Compliance Management System

Code of Conduct

For Wehrhahn GmbH, compliance means observing applicable laws, ethical principles and the requirements of our self-imposed compliance culture.
Compliance does not only apply to Wehrhahn GmbH and its management. In addition to management, compliance also applies to our employees, customers, shareholders, competitors and suppliers, and is based on our own defined compliance culture.

Compliance-Culture

1. Corporate purpose, visions, corporate philosophy

Corporate purpose
Flexibility is the foundation of our company, and so we have constantly evolved: At the end of the 19th century, we produced brickworks machinery, sawmills and grain mills, and today Wehrhahn GmbH is a global player in demand by the world's leading fibre cement and autoclaved aerated concrete manufacturers as a leading plant manufacturer.

Our resources make us unique: 

Visions
We consider Wehrhahn GmbH as an established market player. We were able to counteract the shortage of skilled workers at an early stage by developing fully automated systems, and we strive to develop and manufacture plants to the highest industry standards. 

Corporate philosophy
The core values of Wehrhahn GmbH are the guiding principles for both management and staff: Cohesion, reliability, sustainability.

Cohesion: All Wehrhahn employees from the Wehrhahn family, complementing each other with their different strengths, skills and weaknesses.

Reliability: We keep our promises – to customers, suppliers and to each other.

Sustainability: There are 4 areas in which our sustainability is evident:

• Plants: Wehrhahn plants are designed and manufactured to be as energy-efficient and durable as possible.
• Customers as partners: Wehrhahn wants to build partnerships with its customers to ensure long-term cooperation. The sharing of experience also services this purpose, as partners exchange ideas and insights.
• Employees: All employees are engaged with a view to long-term employment.
• Suppliers: Wehrhahn treats its suppliers with fairness. We select reliable suppliers on the basis of long-term partnerships.

2. Business ethics, morals and lawful conduct

We share the ideals of fair business behaviour, we claim for ourselves a cosmopolitan outlook and liberal orientation, the reliability of ‘word and handshake’, the creation of the conditions for sustainable honourable conduct at Wehrhahn GmbH, the assumption of responsibility for the economic and social order, and the ‘principle of good faith’. 

Our moral values are characterised by the ethical and moral standards of human behaviour. 
We observe applicable law at all levels (local, national and international) and act with integrity. 

3. Environmental protection, sustainability und human rights

Protecting the environment and people is of high importance at Wehrhahn GmbH; we protect and preserve natural resources and human health, and observe threshold values and social values.
We pay attention to ecological, economic and social aspects to ensure the sustainability of our business activities. 

Compliance rules

Open management culture
We, the management of Wehrhahn GmbH, bear a special responsibility and take our duty of care towards our employees seriously. We regard cohesion and lawful conduct as prerequisites for our success. This requires a high degree of cooperation from every individual employee at Wehrhahn GmbH, but it is indispensable in our corporate culture. Only in this way can we build trust and demonstrate reliability to our customers, business partners and the public.  

Human rights
Respecting human rights is a matter of course for us. We fulfil this obligation throughout our company and along the value-added chain in accordance with our circle of influence in order to protect human and children's rights worldwide. We reject all forms of child labour, forced labour, compulsory labour, slavery and human trafficking. 

Anti-discriminination
We are committed to an inclusive work culture. We believe and recognise that all people should be respected for their individual abilities and contributions. Wehrhahn's goal is to offer all employees challenging, meaningful and rewarding opportunities for personal and professional development, regardless of gender, race, ethnicity, sexual orientation, physical or mental disability, age, pregnancy, religion, veteran status, country of national origin or any other legally protected status.
Discrimination and harassment are not tolerated at Wehrhahn. 

Inducements
Inducements are all benefits that objectively improve the recipient's material or immaterial situation and to which there is no legal entitlement. In addition to monetary inducements, these also include tangible assets or monetary benefits, such as vouchers, free tickets or entrance tickets, invitations with hospitality, free services, discounts, invitations to information or representation trips, and the assumption of business travel expenses by a business partner for events organised by the business partner or a third party (e.g. trade fairs or congresses).

At Wehrhahn GmbH, it is not permitted to request, ask for or accept inducements from a supplier, potential supplier or any other person who may be assumed to wish to gain influence over a business decision or transaction of our company. Any gift from one of the aforementioned persons must be returned, stating this policy. If it is impossible to return the gift, it becomes the property of Wehrhahn. Any offer of a gift must be reported to the management.

Competition
Fair competition and integrity are fundamental to us. We conduct our business activities on the basis of the market economy and free, unhindered competition. We act in accordance with the law and follow ethical principles. Wehrhahn does not enter into any anti-competitive agreements with competitors, suppliers or customers. Wehrhahn GmbH expects the same understanding from its competitors and business partners.

Corruption
Wehrhahn GmbH does not tolerate any form of bribery or corruption. Specifically, we do not tolerate kickbacks or other forms of benefits intended to influence any decision-making. We conduct our business in accordance with all applicable competition and antitrust laws and regulations and avoid all conflicts of interest and situations that could give rise to the appearance of a potential conflict of interest in business transactions. The quality of our plants and our reliability are the basis for the success of our company. 
Corruption can result in heavy fines for Wehrhahn GmbH, which could jeopardise the company's existence and thus harm the entire workforce. In addition, the employees involved may be prosecuted. 

Money laundering (and terrorist financing)
Wehrhahn does not make cash payments and does not accept cash payments. There is no reason to believe that the plants supplied by Wehrhahn are linked to money laundering (or terrorist financing). Nevertheless, the management monitors all transactions with regard to money laundering risks.

Confidentialty
We treat all business matters that come to our attention in the course of our work at Wehrhahn as strictly confidential and take the utmost care when processing and recording this information. We would never disclose confidential information to unauthorised persons or misuse it.

Work safety
We protect the health of every employee and ensure their safety. We are committed to continuously improving working conditions and ensuring job satisfaction among our workforce. Occupational safety is not a minor issue, but requires the cooperation of every employee. Wehrhahn's management team plays a key role in setting an example in this regard.

Data protection
We observe the applicable data protection regulations to protect the privacy of every employee. Personal data is only collected, processed or used if this is legally permitted or if the person concerned has given his or her consent. We are committed to the principles of economical storage of personal data and transparency in data processing. We also protect the personal data of former employees, customers, suppliers and other affected parties. 

Environmental protection
Protecting the environment is society's responsibility and is therefore one of Wehrhahn's corporate tasks. We actively promote environmental protection and conserve natural resources in all countries in which we operate. To this end, we comply with applicable environmental laws and regulations as well as applicable international standards for the protection and preservation of the environment. We systematically evaluate the environmental impact of our business activities in terms of energy, water, waste, chemicals, air pollution and biodiversity, and strive to reduce this impact. This applies both to our headquarters in Delmenhorst and to our products.
Wehrhahn GmbH expects all employees to make an individual contribution to environmentally conscious behaviour. The management plays an important role in setting an example in this regard. 

Protection of property
We protect the expertise and knowledge of Wehrhahn GmbH. 
Company property, whether tangible or intangible, may only be used for business purposes. Employees are obliged to protect company property from loss, theft or misuse and to handle it with care. 

Conflicts of interests
All employees of Wehrhahn GmbH are responsible for avoiding situations and relationships that involve actual or potential conflicts of interest. A conflict of interest is defined as a situation in which a business partner is in a position to derive a specific benefit for themselves from the relationship, actions or decisions of directors, employees or consultants of Wehrhahn GmbH or parties associated with them. Such a relationship may be personal or legal.

A conflict situation may arise if you, as an employee, take actions that are not in the interests of the company or that conflict with your ability to perform your job efficiently. Situations that give the appearance that you are unable to perform your duties impartially and with integrity should be avoided.

Whistleblowing / whistleblowers
Please direct any reports of suspected misconduct to the management. Alternatively, reports can also be made anonymously to the whistleblower reporting office at Wehrhahn GmbH. All reports and related information will be treated as strictly confidential and, if requested, anonymously.

Compliance risks
Any violations of the Code of Conduct can hurt Wehrhahn GmbH's reputation and lead to financial losses for the company, but also to personal liability due to individual misconduct or lack of supervision. In addition to other German legal provisions, §§ 9, 30 and 130 of the Gesetz über Ordnungswidrigkeiten (OWiG may form the basis for such claims. It is the aim of the compliance rules to protect Wehrhahn and every member of the company from making serious and costly mistakes.

Compliance guidelines
The compliance culture at Wehrhahn GmbH, together with the compliance rules, forms the basis and framework for compliance management at Wehrhahn GmbH. These are supplemented by in-depth compliance guidelines with specific risk information for the sectors that are most relevant to Wehrhahn's business model.

September 2025

Prevention of corruption (national and international)

As a German limited liability company (GmbH) in the field of mechanical and plant engineering for high-quality production facilities for the manufacture of building materials, it is our goal to conduct our business activities at the highest level of integrity and transparency at all times. This compliance policy is intended to ensure that all employees, managers and business partners understand and comply with our commitment to preventing and combating corruption.

Scope of application
This policy applies to all employees, managers, contractors, suppliers and business partners of Wehrhahn GmbH, regardless of their position or location.

Definitions
Corruption: Any form of bribery, granting of advantages, embezzlement, fraud or other dishonest acts that compromise the integrity of business relationships or decision-making processes.

Bribery: Offering, promising, granting or demanding benefits in return for an act or omission that violates the duties of an employee, agent or public official.

Principles

1. Zero tolerance policy: We do not tolerate nay form of corruption in our business activities.
2. Transparency: All business relationships and transactions must be transparent and traceable.
3. Fairness: We treat all business partners, customers, employees fairly and impartially.
4. Legality: All our actions must comply with the applicable laws and regulations.

Rules of conduct

1. Gifts and invitations:
   Gifts or invitations exceeding a value of 50 euros require prior approval by the management. Gifts or invitations offered in return for an action or omission are strictly prohibited.
2. Donations and sponsorship:
   All donations or sponsorship activities are determined exclusively by management. Donations or sponsorship activities offered in return for an action or omission are strictly prohibited.
3. Travel expenses and accommodation:
   All travel and accommodation expenses must be reasonable and necessary for business activities. The reimbursement of travel expenses is regulated in the travel policy.
4. Confidentiality:
   All employees, managers and business partners are obliged not to disclose confidential information without authorisation. All employees are also obliged to inform themselves about all valid confidentiality agreements with customers or suppliers and to comply with them accordingly.
   The disclosure of confidential information to third parties requires the prior approval of the management.

Reporting suspected cases of corruption / whistleblower hotline

1. All employees, managers and business partners are obliged to report suspected cases of corruption to the management immediately. Alternatively, reports can also be made anonymously to the Wehrhahn GmbH whistleblower hotline.
2. All reports are treated confidentially and only forwarded to authorised persons.
3. All employees, managers and business partners who report suspected cases of corruption are protected from retaliation.

Sanctions

1. Violations of this policy may result in disciplinary action, up to and including termination without notice.
2. Violations of this policy may also result in legal consequences, particularly in cases of bribery or corruption.
   
   

Review and update
The compliance policy is regularly reviewed and updated to ensure that it meets current requirements and developments and is adapted to changes in applicable laws, regulations or our business practices.

All employees, managers and business partners are informed about the contents and changes to this policy.

Coming into force
This compliance policy shall enter into force on 1 September 2025. All previous policies and regulations shall be replaced by this policy.

Binding nature
This policy is binding for all employees, managers and business partners of Wehrhahn GmbH. By accepting this policy, all parties involved undertake to comply with the principles and rules of conduct contained therein.

Observance of foreign trade law

As a German limited liability company (GmbH) in the field of mechanical and plant engineering for high-quality production plants for the manufacture of building materials, it is our goal to comply with the highest standards in foreign trade law and to fulfil our responsibility towards society. This compliance policy serves as a guideline for our employees and managers to ensure that our business practices and processes are in line with applicable foreign trade regulations.

Legal basis
Foreign Trade Act (AWG): regulates foreign trade, including the export, import, transit and transfer of goods, software and technology.

Foreign Trade Ordinance (AWV): details the provisions of the AWG and regulates licensing requirements, prohibitions and restrictions in foreign trade.

EU sanctions regulations: Implementation of European Union sanctions in the area of the Common Foreign and Security Policy (CFSP).

Responsibilities and duties
All employees are obliged to comply with foreign trade law regulations and to consult the relevant authorities in case of uncertainty. Approval requirements and prohibitions for certain transactions, goods, software and technology must be observed, particularly with regard to sanctions and embargoes.

All managers and project managers are responsible for implementing and monitoring this compliance policy in their respective areas or projects.

Complaints
Any suspicion of a violation of this compliance policy or foreign trade regulations must be reported to management immediately. Alternatively, the complaint can also be made anonymously to the Wehrhahn GmbH whistleblower hotline.

Sanctions and consequences
Violations of the compliance policy or foreign trade regulations may result in disciplinary measures, including termination of employment.

Violations of foreign trade law may result in penalties for Wehrhahn GmbH, its management and its employees, both in the form of fines and imprisonment.

Information
Employees and managers in the dispatch and export departments have access to information systems so that they can keep up to date with the latest developments in foreign trade law.

Review and update
The compliance policy is regularly reviewed and updated to ensure that it meets current requirements and developments and is adapted to changes in applicable laws, regulations or our business practices.

Coming into force
This compliance policy shall enter into force on 1 September 2025. All previous policies and regulations shall be replaced by this policy.

Observance of environmental standards

As a German limited liability company (GmbH) in the field of mechanical and plant engineering for high-quality production plants for the manufacture of building materials, it is our goal to comply with the highest environmental standards and to fulfil our responsibility towards the environment and society. This compliance policy serves as a guideline for our employees and managers to ensure that our business practices and processes are in line with applicable environmental laws and regulations.

Legal basis
Federal Immission Control Act (BImSchG): Regulates protection against harmful environmental impacts caused by air pollution, noise, vibrations and similar processe.

Environmental Damage Act (USchadG): regulates liability for environmental damage and the remediation of contaminated sites.

EU environmental directives: In particular Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control).

Environmental goals and commitments
We are committed to continuously reducing our emissions of air pollutants, noise and other environmental impacts. This applies not only to our headquarters in Delmenhorst, but also in particular to our plant concepts with regard to the manufacture of machines and plant operation.

In doing so, we strive to use resources such as energy, water and materials efficiently and are committed to minimising waste and promoting recycling.

Legal conformity and liability
We undertake to comply with all relevant environmental laws and regulations.

Binding nature and sanctions
This compliance policy is binding for all employees and managers of Wehrhahn GmbH.

Violations of this policy may result in disciplinary action, which will be determined by management on a case-by-case basis.

Review and update
Our compliance policy is regularly reviewed and updated to ensure that it meets current requirements and developments and is adapted to changes in applicable laws, regulations or our business practices.

Sanctions
Violations of this policy may result in disciplinary action, up to and including termination without notice. Violations of this policy may also result in criminal consequences, particularly in cases of bribery or corruption.

Coming into force
This compliance policy shall enter into force on 1 September 2025. All previous policies and regulations shall be replaced by this policy.