Introduction

Aircraft Cabin Modification GmbH (ACM) places a great deal of importance on ethical, social and ecological responsibility. With this in mind, we are committed to respecting human rights, social standards and ethical behaviour, protecting the environment and resources and complying with global regulations and legislation.

This code of conduct summarises our standards, which are based on the principles of the UN Global Compact, the UN Guiding Principles for Business & Human Rights and the core labour standards of the International Labour Organisation (ILO).We believe that it is part of our global responsibility to work with suppliers who share these values. This code of conduct is intended to form the basis for cooperation. It applies to all the divisions and business operations of our global suppliers.

A.    Compliance with legislation and directives

We expect our suppliers to observe all the applicable legislation and directives in the countries in which they operate or which apply to them.

B.    Social standards

1. Human rights

Our suppliers treat people with dignity and respect. They respect and support the protection of universally recognised human rights and ensure that they are not involved in human rights violations. They counter any negative effects of their operations on the human rights of others by taking remedial action and introducing appropriate measures to prevent, mitigate and, if necessary, repair any damage caused.

2. Prohibition of child labour
The use of child labour is strictly prohibited in accordance with ILO conventions and/or national legislation. A child is anyone who has not yet reached the minimum legal age as stipulated by the labour law of the country in which the work is carried out. If this age is below the minimum legal age stipulated by the ILO, the age limit in the ILO conventions shall prevail.

3. Prohibition of forced labour
ACM demands all employment to be voluntary. Forced labour, slavery or similar involuntary labour and human trafficking are prohibited.

4. Fair pay and working hours
Our suppliers must pay their staff at least the local statutory minimum wage. Any overtime must be remunerated at the statutory rate, which must be at least the agreed hourly rate. Wage deductions for disciplinary reasons are not permitted. 

We expect our suppliers’ working hours to be consistent with the applicable legislation, directives and industry standards.

5. Occupational health and safety
Our suppliers are responsible for providing a safe and healthy working environment. They must ensure that the respective workplace meets the health and safety requirements applicable in the respective country.

ACM expects its suppliers to have or to establish an adequate occupational health and safety management system and to protect the health, safety and wellbeing of their staff, contractors, visitors and anyone else who may be affected by their operations.

6. Freedoms of association and assembly
Our suppliers respect their employees’ freedom to exercise their right of assembly and the right to form associations. The right of employees not to join an association is also accepted.
Recht der Arbeitnehmer zum Nichtbeitritt einer Vereinigung wird akzeptiert. 

7. Equal opportunities, non-discrimination, diversity of opinion
We expect our suppliers to promote diversity and equal opportunities and to respect different opinions. Our suppliers are also expected to promote an inclusive and ethical culture within their companies and not to discriminate against people based on their race, skin colour, gender, religion, political or other views, national or social background, property or other status.

C.    Ethical business conduct

We expect our suppliers to base their business operations on the highest standards of integrity and to pursue a zero-tolerance policy
with regard to any form of bribery, corruption, extortion and embezzlement at all levels.

1. Prohibition of improper benefits
Our suppliers are not allowed to make, offer or promise payments or other (financial) benefits to anyone – either directly or indirectly – in order to obtain an unfair or improper advantage.

This includes both services rendered and promises made to people or institutions in positions of authority (e.g. government officials, public officials, political parties, those applying for public office etc.) and to people or companies from the business world (e.g. customers, suppliers, their agents and representatives) if these are intended to improperly influence decision-makers or gain an unfair advantage.

Such services or promises are prohibited even if the services do not violate any local legislation in the country concerned.

Any payments that are used to accelerate or guarantee standard administrative procedures, such as obtaining a visa or customs formalities (facilitating paymentsfacilitating payments), are also prohibited. Protection payments are only permitted if there is an immediate threat to personal health or safety.

Conversely, our suppliers and/or their staff, or anyone else employed by our suppliers in connection with our business relationship, may not accept or be promised any benefits from third parties that go beyond courtesies, gifts and invitations, to which the clause below applies.

We expect our suppliers to act to the best of their knowledge and understanding to identify and prevent corruption in all their commercial agreements including partnerships, joint ventures, clearing transactions and when using intermediaries such as agents or consultants.

2. Courtesies, gifts and invitations

Our suppliers must ensure that any corporate courtesies, gifts or invitations offered or accepted do not only comply with the statutory and regulatory requirements, but also do not violate the internal compliance regulations or applicable standards of the recipient’s company or organisation. They must also ensure that any courtesies, gifts or invitations are only of insignificant financial value and comply with the standard business practices in the relevant market and industry. If the third party is someone who holds a position of authority (e.g. government and public officials), particular caution must be exercised in the matter of gifts, incentives and invitations – if these are permitted.

Corporate courtesies, gifts and invitations must not be used to create an unfair competitive advantage. It is forbidden to use corporate courtesies, gifts and invitations to positively influence decision-makers. The same applies to giving and receiving gifts, other donations or benefits of any kind.

3. Fraud and deception

We also expect our suppliers to refrain from gaining any unfair advantages by providing or allowing third parties to provide any false or incorrect information about their product, services or anything else related to the planned commercial transaction.

4. Prevention of conflicts of interest

During the course of their business operations, we expect our suppliers to avoid any relationships or activities that impair or may impair their ability to make objective decisions or are likely to damage our trust, or that of our partners, in the supplier’s integrity. If, during the course of their operations related to their business relationship with us, our suppliers or their staff are subject to a possible or actual conflict of interest, they are obliged to notify us of this immediately and to resolve the issue.

5. Fair competition

Our suppliers are obliged to comply with the applicable antitrust legislation, which in particular prohibits them from making agreements with competitors, sharing competitive information (e.g. pricing or terms) or abusing a potentially dominant market position.

We also expect our suppliers to observe the standards of fair competition.

6. Import and export

During the course of their international business operations, our suppliers must ensure that they comply with all the applicable legislation, directives, guidelines and other provisions regarding the import and export of goods, services and information, as well as any applicable embargoes and other sanctions. When applying for an import or export permit, our suppliers must provide the authorities with the correct and truthful information.

7. Handling conflict minerals

With regard to the conflict minerals tin, tungsten, tantalum and gold, as well as other raw materials that may be contained in their products (such as cobalt), suppliers must establish processes in compliance with the guidelines of the Organisation forOrganisation for Economic Cooperation and DevelopmentEconomic Cooperation and Development (OECD) to fulfil their duty of care to promote responsible supply chains for minerals from conflict-torn and high-risk areas, and must require their suppliers to do the same.
Our suppliers are expected to show due diligence in the examination of the origin and supply chain of these conflict resources within the scope of statutory provisions in order to adequately ensure that the materials they use do not directly or indirectly fund or support armed factions that commit serious human rights violations.

Refineries without adequate, audited due diligence processes must be avoided.

8. Intellectual property/counterfeit products

Our suppliers respect and comply with intellectual property legislation. This specifically includes patents, copyright and trademark law as well as protection against unauthorised disclosure of business or company secrets.

Our suppliers are also expected to develop and establish effective processes to ensure that they do not use or circulate any counterfeit parts or materials. If our suppliers have used counterfeit products, they must notify us immediately and remove them from the product concerned, wherever possible.

9. Confidential information/security measures

Our suppliers must handle sensitive information responsibly, including confidential, private and personal data. Information must only be used for the purpose for which it was transmitted unless the owner of the information consents to it being used for a further purpose.

Suppliers are also required to protect the confidential information of others (including personal data) from unauthorised access, destruction, use, alteration and disclosure or misuse by means of adequate physical and electronic security procedures. Suppliers must comply with the applicable data protection legislation. 

10. Money laundering

We expect our suppliers to have an ethical payment policy and to not do business with people or organisations that are involved in criminal or illegal activities. In this regard, we expect our suppliers to comply with the applicable domestic and international money laundering legislation and directives. Cash should be used as little as possible.
einhalten. Bargeld sollte so wenig wie möglich verwendet werden.

11. Insider trading

Our suppliers and their staff must not use any crucial or non-public information that they obtain during the course of their business relationship with ACM to trade in shares or bonds of a company or enable third parties to do the same.

12.  Documentation

Our suppliers must conduct their business transactions transparently and correctly and fully document these in their accounts and records. These accounts and records must comply with and be maintained in accordance with the application legislation and directives.

D.   Environmental protection and ecological sustainability

We expect our suppliers to treat the environment responsibly, to always consider the environmental risks and ecological impact of their business dealings and to align their actions with a sense of responsibility towards the environment.

We expect our suppliers to comply with the environmental legislation and standards applicable to them, to conserve natural resources and use them efficiently and to make every effort to avoid or reduce any negative environmental impacts (e.g. waste and emissions).

Our suppliers must handle hazardous substances responsibly and endeavour to replace these with less hazardous materials.

We expect our suppliers to have or to establish an appropriate environmental management system with which they can actively implement the objectives, endeavours and standards specified here.

E.   Compliance with the ACM code of conduct and verification of compliance

1. Obligation of compliance

Our suppliers must ensure that they comply with the principles listed in this ACM code of conduct. We reserve the right to request information from our suppliers regarding compliance with these principles or to verify that our suppliers comply with these principles.

2. Other parties’ obligation of compliance

Our suppliers are expected to make every effort to ensure that the principles listed in this code of conduct are also forwarded to and complied with by their own staff and everyone involved in their supply chain who directly or indirectly provides products or services for us.

3. Whistleblower protection

Our suppliers are expected to give their staff the opportunity to report any legal or ethical grievances or other issues without fear of reprisal. Our suppliers will not tolerate any discrimination against anyone who reports any violation of the principles listed in this code of conduct.

4. Consequences

If a supplier violates the principles specified here, we will take action based on the severity of the violation. We may, in particular, request remedial action within a given period, make claims for damages or indemnity or even terminate the business relationship immediately.

Version 1.1 / 21st December 2021