Code of Business Ethics

Preamble

LAPP, as a global group of companies, supplies and sells products and services to the global market. In the process, we constantly improve the self-sustaining development of products and solutions, combining social, environmental and ethical principles in our business activities. In this way, we create the opportunity to meet the current and future needs of society and the environment for ourselves, our suppliers and our customers.

We maintain responsible cooperation with our suppliers based on

creating values-based partnerships to develop a sustainable supply chain. We expect our suppliers to comply with applicable laws and adhere to internationally recognized environmental, social and corporate governance (ESG) standards. We also expect our suppliers to work to implement these standards among their own suppliers.

In particular, we insist that you, the supplier, comply with, support and accept this

ESG-based Supplier Code of Conduct. You must fulfill your obligation to conduct ongoing risk analysis not only on occasion,

but also when there is a significant change or increase in risk in your company due to the introduction of a new product, project or entry into a new business area. This applies not only to your own operations, but also to direct and indirect suppliers. For these purposes, you must maintain an appropriate internal complaints procedure, regardless of when the European Directives are converted into German law.

Matthias Lapp, Chairman of the Board and CEO of LA EMEA |Lapp Holding AG

Jan Ciliaks, Chief Financial Officer (CFO) of Lapp Holding AG

Social responsibility

Human rights. You support the protection of internationally recognized human rights and combat any form of forced labor, slave labor, child labor or similar types of labor. All work is voluntary, and your employees have the opportunity to terminate their employment or business relationship at any time. If children are working, you adhere to the ILO Convention’s minimum age recommendations.

Occupational health and safety. You provide a safe and healthy working environment for your employees while complying with applicable laws. The hazards and resulting health risks to which employees are exposed must be properly assessed and appropriate protective measures must be taken. In particular, you do not tolerate any harassment or abuse of any kind, cruel or inhumane treatment, or unlawful acts such as psychological abuse, sexual harassment, and personal harassment.

Freedom of association and the right to collective bargaining. You acknowledge freedom of association and the right of all employees to collective bargain in accordance with applicable laws.

Prohibition of discrimination. You treat your employees fairly, politely and with respect. You provide a workplace that is free from discrimination, harassment or humiliation. In particular, discrimination against your employees on the basis of ethnicity, culture, disability, gender, religious beliefs, age or sexual orientation is not permitted.

Fair wages and fair working hours. You comply with minimum wages and working hours in accordance with federal and state legal regulations. You provide a living wage, taking into account local living conditions.

Mechanisms for filing complaints. You provide effective mechanisms for filing complaints for your employees and other stakeholder groups that may be adversely affected.

Conflict minerals. You do not supply any products containing conflict minerals that directly or indirectly finance or support armed groups and lead to human rights abuses. We expect you to carry out your conflict responsibilities for complex testing of minerals supply chain in accordance with the recommendations of OECD guidelines.

Environmental responsibility

Environment protection. You comply with applicable environmental, health and safety regulations. You support the safe and environmentally compatible development and production of your products, as well as their transportation, use and disposal.

Environmental management/hazardous materials management. You use appropriate management systems to ensure product quality and product safety meet applicable specifications. You avoid the use of substances hazardous to health in your products and production facilities, so that the danger to the life and health of your employees, neighbors and the public does not come from ongoing processes into the environment. You apply an appropriate environmental management system to reduce the impact of your operations on biodiversity, climate change and water shortage.

Reduction of resource use, waste and emissions. You use resources efficiently, implement energy-efficient and environmentally friendly adapted technologies and reduce waste and emissions into air, water and soil.

Management standards 

Antitrust law and trade control. You comply with applicable national, European and international rules regarding trade and international law, especially, but not limited to, antitrust and competition laws, customs regulations and law on import, export controls of national and third countries, regulations on economic and military sanctions.

Corruption, bribery and money laundering. You fight corruption, bribery and other unlawful enrichments and refrain from any form of money laundering activities.

Conflict of interests. You make operational decisions with LAPP based on objective criteria and a separation of business and private interests. This will avoid conflicts of interest related to personal affairs, economic activities or other activities.

Data protection, information security and privacy. You respect the privacy and confidential information of all your employees and business partners and protect data and intellectual property from misuse.

Implementation of the Supplier Code of Conduct

We expect you, as a supplier, to identify risks in your supply chains and initiate appropriate measures to minimize risks. This will allow us to ensure the principles of sustainable development.

By signing the Supplier Code of Conduct, you acknowledge the stated principles and behavioral measures and confirm your commitment to implement these principles through your own code of conduct and risk management system that incorporates and monitors these standards.

LAPP reserves the right to verify compliance with the above standards and principles through individual questions or audits.

LAPP will take appropriate action regarding business relationships if there is reason to believe that laws, regulations or standards are being violated. In particular,

LAPP reserves the right to suspend or terminate business relationships in cases where measures are not taken to eliminate such violations, or systematic violations are identified.

If you have concerns regarding illegal or dishonest conduct, please contact the LAPP Compliance Hotline at +49 711-7838 8888 or send an email to compliance.de.lhi(at)lapp.com.

Help us ensure the principles of sustainability in our supply chains.