Our Supplier Code

1. Human rights and working conditions

We expect our suppliers to ensure compliance with internationally recognized human rights and to avoid causing or contributing to
of or participation in human rights violations. In addition, we expect our suppliers to comply with the basic labor rights of the applicable law.

1.1 Prohibition of Forced Labor

Suppliers shall not employ persons in forced or compulsory labor. All activities must be on a voluntary basis and may not be performed as a result of bonded labor or human trafficking. The employees of our suppliers must be free to separate from their employer in compliance with the statutory periods of notice. The withholding of identification documents or work permits with the purpose of making this more difficult is prohibited.
Suppliers shall not use any form of slavery and shall not tolerate slave-like practices, bondage and other forms of domination and oppression in the workplace environment, for example through economic or sexual exploitation and humiliation.


1.2 Prohibition of child labor

Suppliers shall not employ children under the age at which compulsory schooling ends under the law of the place of employment, and in no case shall the minimum age be less than 15 years. In addition, children do not perform any risky work for them, for which a minimum age of 18 years is required.


1.3 Harmful use of resources

Suppliers shall refrain from causing harmful soil contamination, water pollution, air pollution,
harmful noise emission, or excessive water consumption that significantly impairs the natural basis for food preservation and production, denies a person access to safe drinking water, impedes or destroys a person's access to sanitation, or harms a person's health.


1.4 Illegal land grabbing

We expect our suppliers to comply with the prohibition of unlawful eviction and the prohibition of unlawful taking of land, forests and waters when acquiring, developing or otherwise using land, forests and waters whose use provides a person's livelihood.


1.5 Respect for Workers, Prohibition of Discrimination

Suppliers shall treat all workers with respect and dignity and create an environment free from inappropriate treatment. This includes sexual harassment and discrimination, including ambiguous gestures, unwanted language or physical touching, and the use of coercion, threats and intimidation.
Suppliers shall promote equal opportunity and shall not tolerate discrimination, favoritism, or harassment of employees
for example, on the basis of national or ethnic origin, social origin, age, gender, skin color, cultural affiliation
sexual identity and orientation, health status, disability, political opinion, religion or belief, unless it is justified by the requirements of the employment. Unequal treatment includes, in particular, the payment of unequal remuneration for work of equal value.


1.6 Freedom of Association and Coalition

Suppliers shall respect the freedom of association and recognize the right of employees to freely form or join trade unions. Workers shall not be discriminated against or given preferential treatment because of forming, joining or being a member of a trade union or other employee representative body. Suppliers shall allow unions to operate freely and in accordance with the law of the place of employment; this includes the right to strike and the right to collective bargaining.


1.7 Compensation of Employees

Suppliers shall pay workers a reasonable wage. The reasonable wage shall be at least the minimum wage established by applicable law and shall otherwise be determined by the law of the place of employment. If no legal provisions exist, suppliers shall compensate their workers in such a way that the wage can cover the basic needs for living.


1.8 Health and safety at work

Suppliers shall comply with all applicable occupational health and safety and time regulations at the place of employment. They shall allow workers to take rest breaks at reasonable intervals. Each worker shall have the right to at least one uninterrupted day off per week. Suppliers shall ensure that working hours are recorded and, including overtime and extra work, are within the legal requirements in the country of employment. Where these do not exist, the total weekly working time shall not exceed 60 hours. If suppliers provide living space for employees on the company premises, they may leave and re-enter the premises unhindered during their non-working hours.
We expect suppliers to maintain an appropriate health and safety management system and to appoint a person responsible for occupational health and safety management. This person ensures that workplaces and processes comply with legal requirements and, in addition, that health hazards are excluded to the best of his or her knowledge. In the event that working conditions entail unavoidable health hazards, suppliers shall make protective equipment available to their employees free of charge and shall provide documented instruction at regular intervals on its proper use and on the prevention of occupational accidents.


1.9 Use of safety personnel

Suppliers shall ensure that any private or public security personnel hired or used by them are adequately trained and supervised to ensure that they comply with all applicable laws when deployed, in particular that they observe the prohibition of torture and cruel, inhuman or degrading treatment, do not unlawfully harm the life or limb of others, and do not interfere with workers' freedom of association and freedom of organization.


2. Business ethics

We expect our suppliers to comply with all applicable laws, rules and regulations and also to take appropriate measures to ensure compliance with such laws, rules and regulations.


2.1 Prohibition of corruption and bribery

We expect suppliers to refrain from any form of corruption or bribery and not to participate directly or indirectly in it.
participate. In this context, gratuities in return for preferential treatment in business dealings may not be
promised, granted or accepted, either to private parties or to representatives of governments and public authorities. This also includes refraining from granting or accepting improper acceleration payments. Invitations and gifts to THEIS employees may only be given if the occasion and extent are appropriate, i.e., if they are of low value and within the bounds of customary business hospitality, custom and courtesy. Suppliers will observe THEIS' prohibition against accepting monetary gifts.
Contributions to political parties and organizations must always be transparent and in compliance with the anti-corruption laws of the respective country.
anti-corruption laws in force in the respective country.


2.2 Avoidance of Conflicts of Interest

Suppliers shall ensure in business activities with customers, their own suppliers and other business partners that there are no conflicts of interest that could influence business relationships. If suppliers are aware that members of the management, employees involved in award decisions or close relatives own shares in the respective partner company or carry out activities there, suppliers must disclose this.


2.3 Fair competition and intellectual property rights

Suppliers shall act in accordance with all national and international competition laws. In their dealings with competitors, suppliers shall not enter into any illegal agreements or perform any other acts that illegally influence prices or delivery conditions or improperly impede free and open competition, for example, price-fixing agreements or the sharing of markets or customers. Suppliers shall respect the intellectual property rights of THEIS and others.


2.4 Foreign Trade and Customs Regulations, Money Laundering and Terrorist Financing

Suppliers shall comply with all applicable foreign trade and customs regulations. This includes consistent compliance with all applicable export control, embargo and sanctions regulations as well as obtaining any required official export licenses. Suppliers shall provide THEIS with all information relevant to compliance with the aforementioned regulations. This includes, in particular, the Export Control Classification Number ("ECCN"), the commodity tariff number according to the harmonized system, the country of origin and, if applicable, proof of preferential trade. Suppliers shall also comply with all applicable money laundering regulations and shall not directly or indirectly promote the financing of terrorism.


2.5 Due Diligence Requirements in the Supply Chain

THEIS strives to work in partnership with suppliers and expects suppliers to follow and behave in accordance with the principles of the THEIS Supplier Code. We expect suppliers to comply with the supply chain due diligence regulations applicable to them and to ensure that suppliers and their related companies also comply with all of the principles described in this Supplier Code, and make reasonable efforts to ensure that their own suppliers, subcontractors and suppliers also comply with these principles. An "affiliate" is a natural person or legal entity that controls or is controlled by a supplier, or that a supplier controls jointly with another natural person or legal entity. Control in this sense means the power to exercise, directly or indirectly, a dominant influence over another natural or legal person, such as by virtue of voting rights or by contract.


3. Data protection and information security

We expect suppliers to process personal data only in a lawful manner based on applicable data protection regulations and only for legitimate purposes. Information received by Suppliers in cooperation with THEIS shall be treated confidentially and shall not be disclosed to third parties without authorization. In particular, non-disclosure agreements and all other agreed upon information security requirements shall be strictly adhered to.


4. Conflict minerals

If Suppliers deliver products to THEIS that contain gold, tin, tungsten or tantalum ("Conflict Minerals"), they will, upon request, investigate their supply chain to an appropriate extent, provide THEIS with appropriate evidence in writing of the origin of these substances, and demonstrate that their raw materials do not originate from conflict and high-risk areas or were extracted at the cost of human rights abuses. Suppliers shall also comply with all applicable legal regulations regarding conflict minerals.


5 Environmental protection

Suppliers shall maintain an appropriate environmental management system and comply with all applicable laws and international standards for the protection of the environment in their country and for business transactions with THEIS. In addition, suppliers proactively promote environmentally responsible practices. We expect suppliers to make a voluntary commitment to preserve our environment for current and future generations. To demonstrate their application, suppliers implement programs in their company in which environmentally relevant fields of action are identified and targets are set, the sustainable achievement of which is ensured through appropriate measures as well as control and monitoring mechanisms. This includes, for example, the ongoing reduction of energy and water consumption, material resources, air pollutants, greenhouse gases, waste and substances hazardous to the environment or health.


6. Reports and notices

We ask our suppliers to report any evidence of violations of the principles described in this Supplier Code that could impact THEIS.


7. Compliance with the THEIS Supplier Code

THEIS requires for a business relationship with suppliers that they accept the Theis Supplier Code. THEIS reserves the right to verify compliance with the principles of this Supplier Code by the Suppliers as part of its risk management. Suppliers will provide THEIS with the necessary information and, in the event of an on-site visit, access to the premises and inspection of business documents to the extent necessary while maintaining the Supplier's business secrets. If there is a concrete suspicion that a Supplier or its own supplier, subcontractor or supplier violates the principles of this Supplier Code, the Supplier will, upon THEIS' request, immediately investigate the suspicion and inform THEIS in writing about the nature and scope of its investigation and its result and initiate corrective measures. If the Supplier demonstrably fails to initiate appropriate corrective or improvement measures within a reasonable period of time, or if the violation is so serious that THEIS cannot reasonably be expected to continue the business relationship, THEIS reserves the right to terminate individual or all contractual relationships with the Supplier without notice or to withdraw from such contractual relationships.


Last updated: February 2023.