Supplier Code of Conduct anton clemens
As a family business with a long tradition, anton clemens is committed to ecologically and socially responsible corporate management.
We expect the same behaviour from all our suppliers, as we consider working together to achieve sustainability throughout the supply chain to be an essential element of our business relationships.
We also expect our employees to observe the principles of ecological, social and ethical behaviour and to integrate them into our corporate culture.
We also strive to continuously optimise our business activities and our products in terms of sustainability and ask our suppliers to contribute to this in the sense of a holistic approach.
For future co-operation, the contractual partners agree to the validity of the following regulations for a joint code of conduct. This agreement shall form the basis for all future business activities. The contracting parties undertake to fulfil the principles and requirements of the Code of Conduct and to strive to contractually oblige their subcontractors to comply with the standards and regulations set out in this document. This agreement comes into force immediately upon mutual signature and is valid for an unlimited period of time. A breach of this Code of Conduct may ultimately give anton clemens cause and reason to terminate the business relationship, including all associated supply contracts, for cause.
The Code of Conduct is based on national laws and regulations such as the Supply Chain Due Diligence Act (LkSG) and international conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines on the Rights of the Child and Business Conduct, the United Nations Guiding Principles on Business and Human Rights and the International Labour Standards of the International Labour Organization.
II. Requirements for suppliers
1. Social responsibility
The supplier undertakes to comply with all applicable labour laws in the country in which it operates. In addition, the supplier undertakes to respect the human rights listed in detail in the following points and to observe the Universal Declaration of Human Rights, the principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights and the ILO core labour standards.
At the same time, the supplier undertakes to create equal opportunities in the workplace, to prevent violations of fair labour conditions and to take effective measures to eliminate any human rights violations.
• Exclusion from forced labour
No forced labour, slave labour or comparable work may be used. All labour must be voluntary and without threat of punishment. Employees must be able to terminate their work or employment relationship at any time. Furthermore, there must be no unacceptable treatment of workers, such as psychological hardship, sexual and personal harassment and humiliation. The hiring or use of security personnel must be prohibited if persons are treated in an inhumane or degrading manner or are injured during their deployment or if freedom of association is impaired.
• Ban on child labour
Child labour must not be used at any stage of production. Suppliers are requested to comply with the recommendation from the ILO conventions on the minimum age for the employment of children.
Accordingly, the age should not be less than the age at which compulsory education ends according to the law of the place of employment and in any case not less than 15 years. If children are found at work, the supplier must document the measures to be taken to remedy the situation and enable the children to attend school. The rights of young workers must be protected and persons under the age of 18 must not be employed for work that is harmful to the health, safety or morals of children. Special protective regulations must be observed.
• Fair pay & fair working hours
The remuneration for regular working hours and overtime must correspond to the national statutory minimum wage or the minimum standards customary in the industry, whichever is higher. The remuneration for overtime must in any case exceed the remuneration for regular hours. If the remuneration is not sufficient to cover the costs of normal living expenses and to build up a minimum level of reserves, the supplier is obliged to increase the remuneration accordingly.
Employees must be granted all legally prescribed benefits. Deductions from wages as a punitive measure are not permitted. The supplier must ensure that employees receive clear, detailed and regular written information on the composition of their remuneration.
Working hours must comply with applicable laws or industry standards, whereby overtime is only permitted if it is worked on a voluntary basis.
• Freedom of association
The supplier supports the right to organise and the right to collective bargaining in accordance with the applicable laws. Employees must not be discriminated against on the basis of their founding, joining or membership of an organisation.
• Prohibition of discrimination
As an international company, anton clemens works with employees and business partners of different nationalities, cultures and outlooks on life. Mutual interaction is characterised by respect, tolerance, appreciation, fairness and openness. We expect the same from our business partners.
Discrimination and unequal treatment of employees in any form is not permitted unless it is justified by the requirements of employment. This applies, for example, to discrimination based on gender, race, caste, ethnic or social origin, skin colour, disability, health status, political conviction, origin, ideology, religion, age, pregnancy or sexual orientation. The personal dignity, privacy and personal rights of each individual are respected.
• Health protection, safety in the workplace
The supplier is responsible for a safe and healthy working environment. The necessary precautionary measures against accidents and damage to health that may arise in connection with the work shall be taken by setting up and applying appropriate occupational safety systems. Appropriate measures must be taken to prevent excessive physical or mental fatigue. In addition, employees are regularly informed and trained on applicable health and safety standards and measures. Employees are given access to sufficient quantities of drinking water and access to clean sanitary facilities.
• Preserving the natural foundations of life
The supplier may not, in violation of legitimate rights, withdraw land, forests or waters whose use secures the livelihood of people. The supplier must refrain from harmful soil changes, water and air pollution, noise emissions and excessive water consumption if this harms the health of people, significantly impairs the natural basis for food production or prevents people from having access to safe drinking water or sanitary facilities.
• Complaints mechanisms
The Supplier shall give its employees the opportunity to report concerns and potentially unlawful practices in the workplace.
• Dealing with conflict minerals
For the conflict minerals tin, tungsten, tantalum and gold as well as for other raw materials such as cobalt, the company establishes processes in accordance with the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas and expects its suppliers to do the same. Smelters and refineries without appropriate, audited due diligence processes should be avoided.
2. Ecological responsibility
anton clemens is guided by the principles of sustainability and environmental protection. We are aware of the scarcity of resources and our responsibility towards future generations. Consequently, anton clemens has implemented an environmental management system based on DIN EN ISO 14001:2015. Compliance with all relevant environmental protection laws, including the respective local regulations, is a self-evident obligation for both anton clemens and our suppliers – as is the endeavour to achieve continuous improvement with regard to the impact on people and the environment.
• Treatment and discharge of industrial wastewater
Wastewater from operational procedures, production processes and sanitary facilities must be standardised, monitored, checked and, if necessary, treated prior to discharge or disposal. In addition, measures should be introduced to reduce the generation of wastewater.
• Dealing with air emissions
General emissions from operations (air and noise emissions) and greenhouse gas emissions must be standardised, routinely monitored, checked and, if necessary, treated before they are released. The supplier is also responsible for monitoring its emission control systems and is required to find cost-effective solutions to minimise any emissions.
• Handling waste and hazardous substances
The supplier shall follow a systematic approach to identify, handle, reduce and responsibly dispose of or recycle solid waste. The prohibitions on the export of hazardous waste in the Basel Convention of 22 March 1989, as amended, must be observed. Chemicals or other materials that pose a risk if released into the environment shall be identified and managed in a manner that ensures safety during handling, transport, storage, use, recycling or reuse and disposal. Mercury shall be used in accordance with the prohibitions of the Minimata Convention of 10 October 2013 and persistent organic pollutants in accordance with the Stockholm Convention of 23 May 2001, as amended.
• Reduce consumption of raw materials and natural resources
The use and consumption of resources during production and the generation of all types of waste, including water and energy, must be reduced or avoided. This is done either directly at the point of origin or through procedures and measures, e.g. by changing production and maintenance processes or procedures within the company, by using alternative materials, by economising, by recycling or by reusing materials.
• Dealing with energy consumption/efficiency
Energy consumption should be evaluated as a key figure in the company. Economic solutions must be found to improve energy efficiency and minimise energy consumption.
3. Ethical business behaviour
• Fair competition
The standards of fair business, fair advertising and fair competition must be observed. In addition, the applicable antitrust laws must be applied, which in particular prohibit agreements and other activities that influence prices or conditions when dealing with competitors. These regulations also prohibit agreements between customers and suppliers that are intended to restrict customers‘ freedom to determine their own prices and other resale conditions.
• Confidentiality/data protection
The supplier undertakes to fulfil the reasonable expectations of its client, suppliers, customers, consumers and employees with regard to the protection of private information. The supplier shall comply with data protection and information security laws and regulatory requirements when collecting, storing, processing, transferring and disclosing personal information.
• Intellectual property
Intellectual property rights must be respected; technology and expertise must be transferred in such a way that intellectual property rights and customer information are protected.
• Integrity/bribery, taking advantage
The highest standards of integrity must be applied to all business activities. The supplier must have a zero- tolerance policy against all forms of bribery, corruption, extortion and embezzlement. Procedures for monitoring and enforcing standards shall be implemented to ensure compliance with anti-corruption laws.
III. Implementation of the requirements
Compliance with the content described must be ensured by implementing internal processes and methods and guaranteed by the supplier’s management. The implementation of these requirements can be reviewed by anton clemens at regular intervals.
IV. Acknowledgement and consent of the supplier
By signing this contract, the supplier undertakes to act responsibly and to adhere to the principles/requirements listed.
The supplier undertakes to communicate the content of this code to its employees, authorised representatives and subcontractors in a manner that is comprehensible to them and to take all necessary precautions to implement the requirements.
Rev. 03.07.2025