Code of Conduct LMT Group

Preamble

As an internationally active group of companies, LMT Leading Metalworking Technologies GmbH & Co. KG and its subsidiaries (hereinafter jointly referred to as “LMT Group”) have to respect diverse social, political and legal rules in Germany and abroad. Even seemingly negligible infringements of law by employees, board members, directors and officers may substantially impair the reputation of the enterprise and cause considerable – including financial – damage.

This global Code of Conduct describes the values, principles and modes of action which guide the entrepreneurial conduct of LMT Group. Its major goal is to safeguard compliance with applicable law and regulations (including the internal guidelines) throughout LMT Group and to create a work environment which distinguishes itself by integrity, respect and fair and responsible conduct. It is applicable worldwide to all employees, board members, directors and officers of the LMT Group.

 

1. Compliance with Applicable Law and Regulations

Compliance with all applicable law and regulations (including the internal guidelines) is the indispensable basis of all actions within LMT Group.

This Code of Conduct cannot deal with all legal provisions which the board members, directors and employees of the LMT Group have to observe worldwide. It only establishes a few essential principles for responsible action of the LMT Group including its employees, board members, directors and officers. The Code of Conduct is complemented by specific internal guidelines and training initiatives for certain fields of law such as the anti-corruption, anti-trust laws and Conflict of Interest.

2. Competition

In its competitive industry environment, LMT Group relies on performance, customer orientation and quality of its products and services. It respects all applicable domestic, supranational and foreign cartel and anti-trust laws as well as the law against unfair competition and also expects its competitors, suppliers and other business partners to act accordingly. Agreements with competitors concerning prices or terms and conditions must be avoided as well as agreements with competitors for the purpose of market or customer allocation. Nor may arrangements that are not allowed under anti-trust law be replaced with modes of behavior agreed with competitors or coordination of interests within trade associations. Where companies hold a market dominating position, this situation must not be misused in the relationship with customers and competitors.

3. Corruption

LMT Group bans corruption in its business activities in Germany and abroad and has established for this purpose strict standardized rules of conduct in its Anticorruption Guideline. This relates to dealings with public officials as well as with employees, board members, directors and officers of other companies. In connection with the business activities of LMT Group in Germany and abroad it is not allowed to promise or grant employees, board members, directors and officers of other companies and public officials any personal advantages or benefits as consideration for preferred treatment.

The employees, board members, directors and officers of LMT Group are not bribable or corruptible and will not draw any benefit from their activity apart from the remuneration they are paid by the company. Hence, they will not accept any presents (except for the usual promotional gifts), invitations exceeding the customary scope or other direct or indirect favors or advantages and will refrain from granting such favors or advantages to competitors, consultants, customers, suppliers, service providers and other business partners of LMT Group.

4. Conflicts of Interests

It is part of the official duties of all employees, board members, directors and officers of LMT Group to avoid conflicts of interests between their private, personal interests (direct or indirect or through related parties) and the interests of LMT Group. The interests of LMT Group shall always prevail.

The avoidance of conflicts of interests also requires that the employees, board members, directors and officers of LMT Group shall prevent even the impression of preferred treatment in business transactions with competitors, consultants, customers, suppliers, service providers and other business partners of LMT Group based on personal closeness to some of the persons mentioned.

Examples of conflicts of interests are, among others, the private exploitation of business opportunities, property or employees of the company.

Conflicts of interests may also occur

- when becoming active as employee, director, consultant or investor in relation to competitors, consultants, customers, suppliers, service providers and other business partners of LMT Group; 
- in case of private business relations with competitors, consultants, customers, suppliers, service providers and other business partners of LMT Group.

5. International Trade

LMT Group complies with the legal provisions governing international business transactions relating to its products and services. That is why the companies of LMT Group abide by all export and import prohibitions and approval requirements imposed by public authorities which are applicable under national and/or international law.

6. Fair Working Conditions, Sustainability and Social Responsibility

The commercial success of LMT Group depends to a high degree on its employees. The company therefore adheres to the principles of social responsibility and will create fair working conditions at LMT Group subsidiaries worldwide. This excludes all forms of discrimination of employees by virtue of their sex, sexual orientation, origin, color of skin or other personal features.

In particular, LMT Group supports the protection of internationally proclaimed human rights, the elimination of all forms of forced and compulsory labor, the effective abolition of child labor and the principle of sustainability in dealing with environmental challenges.

LMT Group considers it its duty to be a social employer everywhere in the world and to treat its employees with respect and in a compatible way. This implies compliance with all occupational health and safety provisions in order to warrant labor safety at the working place.

Vice versa LMT Group expects all employees and superiors to interact with each other respectfully. This includes respect for the rules of social behavior and communication of the respective country the LMT Group subsidiary is located. Nevertheless, LMT Group will definitely not tolerate violations of personal and physical integrity and will consequently pursue – also by means of labor law - any such offense like insults, vilifications or sexual harassment.

7. Loyal and Transparent Reporting

For LMT Group true and transparent reporting both within the Group and to the outside especially the authorities is indispensable. All employees, board members, directors and officers of LMT Group are therefore obliged to conscientious, complete, loyal and timely reporting within LMT Group.

Directors and officers of LMT Group with reporting obligations towards third parties (e.g. auditors, public authorities) shall follow the same principles. This is essential for the credibility of LMT Group in business and social relations.

8. Product Safety and Environment Protection

LMT Group constantly strives for developing innovative and high-quality products and processes for its customers. In doing so, it attributes high priority to product safety.

To the same extent LMT Group attaches great importance to environmental protection in developing and manufacturing its products. This refers to both the consumption of energy and the protection of our natural environment constantly striving for enhancing sustainability.

9. Duty to Observe Secrecy

The knowledge and information acquired at LMT Group are an essential element for its commercial success. LMT Group invests substantial human and financial resources in the development of innovative products and services. The protection of the innovations thus developed secures success in competition.

All employees, board members, directors and officers of LMT Group are obliged to prevent such knowledge and information, inasmuch as they represent company or business secrets, from becoming known outside the LMT Group, for example through the unauthorized circulation of sensitive data in discussions with third parties or in expert journals. Moreover, employees having access to such knowledge and information should verify whether obtaining intellectual property right protection is suitable for such knowledge and/or information.

Trade or company secrets of business partners of LMT Group shall also be protected from unauthorized disclosure.

10. Data Privacy

Respecting the personality of our employees includes the protection of their personal data. LMT Group therefore complies with the respective valid data protection regulations and also asks its employees to observe such regulations.

11. Corporate Governance, Code of Conduct and Compliance Hotline

The LMT Group management board and supervisory board are geared to comply with the major regulations of the German Corporate Governance Code.

Besides the current information and reporting duties an annual Compliance Declarations of the members of the management board of LMT Group, the members of the management boards of the subsidiaries of LMT Group has to be submitted. Conflicts of interest have to be avoided or disclosed.

The executive employees of LMT Group are expected to inform all employees of LMT Group worldwide about this Code of Conduct (including its relevant accompanying internal guidelines) in a suitable form. All employees of LMT Group must know that infringements of the Code of Conduct will by no means be tolerated and may lead to consequences under service or labor law depending on the severity of the infringement. Further, LMT Group expects all stakeholders like suppliers, consultants, dealers and agents to comply with the rules and regulations of this Code of Conduct as well as applicable law.

All employees, officers and directors may report infringements of the Code of Conduct to their respective superiors and companies’ management as well as Group companies’ Compliance Responsibles or the Chief Compliance Officer without having to fear sanctions or disadvantages. In addition employees, officers and directors and the business-partners of LMT Group may submit such report also in an anonym way via the Compliance-hotline by utilizing the following link which also contains further information on the related process:

Compliance Hotline