CODE OF CONDUCT AND ETHICS OF MMC HARTMETALL GMBH

Preamble

As a subsidiary of Mitsubishi Materials Corporation, we (MMC Hartmetall GmbH) share a common vision with our parent company and strive to become the leading business group committed to creating a sustainable world through materials innovation with use of our unique and distinctive technologies for People, Society and the Earth.

In doing so, we are guided primarily by our common values:

Our vision and values are supported by our Code of Conduct which is based on the Code of Conduct of the Mitsubishi Materials Corporation and company-own concepts as well as guided by international guidelines.

We do not only demand ourselves to meet these requirements and act accordingly, but also ask our business partners to act in conformity with these standards.

International Guidelines

• General declaration of human rights and the associated UN conventions
• OECD Guidelines for multinational enterprises
• UN "Global Compact" initiative

Our Code of Conduct

1. Respect Human Rights

We recognize, respect, and uphold the rights of every human being and always act in accordance with the United Nations‘ “Universal Declara-tion of Human Rights“. We see diversity as the key to success. For this reason, we also reject any discrimination based on age, gender, ethnic or social affiliation, nationality, religion and belief, disability, or any other personal characteristics.
We expect our business partners to observe human rights and respect every human being.

1.1. Child Labour/Forced Labour

We are clearly against any form of child labor (International labor organisation [ILO] Convention No 138, Article 2.4 to be considered [minimum age]) and disprize any kind of forced labour.
Should the legislation of a country prescribe a higher minimum age, this shall apply.

2. Safety First

We are committed to providing a safe and healthy working environment for all of our stakeholders. The employees are provided with a safe working environment and a clean workplace. In order to ensure continuous safety, risk areas must be identified, evaluated and controlled. If employees are required to wear protective equipment, the instructions for wearing it must be followed. The same applies to the use of work equipment.
The health and well-being of every employee is always our highest priority.

3. Compliance

In our business activities and in our role as a responsible employer, we will comply with all laws and regulations and act fairly and in good faith. Confidentiality and honesty in all our activities is very important to us. We value fair and free competition (ban on cartels) and expect our business partners to share our values.
We stand for an open and transparent exchange with our business partners.
Whereby the protection of intellectual property and compliance with the general data protection regulation is elementary for us.

3.1. Prohibition of corruption

We reject corruption and bribery in any form. Conflicts of interest must also be avoided. The personal interests of an individual are undesirable in a business relationship.
Gifts or the like, which are only given as gifts to guests, may not exceed local customs and the law.

3.2. Money Laundering

We do not engage in money laundering, nor are we in any way involved in it.

3.3. Employee’s rights

We respect the rights of our employees and make it to our business to always ensure good working conditions. We also promote the skills of our employees through training and further education.

3.3.1. Fair wages

All employees receive fair wages that at least correspond to the legal standard; this implies regular and punctual payment.

3.3.2. Working Hours

The working hours comply with the respective legal regulations in all countries in which the company is represented.
All employees have at least the legal right to paid vacation, as well as corresponding rest periods and similar.

3.3.3. Collective Bargaining Law

The collective bargaining law is respected. It is up to each employee to decide whether to join a labor union of his or her choice. Employees who decide to become part of a labor union may not be disadvantaged as a result of their decision.

3.4. Whistleblower protection

It is important to us that employees and third parties can draw our attention to grievances without having to fear negative consequences. We have set up an independent Contact Point for the confidential receipt of information about violations of the above-mentioned values and other legal, social and ethical standards. After receiving and examining the information, appropriate follow-up measures will be initiated.

For further information on the Whistleblowing System visit www.mmc-carbide.com/eu/company/csr/whistleblowingsystem

4. Mutual Prosperity

We will contribute to the development of each region and build a harmonious relationship with local communities so that all parties involved benefit.

5. Environmental Management

We work to minimise our company’s impact on the environment and promote the effective use of natural resources and recycling.

We are committed to using natural resources competently and to complying with all legal environmental requirements. We strive to continuously improve our processes and contribute to an ecological, sustainable, and low-emission development.

Dangerous goods and chemicals must be labelled as such and properly stored, recycled, reused, or disposed of in accordance with the regulations.

This Code of Conduct does not replace or relativise any applicable laws. The legal requirements always take precedence. However, if the Code of Conduct is more far-reaching and sets higher requirements, the Code of Conduct takes precedence.