Code of Conduct

Code of Conduct for Sustainable Supply Chains

1 Introduction - Preamble
Brugger GmbH has been an environmentally friendly company for many years and attaches particular importance to a partnership-based approach both within the company and with suppliers and customers.
both within the company and with its suppliers and customers. Dealing with the supply chain has not only been an issue for us since the introduction of the Supply Chain Act.
the introduction of the Supply Chain Act. In particular, due to our elementary procurement of raw magnets from China, we have decided to examine our supply chains more closely.
we have decided to examine our supply chains more closely. Procurement is thus subject to a certain level of security. We are working on
We are working on breaking down the UN's sustainability goals, which are relevant for us, to our company and the stakeholders involved in the company's
and apply them accordingly.
Brugger GmbH is committed to ecologically and socially responsible corporate governance. We expect the same
behaviour from all our suppliers. We also expect our employees to observe the principles of ecological, social and ethical conduct.
ecological, social and ethical behaviour are observed and integrated into the corporate culture. Furthermore, we strive to
our entrepreneurial activities and our products in the sense of sustainability, and we call upon our suppliers to
suppliers to contribute to this in the sense of a holistic approach.

At the bottom of the page you will find the Brugger mission statement for download.

For future cooperation, the contractual partners agree on the validity of the following regulations for a joint
code of conduct. This agreement shall apply as the basis for all future deliveries. The contractual partners undertake to observe the
principles and requirements of the Code of Conduct. Suppliers are requested to contractually oblige their subcontractors to
to contractually commit their subcontractors to comply with the standards and regulations set out in this document. This agreement comes into
into force upon signature. A breach of this Code of Conduct may be grounds and cause for Brugger to terminate the business relationship, including all related supply contracts.
including all related supply contracts.
The Code of Conduct is based on national laws and regulations as well as international conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines for the Protection of Human Rights and Fundamental Freedoms.
of Human Rights of the United Nations, the Guidelines on Children's Rights and Business Conduct, the United Nations Guidelines on
United Nations Guiding Principles on Business and Human Rights, the International Labour Standards of the International Labour Organisation and the United Nations Global Compact.
Global Compact of the United Nations.
We expect our suppliers to comply with all relevant laws, regulations and standards requirements.

2 Supplier requirements
2.1 Social responsibility

We expect our suppliers to adhere to the Code of Conduct of the international Business Social Compliance Initiative (BSCI)
and to comply with the conventions of the International Labour Organization (ILO).
2.1.1 Exclusion of forced labour
No forced labour, slave labour or work comparable to forced labour shall be used. All work must be voluntary and the
employees must be able to terminate the work or employment relationship at any time. Furthermore, no unacceptable treatment of
of workers, such as psychological hardship, sexual and personal harassment, shall take place.
2.1.2 Prohibition of child labour
Child labour shall not be used at any stage of production. Suppliers are required to adhere to the recommendation from the ILO
Conventions on the minimum age for the employment of children. According to this, the age should not be lower than the age at which
age at which compulsory schooling ends and in any case not below 15 years of age.
2.1.3 Fair remuneration
The remuneration paid to workers shall comply with all applicable laws on remuneration, including, for example, laws on the minimum wage or overtime.
minimum wage or overtime laws. If the legal minimum wage is not sufficient to cover the cost of living, the business partner is obliged to pay a wage.
business partner is obliged to pay a wage that covers basic needs. Wage deductions as a punitive measure are not permitted. The
basis on which workers are paid shall be made known to the employees on an ongoing basis by means of a pay slip.
wage statement.
2.1.4 Fair Working Hours
Working hours shall be in accordance with applicable laws or industry standards. Overtime is only permissible if it is worked on a voluntary basis and
and does not exceed 12 hours per week, while employees must be given at least one day off after six consecutive working days.
at least one day off after six consecutive working days. The weekly working time shall not regularly exceed 48 hours.
2.1.5 Freedom of association
The supplier shall respect the right of workers to freedom of association, to join trade unions, to appeal to labour representation
or to join works councils in accordance with local laws. Workers must be able to communicate openly with the
management openly and without fear of reprisal or harassment.
2.1.6 Prohibition of Discrimination
Discrimination against employees in any form is prohibited. This applies, for example, to discrimination based on gender,
This applies, for example, to discrimination based on gender, race, caste, skin colour, disability, political conviction, origin, religion, age, pregnancy or sexual orientation. The personal
The personal dignity, privacy and personal rights of each individual are respected.
2.1.7 Health protection; safety at work
The supplier is responsible for a safe and healthy working environment. By setting up and applying appropriate occupational safety systems
necessary precautionary measures are taken against accidents and damage to health that may arise in connection with the activity.
In addition, employees are regularly informed and trained on applicable health and safety standards and measures.
Employees are given access to drinking water in sufficient quantities and to clean sanitary facilities.
2.1.8 Grievance mechanisms
The supplier is responsible for establishing an effective grievance mechanism at the facility level for individuals and communities that may be affected by negative impacts.
affected by negative impacts.
2.1.9 Dealing with conflict minerals
For the conflict minerals tin, tungsten, tantalum and gold, as well as other commodities such as cobalt, the company establishes processes in line with
the Organisation for Economic Co-operation and Development (OECD) Guiding Principles
due diligence to promote responsible supply chains for minerals from conflict-affected and high-risk areas, and expects its supplier to do the same.
from its suppliers as well. Smelters and refineries without adequate, audited due diligence processes should be avoided.
Suppliers shall use the current RMI forms for their declaration (if relevant)
2.2 Ecological responsibility
Brugger has been EMAS-validated since 2007 and thus maintains an environmental management system which, in addition to the environmental topics of ISO 14001, also complies with other legal requirements.
legal requirements. We expect our suppliers to maintain either an ISO 14001 or EMAS environmental system.
2.2.1 Treatment and discharge of industrial waste water
Wastewater from operations, manufacturing processes and sanitary facilities shall be typed, monitored,
and treated as necessary before discharge or disposal. In addition, measures should be introduced to reduce the generation of wastewater.
2.2.2 Managing air emissions
General emissions from operations (air and noise emissions) and greenhouse gas emissions should be typed before release,
routinely monitored, verified and treated as necessary. The supplier is also responsible for monitoring its waste gas purification systems and for
and is required to find economic solutions to minimise any emissions.
2.2.3 Handling waste and hazardous substances
The supplier shall follow a systematic approach to identify, handle, reduce and responsibly dispose of solid waste.
or recycle. Chemicals or other materials that pose a hazard if released into the environment shall be identified and handled in such a way,
handling, transport, storage, use, recycling or reuse, and disposal of such materials shall be carried out in a safe manner.
disposal, safety is ensured.
2.2.4 Reduce consumption of raw materials and natural resources
The use and consumption of resources during production and the generation of waste of all kinds, including water and energy, shall be reduced or avoided.
be reduced or avoided. This can be achieved either directly at the point of origin or through procedures and measures, e.g. by changing the production and maintenance processes or the use of natural resources.
processes or procedures within the company, through the use of alternative materials, through savings, through recycling or through the reuse of waste.
recycling or by reusing materials.
2.2.5 Managing energy consumption/efficiency
Energy consumption shall be monitored and documented. Economic solutions shall be found to improve energy efficiency and minimise energy consumption.
minimise energy consumption.
2.3 Ethical business conduct
We expect our suppliers to comply with the BSCI Code of Conduct.
2.3.1 Fair competition
The standards of fair business, fair advertising and fair competition shall be observed. In addition, the applicable antitrust laws
which specifically prohibit collusion and other activities that influence prices or conditions in dealings with competitors.
Furthermore, these regulations prohibit agreements between customers and suppliers that are intended to restrict customers' freedom to determine their prices and other conditions for resale.
prices and other terms and conditions of resale autonomously.
2.3.2 Confidentiality/Data Protection
The supplier undertakes to meet the reasonable expectations of its principal, suppliers, customers, consumers and employees with regard to the protection of private information,
consumers and employees. The Supplier shall comply with the laws on data protection and information when collecting, storing, processing, transmitting and disclosing personal information.
The Supplier shall comply with data protection and information security laws and government regulations in the collection, storage, processing, transfer and disclosure of personal information.
2.3.3 Intellectual property
Intellectual property rights must be respected; technology and know-how transfers must be carried out in such a way that intellectual property rights and customer information are protected.
customer information are protected.
2.3.4 Integrity/Bribery, Taking Advantage
The highest standards of integrity shall be applied in all business activities. The supplier shall comply with the prohibition of all forms of bribery, corruption, extortion and embezzlement,
corruption, extortion and embezzlement. Procedures shall be in place to monitor and enforce the standards,
to ensure compliance with anti-corruption laws.

3 Implementation of requirements
We expect our suppliers in relation to supply chains to identify risks within them as well as take appropriate action.
In case of suspected violations as well as to safeguard supply chains with increased risks, the company requires the disclosure of supply chains.
Brugger verifies compliance with the standards and regulations listed in this document with the help of a self-assessment questionnaire and, if necessary, with sustainability audits at production sites.
with sustainability audits at the suppliers' production sites.
The company reserves the right to take appropriate measures against suppliers who do not meet these requirements.
Ultimately, these measures may also lead to the suspension or termination of a supplier relationship.

4 Acknowledgement and agreement of the supplier
By signing this document, the supplier undertakes to act responsibly and to comply with the principles/ requirements listed.
requirements. The supplier confirms that it effectively communicates the content of this Code to employees, agents, subcontractors and suppliers and assures that it will do so.
The supplier confirms that it effectively communicates the content of this Code to workers, agents, subcontractors and suppliers and assures that all necessary precautions are properly implemented.