CODE of CONDUCT

to the social responsibility of the ENCORE Group

ENCORE1 defines itself as an extremely customer-oriented company. Customer satisfaction is a particular focus of the company’s activities. In addition, ENCORE sees a special responsibility in the personal and professional development of its employees. The benchmark for any action in the company is ultimately the economic success that forms the basis for the further development of companies and employees. With regard to corporate social responsibility, management and employees, ENCORE supports social engagement both regionally and nationally (usually referred to as ‚CSR‘² internationally) and is committed to environmental action. This Code of Conduct on Corporate Social Responsibility (hereinafter referred to as “CoC”) sets out a guide to what this means in particular with regard to working conditions, social and environmental compatibility as well as transparency, trustful cooperation and dialogue.

1. Basic understanding of socially responsible corporate governance

This CoC is based on a common basic understanding of socially responsible corporate governance. This means that all employees of ENCORE take responsibility and consider the consequences of their business decisions and actions in economic, technological as well as social and ecological respects and bring about an appropriate balance of interests. ENCORE voluntarily contributes to the well-being and scope for action of the global society at the sites where the Company Group operates, within the scope of its scope and latitude. We are guided by universal ethical values and principles, in particular integrity and righteousness and respect for human dignity.

2. Scope

2.1 This CoC applies to all branches and business units of ENCORE.

2.2 ENCORE undertakes to promote compliance with the contents of this CoC also with suppliers and in the further value-added chain within the scope of the respective possibilities and areas of action.

3. Key points of socially responsible corporate governance

3.1 Compliance with laws

ENCORE complies with applicable laws and regulations of the countries in which we operate. Violations of any kind harm the reputation of our company and, moreover, may result in serious legal consequences for the company or persons acting on it. All employees are expected to comply with applicable laws and regulations. Violations of legal provisions may entail sanctions such as labor law measures, but also damages and even criminal consequences for the company, third parties or sanctioning institutions. For countries with a weak institutional framework, ENCORE carefully examines which home -country business practices should be used to support good corporate governance.

3.2 Integrity und Organizational Governance

3.2.1 ENCORE bases its action on universal ethical values and principles, in particular integrity, respect for human dignity, openness and non-discrimination of religion, belief, gender and ethnicity.

3.2.2 ENCORE rejects corruption and bribery in accordance with the relevant UN Convention. We promote appropriate transparency, integrity and responsible leadership and control in the
company.

3.2.3 ENCORE pursues non-disruptive and accepted business practices and fair competition. In competition it is geared to professional behavior and quality work. We maintain a partnership and trusting relationship with the supervisory authorities.

3.2.4 ENCORE keeps books (accounts) in compliance with applicable accounting regulations and tax laws in compliance with legal and regulatory requirements.

3.3 Consumer Interests

As far as consumer interests are concerned, ENCORE adheres to consumer protection regulations and appropriate sales, marketing and information practices. In this regard we especially protect vulnerable groups including minors.

3.4 Communication

ENCORE or the managing directors communicate openly and conversationally about the requirements of this CoC and about its implementation towards employees, customers, suppliers and other interest groups and stakeholders. All documents are duly created, not changed or destroyed unfairly and stored properly. Company secrets and business information are handled sensitively and confidentially.

3.5 Human Rights

ENCORE is committed to promoting human rights. We respect human rights in accordance with the UN Charter on Human Rights, in particular the following:

3.5.1 Privacy: Privacy is anchored in accordance with the EU-GDPR and or applicable national data protection laws and regulations with which ENCORE complies.

3.5.2 Health and Safety: ENCORE takes the necessary measures at all workplaces to prevent accidents and health hazards and ensures compliance with health and safety regulations. The employees of ENCORE comply to the best of their knowledge and belief in the relevant regulations and requirements.

3.5.3 Harassment: ENCORE is committed to ensuring that every employee is treated with dignity and respect and can work in a work environment free from physical harm and sexual, psychological or verbal harassment. Indications of violations will be dealt with promptly, with the protection of the interests of victims and witnesses.

3.5.4 Freedom of opinion: protection and granting the right to freedom of opinion and expression.

3.6 Working Conditions

ENCORE adhere to the following core labor standards of the ILO³:

3.6.1 Child labor: The prohibition of child labor, that is employment of persons younger than 15 years unless local legislation sets higher age limits.4

3.6.2 Forced labor: the prohibition of forced labor of any kind.5

3.6.3 Remuneration & Minimum Wage Act: The labor standards with regard to remuneration, in particular with regard to the remuneration level in accordance with the applicable laws and regulations. We hereby declare compliance with all applicable Minimum Wage Laws.

3.6.4 Workers‘ rights: Respect for the workers’ right to freedom of association, freedom of assembly and collective bargaining, as far as legally permissible and possible in the respective country.

3.6.5 Non-discrimination: ENCORE assures a non-discriminatory treatment of all employees.6

3.7 Working Hours

ENCORE complies with the labor standards regarding the maximum permissible working time.

3.8 Company property

The property of ENCORE must be treated with care. Furnished furniture, office supplies or IT equipment must be handled with care and used appropriately. Consumables are to be used sparingly.

3.9 Environmental protection

ENCORE meets the environmental standards that apply to its operations and acts environmentally aware at all locations. We also use natural resources responsibly in accordance with the principles of the Rio Declaration.7

3.10 Disclosure and Confidentiality of information

ENCORE is committed to treating trusted and / or personally identifiable information in compliance with the OECD’s International Policy and the European Data Protection Convention (EU GDPR), to keep confidential any information regarding business relations, intellectual property, financial condition, business development and / or other relevant information that are to be considered as trustworthy. Under consideration of legal regulations ENCORE will treat such information separately in frame of a confidentiality agreement or secrecy obligation.

3.11 Civic Engagement

ENCORE contributes to the social and economic development of the country and region in which it operates and promotes corresponding voluntary activities of its employees.

3.12 Donations
All donations on behalf of ENCORE and its affiliates are to be submitted to the Managing Directors / CFO for approval. Donations to political or party foundations or institutions are not permitted.

3.13 Invitations and Gifts

ENCORE employees do not accept invitations and gifts that have the character of a personal advantage, or – if the assumption is unavoidable -treat them in accordance with legal regulations.

4. Implementation and Enforcement

ENCORE undertakes all reasonable efforts to continuously implement and apply the principles and values described in this CoC. Contractual partners should be informed on request and also in the context of reciprocity about the essential measures, so that it becomes comprehensible how the compliance of these CoC principles is guaranteed. A claim to the disclosure of trade and business secrets, concerning competition or otherwise worth protecting information, does not exist.

1 ‚ENCORE‘ – ENCORE EMEA and its branches and business units
2 CSR = Corporate Social Responsibility 
3 ILO = International Labour Organziation
4 ILO-Convention Nr. 138 of 1973 and ILO-Konvention Nr. 182 of 1999
5 ILO-Convention Nr. 29 of 1930 and ILO-Konvention Nr. 105 of 1957
6 ILO-Convention Nr. 111 of 1958
7 The 27 principles of the “Rio Declaration on Environment and Development” of 1992 as a result of the of the United Nations Conference on Environment and Development in Rio de Janeir