At KARL HUGO, we are committed to acting responsibly and sustainably throughout our entire value chain. For us, sustainability is not a stand-alone target but a shared journey: only by working closely with our stakeholders – especially our suppliers – can we achieve the ambitious goals we have set for ourselves.

Our partnerships are built on core values: transparency, trust, respect, and open communication. These principles guide our daily decisions and form the basis for long-lasting, fair, and forward-looking business relationships.

PURPOSE

The purpose of this Supplier Code of Conduct is to define and communicate the fundamental requirements that KARL HUGO expects all its suppliers to meet, particularly in the areas of ethics, human rights, working conditions, environmental protection, sustainability, and responsible supply chain management. This Code serves as a binding framework to establish a common foundation for responsible business practices.

SCOPE OF APPLICATION

This Code applies to all suppliers and service providers delivering goods or services to KARL HUGO, regardless of the nature or scale of the business relationship. It covers suppliers of materials, components, and any type of service.

The requirements also apply to suppliers’ parent companies, subsidiaries, employees, and authorized representatives.

1. ETHICAL BUSINESS CONDUCT

Compliance with laws

KARL HUGO requires all suppliers to fully comply with all applicable laws, regulations, and governmental requirements, both nationally and internationally. This includes, but is not limited to:

• respecting human rights, upholding strong labour standards, and conducting business ethically and lawfully,
• complying with embargoes, sanctions, and trade restrictions imposed by the United Nations, the European Union, national authorities, or other supranational bodies,
• honouring all contractual obligations within the business relationship,
• holding all legally required permits, licenses, registrations, approvals, inspections and related documentation.

Meeting these obligations is a prerequisite for maintaining a trustworthy and lasting partnership with KARL HUGO.

Integrity – Anti-corruption and Anti-bribery

KARL HUGO enforces a zero-tolerance policy toward corruption and bribery. Suppliers must strictly adhere to this principle and refrain from engaging in, encouraging, or tolerating any form of corrupt behaviour, either directly or indirectly.

Suppliers must not offer, request, or accept gifts, payments, favours, or other benefits that could improperly influence business decisions or create such an impression.

Reasonable and customary business hospitality or symbolic gifts may be acceptable when:

• they remain modest and socially appropriate,
• they are occasional,
• they carry no expectation of a return favour,
• and they cannot be perceived as an attempt to influence.

Suppliers must also avoid conflicts of interest, and any potential or actual conflict must be disclosed and handled transparently as soon as it becomes apparent.

Fair competition

Suppliers must fully comply with applicable competition, antitrust, and fair-trade laws. They commit to operating transparently, reliably, and with integrity.

They must refrain from practices such as:

• price fixing,
• allocating markets or customers,
• restricting production or supply quantities,
• or engaging in any other anti-competitive behaviour.

Confidentiality and data protection

Suppliers must treat all confidential information and personal data received from KARL HUGO with the highest level of care and ensure appropriate protection against misuse, loss, unauthorized access, or disclosure.

They commit to:

• complying with all relevant data protection laws,
• implementing adequate technical and organizational security measures,
• safeguarding the confidentiality of all non-public information, even after the business relationship ends

KARL HUGO strictly prohibits any form of forced labour, servitude, or degrading working conditions. Suppliers must ensure that all employment relationships are voluntary and free from threats, coercion, or intimidation.

Employees must be able to leave their employment freely, in accordance with applicable legal or contractual notice requirements.

Prohibition of child labour

Child labour is not tolerated under any circumstances.
Suppliers must comply with all relevant International Labour Organization (ILO) standards, particularly Convention No. 138 on the minimum age for employment, which prohibits hiring children under 15 years of age.

Young workers above the minimum age may only be employed if the work does not endanger their health or safety and does not interfere with their education or vocational training.

Fair remuneration

Suppliers must provide fair, transparent and legally compliant wages. Pay for regular hours and overtime must at least meet the legal minimum or the prevailing industry standards – whichever is higher.

Overtime must be compensated separately, at or above the standard hourly rate.

Suppliers must also provide all legally required social benefits and ensure that employees receive clear written information on the structure of their pay.

Working hours

Suppliers must comply with applicable laws regarding daily and weekly working hours.
Overtime must be voluntary, clearly regulated, performed under fair conditions, and remunerated according to legal or collective-agreement requirements.

Employees must receive adequate rest periods and regular days off to safeguard their health and wellbeing.

Freedom of association

KARL HUGO respects employees’ right to freely form or join organizations of their choice. Suppliers must guarantee this right and ensure that no employee is disadvantaged, discriminated against, or pressured for exercising it.

 Non-discrimination

KARL HUGO promotes equal treatment. Discrimination based on gender, age, origin, skin colour, religion, disability, sexual orientation, political views, social background, or any other protected characteristic is prohibited unless objectively required for the role.

Suppliers must maintain a respectful workplace, free from harassment, bullying, or degrading treatment.

Health and safety

Suppliers must provide a safe and healthy working environment. This includes implementing appropriate occupational health and safety systems, preventive measures, and regular safety training.

Employees must have access to clean drinking water, sanitation facilities, and first-aid equipment at all times.

Conflict minerals

Suppliers must ensure that raw materials such as tin, tantalum, tungsten, gold, and cobalt do not contribute to armed conflict, human rights abuses, or other severe violations.
They must implement due-diligence processes aligned with the OECD Guidelines for Responsible Mineral Supply Chains.

Suppliers must monitor all emissions – including air pollutants, noise, and greenhouse gases – and reduce them through appropriate measures.

Waste management and hazardous substances

Suppliers must maintain a structured waste-management system aimed at identifying, reducing, treating and recycling waste.
Hazardous materials must be stored, transported, used, recycled, and disposed of in ways that prevent risks to people and the environment.

Use of natural resources

Suppliers must optimize their consumption of water, energy and raw materials by improving processes, using alternative materials, and adopting circular-economy practices such as reuse and recycling.

 Energy consumption and efficiency