THIMM Code of Conduct

This document is the self-imposed commitment of all THIMM employees (current overview of the companies) to conduct themselves correctly and responsibly in their daily professional lives. This Code of Conduct sets out the company framework for conducting ourselves reliably, transparently, responsibly and in a legally compliant and ETHICAL manner towards internal and external STAKEHOLDERS at all times.

All company rules and guidelines must be compatible with the THIMM Code of Conduct. We are not able to predict every individual case or situation. Therefore, the Code is wide in its scope and by its nature is kept general. It does not replace existing regulations or procedural instructions. It should rather address the core elements of individual and corporate responsibility and as a result give everyone in the company a clear understanding of all the principles and ethical values that apply at THIMM.

There are situations for which the THIMM Code of Conduct does not provide direct guidance. In this regard the following questions can help us make a decision in the interests of the company and in accordance with our attitudes, obligations and guidelines.

Our attitude

We create strategic and structural clarity so we can act and make decisions independently. Our committed management culture ensures that we tackle new fields of action together.

This is based on our attitude statements:

Our collaboration

We create the basis for good collaboration by maintaining an open and continuous exchange based on mutual respect. TRANSPARENT DIALOGUE, an OPEN ERROR CULTURE and a culture of appreciation are the cornerstones of trusting and constructive collaboration at THIMM.

Performance for our customers is the starting point of our business success and our drive. However, we are a family business which means we understand how to combine flexible working (e.g. part-time work, mobile working) wherever it is feasible. This ensures we are well positioned to meet individual requirements and enable different ways of mutual collaboration for a healthy work/life balance.

Good and close collaboration form the basis for our success. Therefore, it is important to assume responsibility – for the concerns of our business partners and for our interaction as colleagues. We support each other and we share important information, our knowledge and our know-how. We work together to find solutions, we continue our development and we bring new solutions to life.

WE SUPPORT EACH OTHER AND WE SHARE OUR KNOWLEDGE AND OUR KNOW-HOW

Scope

Our Code of Conduct applies worldwide to all THIMM employees, irrespective of function, rank or influence. Existing guidelines (such as company agreements or department-specific supplements) continue to apply without restriction in addition to the THIMM Code of Conduct. To the extent permitted by law, in cases of doubt, the regulation which offers a higher level of protection to the persons concerned applies.

EVERY EMPLOYEE ASSUMES PERSONAL RESPONSIBILITY

Every employee assumes personal responsibility, acts as a role model and supports colleagues in complying with the guidelines.

Compliance with laws, standards and guidelines

We are committed to complying with all laws applicable to our company plus with relevant, internationally recognised provisions, standards and guidelines. In particular the THIMM Code of Conduct covers the provisions of the United Nations, the UN Global Compact and the International Labour Organisation (ILO*).

Bribery and corruption

As a company aware of our responsibilities, we do not tolerate any form of bribery or corruption. Actions and (purchasing) decisions must always be conducted with the best interests of our company in mind and independently of any personal interests.

When conducting our business transactions, we resolve not to offer, promise, demand, grant or accept gifts, payments, invitations or services that could potentially influence a business relationship in an undue manner. In particular, we do not accept or offer gifts, courtesies or hospitality invitations to our business partners that exceed an accepted and reasonable scope, DISREGARD THE BUSINESS NATURE or fall outside the scope of our internal regulations. In cases of doubt, the manager or the Code of Conduct officer must be informed and asked for a decision. We avoid such situations where our personal, family or financial interests could come into conflict with the interests of THIMM. Should any such conflict of interests arise, we disclose it and obtain the consent of our management team. In this context, THIMM’s donation guidelines also apply. These are published on our website and can be viewed at all times.

We commit to report any notifications of corrupt conduct. The first point of contact is our manager. Alternatively, our OMBUDSPERSON (see Section 08 Implementation in practice) is available for this purpose.

Antitrust and competition law

s a company, we respect free and fair competition with other companies and we also expect this from our business partners. Price or terms and conditions agreements with competitors are therefore also forbidden as are other agreements which have the effect of restricting competition, and in particular specific agreements with competitors with the purpose of market or customer allocation. We immediately address any notifications of anti-competitive conduct to our management team. Questions on what behaviour is permitted under anti-monopoly or competition law, or on what actions may or must be taken, may be brought to this person as well. Alternatively, an independent, external contact person (see Section “08  Implementation in practice”) is available for this purpose.

Compliance with trade and customs regulations

As a company aware of our responsibilities, we are committed to complying with applicable trade regulations. These include sanctions, export and import controls, customs law and anti-boycott regulations

Correct accounting and financial reporting

We record all business transactions, entries in the company’s books and records correctly, completely and on time in accordance with the principles of GENERALLY ACCEPTED ACCOUNTING PRINCIPLES (GAAP).

We only undertake payment applications and payments in the company interest and only for legally admissible purposes and we ensure that they correspond to the relevant payment documentation. We take precautions to prevent MONEY LAUNDERING.

As a reliable partner for our stakeholders, our financial reporting (annual report, annual financial statements) is timely and accurate.

Protection of business-relevant information and personal data

We protect information about our company, our customers, our business contacts and our colleagues within the framework of data protection provisions and the limits of business confidentiality. We receive regular training in this area. At the same time, we commit to maintain operational and business secrecy.

As THIMM employees we ensure that we do not DISCLOSE confidential information and documents TO THIRD PARTIES. These are only stored in accordance with our privacy policy. We only disclose confidential information externally when legally obliged to do so, or by order of a court or government agency. Employees’ confidentiality obligations also remain in effect after the termination of their employment relationship with THIMM.

We only collect, process and/or use employees’ or third parties’ personal information if the person concerned has given consent or another legal basis exists

Handling company property

We handle THIMM’s assets with due care and in a proper manner and only use them for activities that serve the corporate purpose. In addition to tangible assets, such as buildings, systems, machinery and equipment, this also includes information technology, software, etc.

Without the express consent of our responsible management team or a company provision, we do not use company facilities and objects for private purposes nor remove them from company premises.

WE PROCEED CAREFULLY AND PROPERLY WITH THE OBJECTS FROM THIMM

Free choice of employment

As a responsible company, we are against all forms of forced labour, slavery and human trafficking. All people have the right to freely choose employment. Before starting employment at THIMM, employees sign a written contract that transparently documents the mutual rights and obligations. Significant changes to the working conditions are also agreed in writing with employees.

Appropriate working hours and rest periods

We undertake to comply with the relevant statutory legislation and operating standards relating to working hours, rest periods, holiday entitlements and statutory public holidays.

Freedom of organisation and association

Cohesion and commitment are important to us; therefore we respect the freedom of organisation and association of our employees along with the right to collective bargaining through their respective representatives and we ensure that this right is not restricted. At the same time, THIMM employees are always able to raise their concerns directly

COHESION AND COMMITMENT ARE IMPORTANT TO US

Protection of children and young people

As a company aware of our responsibilities, we are committed to respecting the rights of children and young people. We reject the exploitation of children and young people in any form. We are committed to complying with all International Labour Organisation (ILO) and United Nations Conventions as well as with national standards and regulations that protect children and young workers. Children do not work below the legal minimum age and can start training at the earliest at the age of 15. We ensure that children and young employees are not exposed to harmful, unsafe or health-damaging situations and that, for example, young trainees are not scheduled for night shifts. Their working and school hours must comply with currently applicable laws and must not exceed eight hours per day.

We ensure a safe, healthy and hygienic working environment and comply with occupational health and safety regulations. Our company provides suitable resources for this (including protective clothing, drinking water, skin care and disinfectant agents etc.). Particularly vulnerable groups (for instance young people, pregnant women, mothers and people with disabilities) are provided with appropriate care.

We are regularly instructed and trained in the applicable health and safety standards and safety measures in line with our function. We report inadequate safety standards and infringements of occupational safety regulations to our manager and/or the responsible occupational safety specialist or the ombudsperson.

Sustainable business practices

As employees, we are experts in our respective work processes. This means we assume responsibility for our actions and business practices as defined by THIMM and therefore also for people and the environment that are influenced by THIMM.

The UN Sustainable Development Goals (SDGs) are the orientation point for our sustainability strategy. Regular sustainability reporting and the provision of digital information on the company’s intranet provide an overview of THIMM’s measures and campaigns in relation to sustainability.

When sourcing raw materials and services, we are committed to ACHIEVING A BALANCE between social, economic and ecological needs.

Environmental and resources protection

We are aware that our future and future generations depend on our protection of the environment. We thereby commit to comply with applicable legislation and minimum regulations relating to climate and environmental protection.

OUR FUTURE DEPENDS ON THE PROTECTION OF OUR ENVIRONMENT

We advocate the conservation of natural resources and biodiversity, and we actively tackle climate change. To do this, we use resources such as energy, water, raw materials, auxiliary materials and operating materials, etc. responsibly, sustainably and transparently in cycles and we avoid or reduce waste. At THIMM, environmental and resources protection begins with the development of our processes and products and extends from the procurement of raw materials to their production and packaging to transport. The “Guidelines for Responsible Procurement at THIMM” are our framework for shaping sustainable innovations and responsible supply chains in collaboration with our stakeholders (customers, suppliers, business partners, etc.) and for complying with our duty of care.

Digital solutions

As a forward-looking company we invest in new technologies and regularly train our employees in order to strengthen our innovative capacity, save resources and be as flexible as possible. We use digital platforms to optimise our processes regarding environmental impacts and economic efficiency.

We systematically reduce our CO₂E FOOTPRINT by reducing our business travel and, where possible and sensible, holding digital meetings/appointments. In this context we also use digital formats for training and further education and for candidate management.

Wherever practical and possible, automated processes enable all THIMM employees to have flexible access, both in terms of time and location, to all relevant information relating to their employment relationship. We are also paving the way for paperless working through digital solutions and transitions.

The THIMM Code of Conduct is familiar to all employees and can be accessed by everyone in the respective national languages of our sites. All THIMM employees are trained annually on the contents of this document and informed promptly about changes.

New colleagues are given the Code of Conduct at the start of their work at THIMM and will be trained on the content.

As employees, we are all jointly responsible for implementing the THIMM Code of Conduct. We report any suspected or observed infringements of laws, this Code or other company policies and we listen when others raise concerns. It is also important to address unpleasant topics and make them transparent. This enables us to solve problems in a timely manner and prevent damage to the company. At the same time, we can prevent these topics/problems from recurring in the future.

What you need to know about reporting

All reports are treated confidentially. Employees who report potential infringements of this Code of Conduct in good faith will not be discriminated against. In specific cases, e.g. initiation of preliminary judicial proceedings, the company is legally obliged to disclose information that is generally to be treated as confidential to third parties.

Consequences of infringements

THIMM will not tolerate any infringements of the THIMM Code of Conduct and will handle any non-compliant incidents appropriately. All employees are aware that such infringements can have serious consequences for the company and for themselves.

*ILO

The following summary is designed to provide a better understanding of the applicable International Labour Organisation (ILO) Conventions.

• 1 Working hours
• 14 Weekly rest day (industry)
• 26 Minimum Wage-fixing machinery
• 29 Forced labour
• 79 Night Work of Young Persons (Non-Industrial Occupations)
• 87 Freedom of Association and Protection of the Right to Organise
• 98 Right to Organise and Collective Bargaining
• 100 Equal Remuneration
• 105 Abolition of Forced Labour
• 111 Discrimination (Employment and Occupation)
• 131 Minimum Wage Fixing
• 135 Workers’ Representatives
• 138 Minimum Age
• 142 Human Resources Development
• 143 Equality of Opportunity and Treatment of Migrant Workers
• 154 Collective Bargaining
• 155 Convention on Occupational Safety and Health and the Working Environment
• 158 Termination of Employment
• 159 Vocational Rehabilitation and Employment of Disabled Persons
• 182 Prohibition and immediate action for the elimination of the worst forms of child labour
• 187 Promotional Framework for Occupational Safety and Health
• E 143 Recommendation concerning protection and facilities to be afforded to workers’ representatives in the company
• E 146 Recommendation concerning minimum age for admission to employment

The texts of these ILO Conventions and Recommendations, including English versions, are available under www.ilo.org.