SUPPLIER CODE OF CONDUCT
GERMAN DESIGN CONSULTING INC. | LAST UPDATED, May 1st, 2025
TABLE OF CONTENTS
Sustainability is a key element of German Design Consulting’s values and forms an integral part of our business strategy.
INTRODUCTION
German Design Consulting, Inc. expects all its suppliers to meet or exceed all applicable laws and regulations. We encourage suppliers to go beyond legal compliance by committing to meet relevant international standards (such as those from the International Labor Organization or applicable UN conventions) and to commit to continuous improvement.
These standards are intended to guide you as you fulfill your role as a German Design Consulting supplier. They are not intended to change or replace any specific contractual requirements. Rather, this Code of Conduct establishes the basic principles for business conduct which German Design Consulting expects from you. If our companies have agreed to stricter or more detailed requirements than this Code of Conduct, then we expect you to meet those contractual requirements. This Code of Conduct has been created based on the principles set forth in internationally recognized standards such as the United Nations Declaration of Human Rights and International Labor Organization (ILO) Conventions. German Design Consulting may verify your compliance with this Code of Conduct by performing audits or other assessments of your facilities, records and business processes. Violation of the Code of Conduct may result in your disqualification as a German Design Consulting supplier and the termination of our business relationship.
This Code includes requirement in the following areas:
• Ethics
• Labor and Human Rights
• Health and Safety
• Environment
• Management Systems
ETHICS
German Design Consulting suppliers conduct their business in accordance with the highest ethical standards.
Act ethically
Conduct your business in accordance with the highest ethical standards, and require the same compliance throughout your entire supply chain.
Demonstrate a zero-tolerance policy prohibiting any and all forms of corruption and bribery. All business dealings should be transparently performed and accurately reflected within your records. Choose your business partners carefully and only after conducting a thorough background check.
Please note: Your monitoring and enforcement procedures must be sufficient to ensure compliance with applicable anti-corruption laws including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and EU-Bestechungsgesetz (EUBestG).
Financial Statements and other records
All of the Company’s books, records, accounts and financial statements must be
maintained in reasonable detail, must appropriately reflect the Company’s transactions and must both conform to applicable legal requirements and to the Company’s system of internal controls.
Do not give or receive bribes
Do not offer, give, receive, or solicit any bribes or other means to obtain any improper benefit or advantage. Do not allow others to make improper payments for your benefit.
Disclose information truthfully
We also expect you to truthfully and accurately disclose information regarding your business activities, structure, financial situation and performance in accordance with applicable laws, regulations and prevailing industry practices.
Respect intellectual property rights
Respect Intellectual property rights at all times. Any transfer of technology and know-how should be carried out in a manner that protects intellectual property rights.
Comply with fair business, advertising and competition laws
We expect you to understand and comply with all applicable fair business, advertising and competition laws including fair trading and antitrust laws.
Ensure that there are safe ways to report abuses
We expect you to create an environment where employees are comfortable raising concerns. You should have adequate “whistle-blower” or reporting channels available and feedback processes in place designed to ensure confidentiality and protection for employees and suppliers.
Avoid conflicts of interest
You will avoid conflicts between your company and German Design Consulting by ensuring that you disclose any personal or outside business arrangements between you and your company and any German Design Consulting employees or their families.
Source your materials responsibly
If you manufacture components, parts, or products containing tin, tantalum, tungsten or gold, you must source those materials from environmentally and socially responsible sources only. Materials, which either directly or indirectly contribute to conflict, are unacceptable. Suppliers in this category must exercise due diligence regarding the source and chain of custody of these minerals and make any due diligence measures available to German Design Consulting upon request.
Respect privacy
Commit to protecting the reasonable privacy expectations of personal information of everyone you do business with. This includes your suppliers, customers, consumers and employees. We expect you to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted or shared.
LABOR AND HUMAN RIGHTS
German Design Consulting suppliers ensure that human resources are managed in accordance with internationally recognized principles of corporate responsibility.
Ensure that employment is freely chosen
Do not use forced, bonded or imprisoned labor.
Do not use child labor
A “child” is any person who is younger than (i) 15 years old (or 14 where the law of the country permits); (ii) the minimum age for completing compulsory education in the country of employment; or (iii) the minimum age for employment in that country, whichever is the highest. Additionally, we expect you not to use anyone under the age of 18 to carry out work, which is likely to jeopardize their health, safety or morals.
Provide employees adequate time off
Take all appropriate steps to ensure workweeks do not exceed the maximum working hours as defined by local laws or applicable collective agreements except in emergency or extraordinary situations with the consent of the employee.
Provide adequate compensation and benefits
Ensure that your employees receive at least the minimum compensation, benefits and overtime payments required by law.
Treat employees with respect and dignity
Treat all employees with respect and dignity, and ensure that they are protected from physical, sexual, verbal or other forms of abuse, coercion or harassment.
Do not discriminate in employment or hiring practices
Do not discriminate in your employment or hiring practices. This includes discrimination based on race, color, age, gender, gender identity or expression, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, marital status, or any status or characteristic which does not relate to any individual’s qualifications or the inherent requirements for a job. Treat all applicants and employees with dignity and respect, and provide equal employment opportunities.
Allow freedom of association
Recognize your employees’ rights to join or refuse to join labor unions or associations and to bargain collectively as permitted by law.
HEALTH AND SAFETY
German Design Consulting suppliers provide their employees with a safe and healthy working environment in compliance with all applicable laws and regulations. We expect you to have effective safety programs covering such areas as: human safety, emergency preparedness, chemical, physical and biological agent exposure, ergonomics, which includes incident reporting and investigation.
ENVIRONMENT
German Design Consulting suppliers minimize their business operations’ negative impacts on the community, environment, and natural resources throughout their supply chain. Applicable laws and regulatory minimums in relation to climate and environmental protection must be followed.
Obtain necessary permits and observe reporting requirements
Obtain, maintain and keep current all applicable environmental permits, approvals and registrations. Suppliers should have and follow relevant operational and reporting requirements.
Don’t pollute the environment or waste resources
Ensure that you identify the environmental impacts of your operations, products and/or services. In addition and where possible, investigate ways to improve energy efficiency and reduce greenhouse gas emissions and water consumption, as well as ways to minimize waste generation and promote reuse and recycling.
Control any hazardous substances
Ensure that chemical and other materials that pose a hazard if released to the environment are identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
Implement proper waste management processes
Treat wastewater and solid waste generated from operations and sanitation facilities according to legal requirements and good environmental practices.
Don’t pollute the air
Characterize, monitor, control and treat as required prior to discharge air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations.
Comply with applicable laws and German Design Consulting requirements
Adhere to all applicable laws, regulations and any additional environmental requirements set forth by your agreement with German Design Consulting.
ANIMAL WELFARE
German Design Consulting requires all Business Partners selling animal-derived products to promote good animal welfare throughout their supply chains. We encourage all Business Partners to establish and implement their own Animal Welfare policies, which adopt the Five Domains Model and according Five Provisions and Aligned Animal Welfare Aims designed to assess and encapsulate both the physical and mental state of animals. We commit to strive for the same level of Animal Welfare within our Private Label supply chain, and to understand and reduce confinement, body alterations and journey times, whilst improving enrichment provision across the supply chains. We believe that animals should be pre-stunned at slaughter and are committed to supporting One Health approach to antimicrobial resistance.
German Design Consulting does not permit the use of live animals in photoshoots. Business Partners using animal imagery in marketing materials should ensure imagery used is sensitive to animal welfare issues.
German Design Consulting is committed to increasing traceability and transparency across our supply chain and the industry as a whole. We acknowledge that progress in implementing our Animal Welfare Policy can only be achieved where Business Partners have systems in place to trace back to the source of primary production within their supply chains. We expect all Business Partners to provide key sourcing information as standard about the animal-derived materials they use, including the name of the species of animal (common and Latin), country of origin where applicable (where the animal was reared and slaughtered), and any relevant documentation showing proof of good animal welfare or compliance of materials.
MANAGEMENT SYSTEMS
German Design Consulting suppliers have adequate management systems in place, which are designed to ensure conformance with this Code of Conduct.
Recognize and Protect German Design Consulting Confidential and Personal Information
From time to time you may have access to German Design Consulting Confidential Information and personal information that belongs to our employees, customers, developers and others. You should recognize that information and take appropriate actions to protect it from misuse and improper disclosure. If you have questions, contact your German Design Consulting representative for help.
Commit to corporate, social and environmental responsibility
We encourage you to have corporate, social and environmental responsibility statements, endorsed by executive management. These should affirm your commitment to the values and topics addressed in this document and to their continuous improvement.
Know who is responsible
Identify who in your company is responsible for ensuring implementation of your management systems and associated programs.
Understand your obligations
Ensure that you have adequate process in place for identifying, monitoring and understanding applicable laws, regulations and German Design Consulting’s requirements, including the requirements of this Code of Conduct.
Assess and manage your risks
Have adequate process in place for identifying risks (such as the environmental, health and safety, labor and human rights, ethics and legal compliance) associated with your operations and have appropriate procedural and controls to manage such risks and ensure regulatory compliance.
Communicate your expectations clearly and provide adequate training
Have sufficient processes to ensure that clear and accurate information about your policies, expectation and performance, including the requirements in this document, is communicated to your employees, suppliers and customers. In addition, have sufficient training programs in place to ensure proper implementation.
Always strive for improvement
Periodically evaluate your conformity to the standards set forth in this document and maintain open discussions with German Design Consulting in order to maintain continuous improvement, and correct any deficiencies in a timely fashion.
Maintain proper documentation and records
Ensure that you and your suppliers have adequate process for the creation and maintenance of documents and records designed to ensure regulatory compliance and conformity to document along with appropriate confidentiality to protect privacy.
VIOLATION OF OUR SUPPLIER CODE OF CONDUCT
Failure to comply with this document, any additional requirements set forth by German Design Consulting, or any applicable laws and regulations may result in the termination of any agreement as a German Design Consulting supplier and referral of the matter to local authorities. You may report suspected violations to: info@g-dc-inc.com