Guidelines and Code

CODE OF CONDUCT

preamble

Our code of conduct is in accordance with the “Code of Conduct (CoC)” of the Association of the Railway Industry in Germany (VDB) e. V., to which we ourselves are committed.

The contents of the CoC were developed by the VDB on the basis of the Code of Conduct of the German Electrical and Electronic Manufacturers’ Association (ZVEI) and the German Engineering Federation (VDMA).1

DEUTA’s commitment to the VDB’s Code of Conduct is intended to underscore our interest in fair, sustainable, responsible and ethical principles of conduct.

It is also an expression of DEUTA’s understanding of social responsibility and future-oriented action.

1 The use of formulations from the ZVEI/VDMA-CoC (version of 2022) is with the kind permission of ZVEI and VDMA.

1. Basic understanding of business management

This Code of Conduct is based on a shared understanding of socially responsible corporate governance as defined in the following guidelines. For DEUTA, this means that we assume responsibility by considering the consequences of our business decisions and actions in economic, technological, social, and environmental terms, and by achieving a fair balance of interests.

Within the scope of our respective capabilities and spheres of influence, DEUTA voluntarily contributes to the well-being and sustainable development of society at the locations where we operate worldwide. DEUTA is guided by universally valid ethical values ​​and principles, in particular integrity and rectitude, as well as respect for human dignity, as enshrined in the principles of the United Nations Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the core labour standards of the International Labour Organization (ILO), and the UN Guiding Principles on Business and Human Rights.

2. Scope

The geographical scope of this CoC includes all countries in which DEUTA conducts its business.

The material scope of this Code of Conduct (CoC) encompasses DEUTA and its supply chain. This means that DEUTA undertakes to demand compliance with the contents of this CoC from its suppliers within the scope of its respective capabilities and spheres of influence, and to encourage and support them in doing the same in their supply chains. This is not intended to establish any rights in favor of third parties.

3. Basic principles

DEUTA actively works to ensure that the values ​​and principles mentioned below are observed and adhered to in a sustainable manner.

3.1 Compliance with the laws

DEUTA complies with the applicable laws and other legal regulations of the countries in which we operate. If local laws and regulations are less restrictive, our actions are guided by the principles of this Code of Conduct. In cases where there is a direct conflict between mandatory local law and the principles contained in this Code of Conduct, local law takes precedence, although DEUTA strives to comply with the provisions of this Code of Conduct.

3.2 Integrity and Corporate Governance

DEUTA bases its actions on universally valid moral values ​​and principles, in particular on integrity, transparency, righteousness, respect for human dignity, openness and the requirement of non-discrimination on the grounds of race, ethnic origin, gender, religion or belief, disability, age or sexual identity.

DEUTA rejects corruption and bribery as defined in the relevant UN Convention 2.  DEUTA promotes ethical conduct, responsible management, and control within the company and takes appropriate measures to prevent, in particular, the direct or indirect commission of the following legal violations:

theft, embezzlement, fraud, breach of trust, forgery, money laundering, anti-competitive agreements in tenders such as price-fixing, customer-fixing, market-fixing, or bid-fixing, or market-sharing, as well as violations of trade secrets and unauthorized use of technical documents or regulations, bribery and corruption in business transactions, granting of advantages, and the granting or acceptance of benefits or other advantages to employees of contractual partners.

DEUTA pursues reputable and recognized business practices and fair competition, in particular with due regard to antitrust and competition law requirements.

DEUTA complies with all applicable legal obligations regarding money laundering prevention and does not participate in transactions that serve to conceal criminally or illegally acquired assets. Furthermore, DEUTA avoids conflicts of interest that could illegitimately influence business relationships. Any existing conflicts of interest must be disclosed and resolved through appropriate measures.

2  United Nations Convention against Corruption of 2003, in force since 2005.

3.3 Protection of information and intellectual property

Confidential information is protected and intellectual property is respected; technology and know-how transfer must be conducted in such a way as to protect intellectual property rights and confidential customer information, trade secrets, and other non-public information. All applicable laws protecting trade secrets are observed, confidential information of business partners is handled accordingly, and it is neither disclosed to nor made accessible to unauthorized third parties.

3.4 Consumer interests

Where consumer interests are affected, DEUTA complies with applicable consumer protection regulations and appropriate sales, marketing, and information practices. Particularly vulnerable groups receive increased attention.

3.5 Communication

DEUTA communicates openly and in a dialogue-oriented manner with employees, customers, suppliers, and other stakeholders regarding the requirements of this Code of Conduct and its implementation. All documents and records are created in accordance with regulations, are not unlawfully altered or destroyed, and are stored properly. Within the framework of legal regulations, DEUTA provides its employees and business partners with access to a secure mechanism to confidentially report potential violations of the principles of this Code of Conduct.

3.6 Human Rights and Working Conditions

DEUTA is committed to promoting human rights and upholds human rights in accordance with the UN Charter of Human Rights .  Furthermore, we adhere to the ILO core labor standards ,  insofar as they are referenced below.

Privacy and Data Protection:
Privacy, including personal data, is protected. Personal data is collected confidentially and transparently and used only for lawful, predetermined purposes. Personal data is processed only if it is protected against loss, alteration, and unauthorized use or disclosure by appropriate technical and organizational measures.

Health and Safety at Work:
Health and safety at work are ensured, in particular by guaranteeing a safe and healthy working environment to prevent accidents and injuries. Employee health is protected by taking appropriate health and safety measures (e.g., implementing a company health and safety management system) that adequately address the following:
→ Compliance with applicable laws and adherence to international standards regarding health and safety at work;
→ Appropriate workplace design, safety regulations, and provision of suitable personal protective equipment;
→ Implementation of preventive checks, emergency procedures, an accident reporting system, and other suitable measures for continuous improvement;
→ Ensuring access to sufficient drinking water and clean sanitary facilities for
employees.

Appropriate employee training is guaranteed.

Protection from harassment:
Employees are protected from physical punishment and from physical, sexual, psychological or verbal harassment or abuse.

Freedom of opinion
and free expression of opinion are granted and protected.

Prohibition of child labor.
The prohibition of child labor, i.e., the employment of persons under 15 years of age and, for hazardous work, under 18 years of age, is observed unless local legislation stipulates higher age limits and unless exceptions are permitted. 5

Prohibition of forced labor
The prohibition of forced labor, modern slavery and work involving the use of measures that deprive freedom of liberty is observed6, as is the prohibition of oppression in the vicinity of the workplace.

Remuneration:
The labor standards regarding remuneration, in particular concerning the level of remuneration in accordance with applicable laws and regulations, including those on minimum wages, are observed. Employees  are informed clearly, in detail, and regularly about the composition of their remuneration.

Employee rights:
The right of employees to freedom of association, freedom of assembly, and to collective bargaining and wage negotiations, insofar as this is legally permissible and possible in the respective country, is respected. 8

Prohibition of discrimination:
Employees will not be discriminated against. 9.  All people will be treated equally, regardless of gender, age, skin color, ethnic origin, sexual identity and orientation, disability, religious affiliation, worldview, or other personal characteristics.

Working Hours:
Work regulations regarding maximum permissible working hours are observed. Where such regulations are lacking, at least the following is ensured:
→ working hours, including overtime, do not exceed the respective legally permissible maximum limits;
→ weekly working hours, including overtime, do not exceed 60 hours, even in exceptional cases;
→ employees have at least one full day off per calendar week.

Security forces:
When engaging or using private or public security forces, DEUTA undertakes to provide sufficient instruction and supervision to prevent human rights violations.

 Universal Declaration of Human Rights, UN Resolution 217 A (III) of 1948.
4  ILO = International Labour Organization.
5  ILO Convention No. 138 of 1973 and ILO Convention No. 182 of 1999.
6  ILO Convention No. 29 of 1930 and ILO Convention No. 105 of 1957.
7  ILO Convention No. 100 of 1951.
8  ILO Convention No. 87 of 1948 and ILO Convention No. 98 of 1949.
 ILO Convention No. 111 of 1958.

3.7 Environmental protection

DEUTA complies with all environmental protection regulations and standards, including relevant international agreements , that apply to our respective operations and activities, and conducts business in an environmentally responsible manner at all locations. We take appropriate measures (e.g., the implementation of an environmental management system) for continuous improvement with regard to environmental aspects such as reducing CO2 emissions, increasing energy efficiency and using renewable energies, ensuring water quality and reducing water consumption, ensuring air quality, promoting resource efficiency, reducing waste and its proper disposal, and handling hazardous substances responsibly.

DEUTA appropriately observes human rights and environmental due diligence obligations with the aim of avoiding environmental damage that endangers the community.

10.  Minamata Convention on Mercury of 2013, in force since 2017; Stockholm Convention on Persistent Organic Pollutants of 2001, in force since 2004; Basel Convention on the Control of Transboundary Movements of Hazardous Wastes of 1989, in force since 1992, entered into force for Germany in 1995.

3.8  Handling of conflict minerals

DEUTA takes due diligence to avoid the use of conflict minerals in our products in order to prevent human rights violations, corruption and the financing of armed groups or similar activities.

3.9 Foreign trade, sanctions

DEUTA complies with all applicable national and international foreign trade regulations, in particular customs, trade, import and export control regulations, as well as sanctions and embargoes. This includes, among other things, the import and export of products, services, and technologies.

3.10 Civic Engagement

DEUTA contributes to the social and economic development of the country and region in which we operate and promotes corresponding voluntary activities among our employees.

3.11 Implementation and enforcement

DEUTA will make all appropriate and proportionate efforts to continuously implement and apply the principles and values ​​set forth in this Code of Conduct. Contractual partners will be informed of the essential measures taken upon request and on a reciprocal basis, so that it is transparent how compliance is generally ensured. There is no entitlement to the disclosure of trade secrets or information relating to competition or otherwise requiring protection.

All employees are made aware of the content of the Code of Conduct and receive training on relevant topics as needed. Violations of the Code of Conduct will not be tolerated and may result in disciplinary action.

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