We are committed to creating, maintaining, and continuously improving legal certainty. We raise awareness among all SWJ employees of the importance of treating one another, as well as our customers and business partners, with respect. Our business conduct is guided by moral and ethical principles, applicable law, and international norms and practices, in keeping with our corporate values.

SWJ expects all employees to act with integrity. Business practices and behavior that do not meet this standard are not acceptable to us. Violations of rules are consistently addressed and sanctioned.

This creates trust, credibility, reliability, and reputation. These values are essential for SWJ’s business success. Business success does not take precedence over laws and regulations, morality, and integrity.

Key elements in this regard are:

• Respect for human rights
• Creating a socially responsible and safe working environment
• Socially responsible working hours
• Prohibition of child labor
• Protection for young workers
• Fair remuneration and social benefits
• Prohibition of modern slavery
• Granting freedom of assembly and participation in collective bargaining
• Protection against harassment and discrimination

SWJ’s management is committed to establishing and planning the Compliance Management System, implementing and maintaining it, monitoring it, and continuously improving it. This is based on:

• Consistent compliance with laws, legal regulations and guidelines, as well as general policies and corporate policies
• Adequate and transparent provision of resources
• Expecting all managers to act as role models
• Consistent handling of suspected cases and violations
• Commitment to continuous improvement

SWJ employees receive regular training on compliance-related topics:

• Human and labor rights
• Compliance with laws and regulations
• Export controls and economic sanctions
• Occupational safety and health
• Data protection and information security
• Use of company infrastructure
• How do we behave correctly?

• • Gifts, invitations/hospitality, travel
  • Bribery, corruption, and money laundering prevention
  • Handling of / dealing with suppliers and service providers
  • Copyright and licensing agreements
  • Fraud, theft, and embezzlement
  • Environmental and climate protection
  • Conflicts of interest
  • Plagiarism

Concern Report System/ Whistleblowing

In cases of serious violations (such as extortion, bribery, corruption, etc.) that constitute a breach of applicable laws or regulations or of SWJ’s Compliance Policy, or where there is imminent danger, the whistleblowing system should be used immediately.

whistleblowing@swj.de (Caution! – NOT anonymous)

https://swj.trusty.report/ (Concern report system, can be anonymous)

Protection of concern reporters

Whistleblowers (concern reporters) are protected. Neither employees nor external reporting persons will suffer any detriment for reporting criminal offences, irregularities, or other violations of the law or this Policy. Even if a whistleblower reports an event based only on suspicion, and that suspicion is not substantiated following a review or investigation, the whistleblower will not face any sanctions. The confidentiality of the whistleblower’s personal data will be protected in all cases.

Nevertheless, it is prohibited to discredit colleagues by making intentional false statements and/or to deliberately cause reputational damage to SWJ.

In internal audits and management reviews, the effectiveness of the established systems is regularly evaluated, and, where necessary, measures to improve the compliance management system are defined and implemented.

In the case of violations by employees resulting from intentional conduct or gross negligence (including, where applicable, an omission), disciplinary action may be taken depending on the severity of the violation. This may range from a reprimand or formal warning to termination without notice, including in cases involving criminal offences or sexual harassment.

Zero tolerance!

We take a zero-tolerance approach to violations.
This means:

• Every violation is assessed according to its severity.
• Every violation is sanctioned and has consequences.

The SWJ Code of Conduct covers the following areas:

• Principles of Conduct (Code of Conduct)
• Respect and appreciation
• Integrity
• Sense of responsibility
• Commitment
• Cooperation
• Performance orientation
• Motivation
• Communication
• Environmental and energy awareness
• Compliance / Ethical principles
• Scope of application

The Code of Conduct is supplemented by internal compliance guidelines, processes, and requirements.

SWJ companies require their suppliers and other business partners to comply with fundamental sustainability standards. SWJ will not do business with suppliers or business partners who fail to uphold these principles in word and deed. Since the activities of our suppliers and business partners may be associated with SWJ, and failure to comply with these principles could damage SWJ’s reputation, we require our suppliers and other business partners to demonstrate the same level of integrity and probity.

The Sustainability Policy is based on the principles of the United Nations Global Compact (Link to United Nations Global Compact) and the standards set out in DRIVE Sustainability’s Guiding Principles (Link to Guiding Principles) .

The Supplier Code of Conduct is supplemented by internal compliance policies, processes, and guidelines.