Supplier for Woco

Building a cooperative partnership

Code of Conduct for Suppliers

Portrait

Woco is an internationally active group with the flexibility and organization of a modern medium-sized company based in Bad Soden-Salmünster. The Woco Group has plants, production facilities and partners in Europe, NAFTA and Asia. 
The portfolio includes products for damping and sealing, for preventing vibrations, and for sealing, separating, guiding and controlling media such as air, water and oil, mainly for the automotive industry. The diverse solutions are also used in numerous other industrial applications. These include industrial anti-vibration systems, measurement and control systems, piping systems and railtrack products. Woco products contribute to environmental protection by reducing emissions, immissions and noise.

Preamble

Woco recognizes its responsibility to its own company, to its business partners, and to the environment and society. In particular, our actions are guided by the values of integrity and fairness, regardless of whether the activity is carried out inside or outside Germany.  We can only achieve this by introducing due diligence requirements in our processes and by our suppliers being guided by the same values described in the Code of Conduct for Suppliers. Due diligence at Woco and our partners and suppliers is based on legal regulations such as the German Supply Chain Due Diligence Act (LkSG) as well as internationally recognized standards such as the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises as well as the ILO Core Labor Standards and the principles of the UN Global Compact. We commit ourselves and our business partners to embed these in their business principles and procedures.

This Supplier Code of Conduct outlines the standards with regard to business integrity and ethics, labor / social standards, environmental protection, competition, general business principles and the associated management system that Woco requires its suppliers to comply with. 

Suppliers must ensure that these requirements are also known and adhered to downstream in the supply chain, by their own employees and by all direct and indirect sub-suppliers.

General principles

The supplier shall comply with the law, regulations and directives. The Supplier undertakes to comply with the applicable laws and other relevant provisions of the countries in which it operates in all business actions and decisions. This also includes the necessary duties of care.


1. Social Responsibility: respect for fundamental and human rights 

The supplier respects and supports the observance of internationally recognized human rights. This includes that the supplier, if potentially negative impacts on human rights are to be feared, establishes processes for human rights due diligence (e.g. Human Rights Due Diligence Process) in his company within an appropriate period of time and takes systematic and appropriate due diligence measures in connection with human rights on the basis of this. The national due diligence laws applicable to the partner, as well as the guidelines of the UN Global Compact initiative and the ILO Declaration on Fundamental Principles and Rights at Work and their Follow-up, and the due diligence processes from the requirements of the United Nations Guiding Principles on Business and Human Rights are authoritative in this regard.

In order to implement these requirements, we expect the supplier to draw up a policy on basic rights and the associated working conditions and human rights within his own company:

  • establish a policy on fundamental rights and the associated working conditions and human rights.
  • Conduct training on this policy.

1.1 Child labor

The supplier observes the regulations of the United Nations on human rights and children's rights and undertakes in particular,

  • the Convention on the Minimum Age for Admission to Employment (Convention 138 of the International Labor Organization)

and

  • the Convention concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labor (Convention 182 of the International Labor Organization).

shall be complied with.

If a national regulation concerning child labor provides for stricter standards, the supplier shall observe these as a matter of priority.

1.2 Forced Labor

The Supplier shall outlaw all forms of forced labor; this includes human trafficking, torture, labor performed under duress or threat, and all forms of slavery. This includes, but is not limited to:

  • labor or services which are exacted from a person under threat of punishment and for which the person has not volunteered (ILO 29), and
  • all forms of slavery, practices similar to slavery (e.g. demanding excessive fees and withholding documents), servitude or other forms of domination or oppression (e.g. debt bondage and use of force) in the workplace environment, such as extreme economic or sexual exploitation or humiliation.

The supplier respects and complies with the principle of freely chosen employment.

1.3 Freedom of association

The supplier respects the right to form and be a member of trade unions or employee associations and the freedom of association within the framework of the legal regulations and in accordance with ILO Convention No. 98.

The supplier opposes all exploitative working conditions and recognizes the right to organize trade unions.

1.4 Equal opportunities - Non-discrimination

The supplier shall oppose any form of discrimination within the framework of applicable rights and laws. The supplier undertakes to maintain equal opportunities in employment. Different treatment of employees on the basis of their origin, nationality, religion, ethnicity, gender, age, disability or gender orientation must not take place (ILO 111).

Unequal treatment also includes, in particular, the payment of unequal remuneration for work of equal value.

1.5 Diversity, equality and Inclusion

The Supplier should promote a corporate culture that values and integrates diversity. This culture should include recognition of diversity among all employees at all levels of the organization, particularly with regard to cultural, ethnic and religious differences. The supplier is responsible for ensuring that all employees are able to realize their full potential and contribute to their full potential, while maintaining a work-life balance. We encourage the supplier to promote collaboration with diverse business partners that are minority-owned or women-owned.

1.6 Occupational safety and health
protection

The supplier guarantees occupational safety and health protection at the workplace within the framework of national regulations. The supplier supports continuous development to improve the working environment.

Therefore, Woco expects from its suppliers

  • Introduce and operate an effective, certified occupational health and safety management system in accordance with ISO 45001 (or comparable) and provide evidence of this by submitting a corresponding certificate and,
  • an occupational health and safety guideline.

1.7 Working conditions (remuneration and working hours)

The supplier shall ensure the adequacy of remuneration so that its level is at least equal to the minimum wage established by applicable law and enables employees to at least secure their livelihood. The cost of living and social security benefits in the country concerned and the remuneration for full-time employment must be taken into account. Wages must be paid in full for services rendered and may not be withheld under the law. The supplier shall set clear guidelines for working hours of employees in accordance with ILO Conventions No. 1 and No. 30 on working hours. Workers shall not be recruited in an unethical manner (e.g. misleading, deceiving, confiscating identification documents, etc.). If private or public security forces are required to protect the business project, care must be taken to ensure that appropriate training is provided regarding human rights issues.

1.8 Protection of Local Communities, Protection from Forced Eviction and Deprivation of Land.

The Supplier undertakes not to carry out any unlawful forced evictions and furthermore not to unlawfully deprive land, forests and waters through acquisition, construction or other use.

The supplier assures to respect the rights of local communities and indigenous peoples that may be affected by the business activities at the partner's sites and to take into account the local impacts of its business activities. In particular, the Partner shall take appropriate measures to avoid potentially harmful impacts on the health, safety and livelihoods of local communities and indigenous peoples. The Partner shall neither unlawfully force the resettlement of local communities and indigenous peoples nor unlawfully contribute to their involuntary resettlement.


2. Responsibility as a business partner 

2.1 Avoiding conflicts of interest

Woco expects the supplier to make decisions on the basis of factual considerations and not to be improperly guided by personal interests. As soon as knowledge of an actual or potential conflict of interest exists, internal measures must be taken to eliminate these conflicts and Woco must be informed immediately.

2.2 Money Laundering 

The Supplier shall comply with the statutory provisions on the prevention of money laundering, identify and eliminate any cases or risks in its business operations and properly comply with its reporting obligations.

2.3 Prohibition of Corruption & Bribery

The supplier shall prohibit, not tolerate and not practice any form of corruption, disloyalty and embezzlement. The supplier shall therefore not attempt, either domestically or abroad, to illegally influence others in business dealings by exchanging gifts or offering and/or granting other advantages. The same shall apply to the inadmissible granting and/or acceptance of advantages.

2.4 Antitrust Law (Fair Competition)
The Supplier shall respect fair competition and comply with applicable laws that protect and promote competition, in particular applicable antitrust laws and other laws regulating competition.

2.5 Data protection, information security
The supplier undertakes to comply with data protection regulations. Personal data may only be collected, processed or used insofar as this is necessary for defined, clear and lawful purposes. The use of the data must be transparent for the data subjects; their rights to information and correction and, if applicable, to objection, blocking and deletion must be safeguarded. In addition, the security of information must be guaranteed, i.e. the supplier shall take the necessary measures in accordance with the current state of the art to protect confidential information from unauthorized access by third parties and shall use it only for agreed purposes.  

2.6 Export and Import
Supplier agrees to comply with all applicable import and export control laws, including but not limited to sanctions, embargoes and other laws, regulations, government orders and policies controlling the transfer or delivery of goods and technology.

2.7 Protection of Intellectual Property 

The Supplier shall comply with all applicable national and international laws for the protection of intellectual property. Intellectual property includes registrable property rights (e.g. patents, trademarks, designs), domains, copyrights and requirements under unfair competition law. In addition, the partner must ensure that it has all the necessary rights of use in order to avoid infringements of intellectual property rights.

2.8 Financial Responsibility and Disclosure of Information 
Supplier shall ensure that all financial information, including required taxes, fees and royalties related to business activities, is disclosed in accordance with applicable national and international regulations and industry expectations. Supplier shall also make any required changes consistent with applicable regulatory developments. 

Woco expects the supplier to disclose financial and non-financial information in accordance with future applicable regulations (e.g. CSRD) and industry practices.

3. responsibility for the environment

The supplier undertakes to protect the finite resources of nature. The supplier must comply with all national and international environmental standards and laws applicable to the operating site, minimize environmental pollution and continuously improve environmental protection. This includes the consumption of resources, in particular energy, water, raw (primary) materials, to be continuously more efficient and to minimize the environmental impact (emissions, pollutants, waste).
Furthermore, the supplier undertakes to establish and/or apply an environmental management system according to ISO 14001 or an equivalent system.

In order to implement these requirements, we expect the supplier to

  • draw up a guideline on environmental protection and the use of resources covering the topics 3.1 to 3.7, as well as
  • conduct training courses on this guideline.

3.1 Climate protection

Woco expects sustainable / active climate protection from the supplier, e.g. by increasing energy efficiency or generating or purchasing energy from renewable sources and using secondary or biomaterials. 
The aim is to create transparency about their CO2 emissions and to set ambitious CO2 reduction targets. These should include direct and indirect CO2 emissions (including its upstream value chain).

3.2 Conservation of resources and recycling management

We expect our supplier to refrain from waste and to ensure responsible use of resources such as water, energy, raw materials and materials.
Furthermore, the supplier shall opt for the use of secondary, bio-based and renewable materials if these are available and can be used according to qualitative and technical requirements. When using new materials, environmental due diligence shall identify risks, including unintended impacts on the environment and human rights.

The supplier shall develop new secondary raw material sources through innovative processes or recycle raw materials to a higher value in order to make positive contributions to the circular economy. As a basis for this, the supplier shall ensure the high quality of the recycling of its own waste and compliance with the waste hierarchy.

3.3 Water consumption and quality

The supplier undertakes to use water carefully, especially in areas of water scarcity, in order to ensure access for future generations. Within the scope of and in accordance with applicable legal and regulatory requirements, standards for wastewater quality shall be defined and monitored in order to prevent contamination of surface or groundwater.

3.4 Air and soil quality

We expect the supplier to minimize all types of emissions, especially noise, air and soil emissions, as well as to comply with the relevant legal requirements and the specifications of the local authorities.

3.5 Handling of Hazardous Substances and Waste

When handling hazardous substances, the supplier must not only ensure the storage and delivery of the agents and components, but also take into account the environmental and health and safety aspects.

The supplier shall ensure that these substances are labeled in accordance with the applicable regulations and that it is guaranteed that they are handled, transported and stored safely. Furthermore, the supplier shall ensure that they are properly reused, recycled or disposed of.

At a minimum, we expect compliance with the following conventions:

  • the Minamata Convention (use of mercury),
  • the Stockholm Convention (persistent organic pollutants), and
  • the Basel Convention (transboundary movements of hazardous wastes and their disposal).

In addition, all other laws and regulations relating to hazardous substances, chemicals and substances applicable to the site or market concerned (e.g. European Regulation (EC) No. 1907/2006(REACH)) must be complied with.

3.6 Biodiversity and Deforestation-Free Supply Chains

Woco is committed to halting the deforestation and conversion of natural ecosystems in its supply chains. The supplier must protect natural ecosystems and help prevent alteration, deforestation, and degradation of natural forests and other natural ecosystems within its sphere of influence.

The guidelines are to be applied where applicable:

  • the High Conservation Value Resource Network (HCV)
  • High Carbon Stock Approach (HCSA)

3.7 Animal welfare

It is important to Woco that animal welfare is considered in all business activities. Therefore, if our supplier processes animal products, we expect them to implement and comply with animal welfare standards and best practices throughout the supply chain.


Whistleblower system

Every business partner - their employees or those affected - is called upon to report possible cases of suspicion and violations of this Code of Conduct. 
In this way, the consequences of such violations shall be limited and comparable misconduct shall be avoided in the future. For this purpose, the business partner shall set up its own whistleblower system or join an industry-wide system.

Reports at Woco can be submitted to the Compliance Board of the Woco Group by e-mail (compliance@de.wocogroup.com), by telephone (+49-151-74 11 39 24), by mail (Woco Industrietechnik GmbH, Compliance Board, Hanauer Landstr. 16, 63628 Bad Soden Salmünster) or via the web-based reporting system on the Woco homepage (https://www.wocogroup.com/unternehmen/woco/compliance), which also allows anonymous reports. Our business partners inform their employees about the possibility of submitting a report.

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