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Responsible Conduct

Klöckner & Co takes a holistic approach to responsible conduct. Consequently, although it is defined here as a single action area, responsible conduct may also be regarded as an overarching concept that embraces all other action areas. This is because, for Klöckner & Co, responsible conduct based on ethical convictions paves the way for long-term business success and hence also for sustainability.

Compliance

As an international Group with numerous supplier and customer relationships worldwide, Klöckner & Co aims to ensure integrity and responsibility both within the Company and in interactions with business partners, as well as to establish responsible relationships.

Klöckner expects employees at all levels of the Company, regardless of their hierarchical position, to comply with prevailing competition rules and antitrust laws. The Management Board has unequivocally expressed in its “Tone at the Top” that antitrust violations and corruption are not tolerated at Klöckner & Co and any infringements are systematically pursued. Our employees are provided with a frame of reference and guidance in the form of our Group-wide Code of Conduct together with internal Group guidelines on topics such as adherence to antitrust rules, the engagement of intermediaries and anti-corruption in business dealings.

Classroom training and e-learning programs familiarize new employees with the content of the Code of Conduct and raise awareness of, for instance, compliance-related issues such as antitrust law, corruption risks and fraud. We conduct refresher e-learning sessions throughout the Group to keep our employees up to date and address specific compliance-related issues with examples from their day-to-day work.

Human Rights in the Supply Chain

Klöckner & Co SE and its country organizations ensure ethically correct and compliant behavior in business dealings. This includes prudent and responsible product procurement. As stated in our Code of Conduct and moreover in our internal human rights policy, Klöckner does not tolerate any violation of the principles set out in them under any circumstances.

An important concern for us as distributor is the origin of the minerals incorporated in the products we sell. Of particular interest in this regard are conflict minerals such as columbite tantalite (coltan), cassiterite, gold, wolframite and their derivatives, which include tantalum, tin and tungsten. An in-depth review of our product portfolio in fiscal year 2017 showed that less than 1% of our products possibly contain tantalum, tin or tungsten.

Since the entry into force of the Dodd-Frank Wall Street Reform and Consumer Protection Act and in particular the Conflict Minerals Rule, Klöckner analyzes with due care every year whether conflict minerals are used in the manufacture of the products concerned and, if so, whether they originate from the Democratic Republic of the Congo (DR Congo) or neighboring states. Those neighboring states today comprise Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

If suppliers manufacture components, parts or products using the minerals in question, we require proof that those materials are not sourced from the aforementioned states. For all relevant suppliers, the EICC-GeSI Conflict Minerals Reporting Template is used to systematically track the provenance of conflict minerals. If a supplier fails to comply with the foregoing principles on conflict minerals and proof cannot be provided, the supplier is systematically blocked with regard to further purchases.

We expect our suppliers for their part to formulate and implement conflict minerals policies and principles and to communicate these to their subcontractors. If possible, they should require their downstream providers to adopt and follow corresponding policies and principles. Klöckner expects its suppliers, together with their subcontractors, to trace conflict minerals at least to where they were smelted and to commit to standard reporting processes. Klöckner reserves the right to demand supply chain verification from its suppliers and, where appropriate, to trace conflict minerals back to the mine of origin. We expect our suppliers to retain the relevant documentary proof for five years and to submit it to Klöckner on request.

Alongside observance of applicable laws and human rights, basic principles of Klöckner & Co include the prohibition of child labor and ensuring workforce health and safety, as well as compliance with the statutory minimum wage and working hours. We expect everyone in our supply chain to follow the same principles.

Corporate Citizenship

As a tradition-rich company, Klöckner & Co also regards it as its duty to contribute to the well-being of society. Active involvement in the immediate vicinity of our headquarters and branches is a key aspect and an identity-building factor for our Group.

REGIONAL AID PROJECTS
Joining forces with the Ruhr Piano Festival Foundation, we developed an education project to foster children’s musical and artistic development at different types of schools. This was implemented for the first time with two schools in 2012. No fewer than five schools with over 400 children took part in 2017. Our musical education work has since earned supraregional recognition. In October 2016, the education program garnered the Echo Klassik award presented by Deutsche Phono-Akademie. The prestigious music award was conferred in the Fostering Young Talent category. These and other awards confirm our successful cooperation, which is to remain part of our activities going forward. In addition, Klöckner & Co supports participating schools and a youth center in the provision of healthy meals, the modernization of premises and many other projects in Duisburg’s Marxloh, Germany, district, which has a high proportion of residents with a migrant background.

<p>Gisbert Rühl im Dezember 2015 bei der RiZ Eröffnungsfeier mit dem Oberbürgermeister von Duisburg, Sören Link (Foto Stadt Duisburg)</p>

REFUGEE INTEGRATION
The integration of refugees into our society is another major concern for us. This notably includes creating employment opportunities. One area with an especially large number of vacancies is the IT sector, which often makes it hard for companies to find qualified programmers. To help refugees with IT skills entering the job market, the knowledge they bring with them needs to be enhanced and supplemented in line with the needs of the German labor market in general and our business in particular. Under the umbrella of the “We together” German Industry Integration Initiative, Klöckner & Co therefore supports the ReDI School of Digital Integration in Berlin as main sponsor and provides premises for the project.

ReDI is short for Readiness and Digital Integration. Students are provided with laptops and can take part in free beginners and advanced programming courses. Additionally, students are each assigned a mentor to help them take the course content to a deeper level. Organized networking events make for lively contact with the Berlin start-up scene. We also have our own presence in Berlin with kloeckner.i, our Group Center of Competence for Digitalization, where we are adding to staff numbers on an ongoing basis. When filling new positions, we place special emphasis on recruiting ReDI School graduates. Internships prepare ReDI students for potential permanent employment at kloeckner.i, our digital subsidiary in Berlin.

The German Chancellor, Dr. Angela Merkel, also convinced herself of the success of this collaboration in April 2017 when visiting the ReDI School of Digital Integration in its new premises at kloeckner.i. During her visit, the Chancellor gained an impression of how the highly motivated refugees are learning modern programming languages and techniques, projects that have already been successfully implemented and their next goals going forward. Refugees who have been successfully integrated into companies reported alongside their new employers and colleagues about their daily work and spoke constructively with the Chancellor.

Klöckner & Co also supports a Stifterverband program targeting the integration of refugees through education as part of “Kiron Open Higher Education’s Computer Science study track”. The program aims to offer refugees access to a course of study leading to an accredited bachelor’s degree.

EDUCATION
In Germany, we maintain close contact with the European Business School (EBS) and the University of Duisburg-Essen. As well as high-ranking executives from our Company giving lectures at these two higher education institutions, we also take part in dialog events and answer students’ questions. Furthermore, we offer students internships during which they can apply content from their studies to real business situations.

For some years now, we have supported the Germany Scholarship in collaboration with the German Federal Ministry of Education and Research. Primarily directed at talented and high-achieving college students, the scholarship gives consideration to specific family and social circumstances. Our aim here is to provide support so that students can excel both academically and socially as well as within the family.

Since 2013, we have additionally supported the German National Scholarship awarded by Roland Berger Foundation. This program promotes gifted children with a strong will to learn who come from socially disadvantaged families, with the aim of guaranteeing them the best possible education opportunities and enabling them to complete upper secondary education and/or go on to university. It is our way of helping to remove barriers to equal opportunities among people of different social backgrounds.

Christina Kolbeck
Christina Kolbeck

Head of Investor Relations & Sustainability

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