CODE OF CONDUCT

Introduction – Our Responsible Procurement Strategy

InCase embraces its role as a responsible corporate citizen. This comes with commitment to the highest standards of human and labor rights, environmental protection, and ethical conduct. As part of our efforts, we expect all our suppliers to comply with our Supplier Code of Conduct, which is based on the 10 principles of the UN Global Compact. The Universal Declaration of Human Rights, International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, and the German Supply Chain Due Diligence Act (2021) form an essential foundation of our Supplier Code of Conduct.

Implementation

This Supplier Code of Conduct forms the basis for our entire value chain. We closely work with our suppliers to ensure that this Supplier Code of Conduct is upheld throughout the entire value chain. Our primary means of ensuring compliance is self-declaration. However, we reserve the right to prescribe external audits or in-person factory visits by an InCase representative if any indication of non-compliance is detected. In such case, we aim to collaborate with the supplier to take corrective action. We reserve the right to terminate our business relationship in case of intentional provision of false information or denial to implement corrective action. Costs associated with the compliance of this Code of Conduct must be borne by the supplier.

Human and Labor Rights & Health and Safety

Our suppliers shall respect human and labor rights and shall provide a healthy, safe, and secure working environment as set out in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. This includes:

Elimination of forced labor: Our suppliers commit to a zero tolerance to forced labor policy and shall refrain from use of forced and compulsory labor as well as forms of modern slavery and human trafficking. No bonded labor or involuntary prison labor is tolerated. Suppliers must ensure to take steps accordingly to ensure that no form of forced labor is used within their business operations and within their supply chains.
Prohibition of child labor and protection of juvenile workers: The exploitation of children under the age of 15 and their employment (child labor) in the whole supply chain is prohibited. Should the national statutes impose a higher age, this shall apply. Young employees under 18 years of age should not work overtime or nightshifts. Work undertaken by employees under the age of 18 shall not curtail their educational, mental, social, or health/physical development.
Fair remuneration: The remuneration for regular work hours and overtime should correspond at the very least to the legally guaranteed minimum. Unauthorized deductions in remuneration as well as deductions in remuneration as a disciplinary measure are forbidden.
Fair working hours: Our suppliers commit to ensure that working hours shall be in line with the current, national statutes and industry standards, of which the strictest regulations shall apply. Overtime must be worked on a voluntary basis and may not exceed the limit set by statutory requirements. Every employee shall have the right to at least one free day after six successive working days. Sufficient breaks shall be arranged so that the accidents at work resulting from physical and mental fatigue can be prevented
Granting freedom of association and the right to collective negotiations: Our suppliers respect the right of the employees to establish organizations of their choice, to join them and to conduct collective negotiations. In situations where the rights to freedom of association and collective negotiations are limited by law, other opportunities must be granted for the independent and free union of the employees for collective negotiation. Workers’ representatives are to be protected against discrimination and need be granted free access to the workplaces of their colleagues to being able to exercise their rights in a legal and peaceful manner.
Prohibition of discrimination: Our suppliers ensure ensures that their employees and those of their supply chain stakeholders have the right to equal treatment and the same opportunities. Any discrimination on the grounds of gender, age, religion, philosophy, social background, health status, disability, ethnic and national origin, nationality, membership of employee organizations including unions, political ethos, sexual orientation, or due to any other personal characteristics, for example with regards to employment, wages, access to further training, promotion, ending of the employment relationship or retirement, shall be prohibited.
Establishment of a complaint mechanism: Our suppliers commit to implement a complaint mechanism for their employees to allow for open communication on grievances between workers and management. Our suppliers assure that the use of such complaint mechanism will not jeopardize the worker’s employment.
Ensuring occupational health and safety: Our suppliers guarantee health and safety in the workplace for their own employees and expect the same for all employees of companies in their supply chain. This specifically refers to the work equipment, to working with chemical or biological substances, and to the safety requirements (especially regarding fire incidents) of the factory premises. Rules and procedures to ensure health and safety are to be introduced and communicated to the employees for preventing accidents and injuries during work. All applicable provisions relating to occupational health and safety are to be complied with. Furthermore, a process enabling the continuous reduction of work-related health hazards and improvement of occupational health, safety and fire safety is to be established and maintained

Environment

Our suppliers shall minimize their impact on the environment and natural resources. Beyond this, we expect suppliers to continuously work towards establishing improved environmentally friendly measures by working towards the implementation of an internationally recognized environmental management system such as ISO 14001 or EMAS. This includes:

Treatment and discharge of industrial wastewater: Our suppliers ensure that wastewater is managed in a way that it respects the environment and goes beyond preserving local water sources.
Dealing with air emissions: Our suppliers shall reduce their greenhouse gas emissions through the use of green energy and conservation, where possible.
Dealing with wastes and hazardous substances: Our suppliers shall ensure that waste is managed in a way that it does not lead to environmental pollution and does not pose a danger to people who interact with waste materials, whilst they transported, stored, used, recycled, reused, or disposed of.
Reducing consumption of raw materials and natural resources: Our suppliers shall quantify and set targets to reduce raw material use, including water and energy. To reduce the usage of virgin materials, suppliers shall engage in economizing, for example, recycling and reusing materials, where possible.
Dealing with energy consumption and efficiency: Our suppliers shall monitor energy consumption and devise strategies to minimize energy consumption.
No unlawful forced evictions and land dispossessions: Our suppliers assure that no unlawful forced eviction, unlawful deprivation of forests, lands, and water take place in their operational business and within their supply chains.

Business Ethics

Our suppliers shall operate under a code of business ethics that respects all applicable laws, rules, and regulations. This includes:

Fair competition: Our suppliers must comply with applicable laws on competition, fair trading, and advertising.
Privacy / data security: Our suppliers must comply with applicable laws on data protection and information security concerning the collection, storage, processing, transmission, and transfer of personal data.
Intellectual Property: Our suppliers must comply with intellectual property rights and may not use InCase’s intellectual property rights for any other purposes other than those authorized by InCase.
Integrity / Corruption, personal gains: Our suppliers and stakeholders along their supply chain shall not practice or tolerate any form of corruption, extortion, or embezzlement. They do not offer or accept bribes or other unlawful incentives to/from their business partners. Measures for implementing these principles are in place.
Dealing with conflict minerals: Our suppliers shall comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This concerns the conflict minerals tin, tungsten, tantalum, and gold and is also extended to cobalt.