Code of Conduct
of the Kaufbeurer Mikrosysteme Wiedemann GmbH


Kaufbeurer Mikrosysteme Wiedemann GmbH (hereafter referred to as "KMW”) is a modern and globally active company, with a long corporate tradition, that has always stood for quality, innovation and performance within the framework of fair competition. The success of KMW is based not only on product quality, but above all on the good reputation of the company, as well as the trust placed in it by its customers, partners and employees.
KMW attaches great importance to responsible business dealings with all customers, suppliers, partners, employees and authorities. KMW conversely expects a trustful cooperation with the entire supply chain: the suppliers, consultants and other providers of goods and services to KMW worldwide, (hereinafter referred to as "business partners" or “partners”).
For the KMW, the observance of social, economic and ecological principles represents the basis of responsible and sustainability-oriented entrepreneurial action. Therefore, KMW requires that its business partners comply with all applicable regional, national and international legal regulations regarding working conditions, health, environmental protection, anti-corruption and safety at work and that they communicate this Code of Conduct to their employees, and monitor its fulfilment. Furthermore, KMW expects its business partners to ensure that their upstream suppliers also comply with all applicable legal requirements.
KMW is expressly committed to the core values of integrity, sustainability, transparency and responsibility in business transactions.
KMW expects its business partners to fully comply with the conditions listed below.

1.    Compliance with laws and regulations, taking cultural values into account.

We expect compliance with, and observance of, applicable laws and regulations.
This obligation naturally also applies to applicable guidelines and directives as well as recognized rules of conduct of the cultural areas and countries in which the business partner and KMW are active.

2.    Respect for human dignity

2.1    Non discrimination

KMW employs people with different ethnic backgrounds and experience. 
KMW expects its business partners to reject discrimination in the recruitment, employment and the provision of training and further education based on race, color, pregnancy, religion, gender, sexual orientation, age, physical or mental disability, health status, political affiliation, nationality, social or ethnic origin, union membership or material status (General Equal Treatment Law).

2.2    Health and Safety

KMW expects its business partners to provide a safe and healthy work environment. This includes protecting employees, customers and the public from injury and damage to their health.
This includes, in particular, appropriate sanitary conditions, health and safety policies and safety procedures.
We expect that appropriate protective equipment will be provided free of charge to all employees where necessary.
Safety-related information regarding hazardous materials must be made available to all employees.
For the event of fire or other emergencies, there must be sufficient and clearly marked emergency exits. Escape routes must be clearly described, kept clear and marked. Fire alarms and fire extinguishers should be located on each floor. All applicable laws on occupational health and safety, hygiene, fire protection and risk protection must be observed and regular training provided.

2.3    Working Hours

KMW expects its business partners not to exceed the maximum number of hours set by law. Exceptions are emergencies and extraordinary circumstances. Workers are entitled to at least one day off in a calendar week, as well as an appropriate annual leave. All applicable laws regarding working hours and vacation must be observed.

2.4    Remuneration

KMW expects its business partners to comply with the applicable regulations on the statutory minimum wage or existing collective agreements and to compensate ordered overtime in accordance with these regulations. Wages must be paid regularly and by legally valid means of payment. Wage deductions as a disciplinary measure are not permitted.

2.5    Prohibition of Child Labor

Child labor and any exploitation of children and young people will not be tolerated by the KMW. The term "child" refers to all persons under the age of 15 (or under the age of 14, depending on national law) or to persons of school age or persons who have not yet reached the minimum age for employment applicable in the respective country. The highest age limit in each case applies. Approved training programs that comply with all laws and regulations are encouraged. Workers under the age of 18 are not permitted to perform work that could jeopardize the health and safety of young workers.
KMW expects its business partners to comply with the prohibition of child labor.

2.6    Rejection of Forced Labor

All forms of forced labor are rejected by the KMW. KMW expects from its business partners that no employee is coerced into employment, directly or indirectly, by force or intimidation.

2.7    Freedom of Association / Trade Unions

KMW expects its business partners to respect the right of employees to freedom of association, freedom of assembly as well as collective bargaining to the extent legally permissible and possible in the respective country.
No employee shall expect retaliation or reprisals if they exercise the aforementioned rights.

3.    Environmental Protection

We expect that all resources, including energy, water and raw materials be used sparingly and efficiently.
The use of renewable raw materials and the development of environmentally friendly packaging by business partners is expected by the KMW.
KMW expects its business partners to comply with the applicable regulations and standards on environmental protection affecting its operations at the respective sites.

3.1    Avoiding pollution and reducing the use of resources

Any form of waste, including water and energy, shall be avoided or at least reduced. Either directly at the point of generation or through procedures and measures such as changing production and maintenance processes or company procedures, the use of alternative materials, savings, recycling and reuse of materials.

3.2    Hazardous Substances

KMW expects its business partners to identify and handle chemicals or other materials that pose a risk to people or the environment in such a way that handling, transport, storage, use, recycling, reuse and disposal are carried out safely and any risk to employees, customers, suppliers and other third parties is excluded. Employees shall be provided with appropriate protective equipment free of charge when handling such substances.

3.3    Restrictions on Product Contents

KMW expects its business partners to comply with all applicable laws, regulations and customer specifications regarding the prohibition or restriction of specific substances. This also includes the labeling obligation for recycling and disposal.

4.    Data Protection and Privacy

The business partner undertakes to ensure compliance with data security and data protection provisions. The partner undertakes to treat all data, documents and other information received in connection with cooperation with the KMW, and any work results, strictly confidential and, in particular, not to make them accessible to unauthorized third parties. Furthermore, the partner undertakes to comply with all national and international data protection laws, in particular the General Data Protection Regulation (GDPR/DSGVO) and with the obligation of the employees to observe data privacy, and as far as applicable within the scope of business activities the provision of business telecommunication services according to § 3 TTDSG (Act on the regulation of data protection and the protection of privacy in telecommunications and telemedia). 
The business partner undertakes to comply with the above provisions also with regard to all employees, subcontractors and third parties involved. These obligations shall continue to exist without restriction after termination of the contract.

5.    Competition and Antitrust Requirements

5.1    Corruption and Bribery

KMW does not tolerate any form of corruption, bribery, graft or other illegal granting of advantages.
The business partners must ensure that no personal dependencies or obligations to customers, suppliers, authorities or other business partners arise from bribes, kickbacks or other illegal payments. All national and international laws in this regard must be complied with.
Care must be taken to ensure that no gifts or invitations are accepted or made that could reasonably be expected to influence business decisions.

5.2    Money Laundering

KMW expects its business partners to comply with the relevant legal obligations for money laundering prevention and to not engage in money laundering activities. 

5.3    Antitrust law

KMW is committed to the social and economic policy model of the social market economy. 
The business partners shall be committed to fair competition. Laws protecting competition, in particular antitrust law, as well as other laws regulating competition must be observed. Inadmissible agreements on prices or other conditions, sales territories or customers as well as an abuse of market power, boycott (e.g. non-supply of a customer) contradict the principles of the KMW. In case of violations by the business partner, KMW expressly reserves all possibilities under criminal and civil law.

6.    Responsible procurement of raw materials

Business partners are required to develop measures to ensure, to the best of their knowledge and belief, that the raw materials used in the products they manufacture (namely diamonds, crude oil, tantalum, tin, tungsten, cassiterite, coltan and gold) are not used directly or indirectly to finance or support armed groups guilty of serious human rights violations in crisis regions as defined in Dodd-Frank Act § 1502.  The Business Partner should exercise due diligence with respect to the origin and chain of supply of such minerals and disclose such due diligence to KMW upon request.

7.    Import and Export Regulations

Business Partners shall comply with all applicable import and export control laws, including but not limited to all sanctions, embargoes, and other laws, regulations, government orders, and directives concerning the transport or shipment of goods and technologies.
Furthermore, the Business Partner agrees to comply with all national and international anti-terrorism laws and not to cooperate with any person and/or organization named on any such list. 

8.    Communication and Obligation to Provide Evidence

The KMW's business partners shall communicate openly about the requirements of this Code of Conduct and its implementation to employees, customers, suppliers, subcontractors and other stakeholders. All documents and records are to be dutifully prepared, not unfairly altered or destroyed, and properly stored.

9.    Compliance with the Code of Conduct of the KMW

KMW is entitled to verify compliance with laws, rules and requirements on a case-by-case basis, upon prior notice and in the presence of a representative of the Business Partner, during regular business hours and in accordance with applicable law.

Kaufbeuren, December 2021

Kaufbeurer Mikrosysteme Wiedemann GmbH
- Management -

Conflict Minerals Policy

This statement is based upon information collected from KMW’s supply chain and manufacturing process.

Section 1502 (“Conflict Minerals Provision”) of the “Dodd-Frank Wall Street Reform and Consumer Protections Act” amends the “Securities Exchange Act of 1934” and is applicable for US-companies having reporting obligations toward the US Securities and Exchange Commission (SEC).

To support our customers KMW is working toward the elimination of conflict minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo (DRC) or adjoining countries from its supply chain.

KMW’s ultimate goal is to have a supply chain that consists of material that is DRC Conflict Free.

As we do not source directly from smelters or mines, we are working closely with our own suppliers to understand the sources of the metals contained in their products, to assure to reach the goal above.

Therefore we will exercise due diligence as specified in the document “Due Diligence Guidance for Responsible Supply chains of Minerals from Conflict-Affected and High Risk Areas (2nd Edition)” from the Organisation for Economic Co-operation and Development (OECD).

Kaufbeuren, January 2018

Kaufbeurer Mikrosysteme Wiedemann GmbH