Introduction

KACO sees itself as a company with a culture shaped by medium -sized businesses. Our goal is to be a global leader with a strong presence in all relevant markets. Our basic understanding includes sustainable management. By this we mean the harmony between economic, ecological and social responsibility in all our activities as well as in the entire supply chain.
Our values are based on national and international laws, conventions and guidelines, such as the principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the relevant conventions of the International Labor Organization (ILO), and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
This Code of Conduct defines our minimum requirements with regard to human rights, labor standards, occupational safety, health protection, sustainability, climate and environmental protection and business ethics. KACO and every employee (f/m/d) of KACO are obligated to comply with all legal and official regulations as well as the requirements stated herein.
KACO suppliers and contractors (hereinafter referred to as “Suppliers”) are obliged to recognize this Code of Conduct and to define corresponding principles within their company and towards their suppliers and to pass them on in the supply chain.

1. human rights

Internationally recognized human rights, such as the “UN Guiding Principles on Business and Human Rights”, the principles of the “UN Global Compact” and the internationally recognized standards of the ILO, are respected and compliance with them is required at KACO and throughout the entire supply chain. Furthermore, we require our suppliers to actively cooperate and support us in identifying and classifying potential risks, for example through self-disclosure, on-site assessments or, if necessary, through commissioned third parties, in order to actively prevent the impairment of human rights and to eliminate known impairments within the scope of due diligence. KACO reserves the right to review the implementation and effectiveness of these measures. 

KACO recognizes the special rights of minorities and indigenous peoples as well as women’s rights.

Ensuring public safety and order is a task of the state security authorities. Insofar as the use of private security forces can lead to human rights violations, private security forces are not to be used for this purpose.

2. compliance with laws

Compliance with applicable laws, regulations, equivalent rules and contractual agreements as well as with the values and principles of conduc t additionally defined herein are mandatory requirements for KACO and all KACO employees (f/m/d) as well as for all suppliers. This also includes the respect of property, land, forest and water rights as well as the refusal of forced evictions. Violations can lead to considerable damage and result in serious consequences for all stakeholders. Therefore, they will not be tolerated by KACO.

3. data and information protection, intellectual property

We protect and respect the personal data and privacy of our employees (f/m/d) just as conscientiously as the personal data of our business partners. We are equally conscientious in protecting confidential information of our customers, suppliers and our company. KACO complies with all applicable laws regarding the protection of personal data and trade secrets in all countries where business activities are conducted. All KACO employees (f/m/d) are required to observe trade secrets, respect intellectual property and protect personal data. We also require this from all suppliers in the supply chain.

4. counterfeit parts

KACO requires its suppliers to establish and maintain effective methods and processes to identify and minimize the risk of introducing counterfeit parts and materials into the supply chain. When counterfeit parts or materials are identified, they must be reliably secured and removed from the supply chain. The recipients of counterfeit parts or materials must be informed immediately.

5. working conditions, equal opportunities, and diversity

Recruitment of employees (f/m/d) is carried out according to ethical principles, i.e. lawfully in compliance with international labor standards and in a fair and transparent manner, respecting human rights.
Any form of child labor is rejected. The local legal regulations, but at least the regulations of ILO Convention 138 on the minimum age for employment and on the prohibition of child labor, must be observed. The stricter regulations are to be applied. It is of highest priority to protect children from being forced to do harmful work. No overtime or night work may be required of juvenile workers (f/m/d).
Forced and compulsory labor, debt bondage, human trafficking and modern slavery are rejected. No one is employed or forced to work against their will. The withholding of identity documents or entry papers from workers (w/m/d) or involvement in this is prohibited.
Only workers (f/m/d) who are legally allowed to work in the country may be employed.
Freedom of movement in the workplace when entering or leaving the facilities provided by the company must not be unreasonably restricted.
All employees (f/m/d) may terminate their employment contracts at any time in compliance with the contractual, collectively agreed or statutory notice periods.
Recruitment fees shall not be charged to employees (f/m/d) in any manner.
In employment, the principle of equal opportunity must be upheld and any discrimination must be refrained from.
Employees (f/m/d) shall not be discriminated against on the basis of gender, race, marital status, color, national origin, nationality, disability, ethnic or cultural origin, religion or belief, union membership, age or sexual orientation. Unacceptable treatment of employees (f/m/d), such as psychological hardship or sexual and personal harassment, is rejected.
We are committed to diversity, equality and inclusion and promote the inclusion of people with disabilities in the workforce. Employees (f/m/d) have the right to fair remuneration.
The applicable regulations on minimum wages must be observed and wages must be paid on time. Wage deductions may not be used as a disciplinary measure. Working hours and non-working hours must at least comply with the laws applicable in the respective country.
Employment contract regulations must be in writing and must be available in an understandable form or language to the employees (f/m/d) as well as the future employees (f/m/d).
KACO requires its suppliers to comply with these requirements, to pass them on in the supply chain and to verify their implementation.

6. occupational safety and health protection

Safety and health protection in the workplace are ensured at least within the framework of the applicable national regulations. The aim is to create and continuously improve a safe working environment in order to prevent accidents and health impairments arising from, connected with or occurring in the course of work. Employees (f/m/d) have the right to refuse unsafe work and to report working conditions that are hazardous to health.
Hazards in the workplace must be analyzed and minimized as far as possible through a prioritized process of substituting technical protective measures, organizational protective measures and personal protective measures (STOP).
In occupational health and safety, prevention takes precedence over damage limitation.
In case of a serious health hazard, such as a pandemic, all measures are taken to protect employees.
The facilities and accommodations for on -site employees must ensure the dignity, hygiene and safety of the individual. Their conditions must comply with national laws.
KACO complies with all legal and official regulations on occupational health and safety and also requires its suppliers to do the same.

7. sustainable resource management

Sustainable value creation is based on the three pillars of economic, ecological and social responsibility in all KACO business activities.
It is our task to use natural resources for our production processes, products and services as carefully and prudently as possible. One focus here is on energy conservation and the use of renewable energies, the responsible handling of so -called conflict minerals and generally critical materials such as Mica-Minerals. The use of raw materials from deep-sea mining is prohibited. Furthermore, the focus is on the economical use of fresh water and the minimization of pollution and waste. To this end, all processes are constantly optimized. We dispose of residual materials that we cannot avoid or recycle in a responsible manner and in compliance with all legal regulations.
We protect soil quality, refrain from overexploitation and deforestation, and thereby contribute to the preservation of biodiversity, species diversity, and wildlife habitats.

8. environmental and climate protection

We are aware of our responsibility to protect the environment and climate, people, animals and plants. To this end, we design all processes of the product life cycle of our products, from the design of the products, production and use to disposal at the end of the cycle, to be as environmentally and health compatible as possible and continuously develop them further. We reduce energy consumption, increase energy efficiency and steadily increase the use of renewable energy to reduce air po llution and greenhouse gas emissions. We ensure that no harmful noise emissions are caused by us. We reduce
material use to reduce waste generation and continue to strive to close the value -added circular economy.
We comply with all legal and regulatory requirements for environmental and climate protection.
We require our suppliers to actively promote climate and environmental protection. To demonstrate and further develop the activities, we recommend the suppliers to join corresponding initiatives.
Upon request, KACO shall require its Suppliers to provide environmental and climate data such as the CO2 footprint (Scope 1 -3), waste generation, water consumption, etc., including the basis of calculation for the products and services delivered to KACO.
Furthermore, KACO may require Suppliers to provide the data on platforms specified by KACO.
The collection, calculation, evaluation and communication of data shall be in accordance with the applicable Greenhouse Gas Protocol (GHS Protocol) norms and standards, unless other methods are specified by KACO in individual cases.

9. responsible handling of chemicals

We use chemicals responsibly to protect the environment and employees (f/m/d) in particular and dispose of chemical residues that we cannot avoid or recycle in a responsible manner. We comply with regulations on banned and declarable substances such as ELV, REACH and RoHS. Our suppliers are also obliged to comply with these regulations and to provide KACO with qualified proof of this.

10. social responsibility

We make an appropriate contribution to training and employment.
We encourage our employees (f/m/d) to participate in institutions and associations that serve the good of the community.

11. freedom of association

The right of employees (f/m/d) to associate, join a trade union, appoint representation and be elected to such representation shall be respected. KACO grants employees (f/m/d) the right to engage in collective bargaining to regulate working conditions and to voice their concerns.

12. prohibition of corruption and bribery

The applicable anti-corruption laws must be strictly observed. No bribes or other illegal payments or monetary benefits may be offered, made or accepted. In dealings with business partners and government institutions, the inte rests of the company and the private interests of employees (f/m/d) on both sides are strictly separated. Actions and decisions are made free of extraneous considerations and personal interests.

13. prevention against money laundering

KACO complies with legal obligations to combat money laundering and terrorist financing and also requires its suppliers to do the same.

14. export control

National and international laws and regulations govern the import and export of goods and the provision of services. KACO’s processes ensure that export control and sanctions laws are not violated and KACO requires the same from its suppliers.

15. competition and antitrust law

We require all managers (f/m/d), employees (f/m/d) and suppliers to comply in all respects with all competition and antitrust laws that ensure the functioning of a market and thus prevent undue restrictions of competition. We require our suppliers to carry forward and ensure these expectations in the supply chain as well.

16. financial responsibility and transparency

At KACO, key business processes are properly documented and relevant financial information is recorded to faithfully reflect business operations with complete reports.
Employees (f/m/d) who, in the course of their work , collect or transmit accounting or financial data, calculate and transmit indicators, or manage and disseminate other types of information must ensure that such data, indicators and information are accurate, reliable and honest. KACO complies with its statutory disclosure and reporting obligations in full and on time.

17. audits at suppliers

KACO and KACO’s customers are generally entitled to conduct audits of suppliers and subcontractors upon prior notice and within regular working hours.
Furthermore, Suppliers are obliged to participate in self-assessments on the topics listed in the Code of Conduct on platforms specified by KACO upon request.
Suppliers are obliged to define and implement improvement measures in case of non-achievement of the targets and to check the effectiveness. KACO may verify this on site if necessary.

18. handling of violations / complaints

Violations of these standards will not be tolerated. All KACO employees (f/m/d) and external stakeholders are encouraged to report any violations in KACO’s business units as well as in the supply chain. Reports can be made through various channels, such as the whistleblowing system on the KACO website, confidentially to the W orks Council, or to the General Manager. KACO will not tolerate any form of discrimination against anyone who makes such a report. We also expect our suppliers to establish an appropriate complaints management system.
By putting the Code of Conduct into effect, KACO’s management confirms compliance with the requirements described herein.
In the event of non-compliance with any obligation under this Code of Conduct, including the withholding of audit rights, KACO reserves the right to terminate the business relationship in whole or in part with immediate effect.

Consent of the supplier

As a supplier to KACO, we recognize this Code of Conduct and act in accordance with the requirements set forth herein. We pass on these requirements to our suppliers in the form of this Code of Conduct or through our own equivalent code and ensure compliance through appropriate measures