruption and bribery in the sense of the appropriate UN Convention (United Nations Convention Against Corruption of 2003, in force since 2005) and demand, in the appropriate manner, transparency, actions with integrity and responsible management and controlling in the company.

3.2.3 OBO Bettermann follows clean, recognised business practices and fair competition. In competition, we ensure professional behaviour and high-quality work. With the supervisory authorities, we, OBO Bettermann, will maintain a cooperative, trusting relationship and comply with the specifications of Zentralverband Elektrotechnik- und Elektronikindustrie e.V: "Leitfaden fr unsere Verbandsarbeit Hinweise fr ein kartellrechtskonformes Handeln im ZVEI".

3.3 Consumer interests

If consumer interests are affected, then we will comply with the regulations to protect consumers, as well as with appropriate sales, marketing and information practices. Groups particularly requiring protection (e.g. young people, the severely disabled) enjoy our particular attention.

3.4 Communication

We, OBO Bettermann, communicate openly and in a dialogue-orientated manner about the requirements of this CoC and its implementation with our employees, customers, suppliers and other interest and demand groups. All the documents are created properly, are not changed or destroyed improperly and are stored correctly. Company secrets and the business information of the partners are treated sensitively and confidentially.

3.5 Human rights

We shall work to promote human rights and will guarantee human rights according to the UN Charter of Human Rights (General Declaration of Human Rights, UN Resolution 217 A (111) of 1948), in particular the following:

3.5.1 Privacy

Protection of privacy.

3.5.2 Health and safety
Guarantee of health and workplace safety, in particular the guarantee of a working environment promoting health and safety, in order to avoid accidents and injuries.

3.5.3 Harassment
Protection of employees against physical punishment and against physical, sexual, mental or verbal harassment or abuse.

3.5.4 Freedom of opinion
Protection and guarantee of the right to freedom of opinion and freedom of speech.

3.6 Working conditions

We, OBO Bettermann, comply with the following core working standards of the ILO (International Labour Organization):

3.6.1 Child labour
The ban on child labour, i.e. the employment of people younger than 15 years old, insofar as the local legal requirements do not set higher age limits and insofar as no exceptions are permitted (ILO Convention No. 138 of 1973 and ILO Convention No. 182 of 1999).

3.6.2 Forced labour
The prohibition of any kind of forced labour (ILO Convention No. 29 of 1930 and ILO Convention No. 105 of 1957).

3.6.3 Payment
The workplace standards with regard to payment, in particular with regard to the level of payment according to the valid laws and regulations (ILO Convention No. 100 of 1951).

3.6.4 Employee rights
The respecting of the rights of the employees to freedom of coalition, freedom of assembly and to collective and tariff agreements, insofar as it is legally permitted and possible in the appropriate country (ILO Convention No. 87 of 1948 and ILO Convention No. 98 of 1949).

3.6.5 Ban on discrimination
Discrimination-free treatment of all employees (ILO Convention No. 111 of 1958).

3.7 Working time

We comply with the workplace standards with regard to the highest permissible working time.

3.8 Environmental protection

We fulfil the requirements and standards on environmental protection affecting our companies and act in an environmentally aware manner at every location. In addition, we handle natural resources responsibly and according to the principles of the Rio Declaration (the 27 principles of the "Rio Declaration on Environment and Development" of 1992 as the United Nations Conference on Environment and Development in Rio de Janeiro).

3.9 Civic engagement

We, OBO Bettermann, contribute to the social and economic development of the country and region by being active and promoting appropriate voluntary activities of our employees.

4. Implementation

We make every suitable and reasonable effort to implement and apply the basic principles and values described in this CoC continuously. Contractual partners shall be informed of the key measures, on demand and in the context of reciprocity, in order to make it clear how their compliance is basically guaranteed. It is not possible to make demands for the forwarding of company secrets or information which is related to competition or is in any other way worth protecting.

Modern Slavery Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. lt takes various forms, such as slavery, forced and compulsory labour, human trafficking and child labour, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

OBO Bettermann Holding GmbH & Co. KG (hereinafter called in brief as OBO Bettermann) recognizes that as a business it has a moral and social responsibility to take a zero­tolerance approach to modern slavery in all forms.

We are committed to preventing slavery and human trafficking in our business activities, and to ensuring, as far as we are able, that our supply chains are free from slavery and human trafficking.

OBO Bettermann will achieve these aims in the following ways:

• Stringent vetting and investigation of our supply chain
• Continually audit and review our practices for checking all employees are paid at least the minimum wage and have the right to work
• Encourage the reporting of concerns and the protection of whistle blowers
• OBO Bettermann will not knowingly support or deal with any business involved in slavery or human trafficking
• OBO Bettermann has a zero-tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values.
• Upon request, suppliers must be able to demonstrate compliance with this policy to the reasonable satisfaction of OBO Bettermann.
• OBO Bettermann may perform periodic audits on this policy and suppliers are expected to fully co-operate with any such audit.

lf a supplier to OBO Bettermann is found in violation of this policy, OBO Bettermann will take immediate action which may include the termination of any supply agreement, arrangement or other contract with that  supplier.

Managing directors