The Sanpack GmbH Code of Conduct

Sanpack GmbH, which was founded in 1956 in Hamburg, is a family undertaking. It stands for the latest technology in its manufacturing methods, as well as for social and economic responsibility, and for the promotion of Germany as a production location of choice.

Minimum standards are defined in this Code of Conduct, which Sanpack GmbH, as well as all of its suppliers are obligated to comply with. Furthermore, Sanpack GmbH strives to exceed these requirements whenever possible.

1. Scope

The Code of Conduct presented herewith represents the basis for all business relations for the production, sale and procurement of goods by Sanpack GmbH. Likewise, all business partners are called upon to comply with the principles listed on the basis of this Code of Conduct.

2. Corporate Values

Competence and commitment, as well as responsible actions and conduct by all of the employees represent the fundamental preconditions for the success of Sanpack GmbH. Its corporate mission statement emphasises such responsibility with respect to people and nature, as well as the promotion of fairness and tolerance. This includes the following principles:

Compliance with and observance of the underlying legal and cultural conditions is self-evident.

Dealings with employees and third parties occur in a fair, polite and respectful manner.

The interests of customers and business partners are taken into consideration appropriately.

Each and every form of discrimination resulting from gender, origin, religious affiliation or other characteristics is to be refrained from.

Professionalism, fairness and reliability have utmost priority in all of the business relations.

3. Dealing with Employees and Business Partners

All employees are to be treated with respect and dignity, without exception. Each and every form of physical, mental, sexual or verbal abuse, harassment or intimidation is forbidden. Any disciplinary measures may not be in violation of the national legislation and internationally recognised human rights. Members of staff who lodge a complaint due to violations of the regulations contained in this Code of Conduct or in the national laws may not be subjected to any form of disciplinary measure.

The relations with our business partners are to be characterised by mutual reliability, honesty, politeness and fairness. This includes that decisions are taken and communicated in a transparent and traceable way. These principles are to be exemplified by the management in relation to the employees and complied with by the employees among themselves in the same way.

4. Freedom of Association

It is the right of the staff and workers to establish a labour organisation or trade union of their own choice or to join such a body for the purpose of collective bargaining.

5. Compliance with Laws

The national legislative provisions, and especially the labour and social welfare laws, as well as the environmental protection provisions have to be complied with.

Employment-contract agreements or comparable measures are not permitted to circumvent this Code of Conduct.

6. Non-Discrimination

All of the staff and workers have to be treated in the same way. It is forbidden to discriminate against, abuse or harass someone because of their origin, skin colour, nationality, ethnicity, gender, sexual identity, religious or other beliefs or ideology, political opinions, age, physical constitution or appearance. Each employee is obligated to respect the personal spheres of the other employees. Sexual harassment and bullying are forbidden.

7. Child Labour

The minimum age for employment may not be lower that the age at which compulsory education ends, and under no circumstances beneath the ages of 15 or 14 years old respectively in the event that national law permits same in accordance with the ILO Convention No. 138. The respective national regulations on the protection of children and young employees have to be complied with.

8. Work Hours

German legislation is applicable with respect to regulating work hours. In accordance with this, the regular basis of 40 hours per week and 60 hours per week including overtime may not be exceeded. Employees have to be remunerated adequately. After six consecutive days of work, all employees have to be granted a day off.

9. Remuneration

The payment to the workers and staff has to correspond at least to the statutory minimum wage or, in the event that the amount is higher, to the minimum wage that is typical for the industry. Any overtime has to be remunerated at the statutory additional amounts or those typical for the industry. The wages paid should be sufficient to cover the employees’ basic needs. All of the employees have to receive at least the statutorily prescribed social benefits.

Any illegal or unjustified wage deductions intended as a direct or indirect disciplinary measure are forbidden. Furthermore, staff and workers must be informed on a regular basis in a manner comprehensible for them about the complete composition of their salary or wages.

10. Documentation of the Conditions of Employment

The employment has to be based on a formal document, such as e.g. an employment contract or a letter of employment. The business partners guarantee the written documentation of the work conditions. This document has to provide information about work and employment conditions, including the salary/wages, time period and payment, retirement benefits, holiday entitlements and period of notice. The circumventing of work and social insurance standards is forbidden to the same extent as is the circumventing of the Code of Conduct by means of artificial training programmes, indentured labour or similar methods.

11. Work and Health Protection

Safety at work is a fundamental principle. The safety regulations have to be complied with consistently and strictly. This is applicable for all dangers and hazards that can occur at the employees’ workplaces. Any accidents or any potential hazards and loads identified and recognised as such, as well as any near-misses have to be reported to the management immediately.

The employees are informed on a regular basis about these regulations and receive training in order to enhance their awareness for hazards and dangers, as well as to foster this mind-set during all safety-relevant operations and activities.

The employees are guaranteed a hygienic working environment.

12. Environmental Protection

Sanpack GmbH is committed to the protection of our environment and has declared the resource-conserving manufacture of all products to be a corporate aim. The following environmental protection guidelines are applicable:

We protect our environment, conserve and use all natural resources economically and avoid or reduce the negative impacts for people and nature.

We take into account the requirements for having an intact environment in the development and design, the production processes, the packaging and the shipping of our products, as well as in the improvements to the methods and processes, and when introducing new plant and products.

We also expect of our business partners to comply with all of the laws and ordinances for the protection of people and the environment.

When disposing of waste, the disposal method and route is to be chosen that is most protective to the environment and is economically viable. Should any incidents occur that can have negative impacts on the environment, the management are to be informed immediately and comprehensively about same and, for their part, arrange the forwarding of the statutorily prescribed notifications to the authorities.