200504_KOCH_Code of Conduct_EN_FINAL

KOCHPac

Code

of Conduct

KOCH Pac-Systeme GmbH


Code of Conduct 02

Contents

03

04

Foreword

1 KOCH Corporate Culture Guidelines

Basis for our actions

12

13

13

4 Protection of information and data

4.1 Correctly kept books and records

4.2 Safety and protection of data

4.3 Secrecy in general

05

06

07

08

08

2 Our responsibility as business partner

2.1 Fair competition and transparency

2.2 Quality and safety of our products

2.3 No corruption, bribery, money laundering

2.4 Observance of relevant trade regulations

2.5 Good relations with political institutions and authorities

14

15

16

5 Observance of the principles of conduct

6 Contacts to ask questions and report violations

7 Validity of the Code of Conduct

3 Our responsibility for people and the environment

09

09

10

10

11

11

3.1 Respect and dignity

3.2 Fair working conditions in a safe environment

3.3 Conflict minerals

3.4 Protect and preserve the environment

3.5 Occupational safety, health and fire protection

3.6 Constructive relations with employee representatives


Code of Conduct 03

How we set ourselves apart.

Legally compliant, socially responsible corporate governance forms the basis of our business

conduct at KOCH. To ensure that our joint conduct maintains a high standard of integrity, we

have developed the present principles that govern our doings – our Code of Conduct.

How we meet our responsibilities, how we make decisions, and how we deal with each other

and third parties: this is set out in our Corporate Culture Guidelines. Taking these as a basis,

the Code of Conduct forms the binding framework for everything we do and, at the same

time, defines what we expect of our business partners.

Our principles of conduct combine two key aspects: firstly, the requirement to observe law

and justice; secondly, the special demands on responsible behavior.

Our common objective is to integrate these principles of conduct into our day-to-day activities

and to comply with them as a matter of course. Consequently, we pay close attention to

ensure that these principles are observed by us all, by each individual. This enables us to

strengthen the reputation of KOCH and shape our success over the long term.


Code of Conduct 04

1

KOCH Corporate Culture

Guidelines

KOCH cultivates a corporate culture that is filled with life by everyone – employees and management alike. In addition

to being apparent at all times and governing our actions, this corporate culture shapes cooperation within the

company, our relations with customers, and, subsequently, the quality of our products and services.

We share the fundamental values strong, open-minded, and reliable with the other brands of the Uhlmann Group. Our

guidelines refer to the mission statement of the Uhlmann Group. Above all, however, they are the cornerstone of

our long-term thoughts and actions as KOCH Pac-Systeme GmbH.

BASIS FOR OUR ACTIONS

We are a team. Together we achieve more.

We are innovative and flexible. Our aim is to be a trendsetter and technology leader in order to strengthen and

expand our market position.

We are competent. We generate solutions with added value, thus securing our future.

We act purposefully. We meet the expectations of our customers, shareholders, and seniors.

We are conscientious. We identify ourselves with KOCH and our work.

The objective of our common actions is excellent quality.


Code of Conduct 05

2

Our responsibility

as business partner

2.1 FAIR COMPETITION AND TRANSPARENCY

Our business performance is achieved through fair and honest conduct, and we unequivocally

acknowledge the existence of free and open markets. We compete nationally and internationally

against our competitors solely through the quality and efficiency of our products and services. In

doing so, we always abide by rules and regulations, as well as ethical principles.

We cultivate trusting, fair, and respectful relations with our business partners and we expect the

same of them, also when dealing with third parties. Our partners are selected on the basis of their

performance, which we assess thoroughly and fairly.

We do not enter into any anticompetitive agreements with competitors on set prices or sales

conditions. We neither divide customers or sales areas between ourselves and our competitors, nor

do we participate in anticompetitive boycotts or other illegal methods of competition. If we hold a

dominant market position, we do not misuse this.

When dealing with our authorized sales partners, we adhere to the specific antitrust conditions

governing distribution systems.


Code of Conduct 06

2

2.2 QUALITY AND SAFETY OF OUR PRODUCTS

We define excellent quality as the continuous improvement of all processes. The guiding principles of our quality

philosophy and the key aspects of our quality policy are based on this. Quality reliability necessitates our adherence to

all relevant safety standards, and the implementation of measures that consistently optimize our products and

services and meet the principles of our quality philosophy and policy.

We set standards.

We strengthen our technological leadership by remaining innovative: developing new solutions for customized packaging

systems; making use of opportunities in existing markets; and tapping into the potential of new markets.

We remain a partner beyond the present.

We advise and support our customers over the entire life cycle of their packaging machines and lines, thus enabling a

consistently high level of productivity. Our customer relations focus on the long term – we are a reliable partner over

decades.

We recognize and meet customer requirements.

The KOCH product and services portfolio is specifically aligned to the needs of our customers today and tomorrow.

We are able to shape a cost-efficient and reliable packaging process for every customer on this basis – always tailored

to the respective requirements.

We personify excellent quality.

All employees are responsible for the quality of their personal performance. In the interest of our objective – excellent

quality – our employees receive every form of support to ensure methodical procedures and promote quality awareness.


Code of Conduct 07

2

2.3 NO CORRUPTION, BRIBERY, MONEY LAUNDERING

To prevent the misuse of trust placed in us by customers, business partners, and the

public, we firmly oppose any forms of corrupt conduct. It is strictly forbidden to abuse

a position of trust in any capacity at KOCH with the intention of gaining a material or

immaterial benefit.

We are not open to bribery! Gifts are only permitted to the extent that arises from the

ordinary course of business. Our employees do not respond to the promise or offer of

benefits, nor do they solicit any personal advantage themselves. We avoid even

the mere semblance of influence on business partners (e.g., customers, suppliers, or

authorities).

Examples of personal gain that are not tolerated:

Monetary gifts

Gift vouchers

Personal favors

We adopt all necessary preventive measures to prevent money laundering in our

sphere of influence. We carefully select our business partners and only accept money

transactions (particularly cash payments) in compliance with statutory provisions.

We always do business on the basis of prevailing and applicable anticorruption,

bribery, and money laundering regulations.


Code of Conduct 08

2

2.4 OBSERVANCE OF RELEVANT TRADE REGULATIONS

KOCH abides by international trade control regulations and sanction provisions. Among many others,

these include cargo security, as well as the classification, valuation, and marking of products. We

expect the same legally compliant conduct of our suppliers and business partners.

2.5 GOOD RELATIONS WITH POLITICAL INSTITUTIONS AND AUTHORITIES

We work constructively with political institutions and authorities, while protecting our own interests

and rights. Public announcements always include full, true details, and are prepared and made

available in a timely manner.


Code of Conduct 09

3

Our responsibility for people

and the environment

3.1 RESPECT AND DIGNITY

Everyone at KOCH is considerate and respectful at all times. We respect and protect the dignity of every

individual. Discrimination and mobbing are not tolerated by us.

3.2 FAIR WORKING CONDITIONS IN A SAFE ENVIRONMENT

Our employees form the basis of our business operations and our success. We aim to attract committed and

capable employees. When selecting personnel, the factors age, disability, ethnic origin, color, gender, sexual

identity, nationality, religion, or marital status are not an issue as regards equal opportunities.

Our employees encounter fair, safe, socially acceptable, and healthy working conditions, which are consistently

further developed. No exploitation takes place – we firmly reject this. Payment and social benefits are at least

equal to the local or national legal requirements. We adhere here to the principle “equal pay for equal work”.

National regulations and agreements concerning working hours and rightful, paid vacation are also observed.

We also expect our suppliers and business partners to commit themselves to these standards, and that they in

turn make sure their suppliers comply with these policies.


Code of Conduct 10

3

3.3 CONFLICT MINERALS

Our suppliers must ensure responsible sourcing of coltan (tantalum), cassiterite (tin), wolframite (tungsten), and

gold ore, as well as their derivatives. Their supply chain must be conflict-free. This applies to all materials, parts,

components, and subassemblies (goods) directly used in KOCH products. This way, we ensure that the use and sale of

products containing these conflict minerals (3TGs) by KOCH suppliers have not been made possible through the use

of forced labor or by contributing to the continuation of armed conflicts in the Democratic Republic of the Congo and

its neighboring countries. By stipulating this requirement, we bind our suppliers to compliance with both the “final

rule” of the Dodd-Frank Wall Street Reform and Consumer Protection Act (US Federal Law), adopted on August 22,

2012, and the EU Conflict Minerals Regulation, which comes into effect from January 2021.

3.4 PROTECT AND PRESERVE THE ENVIRONMENT

Thinking and acting sustainably is part of our social responsibility. This includes environmentally conscious and

eco-friendly operating principles, compliance with relevant environmental laws, and the use of technologies that are

as sustainable as possible. We are careful with our working materials and only use these for their intended purpose.

We endeavor to use our resources efficiently and attain an appropriate ecological footprint.


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3

3.5 OCCUPATIONAL SAFETY, HEALTH AND FIRE PROTECTION

We provide a safe and healthy working environment – and expect our employees to adhere to the relevant safety

regulations.

Occupational safety

We pay very strict attention to occupational safety and reinforce this with regular training measures.

Health protection

The health of our employees is a vital commodity that deserves protection. This is all the more important in view

of the ongoing technical changes and longer working lives that are transforming our working world on account

of globalization. In order to master these challenges successfully, we need motivated, healthy employees.

Consequently, we promote and support health-conscious activities and conduct through our broadly based

company health management.

Fire protection

We systematically enforce statutory fire protection regulations and reinforce compliance with regular instruction

and fire drills.

3.6 CONSTRUCTIVE RELATIONS WITH EMPLOYEE REPRESENTATIVES

Every KOCH employee can support labor unions or other forms of democratic employee representation. In doing

so, national regulations and existing agreements must be respected. Our cooperation with employees, employee

representatives, and labor unions is constructive, with a fair balance being sought between the economic interests

of our company and the interests of the employees. Also, in the case of controversial disputes, it is our declared

objective to shape and maintain constructive cooperation over the long term.


Code of Conduct 12

4

Protection of information

and data

We protect the trade secrets of our company and those of our business partners by handling them

confidentially. An obligation of secrecy is imperative and it is essential to handle information correctly.

We attach great importance to the integrity and accuracy of information generated by us, do not

make improper use of confidential information, and prevent unauthorized disclosure to third parties.

4.1 CORRECTLY KEPT BOOKS AND RECORDS

KOCH applies and adheres to the generally accepted accounting and financial reporting principles.

Principle of true and fair representation

Principle of clarity and transparency

Principle of individual evaluation

Principle of completeness

Principle of regularity

Principle of certainty

Document principle

We compile all data and records completely, correctly, and in good time. Our internal and external

reporting is seamless and correct.


Code of Conduct 13

4

4.2 SAFETY AND PROTECTION OF DATA

Data security impacts our business success and our public image. We are aware of the high sensitivity

of data entrusted to us and protect it against unauthorized access, unwarranted and improper use,

loss, or premature deletion. This applies to business and employee data, as well as the personal data

of our business partners and customers. We take a variety of technical and organization measures to

secure the availability, integrity, and confidentiality of personal or personally identifiable data.

Every individual is responsible within the scope of his or her job to secure a high privacy standard at

KOCH. All employees strictly adhere to the privacy policy as well as the General Data Protection

Regulation (GDPR) of the EU, and respect and observe in particular the full rights of the persons

whose data they collect, store, process, and use.

4.3 SECRECY IN GENERAL

In addition to technical and organizational data privacy measures, all employees are obliged to

protect our business interests. Consequently, information from KOCH or concerning KOCH is only

communicated to authorized recipients. This applies internally and externally in equal measure. We

treat sensitive information confidentially and do not allow unauthorized persons to view business

documents.


Code of Conduct 14

5

Observance of the

principles of conduct

The KOCH Code of Conduct is absolutely essential and we explicitly emphasize the

necessity to adhere to the principles of conduct defined in it. Every employee is

personally responsible for compliance.

Violations against the Code of Conduct will not be tolerated. Employees involved

in any infringement are obliged to amend their conduct. In the case of serious

violations, criminal or disciplinary measures may ensue. All employees are obliged to

promptly report to one of the contacts below should a violation or suspected infringement

be revealed. We ensure that no disadvantages whatsoever are experienced

by employees who make such a report.


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6

Contacts to ask questions

and report violations

The following bodies or groups of individuals are the ones to contact in

the case of questions concerning the KOCH Code of Conduct, or to report a

violation or a corresponding suspicion.

Your immediate superiors

Management Board


Code of Conduct 16

7

Validity of the

Code of Conduct

The KOCH Code of Conduct comes into effect upon adoption by the

Management Board.

Pfalzgrafenweiler, February 24, 2020

KOCH Pac-Systeme GmbH

Harald Jung

Chairman of the Management Board

(CEO)

Karl Kappler

Managing Director

(CTO)


KOCH Pac-Systeme GmbH

Dieselstrasse 13

72285 Pfalzgrafenweiler

Germany

Phone +49 7445 181-0

Fax +49 7445 181-50

info@koch-pac-systeme.com

www.koch-pac-systeme.com

Concept and design: Volker Laucher, Grafik Design, Stuttgart, Germany 02/2020

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