07/06/2024
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Due diligence obligations - Supplier Code

Dear suppliers,

As an internationally operating company for water treatment plants with worldwide partners in the supply chains, JUDO Wasseraufbereitung GmbH (hereinafter referred to as JUDO) is aware of its special responsibility for people and the environment in its own supply chains.

Both the basis of our own actions and the requirements we place on our suppliers therefore consist of the internationally recognised standards and principles listed below:

  • the principles of the "UN Global Compact",

  • the OECD Guidelines for Multinational Enterprises

  • the Universal Declaration of Human Rights,

  • the "UN Guiding Principles on Business and Human Rights" and

  • the conventions of the International Labour Organisation (ILO)

We enshrine these in this Supplier Code of Conduct.

Scope of application

This Supplier Code of Conduct is binding for all natural and legal persons in Germany and abroad who sell services, raw materials, products or processes to JUDO themselves or through third parties (e.g. subcontractors or distributors) or provide them for JUDO.

(hereinafter referred to as "Supplier").

1. Values and principles

The business behaviour of JUDO and its employees is always in line with the company's values and principles of conduct as set out in our Declaration of Principles. JUDO demands the same from its suppliers and their employees. Our suppliers must therefore also expressly commit to compliance with the applicable laws and the principles of behaviour and values described below.

1.1 Reliability, transparency and trusting cooperation

JUDO acts as a reliable partner towards its suppliers and partners in a reliable, honest and fair manner in order to build trust, because trust is the basis for successful cooperation. We also expect the same from our suppliers. JUDO therefore only maintains long-term business relationships with suppliers whose business practices comply with the values and principles of this Supplier Code of Conduct.

1.2 Supply chain risks

JUDO attaches particular importance to continuously analysing and evaluating our global supplier network, to which you as a supplier and your sub-suppliers belong. We therefore expect our suppliers, together with their sub-suppliers, to orientate their business activities towards social, ecological and economic principles, in particular taking into account the above-mentioned standards and guidelines.

In order to fulfil this requirement, we expect our suppliers and their sub-suppliers to actively cooperate and support us in identifying and assessing any risks. Such co-operation includes in particular

the acceptance by our suppliers of on-site inspections by us or by third parties commissioned by us,

providing (self-)information at any time on circumstances relating to supply chain risks,

using and publicising the whistleblowing and complaints channels provided by us, both to our own employees and to the employees of our suppliers' subcontractors.

JUDO expressly reserves the right to check the implementation of risk management measures at its suppliers systematically and on a case-by-case basis and, if necessary, to organise its own training courses for the employees of our suppliers.

1.3 Compliance with applicable law

JUDO complies with applicable laws and regulations, as this forms the indispensable basis for sustainable business success. Violations of the law not only jeopardise our company, but can also lead to consequences for its bodies, employees, business partners and other stakeholders.

At the same time, JUDO also requires its suppliers and their subcontractors to observe and comply with the applicable laws and regulations of the respective country. This includes, in particular, tax laws and customs regulations and provisions to prevent money laundering. Violations of the law are not accepted by JUDO.

1.4 Respect for human rights

JUDO is expressly committed to

  • to the international human rights code of the United Nations,

  • the "UN Guiding Principles on Business and Human Rights",

  • the ten principles of the "UN Global Compact" and

  • the internationally recognised standards of the International Labour Organisation (ILO).

JUDO also expects such a commitment from its suppliers. In particular, we expect you as a supplier to respect human dignity and the personal rights of those with whom you are connected through business relationships or products. To this end, JUDO requires you to proactively prevent the impairment of human rights through your own due diligence processes and, if such occur, to eliminate them immediately.

1.5 Anti-corruption and avoidance of conflicts of interest

Avoiding conflicts of interest between business and personal interests in connection with professional contacts, actions and business transactions is also a fundamental prerequisite for lawful and honest behaviour. In this context, personal interests must never be the primary motive behind a business transaction and thus supersede business interests.

Benefits such as gifts and hospitality invitations from suppliers are therefore only permissible if the benefit is customary in terms of the occasion for the benefit and the appropriateness of the value of the benefit with regard to the function and personal standard of living as well as the social status of the recipient. As a JUDO supplier, you are prohibited from granting or accepting any form of advantage for the purpose of exerting influence.

Corruption distorts competition, leads to higher costs and can be associated with considerable fines and damage to reputation, as well as jeopardising jobs. Illegal behaviour and other forms of undue influence are therefore not tolerated either within our company or among suppliers and business partners, and violations are consistently prosecuted. The principle of zero tolerance applies.

1.6 Care in dealing with company assets

If, as a supplier of JUDO, you have been provided with equipment, operating resources, information technology, software, data, intellectual property or other property, you are obliged to handle it carefully and responsibly and to protect it from unauthorised access by third parties.

2. Behaviour towards suppliers and third parties

2.1 Fair competition

JUDO is committed to fair and undistorted competition.

JUDO's competitiveness depends to a large extent on the fact that actions at home and abroad are guided by all applicable antitrust laws and other relevant regulations for lawful and honest competitive behaviour. The relevant laws, regulations and standards include, in particular, German and European antitrust law.

JUDO also requires its suppliers to neither participate in nor tolerate behaviour that violates competition and antitrust law and to make this clear to their own sub-suppliers.

2.2 Export control and sanctions law

National and international laws and regulations govern import, export, trade, brokerage or financing transactions, the provision of services and the transfer of goods (goods, software and technology). JUDO requires its suppliers to ensure through appropriate processes that transactions and activities both with third parties and with JUDO do not violate export control and sanctions law and that any necessary evidence and information is provided immediately.

3. Dealing with employees

3.1 Fair working conditions

JUDO requires its suppliers to pay appropriate and fair wages to their own employees. The wages must at least reach the level of the legally guaranteed minimum wages in the respective country of production or activity. JUDO also requires compliance with all applicable labour laws, in particular with regard to the (maximum) working hours of employees.

When recruiting employees, suppliers are prohibited from making misleading or false statements about working conditions, including the level of wages, any fringe benefits, the place of work, living conditions, the hazardous nature of the work, accommodation and the associated costs. Expenses for the recruitment of employees may not be passed on to the employees.

Suppliers are obliged to provide employees with employment contract documents in writing and with a detailed description of the activities in understandable language before they start work. Employees' identification documents may not be retained, manipulated or destroyed.

3.2 Diversity and equal treatment in the working environment

JUDO requires you as a supplier to create an appreciative and unprejudiced working environment free of discrimination, intimidation and harassment for your employees, in which all employees, regardless of age, gender, gender identity, ethnic origin, nationality, religion or belief, disability or sexual orientation, are valued.

3.3 Rejection of forced and child labour

JUDO condemns and rejects any form of child labour, forced and compulsory labour, modern slavery, involuntary or exploitative prison labour, human trafficking or other forms of exploitation.

JUDO also requires its suppliers to make an explicit commitment against this form of employment and calls on them to demand such a commitment from their own sub-suppliers in the supply chain. In any case, the employment of persons under the age of 15 is prohibited.

All forms of human trafficking, through the recruitment, transfer, harbouring or retention of people by the use of force, coercion, abduction, fraud, deception, abuse of power or weakness, or the granting of payments or benefits to a person who has control over others, are expressly prohibited and will not be accepted in JUDO's supply chains. JUDO therefore prohibits all its suppliers from using forced labour or engaging in any form of human trafficking or the procurement of commercial sex acts.

JUDO also requires its suppliers to introduce effective measures against human trafficking and to regularly review their effectiveness.

3.4 Freedom of association and assembly

JUDO requires its suppliers to respect the right of its employees to freedom of association and assembly and to grant them the right to conduct collective bargaining to regulate working conditions.

4. Environment, health and safety

4.1 Human rights, health protection and safety

JUDO requires its suppliers to strictly comply with all local, regional and international regulations on human rights, health protection and health safety as well as environmental protection laws in the manufacture of all products and the provision of processes and services.

The supplier is required to pay particular attention to the correct handling of so-called conflict minerals such as mercury and the handling of other critical minerals and materials.

The Supplier therefore undertakes to comply with the regulations on prohibited and declarable substances (ELV, RoHS and REACH), to provide evidence of this to JUDO on request and to impose this obligation on its sub-suppliers.

4.2 Environmental and climate protection

JUDO assumes responsibility in its production and service processes, administration and trade for the containment of global warming, the reduction of air pollution, the reduction of energy and water consumption and the avoidance of waste.

4.3 Health protection and occupational safety

Suppliers commit themselves to a "zero tolerance policy" towards JUDO regarding the violation of human rights in their own supply chains.

In this context, suppliers are obliged to create a suitable and safe working environment for their employees and the employees of their subcontractors by taking appropriate care and complying with legal requirements, for example by providing personal protective equipment, drawing up emergency plans and regularly carrying out emergency drills, and to demand the same from their subcontractors in the supply chain. Particular attention must be paid to the protection of young employees.

The implementation of these requirements must be ensured by the supplier through the establishment and regular monitoring of a risk management system. JUDO reserves the right to check the effectiveness of this risk management system at the supplier's premises or to have it checked by third parties commissioned by JUDO. The Supplier hereby agrees to this.

5. Complaints procedure, whistleblowing centre

JUDO attaches great importance to compliance with all applicable laws, regulations and the self-imposed compliance principles of conduct in its own behaviour and business decisions and actions at home and abroad. Our aim is to exclude any risks that could jeopardise our integrity and harm our company, our employees, business partners or third parties. In order to fulfil our responsibility for risks in the supply chains, it is therefore important that we become aware of violations.

Complaints regarding violations of JUDO's principles set out in this Supplier Code of Conduct or the Declaration of Principles, in particular human rights violations, illegal business practices or environmental risks, can be submitted via JUDO's complaints system. The complaints system also enables completely anonymous communication with the JUDO complaints office if desired.

Within its sphere of influence, JUDO ensures that complainants are not disadvantaged or penalised in connection with the complaint they have submitted.

As a supplier of JUDO, you are also obliged to take appropriate measures to ensure that your employees and the employees of your sub-suppliers also have access to JUDO's complaints procedure. This can be done, for example, by means of notices or information on your website.

6. Agreement to the supplier code of conduct of JUDO Wasseraufbereitung GmbH

As a supplier to JUDO, you are obliged to act in accordance with the ethical and legal principles laid down in this Supplier Code of Conduct. At the same time, you must also pass on these requirements in your supply chains and to your sub-suppliers.

It is therefore necessary for you to download or print this Supplier Code of Conduct by clicking on the link below.

Please then confirm with your signature or a digital signature on the Supplier Code of Conduct that you recognise its contents as binding for you, or confirm to us by submitting it that you comply with the above principles and requirements by using your own, equivalent company code of conduct or a declaration of principles in your company.

The management of JUDO Wasseraufbereitung GmbH

September 2023