CODE OF CONDUCT OF MONTRONIX GMBH

Preamble

Montronix GmbH, a member of the MTX Group („MTX“), is a company that provides first-class products and services based on the highest quality and innovation.
MTX‘s business is based on the following core values:

  • Pioneering spirit customer focus
  • Problem-solving skills
  • Responsibility
  • Independence

MTX supports and respects the protection of internationally recognized human rights and endeavors to comply with all applicable laws and regulations. MTX does not tolerate any illegal or unethical behavior on the part of its employees.

This Code of Conduct is binding for the employees of the MTX group of companies. MTX is committed to the principles of integrity, honesty and fairness in all relationships within and outside the company. The management of MTX fully supports the principles set out in this Code of Conduct and expects the company‘s employees to comply with all of the guidelines contained therein. The future success of MTX depends crucially on the fact that this Code of Conduct is followed by all employees. Any disregard could cause MTX financial disadvantages and damage the company‘s reputation over the long term. Compliance with the Code of Conduct aims to exclude or reduce any potential risk to the company itself and to individuals.

MTX is a global company with an excellent reputation. The implementation of the highest standards is an important goal of MTX. Employees are encouraged to contribute to the creation of a work environment that is characterized by motivation and team orientation, mutual respect (renouncing the exploitation of dependency relationships) and nondiscrimination.

Any violation of this Code of Conduct and the principles on which it is based can result in appropriate disciplinary action in accordance with applicable labor law.

 

1. General behavior of the employees

MTX expects a variety of professional behavior from its employees. Existing laws (such as laws against corruption, copyright laws, data protection laws, criminal law, environmental protection laws, laws against unfair competition and restraints of competition, export laws, tax laws, anti-discrimination laws, ...) must be followed and behavior that could be interpreted as disregard of legal provisions must be avoided. Employees must always take care to protect the reputation of MTX and to protect the public image of the company. The behavior of the employees also includes the individual right of the employees to form, or to join, or not to form, or not to join, various trade unions.

 

2. Product Integrity

MTX strives to meet the highest quality requirements for MTX products. The aim is to ensure and maintain the greatest possible trust and customer satisfaction with the MTX brand. Compliance with the relevant regulations and guidelines, in particular with regard to product safety, product liability and guarantees, is a matter of course in this context.

 

3. Data protection and confidentiality

Compliance with data protection regulations is important for MTX. All employees who deal with personal data must comply with the locally applicable laws. The employees are regularly trained in this regard and also obliged to comply in writing in accordance with existing legal requirements.

Personal data relates directly or indirectly to natural individuals and, in some legal systems, to legal persons. This not only includes the names, addresses and social security numbers of our employees, customers and suppliers, but also photographs, videos and voice recordings. For the handling of special personal data, such as criminal or other sensitive data (such as health data), stricter regulations generally apply.

As a general guide for the handling of personal data, the following principles apply:

Personal data ...

  • ... are to be used appropriately and in accordance with statutory provisions.
  • ... may only be collected for special, clearly defined and permissible purposes and may not be further processed in any way which is incompatible with these purposes.
  • ... must be essential for the use and intended use and the extent of use must be in reasonable proportion to the intended use.
  • ... are to be used in such a way that die results are factually correct, taking into account the intended use. If necessary, they are to be brought up to date.
  • ... must be stored in a form that enables the person concerned to be identified, provided this is necessary for the intended use.

MTX endeavors to obtain relevant information directly from those affected and to use only reputable and reliable sources to obtain additional data. In any case, the obligations to inform those affected by the data processing must be observed.

When using personal data, appropriate training, organizational and technical security measures must be taken to ensure data security.

MTX respects the rights of those affected by data processing, such as the right of access, inspection, restriction and deletion.

The absolute secrecy of confidential information is an essential success factor for MTX. Examples of such information are MTX‘s technical, technological and business know-how, as well as confidential information that MTX receives from its customers, suppliers and business partners.

Personal data, business secrets and other confidential information of all kinds relating to MTX must be kept secret. For this reason, employees are required to strictly adhere to the confidentiality provisions contained in the employment contract. Information that is not publicly known may not be passed on to third parties. This confidentiality obligation on the part of employees also applies after the employment relationship with the employer belonging to the MTX Group has ended.

 

4. Illegal Payments and Bribery

MTX is committed to the principles of integrity, honesty and fairness. The employees have to refrain from corrupt and / or unfair actions. This principle applies worldwide. Misconduct can cause serious financial damage to MTX and damage the company‘s reputation over the long term. In most of the countries in which MTX does business, corrupt practices in the respective country as well as those abroad lead to criminal convictions of the person concerned and to very high fines for the company.

As a general guideline, the following principles apply:

  • Our employees must observe the applicable local anti-corruption laws when doing business. Our employees may not offer or give business partners any benefits of value in order to influence business decisions, nor may they request or accept such benefits. Particular care must be taken when dealing with representatives of authorities, because in most countries local law has different provisions for representatives of authorities and other (private) third parties.
  • If third parties are involved, information about their reputation must be obtained and contractual agreements made, which also oblige these third parties to comply with the law.
  • Services are to be acquired and paid for in accordance with the law and according to their value. Payments may only be made if there is an appropriate, conclusive and meaningful description of the service provided.

 

5. Fair competition

The success of MTX depends crucially on its employees refraining from any actions that restrict fair competition and on complying with all applicable competition and antitrust laws as well as other laws against unfair competition. Laws against restraint of competition serve to ensure healthy competition in a fair and appropriate business climate. These regulations usually apply to both the distribution of products and the distribution of services. Violations of this can cause considerable damage to MTX.

In order to promote a fair business climate and to protect MTX, employees are encouraged to observe the local guidelines. MTX sees itself as a dynamic and fair participant in competition and respects the applicable laws against unfair competition.

In this context, the following guidelines must be observed:

  • In general, laws against unfair competition prohibit dishonest business practices that are likely to cause harm to consumers, competitors or other market participants. Antitrust laws, for example, prohibit agreements between companies that could lead to an impediment to competition. The most serious antitrust violations include agreements that involve independent judgments and decisions in business matters intrigue. This includes price fixing, production and procurement cartels as well as agreements to control product quality or to divide markets according to customers, areas, products and procurements. MTX does not enter into such agreements with competitors, as these are almost always illegal.
  • The rights of third parties for the protection of intellectual property (patents, trademarks and copyrights) must be respected; Violations of these rights are to be avoided. Employees are not permitted to gain access to the business or company secrets of third parties or to use them without authorization.

 

6. International trade

The applicable regulations and restrictions with regard to international trade, including the export and import regulations of the country concerned at the time, must always be observed. This is especially true for countries that are under a trade embargo. In the case of international deliveries or orders, MTX must check whether the foreign business partner is subject to a trade ban due to relevant foreign trade regulations.

 

7. MTX Funds and Other Assets

Employees who have any form of access to MTX funds are obliged to adhere to the procedures described in the MTX procedural regulations with regard to the logging, handling and protection of funds. The funds and all other assets of MTX are used solely for the company‘s business purposes and not for personal use, unless otherwise expressly agreed.

 

8. Conflicts of Interest

MTX expects its employees to perform their duties conscientiously, honestly and for the benefit of MTX. It is not permitted to use one‘s own position or the knowledge acquired through employment at MTX to gain unauthorized advantages for oneself or third parties.

Employees must avoid any potential conflicts of interest. This is especially true with regard to personal considerations that could interfere with independent decision-making about what is in MTX‘s interest or how these interests can best be pursued.

It is not permitted to work for suppliers, customers or competitors of MTX or to provide services on their behalf. Employees have to disclose financial holdings in companies that have a contractual relationship with MTX (e.g. delivery of goods and / or rendering of services for MTX) if their decisions in the performance of their tasks on behalf of MTX actually do so or appear to affect it.

Any situation that represents or gives rise to a conflict of interest must be reported to the relevant manager immediately. With regard to secondary employment, the relevant rules of their service contracts or the locally applicable legal provisions must be observed by the employees.

 

9. Communication

Communication between MTX employees and employees with customers, suppliers, authorities, the public and other bodies within MTX must be complete, correct and timely. It must be ensured that personal and business messages are clearly visible as such. The use of the company‘s own identification marks, stationery, operating resources and devices for personal or political purposes is not permitted. MTX employees are particularly required to be careful with information they exchange via social media such as Facebook, Twitter and LinkedIn.

Relationships or contacts with the media and press, insofar as they concern MTX, must be coordinated with the person or department responsible for public relations, primarily the management. Employees are not permitted to comment publicly on a topic on behalf of MTX without express instructions. When dealing with people outside the company, including representatives of authorities, it is important to ensure that the presentation of MTX is in line with their vision and values. The employees have to refrain from actions that could damage the good reputation of MTX or of third parties, companies or authorities.

 

10. Records

In order to meet MTX‘s legal and financial obligations and to manage the company, it is necessary to keep correct and reliable records. All business transactions must be mapped completely, correctly and in a timely manner in MTX‘s books and documents. The employees responsible for bookkeeping and documentation are obliged to disclose and document all of the company‘s assets and liabilities in full, with due diligence. Employees are not permitted to make incorrect records or communications or to participate in such, such as incorrect expense reports, incorrect attendance, production and financial reports as well as misleading advertising and marketing measures.

 

11. Equal treatment and sexual harassment

Hiring and dealing with MTX employees is free of discrimination with regard to gender, race, religion, age, disability, sexual orientation, nationality, political convictions, union membership, social origin or ethnicity.

MTX employees are also required to avoid any form of discrimination when dealing with colleagues. Sexual harassment or behavior that could be interpreted as such is prohibited. These include, among other things, inappropriate use of language, storing and attaching inappropriate materials in the work area, or accessing such materials using a computer.

Human dignity and respect for one‘s personality are of the utmost importance to us. We are committed to the principles of respectful, fair and loyal dealings with one another. All employees are given the same opportunities for recruitment and further personal development in the company. We expect all employees to contribute to a productive work environment through tolerant, polite and considerate interaction with one another.

12. Health and Safety

MTX is committed to protecting the health and safety of its employees and complying with all applicable health and safety regulations.

 

13. Environment

MTX products, services and processes are designed in such a way that they guarantee the efficient use of energy and raw materials as well as a minimization of waste and residual materials over the life cycle of the products. MTX does not use any materials or processes that pose a risk to the environment or human health, provided that suitable alternatives are available. MTX employees are encouraged to give the company their full support in this regard.

 

14. Return of packaging according to VerpackG

As the final distributor of packaging within the meaning of Section 15, Paragraph 1 of the Act on the Marketing, Taking Back and High-Quality Recycling of Packaging (VerpackG), we are obliged to inform our customers about the return options for packaging and their purpose.

Montronix GmbH would like to fulfill this obligation.

Return options

As a customer, you are always free to return transport packaging, which we used to protect your goods from damage during transport, to our location in Oberstenfeld.

Sense of return

By returning it, you help ensure that undamaged packaging can be used again. If possible, damaged packaging is fed into the material cycle or disposed of professionally.

 

15. Working hours and remuneration

MTX adheres to the legal requirements regarding working hours, minimum wages and social benefits, with all employees being informed about working hours and remuneration in a way that is easy to understand.

 

16. Binding character and reporting requirements

MTX expects the company‘s employees to strictly adhere to this Code of Conduct. Violations of the Code of Conduct can result in disciplinary action in accordance with applicable labor law.

The employees must ...

  • ... familiarize yourself in detail with the regulations and guidelines that relate to your own position.
  • ... behave in accordance with the rules in this Code of Conduct.
  • ... unreservedly support employees who report violations of this Code of Conduct.
  • ... cooperate fully in investigations into violations of this Code of Conduct.

In addition, the employees should make various suggestions for improving the application of this Code of Conduct, should its implementation encounter difficulties in practice.

It is expected that employees report any violations of this Code of Conduct to their superiors.

Instead of contacting their supervisor, employees can report to one or both of the managing directors at any time, either alone or, if desired, in the presence of a person of trust.

MTX guarantees employees who comply with this Code of Conduct and in particular report violations of it or who are unjustifiably accused of a violation, full protection against disadvantages resulting from the report.

Employees who act as superiors are particularly responsible for supporting this Code of Conduct.

 

17. Help and information

Employees who need help with the application or interpretation of this Code of Conduct, the general principles on which it is based or a specific legal provision, or who are unsure about this, should speak to their supervisor. Employees who need legal help should contact their supervisor and ask for support. Instead of the supervisor one or both managing directors can be contacted become.

 

Oberstenfeld, den 07. November 2022

 

Michael Heim
Managing Director