Code of Conduct
for Business Partners

Introduction

Dear Business Partners,

Proper, responsible and sustainable business management and the assumption of corporate social responsibility are fundamental components of our corporate policy. Compliance is thus an essential element of ensuring long-term success. Since its foundation, BOGE Rubber & Plastics has been committed to fair and transparent business management and always bases its activities on applicable law and jurisdiction in the countries in which it operates.

Our Code of Conduct, our corporate guidelines, and our principles of social responsibility are binding expressions of the central corporate values of BOGE Rubber & Plastics. These include our commitment to sustainable development as well as our adoption of basic principles in the fields of human rights and working conditions, quality and environmental management, health and safety of employees, fair market behavior and combating corruption.

We also observe the ILO (International Labor Organization) core labor standards, the contents of the German Corporate Governance Code, and the OECD Guidelines for Multinational Enterprises. This clearly underlines the depth of our voluntary commitment and drive to implement these standards.

We expect the same fundamental understanding of these standards from our business partners. In this respect, our Code of Conduct sets even higher standards than the legal requirements. For BOGE Rubber & Plastics, mutual trust and compliance with the contents of this Code of Conduct are therefore indispensable elements of a successful relationship with our business partners.
Damme, Juli 2018
BOGE Elastmetall GmbH

Dr. Torsten Bremer
CEO

Christoph Krampe
CFO

Preamble

In this Code of Conduct, the requirements and the fundamental principles of collaboration with the business partners of BOGE Rubber & Plastics are stipulated.

Business partners are all individuals and legal entities from whom BOGE Rubber & Plastics procures goods and/or services or to whom BOGE Rubber & Plastics provides goods and services. This excludes employees and goods. Business partners can be big suppliers, customers, commercial agents, representatives, intermediaries, consultants and other providers of goods and services.

BOGE Rubber & Plastics expects all its business partners to:

• Conduct their transactions with integrity and fairness in compliance with the applicable law. Accept and implement the principles contained in this Code of Conduct.

• Ensure that their business partners adhere to the principles of our Code of Conduct.

• Assist in making available information essential for BOGE Rubber & Plastics to adopt and execute a business relationship that is founded on partnership.

Rights and Responsibilities

Laws and Human Rights

Business partners undertake to adhere to the national and international applicable laws and regulations at their locations worldwide.
They ensure that human rights are preserved and, in particular, that human dignity is safe guarded.

Business partners do not tolerate any discrimination on the grounds of race, gender, faith, age, nationality, social or ethnic origin, disability, ideology, sexual orientation and/or political and/or trade union activities.

Work Standards

BOGE Rubber & Plastics rejects any form of slavery and/or forced labor, child labor is engaged in their abolishment, and expects its business partners to act likewise.

Business partners must observe the minimum age for employment stipulated in national legislation.

Business partners must respect the freedom of association and the right to form interest groups.
They thus grant their employees the right to represent their interests within national laws and regulations.

BOGE Rubber & Plastics requires its business partners to be aware of their social responsibility towards their employees and to ensure fair and appropriate remuneration and working times.

Business partners support the continuous training of employees to guarantee a high level of performance.

Responsible Raw Material Procurement

Business partners support all efforts to ensure the responsible procurement of resources. They advocate a carefully considered allocation of resources to avoid the procurement and utilization of raw materials that have been attained unlawfully or by ethically objectionable or unacceptable means (conflict minerals).

To exclude such procurements and to identify potential conflict minerals in the products along the supply chain, business partners are obliged to take measures that disclose the origin or source of their resources.

Fair and Free Market Behavior

BOGE Rubber & Plastics supports without reservations the principles of free and fair competition as an elementary component of the market economy. BOGE expects the same of its business partners.

Business partners undertake to observe the relevant statutory provisions concerning anti-monopoly and competition law. In particular, they do not participate in price-fixing and/or the coordination of market activities between competitors. Similarly, business partners do not exchange sensitive information with their competitors.

In their global business activities, business partners observe all applicable international trade regulations. They ensure adherence to the laws applicable to the import and export of goods and services and comply with applicable economic embargos. As part of the supply chain, BOGE Rubber & Plastics expects to be
informed by its suppliers of export restrictions and classifications.

Ban on Corruption

Corruption is banned by international conventions and national laws. BOGE Rubber & Plastics does not tolerate any form of bribery among employees or business partners or any business practices that could create the impression of improper manipulation or influence.

Within the framework of their relations with BOGE Rubber & Plastics, business partners undertake neither to offer third parties advantages of any kind directly or indirectly, nor to obtain advantages or promises of
advantages directly or indirectly for themselves or for others that represents an illegal act according to applicable anticorruption legislation.

BOGE Rubber & Plastics expects its business partners not to tolerate any form of unlawful gratuity, particularly in business dealings with public officials and authorities in Germany and abroad. Business partners also undertake to ensure their employees act and proceed with integrity.

Business partners must also reject facilitation payments (i.e. payments to public officials not required by law for the purpose of inducing the public official to accelerate or carry out an official act to which a right principally exists).

Money Laundering

BOGE Rubber & Plastics undertakes to assist in the international battle against money laundering and adopts applicable measures to comply with the relevant provisions. BOGE Rubber & Plastics expects the same of its business partners.

Conflicts of Interest

Transparency in all business processes is extremely important to business partners.

BOGE Rubber & Plastics expects its business partners to make decisions based solely on factual considerations and to avoid in particular those personal or familial conflicts of interest that could lead to irrelevant considerations.

Business partners undertake to avoid even creating the impression of any non-business like conduct.

Gifts, Invitations and other Gratuities

When it comes to gratuities in the form of gifts or invitations, business partners strictly ensure that no appearance of dishonesty or incorrect behavior can arise, in particular in connection with their activities for BOGE Rubber & Plastics.

Business partners tolerate neither the acceptance nor the offer of gratuities that are extended in expectation of an unlawful return service or advantage that could raise doubts about their integrity or that could appear to influence business decisions.

Donations and Sponsoring

In the allocation of donations, business partners follow the principle of altruistic action. Their donations are solely voluntary and in accordance with the applicable legislation. Business partners sponsor individuals, groups and organizations without any intention of gaining unfair business advantages.

Occupational Health and Safety, Environmental Protection

Occupational Health and Safety

Business partners promote the health and safety of their employees through appropriate provisions such as preventive occupational health and safety measures and a healthy and safe working environment.

Environmental Protection

Business partners are committed to sustainable, responsible and considerate handling of resources and raw materials.

In manufacturing products and executing procedures, they ensure an efficient deployment of energy and resources and adhere to the applicable environmental standards. They require their employees to minimize environmental endangerment while performing their work and to support a sensible handling of resources.

Handling of Information

The confidential handling of information is an essential aspect for our business relationship.

To ensure that confidential and personal information is protected, business partners must keep such information in a secure manner and protect it from unauthorized access by third parties. Business partners may only use information for authorized purposes and in an appropriate manner.

Notices and Reports

BOGE Rubber & Plastics expects its business partners to report indications of possible criminal offenses, wrongdoings and special risks that could impact BOGE Rubber & Plastics.

Neither BOGE Rubber & Plastics nor its business partners tolerate any form of discrimination of persons on the grounds of such indications to BOGE Rubber & Plastics or its business partners.

BOGE Rubber & Plastics places great importance on a trustful collaboration with its business partners.

Also we require selected suppliers to perform self-assessment on the basis of the Supplier Self-Assessment Sustainability. In addition, BOGE Rubber & Plastics conducts a risk-based examination for its business partners to identify possible risks of compliance and integrity (Business Partner Compliance Due Diligence).

BOGE Rubber & Plastics reserves the right to scrutinize the business relationship with the business partner in case of nonconformance with this Code of Conduct. In this regard BOGE Rubber & Plastics acts pursuant to the principle of proportionality, which means that in each case BOGE Rubber & Plastics carefully examines which consequences are appropriate, suitable and necessary. This can lead e.g. to immediate termination of the business relationship as well as to enforcement of compensation claims.

Contact

All business partners have the option of directly contacting the Department Legal/Compliance at any time.

BOGE Rubber & Plastics

Shaping the Future Responsibly

Our enthusiasm for innovative products and processes and our uncompromising pursuit of quality have made us a global leader in NVH-solutions (noise, vibration, harshness) as well as in plastic components and modules for the automotive industry. We are contributing towards a sustainable future by producing advanced technology solutions with the goal of improving mobility, increasing the efficiency of our products and systems and conserving resources.

Our customers in the automotive and industrial sectors welcome our determined focus on products and services, which provide great customer value. Improvements in energy efficiency, cost-effectiveness, dynamics, safety and comfort are keys to our work. At the same time, we are aiming for continuous improvement in our business processes and the services we provide. As a globally active company, we react quickly and flexibly to changing regional market demands with the goal of always providing a competitive price/performance ratio.

Our independence and financial security form the basis of our long-term business success.
We continuously invest in new products, technologies and markets and thus secure the future of our company in the interest of our customers, market partners, employees and the owners of BOGE Rubber & Plastics.

Our managerial decisions are founded on our values and expertise.
They form the basis of our doing and thinking. At BOGE Rubber & Plastics we ensure that locally applicable laws and regulations are adhered to, wherever we operate. Within the framework of our activities we also aim to act responsibly towards society and the environment.

For our employees we aim to be a fair and reliable employer, focusing on the development of our employees.

We value the varied cultural backgrounds of our employees, their competencies, diligence
and motivation. Their goal-oriented dedication to BOGE Rubber & Plastics shapes our company culture and is the key to our success.

BOGE Elastmetall GmbH
Legal/Compliance
Dr.-Jürgen-Ulderup-Platz 1
49401 Damme
Germany
Phone: +49 5491 91-0
E-Mail: wolfgang.reiser@boge-rubber-plastics.com
www.boge-rubber-plastics.com