1. Purpose
   
   This Code of Conduct outlines UAB Hegelmann Transporte (hereinafter referred to as “Hegelmann Transporte”) requirements and guiding principles for our business partners, in the area of compliance with applicable laws and regulations, in particular with regards to: basic working conditions, human rights, caring for the environment and business integrity.
   The term business partners covers anyone that Hegelmann Transporte does business with, for example, organizations that supply goods and/or services to Hegelmann Transporte.
   
   
2. Basic Principles
   
   This Code of Conduct is based on internationally proclaimed human rights, including the International Bill of Human Rights, the eight core conventions of the International Labour Organization and Article 32 of the UN Convention on the rights of the Child. In addition to this, Hegelmann Transporte also supports the United Nations Global Compact initiative which is a strategic policy initiative for businesses that are committed to aligning with ten universally accepted principles for human rights, labour, environment and anti-corruption.
   
   
3. Our expectations of Our Business Partners
   
   At Hegelmann Transporte we are committed to responsible business, wherever we operate, and we rely on the same level of commitment from our business partners. We insist that our business partners not only communicate the principles of this Code of Conduct to their employees, but also ensure that their employees respect them. In doing so, we are seeking to ensure that everyone associated with Hegelmann Transporte demonstrates integrity, responsibility and trust.
   As our business partner, you and your employees must – at all times – comply with this Code of Conduct or similar principles, with all applicable laws and regulations and, needless to say, with your contractual obligations to Hegelmann Transporte. The stricter regulation shall always apply if a topic is covered by this Code of Conduct as well as by applicable laws and/or your contract with Hegelmann Transporte.
   We expect all of our business partners to meet all of the following basic requirements, and we expect them to be managed professionally and systematically.
   
   
4. Basic Working Conditions and Human Rights
   
   We strongly believe that employees are a company’s most important resource. Which is why we insist that our business partners respect and work in line with internationally proclaimed principles for human rights.
   
   4.1 Child Labour
   
   Business partners shall work to prevent all forms of child labour. Under no circumstances should employment be offered to a person younger than 15 years of age (or 14 where the national law so allows) or younger than the countries legal minimum age, if higher than 15.
   
   4.2 Terms of Employment
   
   Our business partners must guarantee that the working conditions for their employees comply with all applicable legal requirements. In addition, each employee should have the right to get written information, in a language that they can easily understand, specifying their terms of employment
   
   4.3 Working Hours
   
   Working hours including but not limited to overtime, and requirements for providing rest periods, for business partner employees must always comply with applicable law. Hegelmann Transporte supports the requirements of the International Labour Organization (ILO) and we encourage our business partners to adhere to and respect the relevant ILO standards on working time.
   
   4.4 Health and Safety
   
   Safety should always be one of the most important factors in any decision, which is why we expect our business partners to provide and maintain a safe and healthy working environment that at least meets, but preferably exceeds, applicable standards and legal requirements.
   
   4.5 Forced Labour
   
   There can be no forced labour of any kind relating to Hegelmann Transporte, our services. Therefore, in no event may our business partner use forced labour, regardless of its form. Forced labour includes debt bondage, trafficking and other forms of modern slavery.
   
   4.6 Wages and Benefits
   
   Our business partners may not pay their employees wages and benefits less than is required by applicable law or collective labour agreement, where applicable. Information about wages and benefits must be available to all employees, in accordance with applicable laws.
   
   4.7 Freedom of Association
   
   Business partners shall respect the rights of their employees to lawfully form, join or exclude themselves from employer-employee relationship related associations and collective bargaining, where permissible by local law. We encourage our business partners to ensure that employees are given the opportunity to discuss their working conditions with management, without fear of reprisal, intimidation or harassment.
   
   4.8 Non-Discrimination and Equal Opportunities
   
   Our business partners may not engage in any form of discrimination based on gender, race, ethnicity, religion, age, disability, sexual orientation, nationality, political opinion, union affiliation, social background and/or other characteristics where protected by applicable law. Business partners are expected to treat their employees with respect, dignity and common courtesy.
   
   
5. Caring for the Environment
   
   Like us, we expect our business partners to be constantly striving to reduce the environmental impact of their operations including the handling of raw material. We also expect our business partners to apply the precautionary principle. By that we mean that precautionary measures should be taken whenever there is a reason to believe that a particular action could have a negative impact on an individual’s health, on society in general or on the environment. Our business partners must ensure that they comply with all applicable environmental requirements stipulated by laws, rules and regulations.
   
   
6. Business Integrity
   
   We expect our business partners to conduct their business ethically and with the utmost integrity.
   6.1 Anti-Corruption
   None of our business partner, their employees may ever engage in, or tolerate, any form of bribery or corruption. As our business partner, you may neither offer nor accept any form of improper benefit to/from a third party including Hegelmann Transporte, whether public or private, with the purpose of obtaining or retaining business or in order to gain preferential treatment. Such improper benefits may include, but not limited to, monetary gifts, monetary loans, pleasure trips or vacations, luxury goods, concealed commissions, facilitation payments or kickbacks. We also expect our business partners to ensure that all of their reports, records and invoices are accurate and complete, and that they contain no false or misleading information.
   
   6.2 Conflict of Interest
   
   We expect our business partners to disclose to us whenever a situation arises in which there appears to be a conflict of interest involving or affecting Hegelmann Transporte. In a similar vein, we expect any employee or other representative of Hegelmann Transporte to disclose to us if they have any involvement in, or financial ties with, any of our business partners.
   
   6.3 Export Control
   
   Hegelmann Transporte is committed to fully comply with applicable export control laws and regulations and we expect our business partners to do the same.
   
   6.4 Fair Competition
   
   Our business partners must support fair business and fully comply with all applicable fair trade, advertising, competition and antitrust laws. We expect our business partners to compete fairly and to never entering into any understanding or agreements that hinder competition. Accordingly, this means that as a business partner you should not undertake in any way with any competitor to: fix prices, discounts or terms of sale; or divide markets, market shares, customers or territories. We also expect our business partners to not competitively exchange confidential or sensitive information, even if it is made via third parties. Sensitive information include things like prices, timing of price changes, magnitude of price changes, costs, profit margins, sales forecasts, sales plans, sales territories, distribution practices, terms offered to particular customers, capacity utilization and intentions, competitive bidding plans or strategy, pricing and marketing strategies, product plans and market shares. This also applies when participating in fairs or trade association meetings.
   
   6.5 Protecting Information and Intellectual Property
   
   Business partners must respect intellectual property rights and protect confidential information by safeguarding it against misuse, theft, fraud or improper disclosure.
   
   
7. Consequences of Violating This Code of Conduct
   
   We reserve the right to conduct an audit, at any time, of business partners that provide goods or services to Hegelmann Transporte. Advance written notice will be provided. If requested, our business partners are obligated to provide all relevant information and/or allow us or our representatives access to their premises for the purpose of the audit. We also reserve the right to appoint an independent third party of our choosing to conduct audits and ensure our business partners are following this Code of Conduct. Lack of cooperation and/or violation of our Code of Conduct and/or applicable laws may result in a reduction in business with that partner and, ultimately, an end to the business relationship with Hegelmann Transporte.
   
   
8. Tell Us
   
   At Hegelmann Transporte we encourage our business partners to ask questions and raise concerns, in the event of an ethical issue or suspected case of non-compliance. These concerns will be treated with the gravity they deserve and will be properly investigated. If you wish to report a violation of our Code of Conduct, please submit a report to us by any means of communication suitable for you.
   
   
   Date: 12.2022

Hegelmann will execute the procurement process at a minimum cost through innovative changes in procurement customs and methods to pursue the Hegelmann Corporate Philosophy of, “Provide valuable products and services to all our customers”. Hegelmann shall strive to achieve and continue its procurement process in cooperation with authorized suppliers across the world as our business partners.

Hegelmann defines the following basic policies in order to execute our sustainable procurement mission in daily operations.

1. CSR procurement

• Hegelmann shall comply with the laws and social norms and ask all authorized suppliers to comply with applicable laws and standards for a healthy workplace including environmental protection and human rights.

2. Conflicts of interest and prevention of unfair business practices

• Hegelmann officers and employees or their families must not engage in the procurement process with a supplier whose relatives engage suppliers’ management.
• Hegelmann officers and employees that are involved in the procurement process must not accept any gifts or benefits beyond the bounds of socially acceptable limits.

3. Pursue economic rationality by engaging in open and transparent processes

• Hegelmann shall execute a fair supplier selection by utilizing open competitive bidding.
• Hegelmann shall always provide opportunities to competitive suppliers all over the world.
• Hegelmann shall promote the consolidation of suppliers and standardization of purchasing goods and specifications.

4. Partnership

• Hegelmann and suppliers shall continually suggest and consult with each other for cost savings and quality improvement opportunities.
• Hegelmann and suppliers shall collaborate to establish a crisis management system for the supply chain and its maintenance.

Hegelmann and suppliers shall drive the implementation of electronic transactions, three-way match (purchase orders, statement of delivery, invoice), and business efficiency for strengthening governance.

Date: 12.2022

Respect for human rights is an essential value of HEGELMANN GROUP. We make every effort to respect and promote human rights in accordance with the International Bill of Human Rights, International Labor Organization Declaration on Fundamental Principles and Rights at Work, and the UN Guiding Principles on Business and Human Rights. This is our focus in our relationships with our employees, those in our value chain, and the communities in which we operate, and is the foundation of our Human Rights Policy.

Hegelmann Human Rights Policy aligns with our Code of Ethics, Business, and Environmental policies covering diversity, environment, health and safety, and employee relations. Hegelmann is dedicated to the principles that all persons should be treated with respect.

Community and Stakeholder

The following parties are considered stakeholders in our human rights policy, among others: shareholders, employees, communities/Neighbours, contractors, producers/vendors/suppliers, governments, and applicable unions.

We are aware that the communities in which we work are a part of us, and that each location has a number of interconnected “community.” Hegelmann is devoted to working with Stakeholders who appreciate honesty, justice, and respect for all people as much as we do. When appropriate, we interact with our communities about issues related to human rights that are significant to them. We want to make sure through dialogue that we are paying attention to, taking notes from, and considering their points of view as we run our company. We think it’s usually best to deal with local problems locally.

Respect for Human Rights

Hegelmann recognizes the importance of maintaining and promoting the fundamental human rights of employees by operating under programs and policies that:

• Promote a workplace free of discrimination and harassment.
• Prohibit child labor, forced labor, and human trafficking.
• Provide fair and equitable wages, benefits, and other conditions of employment in accordance with local laws.
• Provide safe working conditions.
• Recognize employee’s rights to freedom of association.

Forced Labor and Human Trafficking

Hegelmann companies will not engage in any component of its business that involves the use of slave or involuntary labor, including debt slavery or human trafficking, whether it be bonded, prison, military, compulsory, or indentured lobar.

Discrimination and Harassment

Every employee, in our belief, is entitled to a fair working environment and to be treated with respect. Hegelmann prohibits discrimination based on age, race, colour, religion, sex, national origin, marital status, disability, citizenship, sexual orientation, gender identity or expression, military service, and any other feature protected by law.

Everyone is entitled to the right to work without intimidation or fear. Hegelmann’s stance was made plain from the first day of orientation: we do not tolerate abusive behaviour or harassment. It is expected of employees to report circumstances that make it difficult for them to do their duties. Our procedures explicitly forbid retaliation against employees who voice concerns, and formal channels are available for employees who need guidance or a solution. We control how our business is run so that workers feel treated fairly and with respect.

Diversity and Inclusion

Hegelmann companies is dedicated to being a high-performing company founded on the basis of a diverse and inclusive workforce. Individuals and teams are working to combine a wide range of abilities, preferences, and views in pursuit of common goals. Employees are expected to engage in open and honest communication, be accepting of others’ differences, be open to conversation, and assume the best intentions of others.

Child Labor

Under no circumstances is a person under the age of 17 allowed to work for innocent. We also forbid hiring anyone who is under the legal minimum age for employment (applicable by law) or the age at which obligatory schooling must be completed. No means should be used to exploit children. Underage workers are not permitted to do hazardous tasks or night-time shifts. To guarantee that this policy is enforced, thorough age verification checks should be performed before hiring anyone. If children are discovered to be employed, a strategy must be put in place that emphasizes the child’s needs and allows them to continue receiving a quality education until they are no longer considered children.

Freedom of Association

We respect employees’ right to join, form or not to join a labor union without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. The Company is committed to bargaining in good faith with such representatives.

Our experience has demonstrated that open communication and a place where employees can express their concerns, comments, and ideas leads to improved operations, products, processes, and safety that will support ongoing growth and prosperity for all stakeholders, including employees.

Workplace Safety

Hegelmann companies is committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats.

Workplace Security

Hegelmann companies prohibits violence, harassment, intimidation and other unsafe or disruptive conditions due to internal or external threats.

Work Hours, Wages, and Benefits

Hegelmann compensates employees competitively relative to the industry and local labour market. We operate in full compliance with applicable wage, work hours, overtime and benefits laws.

Guidance and Reporting for Employees

We strive to create workplaces in which open and honest communication among all employees is valued and respected. The Company is committed to complying with applicable labor and employment laws wherever we operate. In addition, we work to achieve full employee engagement as the foundation of our mutual success; strive to create a culture that champions respect and inclusion; offer competitive wages and benefits; and implement clear health and safety practices.

Any employee who believes a conflict exists or has come to exist between the language of this policy and the laws, customs and practices of the place where he or she works, or who has questions about this policy or would like to confidentially report a potential violation of this policy should raise those questions and concerns with his or her direct manager, local management, Human Resources or corporate management or through anonymous reporting features in Hegelmann. 

Date: 12.2022