Code of Conduct

Münch Chemie International GmbH (MCI) encourages innovation and is committed to social and ecological sustainability. For this reason, the company has undertaken to ensure that its activities in all areas are sustainable and satisfy the strictest ethical standards. All MCI employees make an important contribution to our sustainable growth and overall success, and so we expect all our staff to identify with the basic principles of MCI and to support their implementation and further development. The MCI Code of Conduct includes the following sustainability principles:

Ethical conduct and social responsibility

Work and people

Safeguarding health and safety

Environmental protection and quality

Management systems

We expect our employees to prove their commitment to the Code of Conduct. As part of our internal company audit, we will examine selected cases to check whether these basic principles are being upheld, and point out where there is room for improvement.

 

§ 1 Ethical conduct and social responsibility

As part of its social responsibility undertaking, MCI expects its employees to act ethically and with integrity, and to uphold the basic principles laid down by MCI.

 

§ 2 Integrity in business transactions

Compliance with the statutory requirements applicable in the context of the processing of business transactions is mandatory. These specifically also include the requirements concerning accounting and the tax regulations. Corruption, extortion, breach of trust and embezzlement, fraudulent accounting, and tax evasion in any form are prohibited. The employees of MCI must neither practise nor tolerate such conduct. The employees of MCI are permitted neither to offer bribes or other illegal incentives to companies or authorities in the course of their business activity nor to accept such for themselves.

The acceptance or giving of gifts to employees on special occasions is permitted as long as no return service is expected for them and as long as they are not conditional upon such gifts and the gifts are to be seen as a gesture of courtesy in the course of general business practice. The employees are furthermore prohibited from accepting gifts or other benefits that represent personal advantage from the business relationship and from offering or sending such to third parties. Monetary gifts are not permitted. These principles also apply for gifts and invitations due to or as part of official corporate events to which employees of MCI are invited or invite others.

 

§ 3 Fair competition

MCI conducts its business in the market in the spirit of fair competition. However, this does not release MCI or its employees from complying with the applicable laws, observing the antitrust law provisions and ensuring that the company’s advertising is correct and truthful.

 

§ 4 Agreements between competitors

Compliance with the provisions of antitrust law is mandatory. Horizontal and vertical agreements with competitors or suppliers and customers are prohibited if they aim or are likely to prevent or restrict free competition. These specifically include price agreements, agreements concerning customer allocation, or terms and conditions of trade. Furthermore, any exchange of information with competitors or third parties that could cause restriction of free competition or result in actions co-ordinated with such is prohibited.

 

§ 5 Data protection

The protection of personal and business data is assured. Data is only used and passed on to the permitted extent. When using data, the rights of the individual, the companies involved and their employees are safeguarded and the legal, corporate and customer-related guidelines complied with.

 

§ 6 Reporting concerns

MCI employees are obliged to report to the company management any illegal activities that take place within the company. The same applies if employees suspect that such activities may be taking place within the company.

To this end, the company has established an appropriate communication system, and undertakes to check any reports received and, if necessary, implement corrective measures. Regardless of the outcome, the employees making such a report shall not experience any disadvantage; in particular, the employee shall not be threatened with reprisals, or suffer intimidation or harassment.

 

§ 7 Protection of animals

No animal experiments take place at MCI.

 

§ 8 Work and people

MCI observes human rights and undertakes to treat and pay its employees fairly and with respect.

 

§ 9 Fair treatment

MCI ensures that its employees are treated within the company in an ethically irreproachable manner. No employee shall be discriminated against or disadvantaged on the grounds of race, skin colour, age, gender, sexual orientation, ethnicity, disability, religion, political or trade union affiliation or civil status. MCI treats its employees fairly, free from sexual harassment, sexual abuse, corporal punishment or torture, mental or physical duress or verbal abuse, and without the threat of such treatment.

 

§ 10 Working hours, pay and other benefits

MCI remunerates its employees in accordance with the legal and collectively-agreed requirements. Minimum wage rates are observed, overtime paid and individual employees informed promptly of the nature and scope of their remuneration. The legal and collectively-agreed requirements concerning working hours, holidays and continuation of pay are stringently upheld. Pay reductions as disciplinary measures are not permitted.

 

§ 11 Freedom of association

MCI operates open, effective communication with its employees and employee representatives. In line with the law, employees have the right to associate freely, to join unions, to appoint employee representatives, to form a works council and to participate in collective bargaining. Employees shall not be disadvantaged in any way by taking up one or more of these rights.

 

§ 12 Child labour and the employment of minors

Child labour is not allowed at MCI. Employees under 18 years of age are only given low-risk, harmless tasks. They are only employed if they have reached the prescribed minimum age for taking employment and have fulfilled the statutory school attendance requirements. Children under 14 are not employed at all.

 

§ 13 Free choice of place of work

The use of forced labour is not allowed at MCI. It is also forbidden to employ compulsory workers or allow the forced labour of prisoners at MCI.

 

§ 14 Safeguarding health and safety

MCI undertakes to safeguard and promote the health of its employees by providing them with safe, low-impact working conditions and to keep its employees free from harmful effects when working. The same applies to accommodation provided by the company.

 

§ 15 Employee protection

Employees shall be protected from all chemical, biological or other risks and should not be exposed to any excessive physical strain. They are to be protected from risks arising from the use of the infrastructure at the workplace.

MCI shall ensure safe working processes, preventive maintenance and the necessary technical protective measures, and shall reduce health and safety risks in the workplace.  In individual cases, should measures for the prevention of overexposure be impossible, or only possible to a limited extent, MCI shall provide the necessary personal protection equipment and ensure its use in each specific case.

 

§ 16 Process safety

MCI shall introduce safety programmes for the control and maintenance of the work processes in accordance with the applicable safety standards, and maintain them. The employees and MCI must address the product-related risks and their possible consequences in each phase of the manufacturing process, evaluate the risks and adopt appropriate safety measures.

Specific risk analyses must also be carried out for dangerous plant and machinery, and measures for the prevention of incidents, e.g. chemical leaks and/or explosions must be implemented in line with the statutory regulations. MCI has in place safety precautions and emergency programmes to prevent or limit the release of large quantities of chemicals.

 

§ 17 Risk assessment and emergency planning

MCI shall carry out risk assessments at the individual work stations. Once the assessment has been carried out, the employees affected shall be provided with the results of the assessment, and where necessary, remedial measures shall be implemented.

Employees shall be trained appropriately, to ensure reasonable protection in the workplace. MCI has in place emergency plans, notification procedures and alarm systems, in order to reduce the risks to employees, the environment or third parties to an absolute minimum. These plans are published within the company and the employees are given training on them.

 

§ 18 Legal compliance

MCI undertakes to obtain all necessary consents, licences and registrations, and to actively maintain them and ensure they remain valid. MCI furthermore undertakes to comply with its duty of notification and to keep the authorities and its customers fully informed as appropriate.

MCI shall hold all necessary product safety data sheets containing all the necessary information. It undertakes to make these available to authorities and customers as required in individual cases.

 

§ 19 Environmental protection and quality

An important objective for MCI is to safeguard natural resources and to work responsibly and efficiently with regard to environmental protection. Negative effects on the environment should be reduced to a minimum and measures for reuse and recycling promoted.

 

§ 20 Waste, emissions and resources

MCI undertakes to reduce waste and emissions to an absolute minimum and to use natural resources (e.g. water, fuels, raw materials) sparingly. The recycling or reuse of products should in all cases take priority over disposal. MCI therefore undertakes to establish and operate a system that supports the attainment of these objectives. MCI furthermore undertakes to operate an appropriate system that ensures the safe handling of waste, gas emissions and waste water, and the transportation, storage, recycling, reuse and management thereof.

All activities that may have a negative effect on human health or on the environment shall be evaluated and controlled before implementation, in particular before harmful substances are released.

MCI operates systems that prevent or keep to a minimum the unintentional or accidental spillage or release of harmful substances into the environment.

 

§ 21 Quality requirements

In addition to the systems for improving environmental protection, for safeguarding safety at work and for minimising risk, MCI should maintain an appropriate system for improving both its products and process safety. This should help to ensure that MCI achieves the quality and safety standards it sets for its products. It is expected that MCI will satisfy the generally-recognised or contractually-agreed quality requirements with its products and services, so that these are in line with customers’ needs.

 

§ 22 Management systems

In order to comply with this Code of Conduct, MCI operates a management system that ensures that these principles are put into practice and are continually developed.

 

§ 23 Resources

MCI shall provide sufficient resources for implementing these instructions.

 

§ 24 Legal and other requirements

MCI shall ensure compliance with all applicable laws, regulations, contractual agreements, other customer specifications and generally-recognised standards.

 

§ 25 Integration and training

MCI shall keep its employees regularly informed, by way of training sessions and employee meetings, on the content of the Code and any modifications to it. All MCI employees are obliged to work towards compliance with this Code and to contribute towards updating it.

 

§ 26 Risk management

MCI has introduced processes for the identification, determination and monitoring of risks in all areas affected by this Code of Conduct and all applicable legal provisions.

 

§ 27 Documentation

MCI shall draw up appropriate documentation, with which it can show that the basic principles and values of this Code of Conduct have been adopted in the company’s internal organisation and are implemented by and for its employees.

 

§ 28 Continuous improvement

MCI sets itself the expectation of continuously improving the sustainability of the company by means of appropriate measures.  This includes setting and continuously developing performance objectives. The results of internal and external examinations and inspections are taken into account in the updating of the sustainability objectives.

 

The company management placed the Code of Conduct in force for the first time on 19.09.2011 in version 1.0. Like all directives, requirements and other documents of MCI, this Code of Conduct is also subject to continuous review and further development. As part of its activity, the sustainability team therefore introduced the present version to the company management on 04.04.2016 and proposed placing this enhanced version in force. The company management took up this proposal by decision on 05.04.2016 and placed this version in force with immediate effect.

 

Wilhelm Münch / Michael Münch

Münch Chemie International GmbH