Primo GmbH is committed to ecologically and socially responsible corporate management. We expect the same behaviour from all our suppliers. We also expect our team players to observe the principles of ecological, social and ethical responsibility and to integrate them into our corporate culture. With the goal always in mind, we are continuously working to optimise our business processes and products in terms of sustainability and we encourage our suppliers to contribute in the spirit of a holistic approach. This Supplier Code of Conduct (“ScoC”) defines the minimum requirements that Primo expects from its suppliers and that must be met in their business operations. This agreement shall serve as the basis for all future deliveries and shall come into force upon signing. Violation of this code may result in us terminating the business relationship, including all related supply contracts.

This “Supplier Code of Conduct” is based on the following internationally recognised standards and agreements:

• UN Global Compact
• International Charter of Human Rights, including the relevant rights under the UN Covenant on Civil and Political Rights
• UN Guiding Principles on Business and Human Rights
• UN Convention on the Rights of the Child
• UN Convention on the Rights of Women
• Core labour standards of the International Labour Organisation (ILO)
• National Plan of Action on Business and Human Rights (Germany)
• OECD Guidelines for Multinational Enterprises
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
• Paris Agreement on climate change
• Minamata Convention
• Basel Convention

We do not tolerate any form of forced or slave labour. All employment relationships must be entered into voluntarily and employees must be allowed to quit their jobs at any time. Any form of abuse, such as psychological violence or sexual and personal harassment, is unacceptable and intolerable.

Child labour is not allowed at any stage of production. Our suppliers are obliged to comply with the recommendation of the ILO Convention on the minimum age of employment for children. Accordingly, the age must not be less than the age at which compulsory education ends and must not be less than 15 years in any case. If children are found at work, the supplier must document the measures to be taken to remedy the situation and enable the children to attend school. The rights of young employees must be protected and special protection regulations must be complied with. Children and adolescents under the age of 18 must not be exposed to any activity that is harmful to their health, safety or morals by its nature or circumstances. They may not use, trade or provide any illegal activities (including buying and selling drugs or prostitution, the production of pornographic contents or sexually explicit performances).

No team player may be discriminated against in any way. This relates to discrimination based on gender, race, caste, colour, disability, political conviction, origin, religion, age, pregnancy or sexual orientation. Respect for the dignity, privacy and personal rights of each individual is mandatory.

Working hours must comply with legal requirements or industry standards. Remuneration for regular working hours and overtime must be at least equal to the national statutory minimum wage or industry minimum standards, whichever sum is greater. Overtime must be remunerated at a correspondingly higher rate. If the wages or salary are not sufficient to cover the costs of ordinary living expenses and to build up a minimum of reserves, the supplier is obliged to increase the income accordingly. The team players should receive all the benefits stipulated by law. The supplier must ensure that the team players receive clear, detailed and regular written information on the composition of their remuneration.

All team players have the right to join and form trade unions, to conduct collective bargaining and to exercise collective rights (e.g. freedom of association, right to collective bargaining, right to strike). The exercising of these rights must not lead to discrimination or retaliation against employees.

Suppliers must ensure a safe and healthy working environment. They are obliged to take the necessary measures to prevent damage to health and accidents. These measures should at least comply with the applicable national regulations. In addition, possibilities should be sought to continuously improve health and safety measures at the workplace.

Care must be taken to ensure that business activities do not have harmful effects on soil, water, air or water consumption that significantly affect the natural principles of food preservation and production. Furthermore, they must not endanger human health or prevent access to clean drinking water.

Primo requires suppliers to set targets and take measures to minimise harmful emissions, greenhouse gas emissions and energy consumption.

Our suppliers strive to increase the resource efficiency of the materials used and to keep the environmental impact of their business activities as low as possible. Appropriate efforts should be made to reduce the amount of waste or wastewater generated and to reduce restrictions (e.g. through recycling and reuse of materials). These measures are aimed at achieving circularity.

The standards of fair business, fair trade, fair advertising and fair competition must be complied with. In addition, the applicable anti-trust laws must be observed, which prohibit special agreements and other activities in dealing with competitors that could affect prices or conditions. In addition, these rules prohibit collusion between customers and suppliers aimed at restricting customers’ autonomy in setting their prices and other conditions for resale.

All suppliers and their team players must behave in such a way that there is no personal dependence, obligation or influence. Suppliers are obliged to base their decisions solely on facts and not to be influenced by personal or private financial interests. We expect business conduct based on fairness and respect for applicable national and international standards, based on regulations.

The supplier follows a systematic approach to the identification, handling, reduction and responsible recycling or disposal of solid waste. Chemicals or other materials that pose a hazard when released into the environment must be identified and handled in such a way as to ensure safety during the handling, transport, storage, use, recycling or reuse and disposal of such substances. In addition, suppliers must comply with the prohibitions on the export and import of hazardous waste within the meaning of the Basel Convention.

The supplier undertakes to meet the reasonable expectations of its clients, suppliers, customers, consumers and employees with regard to the protection of personal data. Any unauthorised use of trademarks, drawings and models is prohibited. Our suppliers must ensure that the goods, technologies and services intended for delivery are not counterfeits and that they do not infringe any copyright, trademark, patent or other intellectual property rights. Suppliers must comply with data protection and information security laws as well as official regulations when collecting, storing, processing and transmitting personal data.

Intellectual property rights must be respected. The transfer of technology and know-how must take place in such a way that intellectual property rights and customer information are protected.