Code of Conduct (CoC)

1. Basic understanding of social responsibility in corporate management
2. Scope of application
3. Key points of social responsibility in corporate management
4. Implementation and enforcement
5. Integrity and compliance
6. Supply chain

1. Basic understanding of social responsibility in corporate management

NORD DRIVESYSTEMS is a globally active family company, founded in 1965. We develop, manufacture and sell drive technology for more than 100 industries.

We thus accept social responsibility towards our globally active employees, customers, suppliers and other partners. For us, this means accepting responsibility by considering the consequences of our business decisions and activities in economic, technological, social and ecological terms, and to appropriately reconcile interests. In the context of the respective possibilities and scopes for activity, we voluntarily contribute to the interests and sustainable development of the global society at the locations where we operate. We orientate ourselves to generally accepted ethical values and principles, especially to integrity and honesty, and to the respect of human dignity.

Any behaviour against the CoC may harm the NORD DRIVESYSTEMS Group. We therefore vigorously reject this.

2. Scope of application

2.1 This CoC applies to all subsidiaries and business units from NORD DRIVESYSTEMS, and is binding for the management board, all managers and employees.
Our managers bear a special responsibility. They must set the right example and must therefore particularly adhere to the CoC. Known violations must be reported without delay.

2.1.1 Dealing with notices of non-compliance
We provide our employees and business partners with access to a protected mechanism to confidentially report possible violations of the principles of the Code of Conduct.
If you want to find out more about our whistleblowing process, find out here .

2.2 Within the scope of its respective possibilities and its scope for action, NORD DRIVESYSTEMS commits itself to encourage compliance with the contents of this CoC also with regard to its suppliers and the further value creation chain.

3. Key points of social responsibility in corporate management

NORD DRIVESYSTEMS actively works towards the sustainable recognition of and the compliance with the following values and principles.

3.1 Compliance with legislation
NORD DRIVESYSTEMS complies with the relevant legislation and other legal requirements of the countries in which it is active. For countries that have a weak institutional framework, the company will carefully examine what good company practices from their home country should be applied to enable supportive, responsible company management.

3.2 Communication
Every document and all information will be duly produced. They will not be unfairly changed or destroyed, and will be stored in an orderly and correct manner. Company secrets and partners’ business information will be handled sensitively and will be kept in confidence.

3.3 Human rights
NORD DRIVESYSTEMS calls for the promotion of human rights and respects human rights stated in the Charter of the United Nations¹, especially those named in the following:

• Privacy protection
• Ensuring health and work safety, especially the guarantee of a safe and health-promoting work environment, avoiding accidents and injuries. This is subject to the generally valid local statutory regulations.
• Employee protection against bodily punishment and against physical, sexual, psychological or verbal harassment or abuse.
• Protection and grant of the right of freedom of speech and the freedom of expression.

3.4 Working conditions
NORD DRIVESYSTEMS complies with the following ILO² core labour standards:

3.4.1 Child labour
The prohibition of child labour, i.e. the employment of persons younger than 15 years, as long as the local legal requirements do not specify a higher age limit and as long as no exceptions are permitted. ³

3.4.2 Forced labour
The prohibition of forced labour of any kind.⁴

3.4.3 Remuneration
Work standards concerning compensation, especially in regards to the level of compensation as stated in the laws and requirements.⁵

3.4.4 Employees' rights
NORD DRIVESYSTEMS respects the rights of its employees.

3.4.5 Non-discrimination
Non-discriminatory treatment of all employees.⁶

3.5 Working hours
NORD DRIVESYSTEMS respects the labour standards with regard to the maximum permissible working time.

3.6 Environmental protection
NORD DRIVESYSTEMS fulfils the requirements and standards for environmental protection that affect their operations. Economic, profit-oriented development and environmental protection and energy savings are not understood as conflicting interests but rather a common goal. The basis of our environmental and energy policy is the consistent compliance with the relevant standards and regulations. Environmental protection and resource conservation are not just a matter of legislation and regulations. We practice both out of our own initiative and commitment aiming at a continuous improvement.

3.7 Civil engagement
NORD DRIVESYSTEMS contributes to the social and economic development of the country and the region.

4. Implementation and enforcement

We will make every appropriate and reasonable effort to implement, to document and to apply the principles and values described in this Code of Conduct both now and in the future. All employees will be made aware of the Code of Conduct and adequately trained on relevant topics on the Code of Conduct. Violations against the Code of Conduct will not be tolerated and may result in disciplinary consequences.

5. Integrity and compliance

We have implemented an operational compliance system that adequately covers the following topics:

5.1 Corruption
Corruption and bribery are illegal and prevent fair competitive conditions. Donations that are connected with the intention or could give the appearance of influencing business decisions or securing other undue advantage shall neither be promised, offered, granted, requested or accepted in our business relations, nor do we accept such promises. Particularly stringent standards shall apply towards persons who are subject to special sanction and liability law regulations (such as officials).

5.2 Fair competition
We act in accordance with the national and international competition and antitrust law, and do not participate in pricing agreements, sharing of markets, or customer, market and bid rigging.

5.3 Protection of information and intellectual property
We protect confidential information and respect intellectual property. Transfer of technology and expertise is to be done in a manner that protects intellectual property rights, customer information, trade secrets and confidential information.

5.4 Prevention of money laundering
Money laundering is the channelling of illegally acquired proceeds or assets into the legal financial and economic system. We fulfil our legal duties for the prevention of money laundering, and do not participate in transactions, which serve the concealment or integration of criminal or illegally acquired assets.

5.5 Data protection
We process, store and protect personal data in compliance with the local statutory regulations.

5.6 Data security
We comply with the respective applicable laws for the protection of trade secrets, and treat confidential information from our business partners accordingly.

6. Supply chain

We expect our suppliers to respect the principles of this Code of Conduct or to deploy equal codes of conduct. Furthermore, we encourage them to also enforce the contents of this Code of Conduct in their supply chains.

We reserve the right to check compliance with the Code of Conduct at our suppliers. This may be effected in the form of questionnaires, assessments or audits.

In case of doubts regarding compliance with this Code of Conduct, the supplier will be requested to take appropriate countermeasures, and to report the case to his relevant contact in our company.