Code of Conduct

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 suppliers and customers. Dealing with the supply chain has not only been an issue for us since the introduction of the
Supply Chain Act has been an issue for us. In particular, due to the procurement of raw magnets from China, which is elementary for us, we have
decided to scrutinise our supply chains more closely. Procurement is therefore subject to a certain level of security. We are working on this,
the UN's sustainability goals that are relevant to us to our company and the stakeholders involved in the company's business activities and apply them accordingly.
and apply them accordingly.
Brugger GmbH is committed to ecologically and socially responsible corporate governance. We expect the same behaviour
behaviour from all our suppliers. We also expect our employees to observe the principles of ecological, social and ethical behaviour.
ecological, social and ethical behaviour are observed and integrated into the corporate culture. We also endeavour to
to continuously optimise our business activities and our products in terms of sustainability and ask our suppliers to
to contribute to this in the sense of a holistic approach.

You can download the Brugger mission statement at the bottom of the page.

For future cooperation, the contractual partners agree to the validity of the following regulations for a joint code of conduct.
code of conduct. This agreement is the basis for all future deliveries. The contractual partners undertake to
principles and requirements of the Code of Conduct. Suppliers are requested to contractually oblige their subcontractors
contractually to comply with the standards and regulations set out in this document. This agreement comes into force upon
in force upon signing. A breach of this Code of Conduct may be reason and cause for Brugger to terminate the business relationship
including all associated 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
the United Nations Universal Declaration of Human Rights, the Guidelines on the Rights of the Child and Business Conduct, the United
United Nations Guiding Principles on Business and Human Rights, the international labour standards of the International Labour Organization and the
Global Compact of the United Nations.
We expect our suppliers to comply with all relevant laws and regulations as well as the requirements of standards.

2 Requirements for suppliers
2.1 Social responsibility
We expect our suppliers to adhere to the Code of Conduct of the international Business Social Compliance Initiative (BSCI)
and comply with the conventions of the International Labour Organization (ILO)
2.1.1 Exclusion of forced labour
No forced labour, slave labour or comparable work may be used. All work must be voluntary and employees must
employees must be able to terminate the work or employment relationship at any time. Furthermore, there must be no unacceptable treatment
of workers, such as psychological hardship, sexual and personal harassment.
2.1.2 Prohibition of child labour
Child labour must not be used at any stage of production. Suppliers are requested to comply with the recommendation from the ILO
conventions on the minimum age for the employment of child labour. Accordingly, the age should not be lower than the age at which
age at which compulsory education ends and in any case not under 15 years of age.
2.1.3 Fair remuneration
The remuneration paid to workers must comply with all applicable laws on remuneration, including, for example, laws on minimum wage or overtime.
minimum wage or overtime laws. If the statutory minimum wage is not sufficient to cover the cost of living, the business partner is
business partner is obliged to pay a wage that covers basic needs. Deductions from wages as a punitive measure are not permitted. The
basis on which workers are paid is made known to employees on an ongoing basis by means of a pay slip.
made known to employees.
2.1.4 Fair working hours
Working hours must comply with applicable laws or industry standards. Overtime is only permitted if it is worked on a voluntary basis
voluntary and do not exceed 12 hours per week, while employees must be granted at least one day off after six consecutive working days.
at least one day off after six consecutive working days. The weekly working time may not regularly exceed 48 hours.
2.1.5 Freedom of association
The supplier respects the right of workers to freedom of association, to join trade unions, to appeal to labour representatives or to be members of works councils in
or to join works councils in accordance with local laws. Workers must be able to communicate with management openly and
management openly and without fear of reprisals 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,
race, caste, skin colour, disability, political conviction, origin, religion, age, pregnancy or sexual orientation. The personal
dignity, privacy and personal rights of each individual are respected.
2.1.7 Health protection; safety in the workplace
The supplier is responsible for a safe and healthy working environment. By establishing and applying appropriate occupational safety systems
necessary precautionary measures are taken against accidents and damage to health that may arise in connection with the work.
In addition, employees are regularly informed and trained on applicable health and safety standards and measures.
Employees are given access to sufficient quantities of drinking water and access to clean sanitary facilities.
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 for other raw materials such as cobalt, the company establishes processes in accordance with
with the guidelines of the Organisation for Economic Co-operation and Development (OECD)
for the fulfilment of due diligence to promote responsible supply chains for minerals from conflict-affected and high-risk areas and expects the same from its suppliers.
from its suppliers. Smelters and refineries without appropriate, audited due diligence processes should be avoided.
Suppliers shall use the current RMI forms for their declaration (if relevant) http://www.responsiblemineralsinitiative.org
2.2 Ecological responsibility
Brugger has been EMAS-validated since 2007 and thus maintains an environmental management system that complies with the environmental topics of ISO 14001 as well as other legal requirements.
legal requirements. We expect our suppliers to maintain either an environmental system in accordance with ISO 14001 or EMAS.
2.2.1 Treatment and discharge of industrial waste water
Waste water from operating procedures, production processes and sanitary facilities must be standardised, monitored, checked and, if necessary, treated prior to discharge or disposal.
and treated if necessary. In addition, measures should be introduced to reduce the generation of wastewater.
2.2.2 Dealing with air emissions
General emissions from operations (air and noise emissions) and greenhouse gas emissions must be standardised before they are released,
routinely monitored, checked and, if necessary, treated. The supplier also has the task of monitoring its exhaust gas purification systems
and is required to find economical solutions to minimise any emissions.
2.2.3 Handling of waste and hazardous substances
The supplier shall follow a systematic approach to identify, handle, reduce and responsibly dispose of or recycle solid waste.
or recycling. Chemicals or other materials that pose a risk if released into the environment shall be identified and handled in such a way
that the handling, transport, storage, use, recycling or reuse and disposal of these substances is safe.
safety is guaranteed.
2.2.4 Reducing the consumption of raw materials and natural resources
The use and consumption of resources during production and the generation of all types of waste, including water and energy, must be reduced or avoided.
reduced or avoided. This is done either directly at the point of origin or through processes and measures, e.g. by changing
production and maintenance processes or procedures within the company, by using alternative materials, by economising, by recycling or by reusing waste.
recycling or through the reuse of materials.
2.2.5 Dealing with energy consumption/efficiency
Energy consumption must be monitored and documented. Economic solutions must be found to improve energy efficiency and minimise energy consumption.
minimise energy consumption.
2.3 Ethical business behaviour
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 must be observed. In addition, the applicable antitrust laws
which, in particular, prohibit agreements and other activities that influence prices or conditions when dealing with competitors.
These regulations also prohibit agreements between customers and suppliers that are intended to restrict customers in their freedom to set their own prices and other conditions when reselling.
prices and other conditions for resale.
2.3.2 Confidentiality/data protection
The supplier undertakes to fulfil the reasonable expectations of its client, suppliers, customers, consumers and employees with regard to the protection of private information,
consumers and employees. When collecting, storing, processing, transmitting and disclosing personal information, the Supplier shall
personal information in accordance with data protection and information security laws and government regulations.
2.3.3 Intellectual property
Intellectual property rights must be respected; technology and know-how must be transferred 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 must be applied to all business activities. The supplier must comply with the prohibition of all forms of bribery,
corruption, extortion and embezzlement. Procedures for monitoring and enforcing the standards must be applied,
to ensure compliance with anti-corruption laws.

3 Implementation of the requirements
With regard to supply chains, we expect our suppliers to identify risks within them and to take appropriate measures.
In the event of suspected violations and to safeguard supply chains with increased risks, the company requires disclosure of the supply chains.
Brugger checks compliance with the standards and regulations listed in this document using a self-assessment questionnaire and, if necessary
with sustainability audits at suppliers' production sites.
The company reserves the right to take appropriate measures against suppliers who do not fulfil these requirements, which may ultimately lead to suspension or cancellation of the contract.
ultimately lead to the suspension or termination of a supply relationship.

4 Acknowledgement and consent 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 its employees, authorised representatives, subcontractors and suppliers and
The Supplier confirms that it effectively communicates the content of this Code to its employees, agents, subcontractors and suppliers and ensures that all necessary precautions are properly implemented.