Supplier Code of Conduct
TABLE OF CONTENT / CONSISTING OF:
 Responsible Business Alliance (RBA) Code of Conduct
 Annex to the RBA Code of Conduct (ebm-papst
additional expectations and requirements towards
Suppliers)

ebm-papst Supplier Code of Conduct
Version of August 2023

Version 7.0 (2021)

RESPONSIBLE BUSINESS ALLIANCE CODE OF CONDUCTThe Responsible Business Alliance (RBA), formerly the Electronic Industry Citizenship Coalition(EICC), Code of Conduct establishes standards to ensure that working conditions in theelectronics industry, or industries in which electronics are a key component, and its supply chainsare safe, that workers are treated with respect and dignity, and that business operations areenvironmentally responsible and conducted ethically.
Considered as part of the electronics industry for purposes of this Code are all organizations
that may design, market, manufacture, or provide goods and services that are used to produce
electronic goods. The Code may be voluntarily adopted by any business in the electronics
sector and subsequently applied by that business to its supply chain and subcontractors,
including providers of contract labor.
To adopt the Code and become a participant (“Participant”), a business shall declare its support
for the Code and actively pursue conformance to the Code and its standards in accordance witha management system as herein.
Participants must regard the Code as a total supply chain initiative. At a minimum, Participants
shall also require its next tier suppliers to acknowledge and implement the Code.
Fundamental to adopting the Code is the understanding that a business, in all of its activities,
must operate in full compliance with the laws, rules, and regulations of the countries in which it
operates.1 The Code also encourages Participants to go beyond legal compliance, drawing
upon internationally recognized standards, in order to advance social and environmental
responsibility and business ethics. In no case can complying with the Code violate local laws. If,
however, there are differing standards between the RBA Code and local law, the RBA defines
conformance as meeting the strictest requirements. In alignment with the UN Guiding Principles
on Business and Human Rights, the provisions in this Code are derived from and respect
internationally recognized standards including the ILO Declaration on Fundamental Principles
and Rights at Work and the UN Universal Declaration of Human Rights.
The RBA is committed to obtaining regular input from stakeholders in the continued
development and implementation of the Code of Conduct.
The Code is made up of five sections. Sections A, B, and C outline standards for Labor, Healthand Safety, and the Environment, respectively. Section D adds standards relating to businessethics. Section E outlines the elements of an acceptable system to manage conformity to this
Code.

1

The Code is not intended to create new and additional third-party rights, including for workers.

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A.

LABOR

Participants are committed to uphold the human rights of workers, and to treat them with dignity
and respect as understood by the international community. This applies to all workers including
temporary, migrant, student, contract, direct employees, and any other type of worker. The
recognized standards, as set out in the References, were used in preparing the Code and may
be useful sources of additional information.
The labor standards are:1)

Freely Chosen Employment

Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison
labor, slavery or trafficking of persons is not permitted. This includes transporting, harboring,
recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction or
fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of
movement in the facility in addition to unreasonable restrictions on entering or exiting companyprovided facilities including, if applicable, workers’ dormitories or living quarters. As part of thehiring process, all workers must be provided with a written employment agreement in theirnative language that contains a description of terms and conditions of employment. Foreign
migrant workers must receive the employment agreement prior to the worker departing from hisor her country of origin and there shall be no substitution or change(s) allowed in theemployment agreement upon arrival in the receiving country unless these changes are made tomeet local law and provide equal or better terms. All work must be voluntary, and workers shallbe free to leave work at any time or terminate their employment without penalty if reasonable
notice is given as per worker’s contract. Employers, agents, and sub-agents’ may not hold orotherwise destroy, conceal, or confiscate identity or immigration documents, such as
government-issued identification, passports, or work permits. Employers can only holddocumentation if such holdings are required by law. In this case, at no time should workers bedenied access to their documents. Workers shall not be required to pay employers’ agents or
sub-agents’ recruitment fees or other related fees for their employment. If any such fees arefound to have been paid by workers, such fees shall be repaid to the worker.

2)Young Workers

Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person
under the age of 15, or under the age for completing compulsory education, or under theminimum age for employment in the country, whichever is greatest. Participants shall implement
an appropriate mechanism to verify the age of workers. The use of legitimate workplacelearning programs, which comply with all laws and regulations, is supported. Workers under theage of 18 (Young Workers) shall not perform work that is likely to jeopardize their health orsafety, including night shifts and overtime. Participants shall ensure proper management of
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student workers through proper maintenance of student records, rigorous due diligence of
educational partners, and protection of students’ rights in accordance with applicable laws andregulations. Participants shall provide appropriate support and training to all student workers. In
the absence of local law, the wage rate for student workers, interns, and apprentices shall be atleast the same wage rate as other entry-level workers performing equal or similar tasks. If childlabor is identified, assistance/remediation is provided.

3)

Working Hours

Studies of business practices clearly link worker strain to reduced productivity, increased
turnover, and increased injury and illness. Working hours are not to exceed the maximum set
by local law. Further, a workweek should not be more than 60 hours per week, including
overtime, except in emergency or unusual situations. All overtime must be voluntary. Workers
shall be allowed at least one day off every seven days.

4)

Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including thoserelating to minimum wages, overtime hours and legally mandated benefits. In compliance withlocal laws, workers shall be compensated for overtime at pay rates greater than regular hourly
rates. Deductions from wages as a disciplinary measure shall not be permitted. For each pay
period, workers shall be provided with a timely and understandable wage statement that
includes sufficient information to verify accurate compensation for work performed. All use of
temporary, dispatch and outsourced labor will be within the limits of the local law.

5)

Humane Treatment

There is to be no harsh or inhumane treatment including violence, gender-based violence,
sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying,public shaming, or verbal abuse of workers; nor is there to be the threat of any suchtreatment. Disciplinary policies and procedures in support of these requirements shall beclearly defined and communicated to workers.

6)

Non-Discrimination/Non-Harassment

Participants should be committed to a workplace free of harassment and unlawful
discrimination. Companies shall not engage in discrimination or harassment based on race,color, age, gender, sexual orientation, gender identity and expression, ethnicity or national
origin, disability, pregnancy, religion, political affiliation, union membership, covered veteranstatus, protected genetic information or marital status in hiring and employment practices suchas wages, promotions, rewards, and access to training. Workers shall be provided withreasonable accommodation for religious practices. In addition, workers or potential workers
should not be subjected to medical tests, including pregnancy or virginity tests, or physicalexams that could be used in a discriminatory way. This was drafted in consideration of ILO
Discrimination (Employment and Occupation) Convention (No.111).
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7)Freedom of Association

In conformance with local law, participants shall respect the right of all workers to form and jointrade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly
as well as respect the right of workers to refrain from such activities. Workers and/or theirrepresentatives shall be able to openly communicate and share ideas and concerns withmanagement regarding working conditions and management practices without fear of
discrimination, reprisal, intimidation, or harassment.

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B.

HEALTH AND SAFETY

Participants recognize that in addition to minimizing the incidence of work-related injury andillness, a safe and healthy work environment enhances the quality of products and services,consistency of production and worker retention and morale. Participants also recognize thatongoing worker input and education are essential to identifying and solving health andsafety issues in the workplace.
Recognized management systems such as ISO 45001 and ILO Guidelines on Occupational
Safety and Health were used as references in preparing the Code and may be useful sourcesof additional information.
The health and safety standards are:1)

Occupational Safety

Worker potential for exposure to health and safety hazards (chemical, electrical and otherenergy sources, fire, vehicles, and fall hazards, etc.) are to be identified and assessed,
mitigated using the Hierarchy of Controls, which includes eliminating the hazard, substituting
processes or materials, controlling through proper design, implementing engineering andadministrative controls, preventative maintenance and safe work procedures (including
lockout/tagout), and providing ongoing occupational health and safety training. Where hazards
cannot be adequately controlled by these means, workers are to be provided with appropriate,
well-maintained, personal protective equipment, and educational materials about risks to themassociated with these hazards. Reasonable steps must also be taken to remove pregnant
women and ‘nursing mothers from working conditions with high hazards, remove or reduce
any workplace health and safety risks to pregnant women and nursing mothers, including
those associated with their work assignments, and provide reasonable accommodations fornursing mothers.

2)

Emergency Preparedness

Potential emergency situations and events are to be identified and assessed, and their impact
minimized by implementing emergency plans and response procedures including emergency
reporting, employee notification and evacuation procedures, worker training, and drills.
Emergency drills must be executed at least annually or as required by local law, whichever ismore stringent. Emergency plans should also include appropriate fire detection andsuppression equipment, clear and unobstructed egress, adequate exit facilities, contact
information for emergency responders, and recovery plans. Such plans and procedures shallfocus on minimizing harm to life, the environment, and property.

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3)

Occupational Injury and Illness

Procedures and systems are to be in place to prevent, manage, track and report occupational
injury and illness, including provisions to encourage worker reporting, classify and record injury
and illness cases, provide necessary medical treatment, investigate cases and implement
corrective actions to eliminate their causes, and facilitate the return of workers to work.

4)

Industrial Hygiene

Worker exposure to chemical, biological, and physical agents is to be identified, evaluated,and controlled according to the Hierarchy of Controls. If any potential hazards were identified,participants shall look for opportunities to eliminate and/or reduce the potential hazards. If
elimination or reduction of the hazards is not feasible, potential hazards are to be controlled
through proper design, engineering, and administrative controls. When hazards cannot beadequately controlled by such means, workers are to be provided with and use appropriate,
well-maintained, personal protective equipment free of charge. Protective programs shall be
ongoing and include educational materials about the risks associated with these hazards.

5)

Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks, including manual material
handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forcefulassembly tasks is to be identified, evaluated, and controlled.

6)

Machine Safeguarding

Production and other machinery shall be evaluated for safety hazards. Physical guards,
interlocks, and barriers are to be provided and properly maintained where machinerypresents an injury hazard to workers.

7)

Sanitation, Food, and Housing

Workers are to be provided with ready access to clean toilet facilities, potable water andsanitary food preparation, storage, and eating facilities. Worker dormitories provided by theParticipant or a labor agent are to be maintained to be clean and safe, and provided withappropriate emergency egress, hot water for bathing and showering, adequate lighting and heatand ventilation, individually secured accommodations for storing personal and valuable items,
and reasonable personal space along with reasonable entry and exit privileges.

8)

Health and Safety Communication

Participants shall provide workers with appropriate workplace health and safety informationand training in the language of the worker or in a language the worker can understand for all
identified workplace hazards that workers are exposed to, including but not limited to
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information shall be clearly posted in the facility or placed in a location identifiable andaccessible by workers. Training is provided to all workers prior to the beginning of work andregularly thereafter. Workers shall be encouraged to raise any health and safety concerns
without retaliation.

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C.

ENVIRONMENT

Participants recognize that environmental responsibility is integral to producing world-classproducts. Participants shall identify the environmental impacts and minimize adverse effects on
the community, environment, and natural resources within their manufacturing operations,while safeguarding the health and safety of the public. Recognized management systems suchas ISO 14001 and the Eco Management and Audit System (EMAS) were used as referencesin preparing the Code and may be a useful source of additional information.
The environmental standards are:1)

Environmental Permits and Reporting

All required environmental permits (e.g. discharge monitoring), approvals, and registrations
are to be obtained, maintained, and kept current and their operational and reporting
requirements are to be followed.

2)

Pollution Prevention and Resource Reduction

Emissions and discharges of pollutants and generation of waste are to be minimized oreliminated at the source or by practices such as adding pollution control equipment; modifying
production, maintenance, and facility processes; or by other means. The use of natural
resources, including water, fossil fuels, minerals, and virgin forest products, is to be conservedby practices such as modifying production, maintenance and facility processes, materials
substitution, re-use, conservation, recycling, or other means.

3)

Hazardous Substances

Chemicals, waste, and other materials posing a hazard to humans or the environment
are to be identified, labeled, and managed to ensure their safe handling, movement,
storage, use, recycling or reuse, and disposal.

4)

Solid Waste

Participants shall implement a systematic approach to identify, manage, reduce, andresponsibly dispose of or recycle solid waste (non-hazardous).

5)

Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting
substances, and combustion byproducts generated from operations are to be characterized,
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routinely monitored, controlled, and treated as required prior to discharge. Ozonedepleting substances are to be effectively managed in accordance with the Montreal
Protocol and applicable regulations. Participants shall conduct routine monitoring of theperformance of its air emission control systems.

6)

Materials Restrictions

Participants are to adhere to all applicable laws, regulations, and customer
requirements regarding the prohibition or restriction of specific substances in products
and manufacturing, including labeling for recycling and disposal.

7)

Water Management

Participants shall implement a water management program that documents, characterizes, andmonitors water sources, use and discharge; seeks opportunities to conserve water; and controls
channels of contamination. All wastewater is to be characterized, monitored, controlled, andtreated as required prior to discharge or disposal. Participants shall conduct routine monitoringof the performance of its wastewater treatment and containment systems to ensure optimal
performance and regulatory compliance.

8)

Energy Consumption and Greenhouse Gas Emissions

Participants are to establish a corporate-wide greenhouse gas reduction goal. Energy
consumption and all relevant Scopes 1 and 2 greenhouse gas emissions are to be tracked,
documented, and publicly reported against the greenhouse gas reduction goal. Participants
are to look for methods to improve energy efficiency and to minimize their energy consumption
and greenhouse gas emissions.

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D.

ETHICSTo meet social responsibilities and to achieve success in the marketplace, Participants and theiragents are to uphold the highest standards of ethics including:

1)

Business Integrity

The highest standards of integrity are to be upheld in all business interactions. Participants shallhave a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion andembezzlement.

2)

No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not to be promised,offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing,
giving or accepting anything of value, either directly or indirectly through a third party, in order toobtain or retain business, direct business to any person, or otherwise gain an improper
advantage. Monitoring, record keeping, and enforcement procedures shall be implemented toensure compliance with anti-corruption laws.

3)

Disclosure of Information

All business dealings should be transparently performed and accurately reflected on theParticipant’s business books and records. Information regarding participant’s labor, health andsafety, environmental practices, business activities, structure, financial situation, andperformance is to be disclosed in accordance with applicable regulations and prevailing industry
practices. Falsification of records or misrepresentation of conditions or practices in the supply
chain are unacceptable.

4)Intellectual Property

Intellectual property rights are to be respected, transfer of technology and know-how is to bedone in a manner that protects intellectual property rights, and customer and supplierinformation is to be safeguarded.

5)

Fair Business, Advertising and Competition

Standards of fair business, advertising, and competition are to be upheld.

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6)

Protection of Identity and Non-Retaliation

Programs that ensure the confidentiality, anonymity, and protection of supplier and employee
whistleblowers2 are to be maintained, unless prohibited by law. Participants should have acommunicated process for their personnel to be able to raise any concerns without fear of
retaliation.

7)

Responsible Sourcing of Minerals

Participants shall adopt a policy and exercise due diligence on the source and chain of custodyof the tantalum, tin, tungsten, and gold in the products they manufacture to reasonably assurethat they are sourced in a way consistent with the Organisation for Economic Co-operation andDevelopment (OECD) Guidance for Responsible Supply Chains of Minerals from ConflictAffected and High-Risk Areas or an equivalent and recognized due diligence framework.

8)

Privacy

Participants are to commit to protecting the reasonable privacy expectations of personal
information of everyone they do business with, including suppliers, customers, consumers, andemployees. Participants are to comply with privacy and information security laws and regulatory
requirements when personal information is collected, stored, processed, transmitted, andshared.

2 Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public

official or official body.

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E.

MANAGEMENT SYSTEMS

Participants shall adopt or establish a management system with a scope that is related to thecontent of this Code. The management system shall be designed to ensure: (a) compliance withapplicable laws, regulations and customer requirements related to the participant’s operations
and products; (b) conformance with this Code; and (c) identification and mitigation of operationalrisks related to this Code. It should also facilitate continual improvement.
The management system should contain the following elements:

1)

Company Commitment

Corporate social and environmental responsibility policy statements affirming Participant’scommitment to compliance and continual improvement, endorsed by executive
management, and posted in the facility in the local language.

2)

Management Accountability and Responsibility

The Participant clearly identifies senior executive and company representative(s) responsible
for ensuring implementation of the management systems and associated programs. Senior
management reviews the status of the management systems on a regular basis.

3)

Legal and Customer Requirements

A process to identify, monitor and understand applicable laws, regulations, andcustomer requirements, including the requirements of this Code.

4)

Risk Assessment and Risk Management

A process to identify the legal compliance, environmental, health and safety3 and labor practiceand ethics risks associated with Participant’s operations. Determination of the relative
significance for each risk and implementation of appropriate procedural and physical controls tocontrol the identified risks and ensure regulatory compliance.

3 Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage facilities,

plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker
housing/dormitories.

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5)

Improvement Objectives

Written performance objectives, targets and implementation plans to improve the Participant’ssocial, environmental, and health and safety performance, including a periodic assessment ofParticipant’s performance in achieving those objectives.

6)

Training

Programs for training managers and workers to implement Participant’s policies,
procedures, and improvement objectives and to meet applicable legal and regulatory
requirements.

7)

Communication

A process for communicating clear and accurate information about Participant’s policies,
practices, expectations, and performance to workers, suppliers, and customers.

8)

Worker Feedback, Participation and Grievance

Ongoing processes, including an effective grievance mechanism, to assess workers’
understanding of and obtain feedback on or violations against practices and conditions coveredby this Code and to foster continuous improvement. Workers must be given a safe environment
to provide grievance and feedback without fear of reprisal or retaliation.

9)

Audits and Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content
of the Code, and customer contractual requirements related to social and environmental
responsibility.

10)

Corrective Action Process

A process for timely correction of deficiencies identified by internal or external assessments,
inspections, investigations, and reviews.

11)

Documentation and Records

Creation and maintenance of documents and records to ensure regulatory compliance andconformity to company requirements along with appropriate confidentiality to protect privacy.

12)

Supplier Responsibility

A process to communicate Code requirements to suppliers and to monitor supplier compliance
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to the Code.

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REFERENCES
The following standards were used in preparing this Code and may be useful sources ofadditional information. The following standards may or may not be endorsed by eachParticipant.
Dodd-Frank Wall Street Reform and Consumer Protection Act
http://www.sec.gov/about/laws/wallstreetreform-cpa.pdf
Eco Management & Audit System http://ec.europa.eu/environment/emas/index_en.htm
Ethical Trading Initiative www.ethicaltrade.org/
ILO Code of Practice in Safety and Healthwww.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf
ILO International Labor Standards
www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm
ISO 14001 www.iso.org
National Fire Protection Association www.nfpa.org
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from ConflictAffected and High-Risk Areas https://www.oecd.org/daf/inv/mne/OECD-Due-DiligenceGuidance-Minerals-Edition3.pdf
OECD Guidelines for Multinational Enterprises
http://www.oecd.org/investment/mne/1903291.pdf
Universal Declaration of Human Rights https://www.un.org/en/universal-declaration-humanrights/
United Nations Convention Against Corruption https://www.unodc.org/unodc/en/treaties/CAC/
United Nations Convention on the Rights of the Childhttps://www.ohchr.org/en/professionalinterest/pages/crc.aspx
United Nations Convention on the Elimination of All Forms of Discrimination Against Women
https://www.ohchr.org/EN/ProfessionalInterest/Pages/CEDAW.aspx
United Nations Global Compact www.unglobalcompact.org
United States Federal Acquisition Regulation www.acquisition.gov/far/
SA 8000 https://sa-intl.org/programs/sa8000/
Social Accountability International (SAI) www.sa-intl.org
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DOCUMENT HISTORY
Version 1.0 – Released October 2004.
Version 1.1 – Released May 2005. Converted document to RBA format, minor page layout
revisions; no content changes.
Version 2.0 – Released October 2005 with revisions to multiple provisions.
Version 3.0 – Released June 2009 with revisions to multiple provisions.
Version 4.0 – Released April 2012 with revisions to multiple provisions.
Version 5.0 – Released November 2014 with revisions to multiple provisions.
Version 5.1 – Released March 2015 with revision to A1 to take effect January 1, 2016.
Version 6.0 – Released January 2018 with revisions to multiple provisions.
Version 7.0 – Released January 2021 with revisions to multiple provisions.

The RBA Code of Conduct was initially developed by a number of companies engaged in the
manufacture of electronics products between June and October 2004. Companies are invitedand encouraged to adopt this Code. You may obtain additional information from:http://www.responsiblebusiness.org

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Responsible Business Alliance (RBA)
Code of Conduct – Annex

In addition to our aforesaid Responsible Business Alliance Code of Conduct (RBA CoC), we haveadditional expectations and requirements towards you. These expectations and requirements are
based on the German Supply Chain Due Diligence Act (“Lieferkettensorgfaltspflichtengesetz” (LkSG))
effective since 1st January 2023 as well as our ebm-papst sustainability ambitions.
As the leading international company in the development and manufacturing of intelligent, innovativeand high-quality motors, fans and air and heating technology, ebm-papst is aware of its responsibility
within the global commodity flow. According to our fundamental values, which we have lived for morethan 60 years, and which are an integral part of our corporate culture, we not only align our actions
with legal requirements, but also strive to achieve the highest possible ethical standards. We knowthat our success as a company is a success of the people in our surroundings. We therefore treat our
fellow human beings and the environment with respect and value them. Our company can only besustainably successful in the future, if the effects of our business activities are in harmony with people
and the environment. Furthermore, we are acutely aware of our responsibility to society. Our guiding
principle and demand on ourselves is built around "Engineering a better life". This principle is not solely
limited to the continuous development of highly optimized, highly efficient and modern products that
reduce CO2 emissions and operate at maximum efficiency and sustainability. We not only want toensure that the end product is part of the sustainability solution, but we also commit ourselves toreducing environmental and human rights risks along the value chain. This means, that we screen ourown operations and supply chain for any potential environmental and human rights risks in order toprevent or mitigate any violation or risk. For that, we need a combined effort and ask you to fulfil therequirements and expectations for a zero-harm value chain.
In the following we add to the RBA CoC three human rights and environmental requirements, each,and our approach to supply chain due diligence to complement the RBA Section on Management
Systems.

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Human Rights
1) No pollution of soil, water and air, that threatens or harms the livelihoods and health of people
We require our suppliers not to change soil, water and/or air in such a way that it threatens livelihoodsor harms the health of people. Consequences that can result from such negative alteration are:1) Threat to the natural conditions for the preservation and production of food.
2) Denying a person’s access to safe and clean drinking water.
3) Make it difficult for a person to access sanitary facilities. Any groundwater contamination or
the withdrawal of excessive amounts of water that threatens the access to sanitation.
Further info: While this human right, as categorised by the German Supply Chain Act, is often
understood as an environmental right, the emphasis here is on the adverse impact on people’s
livelihoods and health. Therefore, it is formally a human right.

2) No unlawful eviction and deprivation of land
We require our suppliers to prohibit any unlawful eviction, illegal taking of lands, forests or waters in
its business operations or development. In any situation, ebm-papst suppliers should ensure that the
livelihood of a person is secured when conducting any business operation.
Further info: In a situation of wanting to acquire new operational sites for business purposes and theforeseen land is inhibited by, for example, indigenous people, then we expect you to follow the
principle of free, prior and informed consent (FPIC). It is a key principle within the United Nations
Declaration on the Rights of Indigenous Peoples and ILO No. 169, and stipulates the right that pertains
to indigenous peoples to give, withdraw or withhold consent to a corporate project that may affecttheir territories and thereby their livelihoods. Furthermore, the principle of FPIC enables them tonegotiate the conditions under which the project will be designed, implemented, monitored andevaluated.

3) No misuse of security forces
We require our suppliers who would like to protect their businesses with public or private security
forces to ensure that these are well trained and maintain high levels of technical and professional
proficiency. An ebm-papst supplier should not use private or public security forces if the security force
poses a threat to peoples’ health or their lives by applying torture or cruel, inhuman or degrading
treatment. The security force shall also not impair the employees’ right to freedom of association.
Further info: For a human rights approach when screening, selecting, hiring and engaging security
forces, we encourage you to follow the Voluntary Principles on Security & Human Rights.

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Environment1) No production of products containing mercury and no use of mercury
We require our suppliers to refrain from manufacturing products containing mercury and from using
mercury and all mercury compounds in manufacturing processes.
Further info: Further information can be found in the Minamata Convention on Mercury.

2) No production and use of hazardous chemicals; environmentally sound handling, storage
and disposal of chemicals
We require our suppliers to respect the prohibition of production and use of hazardous chemicals thatpose a hazard if released to the environment. Chemicals and other related materials posing a hazard
if released to the environment should be identified and managed to ensure their safe handling andmovement. All suppliers should comply with product safety regulations and prohibit nonenvironmentally sound handling, collection, storage, recycling, reuse and disposal of waste thereof.
Further info: Hazardous chemicals, also named persistent organic pollutants (POPs) according to the
Stockholm Convention are listed on following site:
https://chm.pops.int/TheConvention/ThePOPs/ListingofPOPs/tabid/2509/Default.aspx .

3) No export and import of hazardous waste
We require our suppliers to adhere to all trading rules regarding the handling, processing and shipmentof hazardous waste. Particular attention should be paid to the prohibition of thereof.
Further info: Further information can be found in the Basel Convention.

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Management Systems
In addition to the scope as mentioned in the RBA - legal compliance, environmental, health and safety
and labor practice and ethics – the above-mentioned risks under Human Right and Environment areadded to the scope and are relevant across all Management Systems’ elements.
We conduct a yearly risk analysis to screen our supply chain for any potential environmental or humanrights related risk. In case of risk identification, we evaluate and prioritise risks. For prioritised risks wederive preventive measures and for violations we derive corrective measures. In the case of
substantiated knowledge or substantial change of risk in the supply chain due to a new business,
product, material, etc., we conduct an event-based risk analysis also deeper in the supply chain beyondtier-1 if needed. To derive adequate measures, we are constantly willing to co-operate with our
suppliers.
In addition to the information on RBA element 8 “Worker Feedback, Participation and Grievance”, we
expect the supplier to inform its employees and suppliers about our established Incident Reporting
System “BKMS”, which is provided by an external independent platform provider. Via this platform any
stakeholder can make a complaint or hint to any risk or actual violation subject to the RBA and Annex– anonymously if preferred.

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LkSG and International Law

HUMAN RIGHTS (HR) and ENVIRONMENT (E)

DE
LAW
DE
LkSG
§1. (2)1.
§1. (2)2.

Type

Content

HR

No Child Employment/LabourHR

No Worst Forms of Child LaborHR

No Forced Labour§1. (2)
3.

HR

No Slavery§1. (2)
4.

HR

Occupational Health and Safety

HR

Freedom of Association§1. (2)5.
§1. (2)
6.

HR

No Discrimination in Employment§1. (2)7.

HRAdequate Wage/RemunerationHR

No Environmental Degradation: Harmful
Soil change, Water or Air Pollution,
Harmful Emissions or Excessive Water
Consumption§1. (2)8.
§1. (2)
9.

HR

No Unlawful Eviction or Deprivation ofLand, Forests and Waters
No Unlawful Use of Security ForceHR
E§1. (2)10.
§1. (2)11.
§1. (3)1.-3.

No Manufacturing, Using, Treating
Mercury

INTERNATIONAL LAW
Legal BasisILO Convention No. 138
ILO Convention No. 182;
Convention on the Rights of the Child
Art. 32;
International Covenant on Economic,
Social and Cultural Rights Art. 10
ILO Convention No. 29;
International Covenant on Civil andPolitical Rights Art. 8
Universal Declaration of Human Rights
Art. 4;
International Covenant on Civil andPolitical Rights Art. 8
International Covenant on Economic,
Social and Cultural Rights Art. 7
Universal Declaration of Human Rights
Art. 20;
International Covenant on Civil andPolitical Rights Art. 21, 22;International Covenant on Economic,
Social and Cultural Rights Art 8;
ILO Convention No. 87, 98
ILO Convention No. 100, 111;
International Covenant on Economic,
Social and Cultural Rights Art. 7
International Covenant on Economic,
Social and Cultural Rights Art. 7
Universal Declaration of Human Rights
Art. 3;
International Covenant on Civil andPolitical Rights Art. 5;
International Covenant on Economic,
Social and Cultural Rights Art. 12International Covenant on Economic,
Social and Cultural Rights Art. 11
Universal Declaration of Human Rights
Art. 3
Minamata Convention on Mercury
Art. 4 Sect. 1, Annex A Part I;

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E

No Producing and Using Harmful
Chemicals§1. (3)
4.

E

No Non-Environmental Way of Handling,
Collecting, Storing and Disposal of Waste§1. (3)
5.

E

No Export and Import of Hazardous
Waste§1. (3)6.-8.

Art. 5 Sect. 2, Annex B Part I;
Art. 3
Stockholm Convention on Persistent
Organic Pollutants (POPs Convention)
Art. 3 Sect. 1 (a), Annex A
Stockholm Convention on Persistent
Organic Pollutants (POPs Convention)
Art. 6, Sect. 1 (d) (i) & (ii)Basel Convention on the Control ofTransboundary Movements ofHazardous Wastes and their Disposal
Art. 1, 2 & 4

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Legal and Other Relevant Sources
Guidelines
UN Guiding Principles on Business and Human Rights
DE National Action Plan
OECD Guidelines for Multinational Enterprises

Treaties and related
Universal Declaration of Human Rights
Declaration on the Rights of Persons Belonging to National or Ethnic, Religious and Linguistic
Minorities
Declaration on the Rights of Indigenous Peoples

International Covenant on Civil and Political Rights
International Covenant on Civil and Political Rights
International Covenant on Economic, Social and Cultural Rights
Convention on the Rights of the ChildInternational Convention on the Elimination of All Forms of Racial Discrimination
Convention on the Elimination of All Forms of Discrimination Against Women
Convention on the Rights of Persons with Disabilities
ILO Declaration on Fundamental Principles and Rights at WorkILO Tripartite declaration of principles concerning multinational enterprises and social policy
ILO core convention: Freedom of Association and Protection of the Right to Organise Convention,
1948 (No. 87)
ILO core convention: Right to Organise and Collective Bargaining Convention, 1949 (No. 98)
ILO core convention: Forced Labour Convention, 1930 (No. 29) and its 2014 Protocol
ILO core convention: Abolition of Forced Labour Convention, 1957 (No. 105)
ILO core convention: Minimum Age Convention, 1973 (No. 138)
ILO core convention: Worst Forms of Child Labour Convention, 1999 (No. 182)
ILO core convention: Equal Remuneration Convention, 1951 (No. 100)
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ILO core convention: Discrimination (Employment and Occupation) Convention, 1958 (No. 111)
ILO core convention: Occupational Safety and Health Convention, 1981 (No. 155)
ILO core convention: Employment and Service Convention, 1948 (No. 88)
ILO core convention: Minimum Wage Fixing Convention, 1970 (No.131)
Minamata Convention on Mercury
Stockholm Convention on Persistent Organic Pollutants (POPs Convention)
Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their
DisposalResponsible Business Alliance Code of Conduct – Annex
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