Business Code of Conduct

Vogler BV conducts its business based on its core principles of Safety, Integrity and Sustainability. We expect our business partners, to do the same.
This Code explains these core principles and specifies what G. Vogler BV expects. It shows what we stand for.

Safety – People safety

The workplace our partners provide must be safe. Employees and contractors must be made aware of safety rules and instructed to apply them at all times, while at work, visiting customers or travelling.

Safety – Process safety

It is important that our partners systematically assess and control the operational risks of hazards, injuries, waste or harm resulting from their activities for us, such as research, manufacture and transport. Their employees and contractors must follow safety procedures, and safety risks and incidents must be reported and controlled promptly.

Safety – Product safety

Our partners must comply with product safety regulations, label products properly and communicate product-handling requirements. People exposed to products manufactured for and supplied by G. Vogler BV must be protected from exposure to hazardous substances. Products supplied by G. Vogler BV, and the raw materials used to manufacture these products, meet all applicable product regulatory requirements.

Integrity – We expect that all of our partners conduct business fairly and with integrity.

We expect that all of our partners conduct business fairly and with integrity. They will not make, offer or authorize bribes, or conduct any form of unethical business practice. They do not make facilitation payments. Entering into a business transaction with or for G. Vogler BV or accepting certain terms and conditions may not be influenced by gifts or entertainment.

Our partners do not offer G. Vogler BV employees gifts or entertainment of more than modest value. They never offer cash or cash equivalents such as gift cards to our employees.

Integrity – Trade controls

It is essential that our partners comply with export control regulations applicable to their business, and that they provide accurate and truthful information about it to customs and other authorities when required. They identify and manage trade restrictions applicable to their business with us, including those of sanctioned countries and parties.

Integrity – Intellectual property and confidential information

We expect our partners to respect intellectual property rights, including those of G. Vogler BV. There must be appropriate measures to prevent disclosure or unauthorized use of G. Vogler BV confidential information made available to them.

Integrity – Personal data

Our partners protect the personal data of G. Vogler BV’s employees and use this data for legitimate and authorized business purposes only. They must be clear on when and how they collect, use or share personal data. They take appropriate security measures to protect the data.

Integrity – Conflict of Interest

Decisions our partners employees take in regards to G. Vogler BV business transactions may not be influenced by personal or private interests. Personal or friendly relationships with an employee may not be used to influence the employee’s business judgment. If an employee is related to an G. Vogler BV employee, and this may represent a potential conflict of interest in a transaction or business relationship, our partners must disclose this fact to G. Vogler BV or ensure that the G. Vogler BV employee does. Our partners do not provide financial or other support to political parties to influence transactions with or for G. Vogler BV.

Integrity – Company resources

If they use or have access to G. Vogler BV resources, including people, systems, networks and facilities, our partners must use these resources appropriately, in accordance with G. Vogler BV instructions and for their intended business purpose only.

Integrity – Record Keeping

We expect our partners to keep accurate, complete and up-to-date records on their transactions with G. Vogler BV. These records must be retained in accordance with applicable laws.

Integrity – preventing fraud

Our partners must have internal controls designed to detect, prevent and respond to fraud and money laundering. Transactions must be properly recorded and subject to review. Any potential fraud that may have an impact on G. Vogler BV must be reported to us immediately.

Integrity – proper communication

Factual and timely communication with us is essential to a strong relationship. Our partners will not disclose our confidential information without permission. They consider business communications carefully and ensure that they meet high standards. They will not issue press releases about us, our products or our business relationship without our approval.

Sustainability – Human rights

Our partners recognize the human rights of all people as outlined in the Universal Declaration on Human Rights and the UN Guiding Principles on Business and Human Rights. They take responsibility for avoiding infringement of human rights and for remediating the impact, if any, on human rights resulting from activities performed for us and from products made for us.

Sustainability – Employment relationships

The business partner’s employees hired and retained should be suitable for the job. Our business partners are committed to apply principles of the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. People are not employed against their will, transported for exploitation, engaged in slavery or servitude, nor deprived of their rights. Legal minimum age requirements as outlined in the relevant ILO conventions and the laws of the countries of operation are adhered to and children under the age of 16 are not employed.

The people our partners deal with are treated with dignity and respect. Our business partners do not harass or discriminate, whether through culture, nationality, race, religion, gender, political preference, disability, association, sexual orientation or age.

Working hours and remuneration must comply with laws while being fair and just. Overtime is compensated and leave is offered as required. Individual rights to freedom of opinion and association, including the right to collective bargaining, are respected.

Sustainability – Environment and community

Our partners comply with all relevant environmental laws and ensure that the necessary permits are in place. They are committed to the efficient use of raw materials, energy and other natural resources while minimizing waste, emission and noise. They care about the communities they operate in, and listen to their concerns.

Sustainability – Grievance

Our partners provide their employees and other interested parties with a mechanism to raise concerns about violation or potential violation of laws and the principles provided in this Code. These concerns will be addressed in a fair and transparent way. Our partners protect confidentiality and prohibit retaliation against those raising the concern.

Sustainability – Subcontractor compliance

Any party our partners engage on behalf of G. Vogler BV or to perform work for the benefit of G. Vogler BV will be made aware of the principles in this Code and will be held to act in accordance with them.

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