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Code of Conduct for Sustainable Supply Chains

1 Introduction – Preamble

Brugger GmbH has been an environmentally responsible company for many years and attaches particular importance
to a partnership-based approach 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. Due to the procurement not only
of raw magnets from China but also material from all over the world, we have decided to examine our supply chains
more closely. Procurement is thus subject to a certain level of security. We are working on breaking down the UN
sustainability goals relevant to us to our company and the stakeholders involved in the company's business activities
and applying them accordingly.
Brugger GmbH is committed to ecologically and socially responsible corporate governance. We expect the same
behavior from all our suppliers. We also expect our employees to observe the principles of ecological, social and
ethical behavior and to integrate them into the corporate culture. Furthermore, we strive to continuously optimize
our business activities and our products in terms of sustainability and ask our suppliers to contribute to this in the
sense of a holistic approach.

Here you will find Brugger's mission statement and corporate policy.

This "Code of Conduct for Sustainable Supply Chains" (in the following: the "Code") represents the foundation
for any cooperation and collaboration of BRUGGER GmbH with supply chain stakeholders. BRUGGER GmbH
is committed to the principle of sustainable supply chains and takes its social and environmental responsibility very
seriously. BRUGGER GmbH ensures non-discrimination, freedom of association and collective bargaining. They
exclusively employ voluntary staff and reject child labor. In this Code, BRUGGER GmbH defines the requirements
which are to be met by BRUGGER GmbH itself and by all stakeholders of the entire all-over-the-world-based
supply chain, including service providers, but especially concerning suppliers.
Regarding suppliers it is expected that these requirements are met by all direct and indirect suppliers, and that
all suppliers apply the same standards and fulfills the same implementation measures. This is also part of the
contract between the relevant parties. All parties understand that safeguarding the social and environmental
standards stipulated herein are the basis for successful and long-term cooperation. The main international
standards on human rights and working conditions form the basis of this Code, such as the United Nation's
Universal Declaration of Human Rights, the conventions of the International Labor Organization (ILO)
(especially ILO Convention 29 and 105), the UN Guiding Principles on Business and Human Rights, the
National Action Plan for Business and Human Rights, and the Supply Chain Due Diligence Act (adopted on 11
June 2021 by the German Parliament). At the same time, the national and local laws and official regulations of
the country of delivery are to be respected. Any violation of this Code may provide BRUGGER GmbH with sufficient
reason to terminate the business relationship at any given moment, including any subordinate agreements.

2 Labor

2.1 Forced Labor
BRUGGER GmbH follows a clear „zero tolerance to forced labor“ policy, and all stakeholders of the supply chain
reject all use of forced and compulsory labor as well as all forms of modern slavery and human trafficking. No
bonded labor or involuntary prison labor is tolerated. Employment relationships of BRUGGER GmbH and all partners
and suppliers are entered into on a voluntary basis and may be terminated by employees at their own discretion and
within a reasonable notice period.
BRUGGER GmbH thoroughly monitors the labor situation within the own operations and the whole supply chain and
especially pays attention to the following indicators of forced labor: Not paying salaries, limited the employees'
movements, holding back of passports or other documents, intimidation of the worker or people close to him/her,
unacceptable working and living conditions, excessive overwork.
For ensuring the voluntariness of labor, BRUGGER GmbH undertakes dedicated efforts to ensure that the workforce
of their stakeholders enters the work arrangement voluntarily. This includes a complaint mechanism open to all
stakeholders and shielding potential complainants from any possible form of pressure. It also includes regular
monitoring of the measures the stakeholders have in place to be able to guarantee the voluntariness of work and
how the measures and the monitoring are extended to relevant sub-suppliers. All preventive actions taken and
their effects as well as possible alternative actions will be documented in detail and to the extent that third persons
can easily determine whether these measures are plausible. Legal basis: ILO 29, ILO 105, Supply Chain Due
Diligence Act §2 (2) no. 3
2.2 Child Labor
The exploitation of children under the age of 15 and their employment (child labor) at the operations of BRUGGER
GmbH and in the whole supply chain is prohibited. Should thenational statutes impose a higher age, this shall apply.
Young employees under 18 years of age should not work overtime or nightshifts. Legal basis: ILO 79, ILO 138,
ILO 142, ILO 182, Supply Chain Due Diligence Act §2 (2) no. 2
2.3 Occupational Health and Safety
BRUGGER GmbH guarantees health and safety in the workplace for its own employees and expects the same for
all employees of companies in the supply chain. This specifically refers to the work equipment, to working with
chemical or biological substances, and to the safety requirements (especially regarding fire incidents) of the
factory premises. Rules and procedures to ensure health and safety are to be introduced and communicated to
the employees for preventing accidents and injuries during work.
All applicable provisions relating to occupational health and safety are to be complied with. Furthermore, a process
enabling the continuous reduction of work-related health hazards and improvement of occupational health, safety
and fire safety is to be established and maintained. Legal basis: ILO 155, ILO 164, Supply Chain Due Diligence
Act §2 (2) no. 5
2.4 Working Hours
Working hours at BRUGGER GmbH and its supply chain stakeholders shall be in line with the current, national
statutes and industry standards, of which the strictest regulations shall apply. Overtime must be worked on a
voluntary basis and may not exceed the limit set by statutory requirements. Every employee shall have the right
to at least one free day after six successive working days. Sufficient breaks shall be arranged so that the
accidents at work resulting from physical and mental fatigue can be prevented. Legal basis: ILO 1, ILO 14
2.5 Remuneration
The remuneration for regular work hours and overtime should correspond at the very least to the legally guaranteed
minimum. Unauthorized deductions in remuneration as well as deductions in remuneration as a disciplinary measure
are forbidden. Legal basis: ILO 26, ILO 131, Supply Chain Due Diligence Act §2 (2) no. 8
2.6 Freedom of Association and the right to collective negotiations
BRUGGER GmbH and its stakeholders of the supply chain respect the right of the employees to establish organizations
of their choice, to join them and to conduct collective negotiations. In situations where the rights to freedom of association
and collective negotiations are limited by law, other opportunities must be granted for the independent and free union of
the employees for collective negotiation.
Workers' representatives are to be protected against discrimination and need be granted free access to the workplaces
of their colleagues to being able to exercise their rights in a legal and peaceful manner.
Legal basis: ILO 87, ILO 98, ILO 135, ILO 154, Supply Chain Due Diligence Act §2 (2) no. 6
2.7 Discrimination
BRUGGER GmbH ensures that its employees and those of its supply chain stakeholders of the country of delivery have
the right to equal treatment and the same opportunities. Any discrimination on the grounds of gender, age, religion,
philosophy, social background, health status, disability, ethnic and national origin, nationality, membership of employee
organizations including unions, political ethos, sexual orientation, or due to any other personal characteristics, for example
with regards to employment, wages, access to further training, promotion, ending of the employment relationship or retirement,
shall be prohibited. Legal basis: ILO 110, ILO 111, ILO 159, Supply Chain Due Diligence Act §2 (2) no. 7

3 Environment

BRUGGER GmbH and its relevant stakeholders of the supply chain in the country of delivery take over responsibility for
continually improving preventive actions and the application of environmentally friendly measures. Environmental awareness
is to be promoted among employees and employees of suppliers and other relevant stakeholders.
Procedures and standards for resource efficiency (especially water, energy, raw materials), reduced emissions and waste
management (especially wastewater) must correspond to the statutory minimums and are to be continually improved. The
natural basis for sustaining food and drinking water supply as well as people's health shall be ensured.
All environmental damage resulting from the operation of a business need to be prevented, especially harmful soil change,
water pollution, air pollution, and harmful noise emission. No unlawful forced eviction, unlawful deprivation of forests, lands
and waters should take place. The production of mercury products as well as use of chemicals banned at a national or
international level is prohibited. Legal Basis: Supply Chain Due Diligence Act §2 (2) no. 9, 10, 12

4 Ethical Business Conduct

The employees of BRUGGER GmbH and its stakeholders along the entire supply chain in the country of delivery are expected
not to practice or tolerate any form of corruption, extortion, or embezzlement. They do not offer or accept bribes or other
unlawful incentives to/from their business partners. Measures for implementing these principles are in place.
BRUGGER GmbH and its relevant stakeholders will safeguard and make only appropriate use of confidential information and
ensure that all employees' and business partners' privacy and valid intellectual property rights are protected.
Fair and free competition is respected and BRUGGER GmbH and all relevant stakeholders need to comply with the applicable
competition and antitrust regulations, especially not entering in anti-competition arrangements with third parties, abusing a
dominant market position or exchanging of competitively sensitive information.

5 Implementation

All of the above needs to be adhered to by BRUGGER GmbH and accepted by the management of the relevant stakeholders,
needs to be integrated into their company policy, and all employees are to be informed of the content of this Code and regularly
be trained to ensure compliance with these requirements.
A comprehensive and reasonable risk management shall be in place in the entire supply chain, and it is expected that risks are
identified and adequate measures are taken. Measures include trainings of employees, regular on-site audits by independent and
credible auditors and (announced and unannounced) inspections. A responsible person for implementation of this Code is to be
appointed. Complaint mechanisms for employees need to be established and accessibility by all employees needs to be ensured.
An effective complaint mechanism is open to anybody informed about violations of the standards enshrined in this CoC. The
complaint mechanism must exclude reprisals against the complainant.
BRUGGER GmbH ensures that an effective mechanism to remedy violations and to mitigate Code of Conduct Brugger GmbH as
of January 2022 Seite 4 / 5 risks is integrated into its management procedures. Misconduct must be identified, processed and
remedied immediately.
The requirements are expected to be integrated in day-to-day business. BRUGGER GmbH and relevant stakeholders shall
keep adequate records to substantiate compliance with this Code and applicable national and international statutes. All
stakeholders shall agree that BRUGGER GmbH regularly verifies compliance with this Code.

Download of the BRUGGER Code of Conduct