1 Values and scope

Responsible action and dependable values are self-evident for us as a family company operating internationally. Together with our suppliers we are making our value chain sustainable with regard to people, the environment and society. Our company policy is aligned long-term; all decisions are marked by sustainability, so that we can leave future generations an intact ecological, social and economic environment. We don’t just live these values ourselves, we also expect them from our business partners, because sustainable business succeeds only as a collaborative effort.
This Code of Conduct is a binding part of every business relationship with the Stern-Wywiol Gruppe (the Stern-Wywiol Gruppe and its subsidiaries are in the following called “Stern-Wywiol Gruppe”). It applies to all companies supplying us with products or services directly or via third parties, including their subcontractors and partners along the entire supply chain. This Code of Conduct supplements existing agreements and puts into specific terms the requirements of the respective international standards.

2 Our expectations of suppliers

We rely on partnership and collaboration. The requirements below define the minimum level that each supplier must meet at all times.

2.1 Labour and social standards

– Our suppliers, without exception, respect internationally recognized human rights, including the core labour standards of the International Labour Organization (ILO).

– Our suppliers abide by all national legislation on work and rest times, as well as overtime and paid vacation.

– They pay their employees punctually and at least the amount required by law or wage agreements.

– They prevent discrimination in any form and promote equal opportunity for and equitable treatment of all employees.

– They protect the right to freedom of association and collective bargaining without retaliation.

– They use neither child nor forced labour, and prevent all forms of human trafficking.

– They ensure that working conditions are safe and healthy, including providing personal protective equipment and access to clean drinking water.

– They prevent the illegal expropriation of land, forests and water, and use security personnel only appropriately and without infringing human rights.

– Our suppliers may not use security forces that flout human rights, freedom or labour laws.

2.2 Environment & climate

– Our suppliers comply with all relevant environmental legislation and official regulations.

– They continuously improve their energy and resource efficiency.

– The minimize emissions, waste and waste water, and promote a functioning circular economy.

– They ensure that animal raw materials are from suppliers that meet at least the legally mandated animal protection standards for raising, transporting and slaughtering animals.

– They protect forests and biodiversity, and refrain from illegal deforestation in accordance with the EU Regulation on deforestation-free products.

– For all products falling under the EU Regulation on deforestation-free products (EUDR), our suppliers deliver only demonstrably deforestation-free goods; prior to delivery they provide to Stern-Wywiol Gruppe all EUDR information including verifiable geodata, and archive this data for at least five years.

– They store, transport, use and dispose of hazardous materials responsibly, in accordance with REACH and the Basel, Stockholm and Minimata conventions.

– They source raw materials such that no conflict minerals contribute to financing armed groups, and they follow the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

– If information is missing, there is doubt about its accuracy or there is suspicion of noncompliance, Stern-Wywiol Gruppe can refuse to accept delivery, refuse payment, procure replacements and claim damages; suppliers cooperate actively in risk assessment, communicate the requirements along the supply chain, and bear all costs arising therefrom.

2.3 Business integrity

– Our suppliers comply with all relevant legal requirements, laws and regulations along the entire supply chain.

– Our suppliers tolerate no corruption or bribery of any kind.

– They neither give nor accept inadmissible gifts, payments or so-called facilitation payments.

– They practice fair competition and follow all antitrust and competition rules.

– They establish programmes to prevent product adulteration (food/feed fraud).

– They strictly follow all export, import, customs and sanction regulations.

– They perform financial transactions transparently, to prevent money laundering.

– They protect confidential data and intellectual property per GDPR and comparable international provisions.

3 Implementation, documentation & audit

The effective implementation of this Code of Conduct is based on clear responsibilities, documented proof and constructive auditing.

– Suppliers maintain suitable management systems and regularly train their employees.

– They identify, assess and reduce risks in their supply chains.

– They document all relevant evidence fully and make it available to Stern-Wywiol Gruppe on request.

– Suppliers undertake to communicate to their suppliers the human rights and environmental expectations formulated in this Code of Conduct.

– Stern-Wywiol Gruppe is entitled to perform on-site or remote audits, as well as product and documentation inspections. Suppliers are entitled to take suitable measures to protect their company and business secrets and the confidentiality of their customer data.

– Suppliers shall provide unhindered access to facilities, documents and employees, and bear the costs resulting from any breaches that are found.

– Deviations will be addressed together; in the event of grave or repeated breaches, we retain the right to extraordinary termination of the contract relationship and claims for damages.

4 Breaches & reporting system

Dealing openly with undesirable developments enables improvements and reduces risks.

– Our suppliers operate effective, low-threshold complaint mechanisms for employees. They inform their employees and third parties that they can report breaches confidentially using the “Whistle Report” portal of Stern-Wywiol Gruppe.

– Suppliers inform Stern-Wywiol Gruppe without delay of their own breaches of this Code of Conduct.

– They take prompt remedial measures and report on their progress.

– Depending on the severity of the breach, measures may range from improvement plans to delivery and service cancellations, damage claims and termination of the business relationship.

5 Final declaration

Sustainability and integrity work best when they are cooperative efforts. We thank our suppliers for their commitment and look forward to lasting partnerships based on these shared values.