Code of Conduct Veltkamp

This Suppliers Code of Conduct (CoC) describes the minimum standards that Veltkamp imposes on its suppliers (as defined below) when doing business with Veltkamp in addition to their compliance with all laws and regulations related to their activities.

This code of conduct forms an integral part of all agreements between the Supplier and Veltkamp.

1. Definitions

A "Supplier" is any person or legal entity providing products or services to Veltkamp. In addition to suppliers, who have a direct agreement with Veltkamp, this definition also applies to suppliers' subcontractors.

"Veltkamp representatives" refers to the company's employees and its legal representatives.

2. Management Systems

The Supplier must have sufficient management systems in place to enable compliance with this CoC, or compliance with its own equivalent and the strictest of the two versions, as well as with all other relevant and applicable laws and regulations. The operation and quality of the management system must be consistent with the size, complexity and risk associated with the Supplier's business. This means at least that:

2.1 the Supplier will apply a systematic approach to the assessment, mitigation and management of risks related to human and labor rights, health and safety, corporate responsibility and environmental impacts (hereinafter referred to as "Code of Conduct issues"),

2.2 the Supplier will set measurable performance targets in relation to Code of Conduct Issues and define the relevant actions for achieving these targets with a view to continuous performance improvement,

2.3 all applicable laws, regulations and contractual requirements related to the Supplier's assignments will be properly applied and communicated, with adequate training provided to relevant employees and business partners,

2.4 the Supplier shall have the systems in place that allow for the reporting of complaints related to the Code of Conduct issues (e.g. a bell ringer system),

2.5 the Supplier must adequately ensure and monitor that its own suppliers and subcontractors comply with this Code of Conduct or its own equivalent Code of Conduct. The Supplier is liable for the performance of its own suppliers as well as for its own work.

Suppliers are expected to:

3.1.1 respect human rights and not be involved in human rights violations within its sphere of influence,

3.1.2 identify its human rights impacts when the need for such action has been agreed,

3.1.3 have adequate remedy options in the event of human rights violations.

3.2 Minimum Employee Rights

Suppliers are expected to:

3.2.1 not employ workers under the age of 15 (14 in certain developing countries) or under the minimum age set by national law, whichever is higher of the two (in accordance with ILO Convention 138 on Child Labour),

3.2.2 ensure that the employment of young people above that minimum age but under 18 does not jeopardize their education, health, safety or morals,

3.2.3 fully recognize workers' rights to organize, to belong to a trade union and to engage in collective bargaining,

3.2.4 not employ forms of involuntary labour,

3.2.5 not discriminate against any employee,

3.2.6 treat all employees fairly and with respect.

3.3 Wages and Hours of Work

Suppliers are expected to:

3.3.1 pay employees at least the minimum wage and applicable overtime rates as set by national law or any applicable collective bargaining agreement,

3.3.2 apply normal working hours, which are in accordance with applicable laws and collective bargaining agreements and in the absence of such laws or collective bargaining agreements, regular working hours shall not exceed 48 hours per week.

3.3.3 provide all employees with at least one rest day within seven consecutive working days, unless otherwise provided by applicable law.

4. Occupational Health and Safety

Suppliers are expected to:

4.1 comply with all applicable occupational health and safety regulations,

4.2 have their own written health and safety policy, demonstrate that management is committed to the implementation of this policy, and have delegated the responsibilities for this policy within the organization,

4.3 ensure that all operational resources, such as rules and procedures are in place and communicated to all employees,

4.4 ensure effective emergency and response procedures,

4.5 promote its employees' awareness of health and safety issues, ensure safety-oriented thinking through open communication, and ensure that its own staff have received adequate training,

4.6 measure and control its own health and safety performance and risks through properly implemented workplace inspections and audits,

4.7 report and investigate all incidents related to health and safety.

5. Environmental Effects

Suppliers are expected to:

5.1 comply with all environmental requirements laid down in the relevant laws and regulations and environmental permits,

5.2 delegate responsibilities for environmental issues within its organization,

5.3 ensure that its employees have sufficient know-how and experience in relation to environmental issues, and the tools to enable them to act effectively in respect of their responsibilities,

5.4 ensure that written instructions regarding all processes with potential environmental impacts, such as storage and handling of hazardous materials, are available and that relevant information is communicated to all employees involved,

5.5 be proactive in the prevention of emergencies and ensure the ability to respond appropriately to such occurrences by analysing, identifying and implementing preventive and corrective measures,

5.6 deal systematically with violations and complaints and communicate them to employees and external stakeholders, including Veltkamp, if the company was harmed as a result,

5.7 Provide Veltkamp with current material safety data sheets (MSDS or SDS), as applicable, and any other relevant documents and information requested by Veltkamp.

6. Corporate Responsibility

The Supplier must conduct its business in full compliance with Veltkamp's Rules of Conduct and Terms of Delivery. This means, among other things, that the Supplier:

6.1 conduct business in full compliance with all applicable antitrust and fair competition laws,

6.2 avoid situations where there is a conflict of interest between the Supplier and Veltkamp,

6.3 comply with all applicable anti-corruption laws, including by refusing to accept a bribe or payment of tempo money, nor hand over anything of value, with the intent to conduct business or gain any profit or advantage,

6.4 must comply with all rules and regulations regarding the safety and quality requirements for products and services, including those defined by Veltkamp,

6.5 transparent and accurate all data concerning the business activities, company organization, financial situation

record and report performance in accordance with applicable laws and regulations.

When the Supplier does business with Veltkamp, this means, among other things, that:

6.6 Veltkamp Representatives will always pay for their own travel and accommodation costs when visiting the Supplier, conferences, reference factories, etc.,

6.7 Veltkamp Representatives shall not be offered gifts, hospitality or reimbursement of expenses that could be considered unreasonable or inappropriate in relation to potential business transactions.

7. General Requirements

Suppliers are expected to:

7.1 immediately report any violation of this Code of Conduct directly to Veltkamp. The Supplier and all of its employees may report concerns confidentially to
Head of QHSE and Internal Audit.

7.2 at the request of Veltkamp, provide information and data regarding the aspects mentioned in this Code of Conduct, unless this would be incompatible with its legal obligations regarding the disclosure of information.

7.3 Permit Veltkamp, or third parties appointed by Veltkamp who are reasonably acceptable to the Supplier, in the presence of the Supplier, to conduct an audit of the Supplier's activities covered by this Code of Conduct, including but not limited to the facilities of the Supplier and relevant passages from the books and records. At the Supplier's request, all parties involved in such an audit shall enter into a confidentiality agreement regarding the circumstances revealed by the audit.

8. Execution

8.1 If Veltkamp discovers that the Supplier does not meet the requirements and expectations as described in this Code of Conduct, Veltkamp will give instructions and state which matters need to be corrected or improved. The Supplier must then immediately take corrective action as instructed by Veltkamp. Veltkamp nevertheless reserves the right to cancel standing orders, suspend future orders, or terminate the contract with the Suppliers in the event of a breach of this code of conduct.

8.2 If the main agreement between Veltkamp and the Supplier, of which this Code of Conduct forms an Appendix, should contain other termination clauses, it will nevertheless be assumed by both parties that breach of this Code of Conduct may be regarded as a breach of contract entitling Veltkamp to terminate the agreement. to dissolve.