1. Foreword

At LINGUA LEGIS GmbH ("we" or "us"), we are committed to acting in a socially responsible manner and promoting sustainability in all aspects of our business.

This code of conduct defines standards that apply to our suppliers and our supply chain. We expect our suppliers to ensure that their staff and their own upstream suppliers are familiar with these standards and operate in accordance with this code of conduct.

The underlying conceptual framework is the United Nations Global Compact and Universal Declaration of Human Rights, and the conventions of the International Labour Organization (ILO).

2. Human rights and labour

2.1. Human rights

We expect our suppliers to support and respect the protection of internationally proclaimed human rights. Suppliers should make sure that they, their business partners and their own upstream suppliers are never involved or complicit in human rights abuses in any of the business activities within their sphere of influence.

2.2. Child labour

We have a strict policy of zero tolerance for child labour anywhere in the supply chain. We expect our suppliers at the very minimum to comply with the ILO's Minimum Age Convention and the prohibition on child labour. Children must not perform work that jeopardises their development or their health and safety.

2.3. Forced or compulsory labour

Our suppliers must act to eliminate all forms of modern slavery, forced or compulsory labour that may be connected in any way with the products manufactured or services provided. Forced or compulsory labour refers to any work or service that is exacted from any person under the menace of any penalty, and for which that person has not offered himself or herself voluntarily. Examples include compulsory overtime, forced relinquishment of identity documents and human trafficking.

2.4. Harassment

Suppliers must ensure that staff are not subject to harassment. This includes all forms of harsh and inhumane treatment – or the threat of such treatment – including corporal punishment and sexual, psychological, physical or verbal harassment or abuse.

2.5. Health and safety

We expect our suppliers to provide their staff with a safe and healthy working environment that at a minimum complies with all local health and safety laws and regulations. We also expect them to take a proactive approach to continually improving working conditions.

2.6. Discrimination

We expect suppliers to support equal employment opportunities and act to eliminate all forms of discrimination. Staff must not be discriminated against based on their background, ethnic origin, nationality, skin colour, gender, age, religion, disability, medical conditions, pregnancy, sexual orientation, beliefs, political or trade union activity, etc.

2.7. Fair pay, working hours and benefits

Wages, salaries and benefits must comply with the applicable laws, rules and regulations governing minimum wages, paid overtime and statutory social benefits. Working hours and leisure time must comply at a minimum with the applicable laws, industry standards or the respective ILO conventions.

2.8. Freedom of association and collective bargaining

Suppliers should uphold the freedom of association and the effective recognition of the right to collective bargaining. The right of employees to associate, join a trade union, appoint representation and represent others must be respected. Suppliers must ensure that employees can freely discuss working conditions with management without fear or hindrance.

3. Ethical business practices

3.1. Compliance

Suppliers must comply with all laws, rules and regulations that apply to them and to their business relationship with us. We expect the highest standards of integrity in all business activities and relationships.

3.2. Free and fair competition

Suppliers must comply with all laws that protect and support free and fair competition, in particular antitrust and competition laws. They must pursue ethical business practices and abide by the ban on price fixing and other forms of market manipulation.

3.3. Bribery and corruption

Suppliers must not engage in any form of fraud, embezzlement, insolvency offences, corruption, or passive or active bribery. We expect suppliers to make their business decisions objectively and not allow themselves to be influenced by personal financial gain.

3.4. Conflicts of interest

A conflict of interest arises when secondary personal or institutional interests risk compromising primary interests. We expect our suppliers to be guided solely by objective criteria in their business dealings with us.

3.5. Money laundering

Suppliers must comply with any applicable anti-money laundering and tax evasion laws and take no part in money laundering activities.

3.6. Business secrecy/data protection

Suppliers must maintain the confidentiality of all non-public technical and business details that they become privy to in the course of business relationships. A process must be implemented to ensure that employees and business partners comply with this requirement after the termination of employment or cessation of business activities.

Personal data must be handled in compliance with the applicable laws.

3.7. Intellectual property

We expect suppliers to uphold the protection of third-party intellectual property.

Intellectual property relates to products of the human intellect such as inventions, literary and artistic works, industrial designs, and the symbols, names and images used to distinguish products and services. Intellectual property rights are legally protected, including by means of patents, copyright and trademarks through which authors, artists and inventors can gain recognition and earn financial benefits from their inventions or creations.

4. Environment

4.1. Environmental responsibility

Suppliers should support a precautionary approach to environmental challenges, undertake initiatives to promote greater environmental responsibility and encourage the development and diffusion of environmentally friendly technologies.

4.2. Environmentally friendly processes

Suppliers must seek to continually improve their environmental footprint. This includes taking a proactive approach to avoid or minimise the adverse environmental impact of accidents. A key aspect is the use and development of technologies to conserve energy and water, and strategies to reduce emissions and support reuse and recycling.

4.3. Water use, water quality

Suppliers must take a systematic approach to conserving water resources and reducing consumption. Action must be taken to improve water quality.

4.4. Air quality, emissions

Specific action must be taken on a systematic basis to cut emissions – in particular carbon dioxide – to the bare minimum. This applies specifically to investments in new plants and equipment and the procurement of raw materials.

4.5. Environmentally friendly products

All products manufactured and used along the entire value chain must meet the environmental standards in their respective market segments. This includes all of the materials used. Chemicals and other substances that pose a hazard when released into the environment must be identified. A hazardous substance management system must be put in place to ensure that they can be safely handled, transported, stored and recycled, reused or disposed of.

5. Whistleblowers reporting breaches of EU law

It is in our interests for non-compliance, violations and misconduct in relation to the obligations specified in this code of conduct to be identified and addressed. We will protect whistleblowers.

The legal basis is Regulation (EU) 2019/1937 of 23 October 2019.

Employees are required to report (suspected) cases of non-compliance.

The point of contact is the compliance manager and/or compliance@lingualegis.de.

We undertake to preserve the whistleblower's anonymity and protect them against retaliation.

The internal reporting and grievance mechanism is specified in the compliance policy.

The grievance mechanism is also open to external stakeholders, suppliers, customers, etc.

Contact for external complaints: compliance@lingualegis.de.

The LINGUA LEGIS employees responsible for the reporting and complaints procedure are obligated to observe discretion and confidentiality.

6. Applying this code of conduct

We make all reasonable efforts to systematically implement and apply the principles and values laid down in this code of conduct and rectify any shortcomings without delay.

We communicate this code of conduct and reference its application to our employees, business partners and other stakeholders, for instance on our website and as part of in-house training for our staff.