Code of Conduct

Preamble

Kloska Group represents worldwide a recognized service partner and supplier of systems for the shipping industry, shipyards, onshore/offshore industries, manufacturing industry, trades, and construction industry.

As an internationally operating family-owned business with a long-standing tradition, Kloska Group stands for a reliable partnership with regard to its customers, employees, and suppliers.

The code of conduct describes the basic values and rules which are binding for all employees of the Kloska Group in their daily assignments, while dealing with their colleagues, customers, and suppliers. This code of conduct purposes that we, as a company and as employees, act in a law-abiding, ethical, and environmentally conscious manner. Every single employee of the Kloska Group also acts as its representative and leaves an imprint on reputation of the company by his/her demeanor, conduct, and behavior.

This code was prepared based on the recognized standards such as the Universal Declaration of Human Rights (UDHR) of the United Nations or the International Labor Organization (ILO). The following principles are based on these standards.

Special rules with regard to laws, statutes, company agreements, internal rules (procedural instructions, security and quality regulations, in particular), etc. remain unaffected.

These regulations are not static but based on changing social conditions will be amended continually.

 

Dealing with Employees, Customers and Business Partners

The dealing with our business partners and customers must be characterized by fairness and honesty. We expect all employees, customers, and business partners to deal with one another in a fair manner, respect mutual rights, and privacy.

Kloska Group maintains long-term customer business relationships, characterized through a sustainable collaboration. As a globally active enterprise we approach our customers, employees, and business partners in a fair and honest manner, as well as with understanding and tolerance. This results in a fair and respectful treatment of the customers and other external persons, who conduct business with the Group.

 

Human Rights

We commit ourselves to the protection and strengthening of human rights in compliance with the international rights. The Kloska Group views, i.a., the following rights as fundamental and universal: Protection against any form of discrimination, be it on basis of race, belief, skin color, nationality, ethnic origin, age, religion, sex, sex transformation, sexual orientation, family status, affiliation to a national minority, disability, or any other status; protection from any form of arbitrary detention, murder or torture; freedom of peaceful assembly and association; freedom of thought, conscience and religion, as well as freedom of opinion and expression.

We do not tolerate forced labor and reject child labor.

The rights of adolescent employees must be protected.

 

Health, Safety and Environment

We strive to create for our employees a healthy and secure work environment. Every single person has a shared responsibility to support the Kloska Group in its attempt to create safer working conditions. We ensure that our employees are regularly informed and trained with respect to health protection and safety norms, as well as safety measures, so that they are in the position of applying these.

We constantly strive to improve our operations, processes and working environment. By setting consequent goals and monitoring the achievement of goals we create the premises for this continuous improvement process. In addition to the economic objectives, we also set goals in the areas of health protection, safety, environment protection, and quality. The Kloska Group companies are under constant obligation to observe the objective of protecting the natural resources for the present and future generations.

It is our goal to deploy energy and natural resources efficiently, avoid pollution of environment, and foster ecological awareness of employees, in order to minimize harmful influences.

 

Fair Competition

It is our desire to develop and maintain long-lasting, trustworthy and mutually respectful business relationships with our customers and partners. Kloska Group is committed, without limitation, to competition using fair means, and is expecting the same from its business partners. Anti-competitive practices, such as the price rigging with competitors, collusions with respect to production outputs, sales, tender processes, resale pricing or market splitting, as well as the abuse of the market-leader position are prohibited.

 

The Foundations of Combating Economic Crime and Corruption

The company's management has assumed a role model function for its employees and has committed itself to a responsible management. All companies included in the Kloska Group are strictly against corruption and bribery and clearly distance themselves from such. A free and fair competition is the foundation of economic trade. All business transactions are processed in an honest and ethical manner. Corruption is understood as abuse of a position of trust, with the goal of attaining a material or immaterial advantage to which no legal claim exists.

With respect to cross-border corruption we adhere to the OECD Convention which came into effect in 1999 and which presents the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. In addition, the Kloska Group companies comply with the United Nations' Convention against Corruption as of October 31, 2003.

 

Conflicts of Interest

A conflict of interest describes the conflict between the private interests of the employee and the interest of the company. A conflict of interest is present when invitations or gifts exceed the usual business-related limits. Potential conflicts must, as a result, be identified as soon as possible. If it is not possible to avoid a conflict of interest, this must be dealt with fairly. A secondary employment may not be assumed if this interferes with the rightful interest of Kloska Group. The details are specified in the regulations contained in the employment agreement.

 

Managing Information, Data Security and Data Protection

All employees commit themselves to an honest, true, and complete exchange of work-related information and knowledge within the company. An exemption applies to data, which is considered confidential. The Kloska Group employees are obligated to contribute, in accordance with the existing guidelines, to the active safeguarding of confidential information in order to prevent unpermitted access by third parties.

Kloska Group undertakes to treat all personal data with utmost care and to protect it from abuse, in order to assure that personal rights are not affected.

 

Adoption and Organization

This code of conduct applies to all Kloska Group offices and business units.

All the Group employees are under obligation to conduct themselves as stated by this code of conduct. Management employees, in particular, are called upon to actively promote its adoption. This includes that it must be ensured that all employees are familiar with the code of conduct and are, as a result, able to apply it in practice.

The Kloska Group will ensure that the direct suppliers are familiar with the regulations of this code of conduct and will demand its compliance from them.

 

Bremen, August 2014