Ortlinghaus Group
Code of Conduct, Compliance & Anti-Corruption Policies.

 

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Ortlinghaus Code of Conduct for employees, subcontractors, sales partners and suppliers

Issue: 2023

Preamble

The Code of Conduct, which was first adopted in 2017 and last revised in 2023, sets out rules of conduct for Ortlinghaus employees, subcontractors, suppliers and sales partners (hereinafter also referred to as "business partners") in compliance with the principles of corporate governance and the ten principles of the United Nations Global Compact Initiative (www.unglobalcompact.org).

Ortlinghaus is committed to the principles of

  • ethics,
  • integrity,
  • compliance with the law,
  • respect for people and
  • the environment.

The principles enshrined in the Code of Conduct form the framework for Ortlinghaus's corporate and social activities. In this way, we encourage our employees to act independently and responsibly. The Code of Conduct is intended to provide clear guidance in day-to-day work. It regulates the conformity of our actions with the law and with societal, cultural and social norms and values. Through the Code of Conduct, we give our business partners a clear framework of values which they must uphold.

 

Social responsibility

Our social responsibility includes observing and complying with the law, but also goes beyond this for the benefit of people and the environment.

Human rights

Ortlinghaus is resolutely committed to complying with an extensive catalogue of international human rights standards.

Ortlinghaus integrates the following standards into its own business processes:

  • Universal Declaration of Human Rights
  • United Nations Covenants on Human Rights
  • Core labour standards of the International Labour Organization (ILO)
  • OECD Guidelines for Multinational Enterprises
  • UN Guiding Principles on Business and Human Rights
  • UN Global Compact ("The Ten Principles")

What do we do?

We respect, protect and promote the applicable regulations for the protection of human rights and children's rights (hereinafter "human rights") worldwide as fundamental and universally applicable standards. We reject all forms of child, forced and compulsory labour as well as all forms of modern slavery and human trafficking and are committed to the protection of minorities and indigenous peo- ples. We observe the principles of freedom of association and assembly, advocate appropriate re- muneration (wages and social benefits) and working hours and participate in collective bargaining. This applies not only to cooperation within our company, but also, of course, to the conduct of and towards business partners. We will refrain from and prevent the commissioning or use of private or public security forces if the prohibition of torture and cruel, inhuman or degrading treatment is disre- garded, life or limb is injured or freedom of association and union is restricted due to insufficient instruction or control on the part of the supplier when deploying the security forces. We respect the land, forest and water rights of others and reject unlawful eviction.

We encourage our employees to

  • watch for signs of human rights violations,
  • take responsibility if indications of human rights violations arise at work (e.g. child labour in a supplier's production operations or employees working in inhumane conditions) and
  • ensure that these violations are prevented or remedied.

Our business partners keep these fundamental rights firmly in mind and take them into account in their work as a matter of course.

Equal opportunities, equal treatment and diversity

Discrimination deprives us of opportunities that arise from different views, ideas and experiences.

Equal opportunities, equal treatment and diversity are important cornerstones for fair, unprejudiced and open interaction. Protected personal characteristics are the following in particular:

  • Age
  • Gender or gender identity, in particular women's rights
  • Participation in employee representation including trade union activities
  • Political beliefs
  • Sexual orientation
  • Marital status
  • Ethnic origin
  • Pregnancy
  • Nationality
  • Language
  • Disability
  • Religion
  • Genetic profile

What do we do? 

We do not tolerate any form of discrimination, including racism. We always treat our employees, business partners and customers with respect, regardless of personal characteristics. Judgements are based on performance and ability, not on an individual's personal background, beliefs or personal characteristics. In this respect, we take into account the applicable national regulations, in particular the General Equal Treatment Act (AGG), and routinely take anti-discrimination measures and uphold ethical recruitment. Ortlinghaus fosters an environment of trust, integrity and mutual respect. This enables us to maximise productivity, competitiveness, innovation, creativity and efficiency. We are actively committed to inclusion and create an environment that promotes the individuality of each person in the interests of the company.

Our employees

  • treat each other fairly by keeping the principles of equal opportunities and equal treatment in mind and also encourage people around them to observe these principles.
  • actively tackle violations of the principles of equal opportunities and equal treatment (e.g. dis- crimination on the basis of gender or background) and do not accept violations silently.
  • inform the individuals concerned of their misconduct or report it if necessary.

Our business partners uphold these principles and, like Ortlinghaus, actively work towards compli- ance with them in their companies.

No bullying, no intimidation, no ostracising, no sexual harassment

Bullying, discrimination, hostility or harassment are detrimental to productive cooperation and are unacceptable both among employees and managers.

A hostile working environment should be avoided at all costs. Examples of unacceptable behaviour include:

  • Intimidation of any kind
  • Destructive criticism
  • Spreading lies or insinuations
  • Sexual harassment (e.g. lewd remarks, unsolicited advances or physical contact)
  • Exclusion, including from workplace communication
  • Jokes or demeaning comments about ethnic origin or other personal characteristics
  • Bullying, i.e. unfair treatment of a person or group of people who are systematically and regularly attacked and marginalised through harassment, insinuations, malice or scheming over a lengthy period of time.

What do we do?

There can never be any justification for such behaviour. We therefore strictly reject such behaviour and will immediately follow up on any information in this regard.

Our employees who are personally affected or who observe such incidents

  • always consider confronting the person responsible and pointing out that their actions are unacceptable.
  • turn to colleagues in confidence or report the inappropriate behaviour, if a direct approach is not possible in the specific situation or if the inappropriate behaviour continues despite being addressed.

As a business partner, you should also reject such behaviour and actively counteract it.

Environmental protection

We help to maintain a sustainable basis for life.

Ortlinghaus develops, produces and distributes first-class drive technology worldwide. Our aim is to be a global provider of sustainable, customised technology. We are aware of our special responsi- bility for the environment.

What do we do?

As a commercial enterprise, we bear responsibility for the environmental compatibility and sustain- ability of our products, sites and services. As part of our sustainability strategy, we focus on environ- mentally friendly, advanced and efficient technologies and implement these throughout the life cycle of our products.

In development, purchasing and production, we pay attention to

  • careful use of natural resources, in particular sustainable resource management, waste avoid- ance and the reuse and recycling of raw materials in accordance with the Basel Convention,
  • responsible procurement of raw materials,
  • continuous reduction of our environmental impact, in particular taking into account aspects such as energy efficiency using renewable energy, proper monitoring and reporting of greenhouse gas emissions, continuous review of decarbonisation to reduce carbon turnover and improve air quality, noise emissions, water quality, water consumption and water management, as well as soil quality at the relevant sites,
  • chemicals management (hazardous substance management, REACH and ROHS) in accord- ance with the Stockholm Convention (POP Convention)
  • compliance with environmental protection laws and regulations,
  • animal welfare,
  • biodiversity, land use and deforestation.
We have various certifications, and we are happy to provide up-to-date information on their specific details. In addition, we constantly reevaluate the environmental compatibility of products and manufacturing processes and optimise them where necessary. We are a responsible member of society and a partner in politics.

Subcontractors working for Ortlinghaus are obliged to comply with appropriate environmental stand- ards. Suppliers are checked accordingly before they form a business relationship with Ortlinghaus and asked to commit to the values described.

Our employees

  • adhere to our environmental guidelines and endeavour to use resource-conserving working practices.
  • take the initiative to participate in local action in the form of voluntary and community service, and
  • consider how they can advance environmental or social issues for the benefit of society in their role.
  • take an active approach when they notice something environmentally damaging (example: at a production site, chemicals drip onto the floor and seep into the ground) and inform the employee responsible as soon as possible.
  • do not assume that a problem is already known - it is always better to report it several times than not at all!

Our subcontractors and suppliers take environmental protection concerns into account in their activities and use resources and energy efficiently and sparingly. They ensure that their activities have the smallest possible negative impact on the environment and that they comply with environ- mental laws and regulations.

Product conformity and safety

Ortlinghaus products are used in a wide variety of scenarios. We are responsible for minimising the resulting risks (both economic risks and risks to health, safety and the environment) for our custom- ers or their customers.

What do we do?

Our products meet the current state of the art and are developed and certified in accordance with legal requirements. This is ensured continuously and systematically thanks to our processes and structures. We are committed to complying with legal requirements and official regulations and standards. This is part of our high quality standards. We have a product safety officer who monitors our standards.

Our employees

  • are self-critical.
  • take remedial action if they believe that a product may pose a risk or if regulations are not complied with.
  • report hazards to the responsible bodies.

Our business partners undertake to inform Ortlinghaus if they become aware of imminent or existing risks and to counteract these as best they can in co-operation with Ortlinghaus.

Our responsibility as a business partner

Integrity, transparency and fairness are the foundations of credibility and trust in business dealings.

Free and fair competition

Fair and free competition is protected by the applicable competition and antitrust laws. Compliance with these laws ensures that there is no distortion of competition on the market - to the benefit of all market participants. The following in particular are prohibited:

  • Agreements with competitors, including price fixing, bid rigging, market sharing and supply short- age agreements,
  • Exchange of competitively sensitive information with competitors,
  • Imposition of restrictions or obligations on customers and suppliers, and
  • Abuse of market power.

Not only can anti-competitive behaviour cause considerable damage to Ortlinghaus's good reputa- tion, it can also result in severe fines and penalties.

What do we do?

Ortlinghaus undertakes to comply with the principles of free and fair competition.

We conduct business exclusively in line with the performance principle and on the basis of the market economy as well as free, unhindered competition. We like to measure ourselves against our com- petitors and always adhere to the law and ethical principles. We do not enter into anti-competitive agreements with competitors, suppliers or customers. Insofar as our company has a dominant mar- ket position, we do not abuse it. When dealing with our authorised sales partners, we comply with the specific antitrust framework for distribution systems.

Correct and non-discriminatory corporate behaviour and compliance with the principles of fair com- petition have always been a matter of course for Ortlinghaus. We aim to be a role model in this area too.

Our employees

  • familiarise themselves with the Ortlinghaus guideline on antitrust law and compliance and follow it. The guideline provides specific information on what is and is not permitted.
  • question their actions and take the initiative.
  • consult others if they are unsure about something. Again, this principle applies here: better one too many than none at all.

Our business partners guarantee compliance with these basic rules of free and fair competition.

Combating corruption - gifts, hospitality and invitations

Any appearance of inappropriate behaviour must be avoided.

Corruption is a serious problem in business transactions. It harms society and distorts competition. The consequences are substantial fines for the company and criminal sanctions for the employees concerned, as well as claims for damages and other costs (e.g. legal fees and court costs).

Depending on the country, there may be further civil, criminal and administrative consequences. It is important to be aware that ignorance is no defence against punishment. This means that even a payment that is not known to be illegal can be deemed corrupt and penalised.

Corruption does not just start with large bribes. Corruption must already be considered a possibility where gifts, hospitality and invitations are given that exceed an appropriate level and violate internal or legal regulations.

What do we do?

Ortlinghaus only gives benefits to business partners, customers or other external third parties to the extent permitted by law. Ortlinghaus strictly adheres to the ban on corruption and practices that suggest corruption. We do not pay bribes and do not accept bribes. We regularly train our employees to raise awareness of this topic and issue internal guidelines on how to deal with gifts, hospitality and invitations to events, which benefits are appropriate and which checks must be carried out (see anti-corruption guidelines). We also call on our business partners to behave correctly.

Our employees

  • familiarise themselves with the Ortlinghaus anti-corruption guidelines and follow them. The guidelines give specific information on what is and is not permitted.
  • never offer bribes and never allow themselves to be bribed, whether directly or indirectly.
  • always proactively check internal regulations before giving or receiving gifts or issuing or accepting invitations.

Our business partners act in accordance with these values and take precautions in their own com- panies to prevent corruption from the outset.

Dealing with public officials and elected representatives

Special legal conditions often apply when dealing with public officials or elected representatives, governments, authorities and other public institutions. Even supposedly minor offences can have serious consequences and can permanently exclude us from being awarded public contracts.

What do we do?

Ortlinghaus's contacts with public officials and elected representatives are strictly based on the law and the relevant internal regulations to avoid conflicts of interest and corruption. In particular, we do not make facilitation payments, i.e. payments to public officials to expedite routine official acts.

Our employees

  • are aware of their responsibility in dealing with public clients and the particularly strict rules.
  • if in doubt, always consult the responsible contact person in the company. Our business partners should act just as carefully and thoughtfully here.

Avoiding conflicts of interest

It is possible that private interests or interests from secondary activities may conflict with the interests of Ortlinghaus. In this case, a conflict of interest arises which can damage the company.

What do we do?

Ortlinghaus respects the private and personal interests of its employees. Nevertheless, we attach particular importance to avoiding conflicts between private and business interests or even the ap- pearance of such conflicts. Decisions are made exclusively on the basis of objective criteria.

Our employees

  • avoid conflicts of interest or the appearance of conflicts of interest by actively approaching their managers if necessary in order to find a joint solution.
  • actively address any conflicts of interest they notice among colleagues. Our business partners actively point out existing conflicts of interest.

Export control

Cross-border trade is subject to prohibitions, restrictions, authorisation requirements or other moni- toring measures within the framework of export controls. In addition to actual exports, this also in- cludes temporary exports, such as taking items and technical drawings on business trips, as well as technical transfers, for example by email or the cloud.

What do we do?

We ensure compliance with all regulations on the import and export of goods, services and infor- mation.

Our employees

  • use internal guidelines to check whether export control regulations apply.
    • contact their managers and the individuals responsible for export control in cases of doubt Our business partners independently check whether regulations apply and comply with them.

Compliance with economic sanctions

Economic sanctions are trade or financial sanctions imposed by one or more countries specifically against a state, a group of states or individuals or a natural person. In principle, they serve to bring about a change in the behaviour or foreign policy of another nation, to enforce human rights or to avoid the use of military force.

What do we do?

Ortlinghaus considers it its duty to conduct its business activities in full compliance with all applicable economic sanctions.

Our employees

  • actively contribute to ensuring that we as a company fulfil this obligation and
  • observe any prohibitions that may be issued for the fulfilment of individual obligations.

Business partners should join us in complying with economic sanctions.

Prohibition of money laundering and terrorist financing

Almost all countries in the world have laws against money laundering and terrorist financing. Money laundering occurs when money or other assets originating directly or indirectly from criminal offences is brought into the legal economic cycle, concealing the money's origin. Terrorist financing occurs when funds or other resources are made available for terrorist offences or to support terrorist organ- isations. Liability for money laundering does not require the party involved to be aware that money is being laundered through the legal transaction or transfer in question. Even unintentional involve- ment in money laundering can result in severe penalties for all those involved.

What do we do?

We carefully verify the identity of customers, business partners and other third parties with whom we wish to do business. It is our declared aim to maintain business relationships only with reputable partners whose business activities comply with legal regulations and whose resources are of legiti- mate origin. We immediately allocate incoming payments to the corresponding services and post them. We ensure transparent and open payment flows.

Our employees

  • ensure that they do not take any measures that could violate domestic or foreign money launder- ing regulations.
  • undertake to comply with the regulations laid down in the anti-corruption guideline.
  • pay attention to suspicious behaviour on the part of customers, business partners and other third parties and report this where necessary.
  • observe all applicable regulations on recording and accounting for transactions and contracts in their area of responsibility.

Our business partners are careful when selecting their customers, business partners and other third parties and take precautions to prevent money laundering and terrorist financing.

Proper bookkeeping and record-keeping

For Ortlinghaus to develop and maintain the trust of the public, contractual partners and supervisory authorities, proper accounting and correct financial reporting are essential. If irregularities occur, this may have serious consequences for the company and also for the individuals responsible.

Examples of relevant "books" are:

  • Expense reports,
  • Invoices,
  • Financial reporting,
  • Annual reports,
  • Contracts,
  • Emails,
  • Other documents that we create or process in the course of our work.

What do we do?

Ortlinghaus is aware of its financial responsibility. Proper documentation of our work helps each of us to do our job to the best of our ability. Any records we keep or create must be accurate, complete, up to date and truthful. In this way, we ensure that we comply with the relevant legal requirements for proper accounting. This helps us to make good decisions and inform interested parties about our business activities to the extent necessary.

Our employees

  • organise themselves in such a way that all business financial data is recorded correctly and on time and can also be processed in the accounting department.
  • take our internal guidelines into account.
  • contact the relevant department if they have any questions about correct data recording.

Our business partners ensure the necessary degree of reliability and transparency in order to fa- cilitate a trusting working relationship.


Our responsibility in the workplace

The health and safety of every single employee is in our own best interest - this also applies to the data of employees, customers or contacts, as well as to company-specific expertise, business se- crets and company assets.

Occupational health and safety

Ensuring a safe and healthy working environment for employees and all our stakeholders is one of our top priorities. In this respect, it is particularly important to take into account and implement the applicable national statutory protection laws, for example the Working Hours Act, the Minimum Wage Act and the Occupational Health and Safety Act in Germany. At the same time, a company-wide health and safety policy must be developed and maintained in order to protect and motivate the company's greatest asset - its employees.

What do we do?

Ortlinghaus takes its responsibility for the health and safety of its employees very seriously. We ensure occupational health and safety within the framework of the applicable national regulations and on the basis of our company's health and safety policy. We minimise risks and promote the health, safety and job satisfaction of our employees by continuously improving our processes and implementing health promotion and healthcare measures. We make no compromises when it comes to occupational health and safety. No job is worth jeopardising people's health or even their lives. We therefore expect all our employees to comply with our health, safety and security regulations, to promote a safe and healthy working environment and to improve our health and safety culture. To do this, we need to create a common understanding of what it means to act and work together in a safe way.

Our employees

  • familiarise themselves with the applicable occupational health and safety regulations
  • use the Ortlinghaus health promotion programmes.
  • make an active contribution to maintaining and promoting their health by voluntarily taking ad- vantage of prevention and health promotion measures.
  • never jeopardise the health and safety of a colleague or business partners
  • actively co-operate within the limits of their authority and take all reasonable and legally required measures to ensure that their workplace is always safe to work in.
  • report any violations.

Our business partners guarantee occupational health and safety to the appropriate extent.

Data protection

In order to protect privacy and personal rights, special legal regulations must be observed when handling personal data. These include national regulations such as the Federal Data Protection Act, but also international regulations such as the General Data Protection Regulation.

Personal data processing (collection, storage, use, etc.) always requires a legal basis. This can be consent, but also the necessity of processing the data to fulfil a contract or another legal basis.

What do we do?

We process personal data in strict compliance with the applicable data protection regulations. In particular, we protect the personal data of our employees, but also that of customers, suppliers and other data subjects. Ortlinghaus has a data protection officer who can be contacted at any time with questions about data protection. In addition, regular sessions are held to raise awareness of data protection and data security.

Our employees

  • actively observe data protection issues in their day-to-day work
  • keep in mind that personal data processing always requires a legal basis.
  • familiarise themselves with our data protection and IT security policy.
  • contact the office responsible for data protection if they are unsure in individual cases whether processing is permitted.

Our business partners meet the applicable data protection conditions.

IT security

Information technology (IT) or electronic data processing (EDP) is an integral part of our everyday working lives, as digitalisation is increasing on a daily basis. However, this welcome progress also harbours a number of risks. This includes, in particular, the impairment of data processing by mal- ware (viruses), the loss of data due to program errors or the misuse of data (e.g. by hackers).

What do we do?

We draw up IT and data security guidelines in order to protect our company in the best possible way and position it technologically.

Our employees

  • familiarise themselves with our IT usage guidelines and adhere to them.
  • prefer to ask too much rather than too little when questionable incidents occur.
  • observe the basic rules for secure data exchange in particular by only using data carriers or sys- tems provided by the company for data exchange.
  • act in accordance with the specifications for information classification. Our business partners are committed to an equally high standard.

Security and protection of information, knowledge and intellectual property

Ortlinghaus holds various internationally protected patents and has extensive trade and business secrets as well as technical expertise. This knowledge is the cornerstone of our success. Ortlinghaus also has access to customers' intellectual property, trade secrets and expertise.

The unauthorised disclosure of such knowledge could cause the company millions in damage. Em- ployees would also face consequences under labour, civil and criminal law.

What do we do?

We are aware of the value of this knowledge and take a range of measures to protect Ortlinghaus and customers from unauthorised use. We provide our employees with guidelines on handling pro- tected information and regularly raise awareness of this issue.

We recognise the intellectual property of competitors, business partners and other third parties and expressly reject plagiarism.

Our employees

  • learn how to handle internal information and handle all company information with care.
  • do not pass on any information to third parties.
  • comply in particular with the special requirements for handling technical expertise, patents, trade secrets and business secrets.

Our business partners recognise our intellectual property and that of competitors, partners and other third parties and handle it accordingly.


Management systems

We expect our suppliers and subcontractors to implement management systems that support com- pliance with applicable laws in their organisations and promote continuous improvement in relation to the expectations set out in this Code of Conduct. This includes the following aspects:

Legal and other requirements

Suppliers and subcontractors should comply with all applicable laws, regulations, contractual agree- ments and generally recognised standards.

Communication of sustainability criteria in the supply chain

Suppliers and subcontractors should communicate the principles set out in this Code of Conduct throughout their supply chain.

Commitment and responsibility

Suppliers and subcontractors are required to fulfil the expectations of this Code of Conduct by provid- ing appropriate resources within their companies.

Risk management

Suppliers and subcontractors are expected to implement processes to identify, determine and mon- itor risks in all areas addressed in this Code of Conduct and all applicable legal provisions.

Documentation

Suppliers and subcontractors are expected to draw up appropriate documentation to demonstrate that they share the principles and values of this Code of Conduct. If the parties agree, Ortlinghaus may inspect this documentation.

Training

Suppliers should organise training to provide their managers and employees with an adequate un- derstanding of the contents of the Code of Conduct and the applicable laws, regulations and gener- ally accepted standards.

Continuous improvement

Suppliers are expected to continuously improve their sustainability performance through appropriate measures. 


Contact person and whistleblower portal

This Code of Conduct summarises Ortlinghaus's fundamental ethical values and our expectations of our employees, subcontractors, sales partners and suppliers. In order to uphold these values and constantly improve, we ask everyone to join us in keeping these values in mind. Talk to us or contact us if something is not right.

Contacts

If you have any questions, feel unsure about something or suspect internal or external requirements and legal regulations have been violated, please contact the relevant departments in confidence. They can be found in our organisation chart.

You can also contact the Compliance Officer at Ortlinghaus about anything at any time:

Dr Georg Jaster

TIGGES Attorneys at Law Zollhof 8, 40221 Düsseldorf

Tel.: +49 (0)211 8687-145, email: jaster@tigges.legal

Disclosure of information

Information on breaches of regulations can be reported by Ortlinghaus employees, subcontractors, suppliers and sales partners via the Ortlinghaus whistleblower portal. The whistleblower portal should always be used if it is not possible to approach the direct line manager or one of the above contacts for practical or emotional reasons or if a breach of rules is to be reported anonymously.

All information provided within the whistleblower system is treated in strict confidence. The infor- mation is reviewed by the Compliance Officer in cooperation with the responsible departments at Ortlinghaus. If the identity of the whistleblower is known, it will be kept secret. The whistleblower or complainant will be kept informed about the handling of their complaint. In accordance with legal requirements, whistleblowers need not fear any reprisals.

You can use the following channels to report information: 

Online:

https://ortlinghaus.app.workflows.ai/portal

By telephone

+49 211 81 99 82 - 30

Email

employees: hinweise.ortlinghaus@tigges-dco.de

subcontractors, sales partners and suppliers:

speakup.supplychain@ortlinghaus.com

Implementation of requirements by subcontractors, suppliers and sales partners

We expect our subcontractors, suppliers and sales partners (hereinafter referred to as "the supplier" for simplicity's sake) to identify risks within supply chains and to take appropriate preventive and remedial measures.

The supplier must impose this Code on its own suppliers and employees or ensure its suppliers and employees comply with the regulations contained in this Code by means of appropriate contractual arrangements. In the event of suspected violations and to safeguard supply chains with increased risks, the supplier must inform the company promptly and, if necessary, routinely about the violations and risks identified and the measures taken.

Ortlinghaus is entitled to check compliance with the standards and regulations specified in this Code of Conduct using appropriate and suitable methods, e.g. with the help of a self-assessment ques- tionnaire and supplier certifications. Ortlinghaus and the supplier may agree on the details of the certifications, in particular the issuer of the certificate, in a separate document. If a risk analysis carried out by Ortlinghaus shows that an audit at a supplier site appears necessary, the supplier hereby agrees that such an audit to check compliance with the Code may be carried out at the supplier's site in question during normal business hours by an authorised person with reasonable advance notice.

The supplier undertakes to provide all documents and information required for the performance of an audit. During the audit, data protection provisions will be observed and care taken to ensure that the confidentiality of the supplier's business secrets is protected.

Should a breach of the provisions of this Code of Conduct be identified, Ortlinghaus will notify the supplier of this in writing without delay and set the supplier a reasonable grace period to bring its conduct into line with these provisions. If a remedy is not possible in the foreseeable future, the supplier must notify Ortlinghaus of this immediately and draw up a plan and schedule with Ortling- haus for ending or minimising the breach. If the grace period expires without action being taken or the implementation of the measures in the plan does not remedy the situation after the expiry of the schedule and less drastic means are not available, Ortlinghaus may terminate the business relation- ship and cancel all contracts. The statutory right to extraordinary termination without setting a grace period, in particular in the case of very serious violations, will remain unaffected, as will the right to compensation.

No third-party protection

This Code of Conduct exclusively governs the relationship between Ortlinghaus companies and their suppliers. Third parties are not included in the scope of protection of this Code of Conduct and cannot assert any rights under it.