1 Introduction

MAKA Systems is committed to ecologically and socially responsible corporate management. MAKA Systems acts in accordance with all relevant laws and regulations as well as the following group-wide guidelines:

 

• Code of Conduct MAKA Systems,

• Policy statement on respect for human rights and fair working conditions

• environmental policy

 

We expect our employees to observe the principles of ecological, social and ethical behavior. Furthermore, we strive to continuously optimize our business activities and our products in terms of sustainability and ask our suppliers to contribute to this in terms of a holistic approach.

 

Rules of conduct will be drawn up for future cooperation, hereinafter referred to as the "code of conduct". We expect our business partners to identify with the principles and requirements of this code of conduct and to take all necessary measures to fulfill them. The suppliers are requested to contractually oblige their subcontractors to comply with the standards and regulations listed in this document. If the local law at the company's location imposes specific requirements, these apply; the Code of Conduct then applies in addition.

 

The Code of Conduct is based on laws and regulations as well as conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children’s Rights and Business Conduct, the United Nations Guidelines on Business and Human Rights, the international labor standards of the International Labor organization and the Global Compact of the United Nations, of which MAKA Systems is a member. We expect our suppliers to comply with all relevant laws and regulations as well as the requirements stated in this code of conduct.

 

2. Labor and Human Rights

2.1 Working Conditions, Hours and Wages

We expect our suppliers to stand up for fair working conditions and to comply with the applicable regulations regarding working hours and holiday regulations. Overtime is always worked within the legal framework.

Employees should have at least one day off every seven days. Local laws and regulations on maximum working hours and vacation time are to be respected by the supplier. The supplier ensures appropriate remuneration on a contractual basis, which complies with the legally guaranteed minimum wage and is based on the respective national labor market.

 

2.2 Harassment and Discrimination

The supplier must prevent any form of harassment such as sexual harassment, sexual abuse, corporal punishment, psychological or physical coercion or verbal abuse by any means.

Regardless of their personal characteristics, including gender, skin colour, ethnic or social origin, genetic characteristics, language, religion or belief, political or any other opinion, membership of a national minority, property, birth, disability , age or sexual orientation, every individual or group must be treated equally.

 

2.3 Freedom of Association

We expect our suppliers to give their employees the opportunity to peacefully gather and unite, especially in the political, trade union and civil society spheres. This also includes the right, where provided for by law, to form trade unions and to engage in collective bargaining to protect their interests.

 

2.4 Forced Labor and Human Trafficking

The supplier must prevent any form of modern slavery. Examples of this are forced overtime, the withholding of identity papers and human trafficking.

 

2.5 Child Labor and Young Workers

The supplier undertakes not to employ children below the legal minimum age (according to ILO Convention 138). In addition, suppliers are expected to ensure that young workers under the age of 18 do not work night work or overtime and are protected from working conditions that are harmful to their health, safety and development. The supplier should ensure that the tasks of the young workers do not interfere with school attendance.

 

2.6 Health protection and occupational safety

The supplier must have occupational health and safety measures that meet local legal requirements. The supplier must ensure that workplaces, machines, equipment and processes under its control are safe and free of health risks. It is the responsibility of senior management to allocate adequate health and safety resources and to conduct regular risk assessment and reporting to ensure continuous improvement of the system. The use of a certified occupational safety management system according to ISO 45001 or comparable is recommended.

 

3.Business ethics

Every supplier is expected to refrain from criminal acts.

 

3.1 Anti-Corruption

MAKA Systems does not tolerate corrupt practices and takes action against them. Suppliers shall not engage in or tolerate any form of corruption, bribery, extortion or embezzlement.

Any form of direct or indirect bribery or benefit, whether by accepting or making payments, gifts or benefits of any kind that go beyond the legal framework and the usual extent, is not permitted.

 

In addition, we require our suppliers to take an active role in preventing corruption and fraud.

 

3.2 Prevention of Money Laundering and Terrorist Financing

The supplier undertakes to comply with its legal obligations to prevent money laundering and the financing of terrorism within the framework of the applicable legal provisions and to neither directly nor indirectly support them.

 

3.3 Privacy and Data Security

The processing of personal data from employees, customers and business partners, ie the collection, storage, collection, use, provision, only takes place in accordance with the applicable legal requirements.

 

The supplier is obliged to handle and protect any information in an appropriate manner. Data and information are only used according to their classification. The supplier ensures that data to be protected is properly collected, processed, secured and deleted. He also ensures that the technical information systems are adequately secured against cyber threats by complying with the usual standards (e.g. virus protection, encryption, segmentation, roles and rights management, etc.). Evidence of a certified information security management system is recommended.

 

3.4 Fair Competition and Antitrust Law

The supplier respects fair and free competition. MAKA Systems expects its suppliers to comply with the applicable competition and antitrust regulations. This includes business practices that unlawfully restrict competition, the improper exchange of competitive information, as well as price fixing, bid manipulation or abusive market allocation.

 

3.5 Conflicts of Interest

The suppliers must avoid and disclose any conflicts of interest relevant to MAKA Systems to MAKA Systems if these could influence the business relationship. Decisions are made exclusively on an objective basis.

 

3.6 Physical and Intellectual Property

The supplier undertakes to respect the protection of intellectual property and to observe it along the entire supply chain.

This also applies to material property of MAKA Systems, which must be protected against loss, theft or misuse.

 

3.7 Export Controls and Economic Sanctions

The supplier strictly observes compliance with all applicable regulations and laws for the import and export of goods, services and information as well as payment transactions. Existing sanctions and embargoes within the framework of the laws and regulations are observed in business activities.

 

3.8 Whistleblowing  and  Protection Against Retaliation

MAKA Systems expects that the employees of the supplier can express themselves freely and without fear of retaliation if the contents defined in this code of conduct are violated.

 

4. Environment

4.1 General

MAKA Systems expects its suppliers to minimize negative effects on the environment and the climate resulting from its business activities and to use natural resources carefully.

 

4.2 Compliance with Environmental Laws

MAKA Systems expects its suppliers to comply with national and international environmental standards and laws.

 

4.3 Environmental Management Systems

The supplier is encouraged to continuously monitor and improve its ecological footprint. Suppliers with production sites should have suitable environmental management systems.

 

4.4 Consumption of natural resources and air pollution

The supplier shall reduce or avoid the use and consumption of natural resources, including raw materials, water and energy. Economical solutions must be found to improve energy efficiency and minimize energy consumption. General emissions from operational processes (air and noise emissions) should be avoided as far as possible.

 

4.5 Climate protection and CO2 reduction

With the MAKA Systems climate strategywe have set ourselves scientifically validated climate targets for the year 2030 and are taking comprehensive measures to reduce greenhouse gas emissions. To this end, we also involve our suppliers and support them in reducing greenhouse gas emissions. The supplier is required to find economical solutions to minimize greenhouse gas emissions.

 

4.6 Waste, Sewage and Hazardous Substances

The supplier should have measures in place to reduce both waste and waste water and to treat them in accordance with all legal requirements. Waste is to be fed into the material cycle (recycling) as far as possible. When handling chemicals and hazardous substances, the supplier ensures responsible handling with regard to environmental and health protection.

 

5. Promoting a responsible supply chain

MAKA Systems is committed to a responsible supply chain. Our goal is that our products and materials are free of so-called conflict minerals (tin, tantalum, tungsten, their ores and gold from conflict and high-risk areas), which contribute to the direct or indirect financing of armed groups, forced labor and other human rights violations.

 

We expect our suppliers to source any conflict-affected and high-risk minerals - particularly tantalum, tin, tungsten and gold - only from audited, conflict-free smelters and refiners. If goods and materials contain conflict minerals, the supplier is obliged to create transparency across the entire supply chain including the industrial processors (smelter / smelter) upon request.

 

6. Ask questions and ways to report misconduct

MAKA Systems investigates reported indications of possible misconduct. In order for us to find out about possible rule violations in the first place, we rely on employees, business partners and third parties to report possible misconduct. This requires the support and help of everyone involved in pointing out possible rule violations that are relevant to us.

 

Suppliers can address questions about the code of conduct to their responsible specialist buyer (Einkauf@maka.com) at any time.

 

If you discover possible misconduct by employees of MAKA Systems or employees of our business partners during the cooperation, you have the option of reporting this anonymously to MAKA Systems.

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7.  Compliance with  of the  requirements of MAKA Systems

MAKA Systems reserves the right to review this code of conduct through appropriate measures. This can be done, for example, in the form of questionnaires, assessments or on-site supplier audits. On-site inspections are always announced in advance and carried out together with the business partner's representatives, in compliance with applicable law, including data protection regulations, and contractual agreements, including non-disclosure obligations.

 

If deviations from the principles of this code of conduct are identified, it is clarified together with the supplier how corrections can be implemented sustainably within a reasonable time frame. The implementation of the measures is carried out independently by the supplier and without incurring any costs for MAKA Systems.

 

8. Legal Consequences of Violations

The requirements formulated here are considered important for MAKA Systems. A breach of this code of conduct may be grounds for MAKA Systems to take appropriate legal action. In particular, MAKA Systems reserves the right to terminate the business relationship in the event of a serious or repeated violation of this Code. Such steps may be waived if the supplier credibly assures and can prove that he has immediately taken countermeasures to avoid future violations.

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Ruijun Yang

 CEO MAKA Systems