Code of Conduct

A. Preamble

Köhlerpappen GmbH is committed to social responsibility and value-based, responsible corporate management. This Code of Conduct sets out the fundamental principles that are decisive and trend-setting for our business activities.

Our actions in all business areas – especially in our dealings with customers, suppliers, business partners and our employees – are based on the values of integrity, fairness and transparency. Sustainability and the protection of the environment are central guiding principles for us and an integral part of our corporate policy.

Compliance with all applicable laws forms the foundation of our actions. The principles formulated in this Code of Conduct reflect the ethical attitude and self-commitment of Köhlerpappen, but do not establish any directly enforceable legal claims against the company.

B. General principles

  1. Compliance with laws: We comply with applicable laws, standards and other legal provisions in all countries in which we operate, as well as comply with existing social rules.
  2. Commitment to the ILO core labour standards: Köhlerpappen is expressly committed to the core labour standards of the International Labour Organization (ILO).
  3. Business partners and authorities: Köhlerpappen is committed to the principle of fair competition towards all market participants and works exclusively in accordance with generally accepted business practices, with special consideration of fairness and honesty. We maintain a trusting relationship with authorities.
  4. Trade secrets: All employees of Köhlerpappen are obliged to maintain confidentiality about all operational matters. This obligation continues to apply even after the termination of the employment relationship. Trade secrets of third parties are also treated with the necessary confidentiality by Köhlerpappen and its employees.
  5. Environmental protection and sustainability: Protecting the environment and sustainable products and production processes are both our concerns and obligations. It is an essential endeavour of ours to reconcile ecology and economy. This is a fundamental part of our corporate policy and corresponds to our responsibility for the region and the people living here. In order to meet our demand for environmentally friendly and sustainable production, our production processes are continuously optimised, also from the point of view of ecology.
  6. Data protection: Data protection is a high priority for our company. Our workforce is regularly sensitized through constant training and information on the handling of personal data. Compliance with the relevant laws, in particular the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG), is of course the basis of our actions.

C. Ethical, global and social principles

  1. No child labor: No employees under the age of 15 are employed. Persons under the age of 18 will not be assigned to perform dangerous or heavy work, unless it is an approved training in accordance with applicable national laws and regulations.
  2. No forced or compulsory labour: Any form of forced labour is excluded.
  3. No discrimination: We firmly reject any form of discrimination. This applies in particular, but not exclusively, to discrimination and disadvantages on the grounds of race or ethnic origin, gender, religion or belief, disability, age or sexual orientation.
  4. Occupational health and safety: For us, occupational health and safety are very valuable goods that take precedence over the goals of production without exception. All applicable regulations in this area must be strictly adhered to, conditions must be created that avoid risks to health and safety. In this context, the regulations of the occupational health and safety laws and the Working Hours Act must also be strictly observed.
  5. Remuneration: Köhlerpappen ensures that the remuneration of its employees fully complies with the applicable laws, in particular the Minimum Wage Act as a minimum standard. In addition, the collective bargaining regulations on remuneration issues are fully guaranteed and adhered to.

D. Principles of competition law

  1. Antitrust law and fair competition: We are fully committed to fair and free competition and always act responsibly towards our competitors. We consistently comply with all antitrust and competition law regulations. We firmly reject any form of price or condition agreements as well as agreements to restrict competition or to share markets and customers.
  2. Combating bribery and corruption: Köhlerpappen does not tolerate any form of bribery or corruption. Such behavior will not be accepted under any circumstances and will be strictly prohibited.
  3. Dealing with gifts and invitations: Köhlerpappen does not tolerate any form of bribery or granting of advantages. Gifts or invitations may only be given within the framework of what is socially customary and must not expect or influence anything in return. The acceptance of monetary gifts is strictly prohibited in any case, regardless of the amount. A particularly strict standard applies here.

E. Implementation

  1. Employees: Köhlerpappen brings this Code of Conduct to its employees’ attention in an appropriate manner and at regular intervals and ensures compliance with the regulations written down here. All employees are encouraged to report violations of this Code – openly or anonymously. You can reach this reporting office at the following e-mail address: koehlerpappen@kanzlei-endingen.de

    The reporting office is: Die Kanzlei Rechtsanwälte Kleine, Eisenbahnstr.3, 79346 Endingen.

    The task of this reporting office is to receive and check information about violations in accordance with §2 HinSchG by name or anonymously and, if necessary, to take further steps.
    Whistleblowers are protected from reprisals by internal procedures. The confidentiality of the identity is maintained to the extent legally possible.

  2. Business partners: We expect our business partners to also comply with all applicable laws and regulations when working with Köhlerpappen. We recommend that our business partners also adopt similar principles.
  3. Conflicts of interest: Employees must avoid potential conflicts of interest between private interests and the interests of the company. If unavoidable, these must be openly disclosed to the responsible manager.
  4. Validity and review: This Code of Conduct is regularly reviewed to ensure that it is up-to-date and adapted if necessary. It shall enter into force upon publication. All managers are obliged to ensure compliance with it within the scope of their responsibility.

Köhlerpappen GmbH, Mr. Christian Geiger, Manager

Gengenbach, 13.06.2025