Business conduct

Responsible conduct is viewed holistically at Klöckner & Co. For us, an integral part of our corporate culture is the rule-compliant behavior of our employees and business partners, which forms the basis for corporate responsibility. Adherence to internationally applicable rules and fair dealings with our business partners and competitors are among the most important principles of our company. In addition to consistent respect for human rights, compliance with the fundamental values and principles of our company is also of central importance to us. We have formulated these in our Code of Conduct. Compliance is the direct responsibility of each and every individual.

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 & Co expects employees at all levels of the Company, regardless of their hierarchical position, to comply with prevailing rules. The Management Board has unequivocally expressed in its "Tone from the Top" that compliance violations are not tolerated at Klöckner & Co and any infringements are systematically pursued.

In this regard, it is a fundamental principle of Klöckner & Co that our employees act in accordance with the applicable competition law. We are committed to free competition and to the recommendations of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. In addition, Klöckner & Co strives to comply with all anti-corruption laws of the countries in which we do business.

The Groupwide Code of Conduct and the Group's internal policies and procedures serve as a reference and guide for our employees. A Groupwide training program, which is mandatory for all employees of the Group, raises awareness of our Code of Conduct.

The training program is divided into various modules appropriate to the target group, which are updated at regular intervals by refresher training courses. The assignment and success monitoring of mandatory training courses is carried out in an IT-supported learning management system. We expect our external business partners to observe the ethical values and principles of our Code of Conduct or Supplier Code of Conduct or an equivalent code of conduct of their own and to implement them effectively in their organization. It is possible to anonymously report indications of possible compliance violations to the Corporate Compliance Office. Employees and third parties can report possible violations of our Code of Conduct on the platform's homepage or via the company's website. In addition, a 24/7 telephone hotline is available free of charge worldwide.