CODE OF CONDUCT

ELTEN GmbH is a leading company in the sector of safety footwear with more than 100 years of tradition and know-how. The combination of tradition, the use of the latest production technologies and our professional approach makes us strong. We focus on the needs of the people and our products
contribute on a daily basis to make the work environment a safer place.
Our high quality products are manufactured under strict environmental protection requirements and decent working conditions. Only that way we can meet the high standards placed on ourselves and on our products.
Our successful existence for generations is only possible because of the economic, ecological and social aspects that have always been a part of our corporate policy. Our long-term relationships to customers, suppliers and other business partners are based on mutual trust and require that all involved
parties respect the principles of honesty, reliability and professionalism.

1. SCOPE
The standards and requirements set out in this Code of Conduct apply to all locations and business units of ELTEN GmbH, to all our contractors, their sub-suppliers and subcontractors within the footwear and leather goods manufacturing chain.
All applicable local laws and regulations, industry minimum standards and conventions of the International Labour Organization (ILO), the United Nations (UN) Global Compact, the OECD Guidelines for Multinational Enterprises as well as all internationally recognized environmental standards are valid.

2. SOCIALLY RESPONSIBLE CORPORATE GOVERNANCE
ELTEN GmbH pursues legally irreproachable and accepted business practices and fair competition. In particular, it will not participate in any collusion or behave in a way that contradicts the German or European anti-trust laws or those of any other State in which the ELTEN GmbH operates. The company
rejects corruption and bribery as defined by the UN Convention.

3. DEMANDS SOCIAL RESPONSIBILITY
• CHILD LABOUR
The general rule is that children must not be employed. Children are persons who have not reached the age of 15, but may also be older if the compulsory education is not completed or the local legislation requires a higher minimum age. An exception according to ILO Convention 138 is allowed. If young
workers are employed, compliance with youth protection laws must be ensured. They must not be exposed to situations that are dangerous, harmful, unsafe or morally questionable. To give young people a professional perspective, opportunities for vocational training or training programs should be made available.
ILO Conventions 79, 138, 142, 182 and ILO Recommendation 146 apply.

• FORCED LABOUR
The terms of employment must be voluntary and terminable at any time complying with the statutory periods. Each employee may leave work and the corporate premises after the end of regular working hours. The working environment should be arranged in a way that human dignity and respect are
ensured and that it is free of all forms of forced labour, bonded labour and prison labour, harassment, exploitation, corporal punishment or involvement in human trafficking. The hiring process must not require the employees to deposit money or personal documents.
ILO Convention 29 and 105 apply.

• DISCIPLINARY ACTION
Any form of disciplinary action such as verbal or physical abuse and violence, psychological or sexual abuse, coercion and other forms of intimidation are prohibited. The system of rules and their consequences must be known by the employees.
In case of unacceptable disciplinary action exerted by managers, this behaviour must have appropriate consequences for them. The workers must be given an opportunity to complain (anonymously) about disciplinary actions and abuse.

• FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING
All workers must be granted the statutory right to form or join labour unions or to engage in collective bargaining.
In countries where the right to freedom of association and collective bargaining is restricted, the employees should be granted alternative ways to independently advocate their interests. Workers must be warranted to select their representation of interests freely.
Employee representatives or labour union members must not be threatened, exposed to harassment, discrimination or otherwise be disadvantaged in any form. Employee representatives must be able to contact the employees in the workplace.
ILO Conventions 87, 98, 135, 154 and ILO Recommendation 143 apply.

• DISCRIMINATION
Every worker should have the same opportunities and not be discriminated on personal specific characteristics such as ethnic or national origin, race, skin colour, language, ideological or religious beliefs, gender, sexual identity, age, family responsibilities, marital status, disability or membership in a labour organization or union. Concerning hiring, compensation, training, promotion, termination or retirement, the equality principle is to be followed.
ILO Conventions 100, 111, 143, 158, 159 and 183 apply.

• WORKING HOURS
The maximum weekly working time of the applicable national law applies. This shall in no case exceed the requirements of the ILO Convention (48 normal working hours per week, including overtime 60 hours per week). Overtime is not disposed on a permanent basis. All workers are granted at
least one day off in a period of seven days.
It must be ensured that overtime work is only done on a voluntary basis, and when required by law, compensated with a surcharge.
ILO conventions 1 and 14 apply.

• REMUNERATION
For the regular working time all workers must be paid at least the currently applicable local minimum wage, plus all other legally required benefits. The remuneration must be sufficient to cover the cost of living and to have an additional amount at free disposal.
All overtime must be paid for in accordance with the statutory provisions. The remuneration of the regular working time and overtime including surcharges must be paid within a reasonable time to the employees.
The legally required social security contributions must be implemented. In countries where continued pay in case of illness is not regulated, the employees must be adequately remunerated in sickness absence days. In the event that the employees do not have access to free medical care, the company has to bear the costs of medical care for the employees.
Illegal deductions from wages (e.g. as unlawful disciplinary action) are not allowed.
All employees shall receive full and comprehensible information on the composition of their compensation at regular intervals.
ILO Conventions 26, 102 and 131 apply.

• REQUIREMENTS FOR EMPLOYMENT CONTRACTS
Workers have the right to a written employment contract at the beginning of the employment relationship. The following topics must be included: position, start of work, working hours, remuneration, leave entitlements, notice periods and conditions, payment date, probationary period and signatures of the contractor including date. Each employee will receive a copy of the employment contract after signing. Consecutive temporary employment contracts are not tolerated.

• HEALTH AND SAFETY
We stand for safety. All employees in the company must be provided with a safe and healthy work environment. The employer is obliged to take appropriate measures to prevent accidents and health damages. At least the legal preventive measures concerning building security and stability, fire safety, machine safety, chemical safety and emergency medical care have to be ensured. These requirements apply also to dormitories, if provided by the company.
ILO Convention 155 and ILO Recommendation 164 apply.

4. ENVIRONMENTAL PROTECTION REQUIREMENTS
Environmental protection is an integral part of our corporate policy. An environmentally and socially sustainable production is to be sought by all business partners. The effects on the environment must be minimized, and preventive measures have to be taken. Legal regulations, environmental standards, internationally established standards and industry standards must be adhered to. A steady and longterm improvement of the environmental impacts by appropriate technologies and production processes, which allow efficient use of natural resources and energy as well as minimization of emissions, must be promoted. The chemicals used must be selected by taking into account environmental, occupational health and safety aspects. In doing so, efforts must be made to replace particularly polluting chemicals as far as this is possible. A proper disposal of waste as well as a possible re-use of substances in the context of the cycle management are important, if this is possible due to local conditions.

5. ANIMAL WELFARE
The ELTEN GmbH does not use leather of exotic animals and no materials derived from species that are endangered or threatened with extinction, as specified on the Red List of the International Union for Conservation of Nature and Natural Resources (IUCN). As sentient beings, all free-living or farmed animals shall be treated and kept according to their species-specific needs.

6. CONSUMER INTERESTS
The needs and interests of consumers are important to us. We will therefore ensure that the products for a specific purpose are safe and secure. All business partners must adhere to the statutory emission standards as well as to further Restricted Substances applicable to the products of ELTEN GmbH.

7. MANAGEMENT PRACTICE
The standards required by this Code of Conduct are binding and contractual part of the cooperation with the ELTEN GmbH. All employees must be informed of the rights and duties this Code of Conduct entails.
In the process of integrating the defined standards in the corporate policy, the requirements must be implemented sustainably through systematic management. The tasks must be affiliated to leaders who have the necessary knowledge and authority. Continuous monitoring of the implementation is required.
All relevant processes must be adequate, transparent, comprehensible and truthfully documented.