Code of Conduct

1. Purpose and scope

This code sets out the principles by which A1-ESD Equipment GmbH acts. It applies to the management and to all employees of the company. We expect suppliers, service providers and other business partners to observe equivalent standards, as set out in our Supplier Code of Conduct.

This code does not replace statutory provisions. Where applicable law imposes stricter requirements, the law prevails.

2. Compliance with the law

We comply with the laws and regulations of every country in which we operate. No commercial objective justifies a breach of law. Where the permissibility of an action is in doubt, we obtain expert advice before deciding.

3. Human rights and working conditions

We respect internationally recognised human rights and are guided by the core labour standards of the International Labour Organization.

• We reject forced labour, debt bondage and every form of involuntary work (ILO 29 and 105).
• Child labour is excluded. We observe minimum age requirements and the prohibition of the worst forms of child labour (ILO 138 and 182).
• We tolerate no discrimination on grounds of origin, gender, age, religion, belief, disability, sexual identity or political opinion (ILO 100 and 111).
• Harassment, bullying and intimidation have no place in our company.
• We respect freedom of association and the right to collective bargaining (ILO 87 and 98).
• Remuneration and working hours meet at least the statutory and collectively agreed requirements.

4. Occupational health and safety

We design workplaces and processes so that hazards are avoided. Hazardous substances used in soldering and cleaning applications are handled, stored and disposed of in accordance with their safety data sheets. Required protective equipment is provided and used.

5. Integrity and prevention of corruption

We neither grant nor accept benefits capable of improperly influencing business decisions. This applies to private business partners and public officials alike.

• Benefits must not be demanded, offered or accepted where doing so creates any appearance of influence.
• Gifts and hospitality of modest value within the scope of customary business relations are permitted, provided they are transparent and do not exceed 50 euros.
• Benefits of any kind towards public officials are not permitted.
• Donations are made openly, are documented and carry no expectation of return. We make no contributions to political parties.

6. Conflicts of interest

We keep personal interests separate from business decisions. Secondary employment, holdings in competitors, suppliers or customers, and business relations with closely associated persons are disclosed. We do not decide on matters in which we have a personal interest.

7. Fair competition

We compete on merit. Agreements with competitors on prices, terms, customers or territories are excluded. We do not exchange competitively sensitive information. We observe European Union competition law, the German Act against Restraints of Competition and the requirements of the Act against Unfair Competition regarding advertising and price indication.

8. Foreign trade, export control and sanctions

We observe applicable foreign trade law, in particular Regulation (EU) 2021/821 on dual-use items, the German Foreign Trade and Payments Act and Ordinance, and the sanctions and embargo provisions of the European Union and the United Nations.

• Before export, transfer and re-export we check listing of the goods, the end use and the recipient.
• We screen business partners against the relevant sanctions lists.
• We implement contractual obligations against the circumvention of export restrictions towards our customers.
• Where the permissibility of a transaction is in doubt, it is suspended until the assessment is complete.

9. Product safety and conformity

We distribute only products that meet applicable requirements. As a distributor we verify formal conformity, in particular marking, declarations of conformity, instructions in the language of the destination country and the details of the manufacturer and of the responsible person in the Union.

Relevant provisions include Regulation (EU) 2023/988 on general product safety, Directive 2011/65/EU on the restriction of hazardous substances and Regulation (EC) No 1907/2006 (REACH), including the duty to communicate information on substances of very high concern. In the field of ESD protective equipment we follow EN 61340-5-1 and the associated technical report series.

Where we identify a safety risk, we inform manufacturers, customers and the competent authorities without delay.

10. Environment and resources

We meet our registration and take-back obligations under German electrical equipment, packaging and battery legislation. We select shipping packaging according to protective performance and recyclability and avoid unnecessary material use. Our Solingen site is partly supplied by an on-site photovoltaic installation.

11. Data protection and information security

We process personal data in accordance with the General Data Protection Regulation and the German Federal Data Protection Act. We collect only the data required for the respective purpose. Access rights are granted restrictively. Systems are kept up to date, data is backed up regularly and restoration is tested.

We treat the trade and business secrets of our customers and suppliers as confidential, including after the end of the business relationship.

12. Records, taxation and prevention of money laundering

We record business transactions completely, accurately, promptly and in an orderly manner, observing the German principles for the proper keeping and retention of books and records in electronic form. We meet tax obligations on time. We examine unusual payment transactions, in particular cash payments above the statutory thresholds or payments by uninvolved third parties, and decline them in case of doubt.

13. Raising concerns

Anyone with indications of a breach of this code or of applicable law may contact us. The procedure is described under Whistleblowing. Reports are treated confidentially. Those who report in good faith need not fear any disadvantage.

14. Binding effect

This code is binding on all employees. Breaches are investigated and pursued under employment law. We review the code at least annually and whenever circumstances require, and adapt it to changed conditions.

Version: August 2026
A1-ESD Equipment GmbH, Keldersstrasse 15, 42697 Solingen, Germany
Commercial register: Amtsgericht Wuppertal, HRB 29665
Contact: compliance@esd.equipment