Corporate Social Responsibility of

NOMOTEC Automation GmbH

Foreword

At NOMOTEC, we strive for exemplary quality in our products and processes, but also in our behavior.

The behavior of every NOMOTEC employee has a significant impact on the reputation of our company. As the management, we have therefore decided to summarize in this Code of Conduct the basic rules that we expect all employees to observe with regard to ethically impeccable behavior in business dealings.

We maintain a respectful interaction with each other

All NOMOTEC employees are committed to treating each other with respect, as well as our customers and supply partners. We behave respectfully towards everyone regardless of origin, skin color, religion, gender and sexual orientation.

We accept objective criticism and complaints from our employees and colleagues. Every employee has access to our internal complaints management system, which ensures that complaints and suggestions are treated confidentially. Such a tool is also available for our business partners under compliance@nomotec.at.

We reject discrimination

Our behavior towards employees, colleagues, customers, partners and authorities is free of any discrimination. This refers to all types of discrimination (religion, skin color, origin, political and sexual orientation, etc.). We always behave correctly towards our interlocutors.

We behave in accordance with the law

We comply with the laws of the countries in which we operate. This is in line with our fundamental values and applies irrespective of the threat of penalties.

Unlawful conduct is not in the interest of our company because it is unethical, leads to serious reputational damage and can result in criminal prosecution, damages and loss of contracts.

We comply with the applicable, relevant labor laws, which also serve to protect our employees. We take into account existing laws and restrictions (export bans, UN sanctions against third countries, etc.) in our business activities.

Employees who act unlawfully must be aware that they themselves are at risk of criminal prosecution. Law-abiding conduct therefore serves the employee’s own protection.

We reject bribery and corruption

Bribery is unethical, illegal and involves high risk for our employees and our company. Bribery is therefore not in the interest of NOMOTEC and must be refrained from in any case.

We do not offer or accept any improper advantages to our business partners. We are cautious in accepting and giving gifts and other benefits (including invitations to meals or events). Under no circumstances may these be designed in such a way that their acceptance must be concealed by the recipient or places him or her under a more than insignificant moral obligation. An extremely restrictive approach must be taken in connection with public officials; here the legal regulations are very strict worldwide.

Commissions and remuneration to be received by traders, intermediaries or consultants may only be paid for permissible services actually rendered and must be commensurate with these services.

We focus on fair competition

We do not coordinate our competitive behavior with competitors and comply with laws designed to protect competition. In particular, agreements on prices and conditions, the sharing of markets and regions, the allocation of customers and the coordination of supply, development or production strategies are prohibited. In this respect, not only explicit agreements are prohibited, but also concerted practices.

Even the exchange of information with competitors (which can form the basis of such a concerted practice, i.e. in particular on prices, costs, margins, conditions, customers, offers, product development, and production capacities) is impermissible.

Violations of these prohibitions are consistently pursued by the antitrust authorities and can lead to sanctions that threaten the existence of the company.

We avoid hazards for people and the environment

We place the highest demands on the quality and safety of our products and services. We monitor the performance of our products on the market and help customers avoid hazards.

We ensure a safe working environment. Safety regulations are to be strictly observed and their effectiveness constantly checked. Malfunctions are to be pointed out and eliminated without delay.

We use natural resources sparingly and strive to do the same for our products.

We avoid harmful effects on the environment. Compliance with the laws for the protection of the environment is a matter of course for us.

We handle conflicts of interest openly and in accordance with applicable laws

We behave fairly and openly with regard to potential conflicts of interest of our employees as well as with regard to our partners, and our ordinary business practices and customs are designed to prevent such conflicts from arising in the first place.

We must avoid possible, actual or even apparent conflicts of interest in our business activities. To this end, we must also regularly review the relationships between our private interests and our business obligations. E.g. related persons in personnel management (personnel recruitment, personnel allocation), purchasing / sales (acceptance of gifts) or similar.  In cases where we cannot avoid conflicts of interest, we must disclose them and deal with them as described below.

Also, despite everything, in today’s globalized business world, conflicts of interest can arise between business partners and customers.

Therefore, we have trained our employees to recognize such conflicts and to inform the relevant office immediately. This office will immediately contact the parties concerned in order to resolve these conflicts of interest.

We (the employees and supervisors) must work together to manage the conflict of interest with appropriate measures so that the situation that has arisen does not impair the judgment, obligations or loyalty of the employee involved. These measures may include (but are not limited to):

To the extent necessary or appropriate, the supervisor must seek advice from Human Resources, management and/or the Compliance Organization. All persons and departments involved must keep the conflict of interest information confidential and may only disclose it as necessary.

We protect the intellectual and material property of NOMOTEC.

We treat operating resources carefully and in accordance with their purpose. We do not use operating resources – including PCs, laptops, landline and cell phones – for private purposes unless this is expressly permitted.

We handle the assets of NOMOTEC responsibly. Unnecessary costs are to be avoided. We make business decisions on the basis of commercially comprehensible analyses of opportunities and risks. In doing so, we also pay attention to the integrity of our business partner.

As a technology company with a high expenditure in research and development, NOMOTEC is particularly dependent on the protection of its inventions and know-how. We therefore handle business secrets with particular care. It must be ensured that confidential information does not reach unauthorized third parties. This also applies to confidential information that we receive from our business partners.

We avoid hazards for people and the environment

We place the highest demands on the quality and safety of our products and services. We monitor the performance of our products on the market and help customers avoid hazards.

We ensure a safe working environment. Safety regulations are to be strictly observed and their effectiveness constantly checked. Malfunctions are to be pointed out and eliminated without delay.

We use natural resources sparingly and strive to do the same for our products.

We avoid harmful effects on the environment. Compliance with the laws for the protection of the environment is a matter of course for us.

Chemical substances or processes are handled in strict compliance with applicable laws, standards and regulations.

We act according to our environmental mission statement

For all our products and solutions, we strive to minimize environmental impacts along the entire life cycle – from raw material extraction to end of life, including waste handling and prevention – in order to keep ecosystems intact and create a positive impact on society. Compliance with environmental regulations, standards and voluntary commitments are basic requirements for our actions.

We focus on the following fields of action:

Climate change:

We are committed to the 2° target of the Paris Climate Agreement. We intend to become a CO2-neutral company by 2050. We actively contribute to the switch to renewable energies along the entire life cycle.

Air quality / Pollutant emissions:

We are driving electric mobility in our fleet to improve local air quality. By 2030, the share of battery-electric vehicles in the NOMOTEC vehicle fleet will be between 20 and 25%. By 2035, the share of electric vehicles in our fleet should increase to at least 40%.

Resources:

We maximize our resource efficiency. Circular economy approaches in the areas of materials, energy and water.

Environment Compliance:

We aim to become a role model for a modern, transparent and successful company in terms of the environment by installing and controlling effective management systems that cover the environmental impact of our products throughout all life cycle phases.

We protect the intellectual and material property of NOMOTEC

We treat operating resources carefully and in accordance with their purpose. We do not use operating resources – including PCs, laptops, landline and cell phones – for private purposes unless this is expressly permitted.

We handle the assets of NOMOTEC responsibly. Unnecessary costs are to be avoided. We make business decisions on the basis of commercially comprehensible analyses of opportunities and risks. In doing so, we also pay attention to the integrity of our business partner.

As a technology company with a high expenditure in research and development, NOMOTEC is particularly dependent on the protection of its inventions and know-how. We therefore handle business secrets with particular care. It must be ensured that confidential information does not reach unauthorized third parties.

This also applies to confidential information that we receive from our business partners.

If there are separate / additional agreements with our business partners (non-disclosure agreement or similar), we are obliged to comply with them. Any disclosure or publication of business data will only take place under consideration of the legal or contractual basis.

We are obligated to inform our business partners about unfair or illegal processes concerning your products or services (plagiarism, copies, obvious betrayal of secrets by third parties and the like). For the protection of information (both from NOMOTEC as well as from our partners and clients) we follow the specifications of our information security management system (ISMS).

We handle personal data responsibly

We use personal data of our employees and contractual partners exclusively for the purposes for which they are made available to us and treat them confidentially. The laws enacted to protect personal data must be strictly observed. The current General Data Protection Regulation has been fully implemented in our company.

We comply with the laws regarding employees

We comply with all legal requirements with regard to our employees.

This refers especially, but not exclusively, to the valid employee protection regulations, the collective agreement (metal trade) valid for us, to age-appropriate workplaces, strict avoidance of child labor, any form of forced labor, avoidance of wage dumping and social fraud as well as compliance with the legally permissible working and rest times. We allow our employees freedom of association and free and unhindered access to collective bargaining as well as to elections and/or meetings/events of your interest groups.

We document the essential business transactions in a comprehensible and timely manner

Both internal and external reports must be correct and complete so that the recipient can form an accurate picture. In doing so, we adhere to the presentation of facts and a factual style of expression. Hasty conclusions are to be avoided.

Documents that are required for ongoing or anticipated internal investigations or investigations by the authorities must not be destroyed, removed or altered.

We review and evaluate our business data in a comprehensible and timely manner

(Commercial) Order Controlling is an essential contribution to the success of our company. We have the appropriate tools (EPR, accounting) and report any irregularities to the appropriate department (management, accounting, purchasing) immediately after they become known.  Each employee will treat or use the resources (material as well as financial) to the best of his or her knowledge and belief.

This Code of Conduct is binding for all employees of NOMOTEC.

Violations of this Code will not be tolerated and will result in disciplinary action.