CODE OF ETHICS

of the company Becker GmbH CAD-CAM-CAST

Brückenstraße 19, 35239 Steffenberg

Preamble

Engineering, casting, and additive manufacturing - these are the core competencies of BECKER CAD-CAM-CAST. As a business partner of the automotive industry and motorsports, the company offers the complete process chain in-house. Reducing development times and costs, as well as meeting high quality standards - our actions are mostly based on these three criteria. Constant contact and communication with our business partners enables us to comprehensively understand current and future customer requirements and to implement them efficiently.

The company has the ambition to create a high market value for its customers, to be a preferred employer for its employees and to be a recognized company in society. In order to do this justice, the highest level of professionalism and integrity is required.

Therefore, this Code of Ethics serves as an ethical and legal compass to the company. It contains the important rules for our conduct within the company, as well as with our business partners and in public.

This Code applies to all business activities of Becker GmbH CAD-CAM-CAST. We are striving to offer our customers the best performance and to be their dependable partner. In order to maintain and further expand this position in the future, ethically correct and responsible actions of each individual employee are essential.

Shareholders and executive management expect all employees to strictly comply with the rules of this Code.

1. General principles

1.1 Basic understanding

Becker GmbH CAD-CAM-CAST is aware of its role in society and its responsibility towards business partners, shareholders, and employees. Explicit basic principles serve to ensure a value-oriented, ethical, and legally compliant corporate management in order to meet this responsibility in all corporate activities.

1.2 Commitment for all employees

All managers and employees are compelled to comply with the applicable laws and other relevant provisions at home and abroad in all business activities and decisions. This applies in particular to the compliance with the export and import regulations, as well as the provisions for handling conflict minerals. Business partners have to be treated fairly. Contracts are complied with, changes in the framework requirements must be taken into account.

​​​​​​​1.3 Universal values and principles

Becker GmbH CAD-CAM-CAST is guided by universally accepted ethical values and principles, in particular integrity, honesty, respect for human dignity and non-discrimination. Business partners have to be treated fairly, respectfully, reliably in all activities. The reputation of Becker GmbH CAD-CAM-CAST has to be respected and promoted. The products developed and marketed by Becker GmbH CAD-CAM-CAST are based on these standards. The company property has to be protected.

Conflicts of interest between business and private matters have to be avoided. It is prohibited, among other things, to obtain illegal advantages. When making donations, it is ensured that they only flow to non-profit organizations. The regulations regarding occupational safety, environmental protection, information security and data protection must be complied with. Participation in any form of money laundering is prohibited. Violations of this Code have to be reported immediately to the Managing Director (MD) or the Quality Management Officer (QMO).

Each supervisor is committed to judge his employees only by their performance and to ensure compliance with this policy in his area of responsibility.

The Code of Ethics cannot cover all the situations that we encounter in our daily work. We may face a dilemma, which we cannot solve easily. There are several ways to get advice and support. We can contact our direct supervisor, another person in the management structure, the human resources department, the MD or the QMO. Problems must not remain unresolved. Reprisals against employees who report problems in good faith will not be tolerated.

2. Corporate and social responsibility

​​​​​​​2.1 Human rights

Becker GmbH CAD-CAM-CAST respects and supports the adherence of internationally recognized human rights. In particular, Becker GmbH CAD-CAM-CAST complies with human rights in accordance with the UN Charter on Human Rights (Universal Declaration of Human Rights, Resolution 217 A (III) of the General Assembly from 12.10.1948).

​​​​​​​2.2 Non-discrimination rule

Becker GmbH CAD-CAM-CAST rejects any form of discrimination within the framework of the applicable rights and laws. This refers in particular to discrimination against employees on the basis of race, ethnic origin, gender, religion or convictions, disability, age, or sexual orientation.

​​​​​​​2.3 Occupational Health and Safety

Becker GmbH CAD-CAM-CAST guarantees occupational health and safety  protection at the workplace within the framework of national regulations. Becker GmbH CAD-CAM-CAST supports a continuous development to improve the working environment.

​​​​​​​2.4 Working conditions

Becker GmbH CAD-CAM-CAST respects the right to freedom of association and assembly of employees within the framework of the applicable rights and laws.

Becker GmbH CAD-CAM-CAST complies with the labor standards with regard to the maximum permissible working hours and compensation, in particular with regard to the level of compensation, in accordance with applicable laws and regulations.

Becker GmbH CAD-CAM-CAST supports the promotion of personal development of its employees. Employee appraisal interviews contribute to determine the necessary competencies, achievements, development plans and career paths in accordance with the individual needs and goals of the employee, as well as business requirements. Training and collaborative ways of working support this process. Becker GmbH CAD-CAM-CAST supports its employees in the development of their best potential by

•           Internal and external training

•           Assignment of responsibilities and empowerment to independence

•           Promoting continuous advancement at all levels

•           Offering career opportunities and fair pay

•           Active contribution to vocational training

We have the responsibility to treat others with respect. Becker GmbH CAD-CAM-CAST supports the creation of an environment in which employees are not afraid to express their opinion in a factual and constructive way with regard to improving and optimizing their working environment. Becker GmbH CAD-CAM-CAST does not tolerate any form of humiliation, harassment – be it sexual, physical, or psychological –, coercion, bullying or any other offensive behavior.

The privacy of employees is respected. Access to personal data is reserved for individuals whose role and responsibility requires the handling of personal data. Becker GmbH CAD-CAM-CAST does not transfer any personal information to third parties, except to the extent that this is necessary and permitted by the applicable laws and regulations.

The prohibition of forced labor of any kind is observed. In particular, the Forced Labor Convention from 1930 (Convention 29 of the International Labor Organization) and the Abolition of Forced Labor Convention from 1957 (Convention 105 of the International Labor Organization) are complied with.

Becker GmbH CAD-CAM-CAST complies with the regulations regarding the prohibition of child labor, in particular the Convention concerning Minimum Age for Admission to Employment from 1973 (Convention 138 of the International Labor Organization) and the Convention concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labor from 1999 (Convention 182 of the International Labor Organization). If a national regulation concerning child labor provides for stricter standards, these must be observed as a matter of priority.

​​​​​​​2.5 Environmental protection

Becker GmbH CAD-CAM-CAST is committed to sustainably protect the natural foundations of life for the present and future generation. Laws and regulations that have been enacted to protect the environment must be observed. Becker GmbH CAD-CAM-CAST strives to minimize the environmental burden caused by its processes and to regularly evaluate and monitor the environmental impact. This is also expected from suppliers.

​​​​​​​2.6 Communication

This Code of Ethics has been agreed upon with all responsible parties within the company.

Becker GmbH CAD-CAM-CAST communicates openly and dialogue-oriented regarding the requirements of this Code of Ethics and about its implementation to employees, customers, suppliers and other interested parties and stakeholder groups.

Becker GmbH CAD-CAM-CAST also strives collectively to promote a trustful dialogue between the company and its employees. In this sense, the company keeps its employees informed about business activities and complies with the legal requirements regarding the disclosure of information.

3. Fair competition

​​​​​​​3.1 Association with customers and suppliers

We are committed to treat all our customers honestly and fairly, regardless of the size of their company, and always comply with our contractual obligations. We must deliver high-quality and safe products and services to our customers that meet their expectations. Quality and safety are core values of Becker GmbH CAD-CAM-CAST. As a result, we must comply with all control standards, all applicable laws and regulations and internal control procedures to ensure that our customers receive safe and high-quality products.

Our suppliers make an important contribution to the value of our products and play a key role in customer satisfaction. We must promote relationships with our suppliers that are based on ethical principles and ensure that our suppliers are treated fairly and with respect. The criteria for the selection of goods and services are price, quality, performance, terms of delivery and suitability.

​​​​​​​3.2 Prohibition of corruption

Becker GmbH CAD-CAM-CAST rejects corruption and bribery. When dealing with business partners and state institutions, the interests of the company and the private interests of employees on both sides are strictly separated from each other. Decisions are made free from extraneous considerations and personal interests. The applicable criminal law regarding corruption must be observed. The granting of personal benefits by Becker GmbH CAD-CAM-CAST and its employees to domestic or foreign public officials (such as civil servants or employees in the civil service) with the aim of obtaining advantages for the company or personally or for third parties is not permitted.

Monetary personal advantages in return for unfair preferences in business transactions between companies cannot be offered, promised, granted, or approved. Likewise, in dealing with business partners, personal advantages of value in return for unfair preferences in business transactions cannot be requested or accepted. The management and employees of Becker GmbH CAD-CAM-CAST may not offer, promise, request, grant or accept gifts, payments, invitations, or services in business transactions that are granted with the intention of influencing a business relationship in an unfair way or in which there is a risk of jeopardizing the independence of the business partner. In principle, this is not the case regarding gifts and invitations that are within the scope of business hospitality, customs, and courtesy.

Every employee must strictly separate his private interests from the interests of Becker GmbH CAD-CAM-CAST. Even the appearance of a conflict of interest should be avoided. For example, it is not permitted to place orders with closely associated individuals (e.g. spouses, relatives, friends, and private business partners). It is also inadmissible to order something from companies in which closely associated individuals work or in which closely associated individuals have a stake of 5% or more. Secondary employment with competitors and secondary employment with business partners are not permitted. Only the responsible managing director can approve exceptions. Employees who would like to have a stake with 5% or more in one of our direct competitors or are already involved must report this to the MD or the QMO. They will review if there is a conflict of interest.

​​​​​​​3.3 Competitors

Becker GmbH CAD-CAM-CAST respects fair competition. Therefore, the applicable laws that protect and promote competition, in particular the applicable antitrust laws and other laws regulating competition, must be complied with. In dealing with competitors, these regulations prohibit, in particular, collusion and other activities that unfairly influence prices or conditions, illegally allocate sales territories or customers, or impede free and open competition in an inadmissible manner. Furthermore, these regulations prohibit unfair agreements between customers and suppliers, with which customers are to be restricted in their freedom to determine their prices and other conditions autonomously when reselling.

The distinction between prohibited cartels and permissible cooperation can be problematic. The MD or the QMO have to be contacted in these cases.

​​​​​​​3.4 Trade secrets

Becker GmbH CAD-CAM-CAST respects and protects the trade and business secrets of others. Confidential information and confidential documents may not be transferred to third parties without authorization or made accessible in any other way, unless a power has been granted in this case, it is publicly accessible information or an enforceable decision of an authority or a court forces the transfer.

4. Scope, implementation, and suppliers

​​​​​​​4.1 Scope

This Code of Ethics applies to the entire Becker GmbH CAD-CAM-CAST company as well as any affiliated companies.

​​​​​​​4.2 Implementation and compliance

Becker GmbH CAD-CAM-CAST will make this Code of Ethics known to its employees and act appropriately to ensure its compliance.

​​​​​​​4.3 Suppliers

Becker GmbH CAD-CAM-CAST will gladly transfer this Code of Ethics to its immediate suppliers upon request, to promote compliance with the content by its suppliers in the best feasible way and ask them to comply with these rules.

​​​​​​​4.4 Consequences of violations

For employees, violations of this Code may have the following consequences

•           Written warning

•           Termination

•           Claims for damages of third parties

For Becker GmbH CAD-CAM-CAST, violations of this Code may include the following

consequences

•           Claims for damages of third parties

•           Cost-intensive court proceedings

•           Fines

•           Loss of reputation

​​​​​​​​​​​​​​4.5 Contact

Do you have any concerns or questions?

•           Talk to your supervisor or the responsible department.

•           If a clarification is not possible, the MD or the QMO is available as contact.

•           The MD or the QMO can be contacted directly at any time, also confidentially and anonymously upon request:

              Michael Becker: 06465 9143-10 / mbecker@beckerccc.com
Beate Lenz: 06465 9143-14 / blenz@beckerccc.com

Becker GmbH CAD-CAM-CAST adheres to the EU Directive regarding the protection of individuals who report violations of EU law, the so-called Whistleblowing Directive, Directive 2019/1937 from 11.26.2019. All individuals who report actual or potential violations of which they have become aware in a professional context are protected.

If you become aware of a violation of this Code, you are required to inform the MD or the QMO immediately.