// TEST r2p – Code of Conduct Code of Conduct
Introduction

Now this is our endeavour in a nutshell: make the best of the impact we can have on the world. We know this is a long journey –even more, unmistakable directions must be defined and communicated to every fellow traveller. This Code of Conduct (CoC) defines our core principles, which guides all our business, which we expect all our employees to follow.

r2p is an international company which operates in 45 countries. Therefore, we have a global responsibility for our employees, partners, suppliers, clientsand the environment. We are fully aware of the influence our economic performance, our personnel policy and our behaviour towards our environment has, and we only conduct business with this in mind.

The r2p management team has a specific role to play in setting an example, living up to this guideline, communicating our values, thus ensuring that every team member, partner and supplier fully understands and applies this CoC throughout our organisation.

The CoCwas created to follow the principles of the United Nations Global Compact, which is available for you to access via the link https://www.unglobalcompact.org/library

Which topics are covered by this Code of Conduct?

Section 1 covers all issues regarding the interaction between the r2p Group as an employer and the r2p team as employees: the values we stand for, our corporate culture and the resulting mutual rights and obligations.Section 2 covers issues regarding the interaction between the r2p Group and our partners, clients and suppliers as well as society as a whole.

For individual situations and circumstances in the local work environment, separate policies and agreements are available on request. 

Who should comply with this Code of Conduct?

This Code of Conduct (CoC) applies to all employees of the r2p Group. Every team member throughout the r2p Group is required to read and understand this Code of Conduct, confirming this by their signature of their employment contract. The guidelines defined in the CoC will also be highlighted in our regular appraisal interviews. It is the obligation of all employees to update their knowledge and understanding of this CoC by regularly checking the Intranet ONEr2p for any adjustments to these guidelines. All arising questions in this context should be posed to your local HR team.

We also expect our suppliers and partners to concern themselves with the values and guidelines provided in the CoC, making sure that they act accordingly throughout their entire business conduct with us.

What happens if I violate against the Code of Conduct? 

The action taken will depend on the nature and circumstances of each breach and may range from a formal apology or counselling to a demotion or dismissal.

What to do in case of violation against the Code of Conduct?

In the first instance, you should contact your supervisor. Don’t hesitate to directly contact the Managing Director if in doubt. You may also contact the r2p Group HR Manager, highlighting your concerns. Any issues raised will be treated in the strictest confidence.

How are local laws balanced against the Code of Conduct?

All our dealings must be in compliance with relevant legislation and local legal rules at all times. As a minimum, local laws of all countries of operation must be complied with.

Our CoC may exceed these regulations and will then set our standard.

1 The r2p Group and our employees

It is vital that the r2p Group treats all people fairly, respecting human rights and equal opportunities whilst maximising the talent, capability and performance of our employees to benefit our business and ultimately the customer. As an employee of the r2p Group you must ensure that you always act in the best interests of the company.

We are an equal-opportunity employer

We regard the diversity of our employees as a competitive advantage. From young trainees with fresh ideas to long-term employees with a wealth of experience: at r2p we employ people from all walks of life, with different life experiences and family backgrounds, from different nations and cultures.

  • The hiring of employees’ family members is permitted if there is no actual or potential conflict of interest. Guidelines to this topic can be found in the document “Avoiding Conflicts of Interest”.
  • Secondary employment relationships in another organisation must be reported and approved in advance.

We take responsibility to train our employees

It is important to us to contribute to the training of our staff.

  • We take on new apprentices every year and constantly offer interns the opportunity to gain insight into our professional practice.
  • We consider continuing vocational training an important investment in our team and our company. We support life-long learning and help with implementing the new knowledge in the daily work. For further details, please contact your local HR responsible.

We stand against discrimination

  • No employee, business contact or anyone else may be discriminated against regardless of ethnic or national origin, gender, maternity, disability, age, religion, skin colour, their membership in or support of unions or political parties, their sexual orientation or family status. If in doubt, please check out the definitions given in our “Anti-Discrimination and Harassment Policy”. 
  • We endeavour to have the strength to show courage to stand up for each other. We aim to create an environment in which all our employees can develop their full potential. Valuing and promoting diversity across all our businesses is an essential part of achieving that goal.

We foster a respectful and friendly working environment

  • We remain friendly in our dealings with others, no matter how stressful the situation.
  • Should conflicts arise, we address them in a respectful, open manner to try and resolve the matter to avoid further conflicts in the future.
  • We continuously strive to treat each other with respect, understanding and tolerance and to critically reflect how we deal with others.

This is essential to develop a working atmosphere in which everyone is appreciated and valued.

We communicate openly with each other

By communicating openly and respectfully with each other and from the management, our structure is transparent with well-defined goals. We consider and re-think our working methods as well as the way we interact with each other, find friendly words to address challenges and work together towards feasible solutions.

We use the internet and Social Media with prudence

We expect all our employees to use the internet responsibly and productively solely for work-related activities. We safeguard our internet security and act online as politely and honestly as in face-to-face contacts. For further details, please refer to our “Information Security Policy”.

Social media includes any digital communications channels that allow individuals to create and share content and post comments. For further details, please refer to our “Social Media Advice and guidelines”.

  • Employees are allowed to associate themselves with the company when posting but they must clearly brand their online posts as personal and purely their own. The company should not be held liable for any repercussions the employees’ content may generate.
  • Content pertaining to sensitive company information (particularly those found within r2p’s internal networks) should not be shared to the outside online community. Divulging information like the company’s design plans, internal operations and legal matters are prohibited on social media.
  • Proper copyright and reference laws should be observed by employees when posting online.
  • Employees cannot post any negative comments or any content of any kind which compromises r2p competitiveness as your conduct may impact the way customers, suppliers, rival competitors and your fellow employees view who we are and what we stand for as a Company.

We protect confidential company information

r2p’s information is one of its most valuable assets, which is held many different formats including paper, electronically in documents or in IT applications & systems. If it isdisclosed, it could result in significant loss to the r2p Group and create an advantage to our rival competitors therefore,we must take its protection seriously. All internal information should be assumed to be confidential, unless already demonstrably publicly available.

When handling confidential information, we must ensure that we:

  • understand the nature and confidentiality of the information and take personal responsibility for the use, circulation, retention, protection and disposal of r2p’s information;
  • only distribute or share information with a legitimate business need and a respective confidentiality agreement in place,or as required by law;
  • do notdisclose r2p’s information in public places and take all necessary steps to protect documents and IT devices away from the workplace. If in doubt how to handle any information, we must seek advice from our immediate line manager or contact Group Legal.

We take care of our company property

We use the company’s property and resources correctly and carefully and protect them from loss, theft and misuse. We use the company’s tangible and intangible assets exclusively for business purposes and not for personal reasons, except where expressly permitted.

Our employees bear joint responsibility with their supervisors for ensuring that business trips are always appropriate in nature and scale to the purpose of the trip and are efficiently planned and carried out taking time and cost aspects into account. For details, please refer to our Travel Guideline and Company Car Guideline.

Our company’s intellectual property represents a competitive advantage for the r2p Group and is therefore a valuable asset which we protect against all unauthorized access by third parties.

  • Employees must report to Group Legal of any suspected counterfeit products or any product, packaging, communication or marketing practice that are suspected of infringing our copyright, trademarks, patents, design rights, domain names and/or other intellectual property rights.
  • When researching, developing or preparing tolaunch new brands, sub-brands, services, designs, inventions, communication, advertising and promotional materials, we must ensure that all the necessary checks and filings have occurred with respect to patents, designs and trademarks or intellectual property. If in doubt, please seek advice from Group Legal.
  • When undertaking collaborative work with third parties, we must ensure a contract is in place with appropriate clauses to protect r2p’s intellectual property and ensure freedom to use results. If in doubt, please seek advice from Group Legal.

We foster a healthy work-life balance

Our flextime system enables us to use our time flexibly and responsibly. Thus, we can achieve an individual balance between times with high and low workloads, between career and family life. For further details, please contact your local HR responsible.

We foster health and safety at work

The r2p Group will do its utmost to provide a safe and healthy work environment, ensuring that local legislation regarding health and safety is adhered to. All managers are obligated to instruct and support their employees in meeting this responsibility.

We respect our employees’ data privacy

When r2p is collecting, using and storing individual personal data we will ensure that:

  • consent is obtained from the employee;
  • only collect data that is adequate, relevant and used solely for the purpose for which it is collected;
  • use of personal data in accordance with the relevant published privacy notice; and
  • personal data is kept confidential and secure with paper copies also stored securely.
2 The r2p Group towards external partners and society

It is of fundamental importance that no representative of the r2p Group enters into, or condones, any action that is contrary to local legal rules or its stated policies or practices. We take care when interacting with other parties, to make sure wealwayscomply with applicable lawsand regulations and follow our own policies. Ignorance of the law is no excuse. Timely legal consultation is essential to ensure that r2p legitimate business interests and opportunities are protected. The r2p Legal team is hereto help, so please ensure they are consulted on any legal matters (e.g. commercial contracts for goods or services, civil litigation such as employment or contractual disputes, criminal prosecutions). We immediately notify our line manager and take advice from r2p’s Group Legal if we suspect or discover any illegal activity in relation in relation to r2p’s operations or associated activities involving third parties.

Our economic behaviour in a global context

In our daily work, we strive to implement ethical and moral standards. The r2p Group holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees.

  • Our German headquarters as well as our subsidiaries in the UK, Australia and Malaysia are certified according to ISO 9001.
  • We base our business relations solely on objective criteria such as quality, service, pricing and sustainability.
  • We do not use our market position to get advantages through dictating prices or refusing to supply.
  • We do not knowingly infringe the valid patents, design rights, trademarks, copyright and other intellectual property rights of any third party.
  • We comply with competition laws and do not take part in collusive pricing or cartel agreements.
  • We avoid taking unfair advantage through manipulation, concealment or misrepresentation of key facts.
  • We make sure that our subcontractors and suppliers operate in accordance with our own integrity requirements, including health and safety at work.
  • Any contact with government regulators, ministers or officials must have the approval from your Line Manager and Group Legal.

Gifts, Hospitality and Prevention of Bribery

Most countries in the world have implemented laws prohibiting corruption. In some cases, bribes in foreign countries are even enforced across territorial boundaries. r2p is committed to a zero-tolerance approach towards bribery and corruption. We must immediately notify our Line Manager or Group Legal of any suspicious behaviour or actual bribery.

  • We neither pay nor accept payments or other advantages from or to customers, suppliers or other parties that would influence business decisions.
  • Facilitation payments are also prohibited. A facilitation payment is a payment to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has a legal or other entitlement. Although in some legislations, facilitation payments are not considered as bribery, the r2p Group does not engage in this practice.
  • Occasional gifts of small value (less than 90 €) are an exception to that rule. Should cultural reasons make it inappropriate or impossible to turn down a gift, we donate it or raffle it within the company.
  • Any gift or hospitality of more than a token value must be reported to your supervisor or Group Legal to determine if it may be accepted.
  • We transparently account for all invitations we receive. If there is a requirement for overnight stays or foreign travel, prior written consent will be needed from your line Manager. For further details, please refer to our “Travel Guidelines”. 

These prohibitions apply to any person who may be seen to be representing the r2p Group and any improper behaviour with regard to the use of bribery or facilitation payments will be considered to be a breach of the employment contract and subject to disciplinary procedures.

Donations and Sponsoring

Donations and sponsoring activities consistent to the company values are part of our social commitment and responsibility. When supporting organizations and projects with donations, we want to contribute to a good cause. We do not expect or accept anything in return. Our sponsoring activities can never be linked to seeking or obtaining an improper business advantage.

Prevention of Money Laundering

To protect r2p’s reputation and avoid potential criminal liability towards the company or even its employees, it is important not to become associated with criminal activities of others. In particular r2p does not receive the proceeds of criminal activities, as this can amount to the criminal offence of money laundering.

All employees are required to immediately report to their Line Manager, Group Legal, finance or their compliance department for review for any unusual or suspicious financial transactions. This may include a supplier or a customer requesting to pay funds to a bank account in the name of a different third party or outside the country of their operation or make payments in a form outside the normal terms of business or making spilt payments to several bank accounts and making significant overpayment and requesting immediately refund of the overpayment. For further information, please refer to the “Financial Manual”.

Human Rights and Modern Slavery Ban

The r2p Group is vehemently opposed to the use of slavery in all forms (ILO Conventions 29 and 105); cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion.

The r2p Group will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.

The r2p Group will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities.

Conflict Minerals

Today’s electronic technology relies heavily on minerals whose global occurrences are concentrated in few, politically instable and poor regions of the world. This is also true for the technologies used at the r2p Group: tantalum capacitors are a standard component for on-board PCs, for example. Our business is therefore dependent on these minerals. Their exploitation can be linked to armed conflicts, the violation of human rights and environmental damages –if we do not take measures against it. For these measures to work we depend on our suppliers’ support, as our in-house production depth reaches only the use of intermediate goods such as components but never the use of any raw materials.

  • We expressly encourage our suppliers to monitor and certify their supply chains and honour this effort in our sourcing decisions.
  • We invite and expect our partners to join us on this journey towards a fair and responsible usage of minerals for modern technology.

Child Labour Ban and Youth Protection

The r2p Group is vehemently opposed to child labour and will not accept it in any business activity including its supply chain (ILO Conventions 138 and 182).

  • We expressly encourage our suppliers to monitor and certify their supply chains and honour this effort in our sourcing decisions.
  • We invite and expect our partners to join us on this journey towards the compliance with child protection and human rights.
  • If employing a juvenile, the r2p Group ensures they are over the local minimum age for employment. Any employee younger than 18 years must not perform dangerous work, work at nights and is entitled to more breaks.

Environmental Responsibility

We aim to minimise our environmental impact, both in product development and in our day-to-day work. Our German headquarters is certified according to ISO 14001.

  • We separate recyclable waste.
  • We switch off our monitors and lights and use the power save mode of our computers when we leave the office. In doing so, we strive to steadily reduce our electricity consumption per capita.
  • We want to steadily increase the fuel efficiency of our company cars.
  • We use our company bikes and try to use public transport for travelling to our external appointments –not least to show our colours for eco-mobility to our customers and business partners
  • We expressly encourage our suppliers to monitor and certify their supply chains regarding their environmental impact and honour this effort in our sourcing decisions.

Data Protection

The r2p Group commits to protecting any information it obtains through the course of doing business, especially those entrusted to us by our clients. Specifically, wemust:

  • protect customer data and should not share it with any third parties
  • protect personal information relating to co-workers, suppliers or business partners and
  • keep any such information secure.

When dealing with personal information, weensure business decisions are based on sound judgement and not personal information that could result in suggested discrimination. Employees are asked to read and familiarise themselves with local data protection policies and, if unclear, speak to their line manager to ascertain how it applies to them in their role.

Information received by employees, contractors or agents of the r2p Group will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given. We will not seek to obtain competitors’ confidential information. Where an employee acquires a competitor’s confidential information unintentionally, they must not use it or forward it to anyone except their line manager or Group Legal. 

Communications

Transparency and honesty are important to the r2p group and to our stakeholders why we are aiming at an open and direct communication with partners, suppliers and society.

Material information about our performance and prospects will always be published to the financial community at the same time so as not to advantage or disadvantage any particular organisation.

3 Contacts

For further questions relating to the Code of Conduct, all employees as well as third parties (customers, suppliers, etc.) may contact the r2p Group HR department HRM(at)r2p.com or seek advice from our Group Legal jay.saw(at)r2p.com or contact Jeremy Abbett (ombudsman(at)r2p.com) who is a member of r2p’s advisory board. In need of reporting: in the first instance you should contact your supervisor, however the Managing Director may be contacted directly. Should, for any reason, something not be clear to you, you may also contact the r2p Group HR Manager, highlighting your concerns. Any issues raised will be treated in the strictest confidence.