Scope of appli­cation: KH Boddin Group**
KH Boddin GmbH**
KHB Feed GmbH**
Kapstadtring 7
22297 Hamburg
Germany

Doing the right thing has been one of the top priorities of all KHB employees ever since the company’s foundation.

We acknow­ledge and place great importance on the fact that our success is based on our values, rather than values based on success!

Together, we demons­trate our outstanding expertise in our fields of business, successfully generating additional value for our business partners, employees and owners.

We deliver high-quality products as well as integrated, sustainable, positive services along the entire supply chain – now and in the future!

The solid foundation is formed of the highest ethical standards, the task of making a constructive contri­bution and our connection to each other.
We go beyond compliance obliga­tions and seek to outperform them wherever possible and reasonable.

The secret to our success? We actively use our expertise to implement respon­sible, sustainable and integrative solutions for opera­tional and social tasks.

This can only be achieved with a prono­unced quali­fi­cation of all parties involved in the process, who aim to act respon­sibly, with integrity, compe­tence and self-confi­dence. This is what we stand for.

With this strong set of values as a backing, our appre­ciation for each other, our feeling of well-being with each other, we increase our perfor­mance and never stop improving ourselves.

Why? Because we put our business partners and employees first.

This not only results in success-driven added value for everyone, but also in universal safety that is charac­te­rized by integrity.

Our business is global, which is why concepts such as integrative inter­na­tio­nality, equality, human rights, environ­mental protection, no room for corruption, fairness, respect and compre­hensive tolerance are valued gains and uncom­pro­mising, all-round prere­qui­sites for us.

For everyone at KHB, our Code of Business Ethics is what we live by, what we align with, how we measure success and how we work together, day in and day out.

The Code of Business Ethics is our compass that helps us doing the right thing at all times – in society, mutually each other and in the best interest of the community spirit.
All of this is brought together in our Code of Business Ethics, which is comple­mented by internal measures, training and additional documentation.

As part of our Code of Business Ethics measures, we offer the option of anony­mously reporting concerns with respect to conduct within KHB that may possibly not confirm with our ethical and/or business and/or legal and/or opera­tional and/or other requi­re­ments. Reports received by us will be followed up immediately in a value-oriented and consistent manner, keeping in mind our corporate values. That is important to us!

We are confident that our Code of Business Ethics provides important guidance to act correctly and honestly in all directions.

With this funda­mental conviction, with integrity, ethically flawless conduct and, of course, in compliance with legis­lative requi­re­ments, we conti­nuously improve our perfor­mance – for our employees and in turn also for our business partners.

You have probably noticed already: We are fully committed to the values of our Code of Business Ethics and expect our partners anywhere around the world to uphold funda­mental human rights, legal compliance, environ­mental protection, sustaina­bility, tolerance and respon­si­bility for society.

Together, we can and will make a positive diffe­rence for ourselves and future generations!

- Carsten Nöthe –
Director

Hamburg, 02 September 2022

Imple­mented commercial respon­si­bility for a bright future

We are fulfilling our respon­si­bility to create a better, more efficient and more sustainable company for future generations.

We act with an owner’s mentality by supporting and promoting our employees/colleagues, assessing matters in detail and providing a respon­sible overview in a large context.

We make decisions within our powers on the basis of sound commercial judgement. Risks are only assumed in a respon­sible, appro­priate and sensible manner.

We work with maximum care and ask for assis­tance in cases where it makes sense and/or is necessary to carry out specific and/or high-level reviews.

We spend KHB’s money as if it were our own.

We use resources respon­sibly and do not waste them.

We actively report any waste of natural and financial resources.

Quality matters

Our respon­si­bility to deliver quality and first-class perfor­mance is a top priority for us.

High quality and top perfor­mance are the key elements of a smoothly functioning supply chain = for successful customers who expect us to meet their requi­re­ments with maximum precision.

This is why products, suppliers and service providers are subjected to detailed approval processes at our company before all other steps.

Our quali­tative requi­re­ments profile is quite challenging for suppliers who want to establish themselves with us.
We are tasked with conveying to these potential new partners that it is worth seeking approval in a joint effort, because we under­stand our suppliers as trust­worthy long-term partners.
Secure and sustainable quality and perfor­mance at all levels and at all times is the prere­quisite for satis­factory and high-perfor­mance relati­onships over the long term.

And what is one of the crucial elements in gaining approval?
Compliance with the standards of relevant, certified quality assurance systems, specific quality standards, conformity with environ­mental regula­tions, internal process and requi­rement defini­tions, analyses, expert reports, flow charts and frequently many more….

In this way, we ensure that the requi­re­ments, the appli­cable standards and legis­lative framework condi­tions for goods, packaging, security, desti­nation and perfor­mance are met and good quality is achieved!

Products that do not meet the specified requi­re­ments profile are not eligible for approval from us and therefore cannot be supplied by us.

And because we are aware of the fact that every­thing is constantly evolving and that we are not only keeping up with time, but also conti­nuously improve ourselves, we have our perfor­mance develo­pment and the effec­ti­veness of our systems and processes subjected to independent regular internal and external audits.

Environment / Sustainability

We only have this one planet and the respon­si­bility to protect it, for us who live today as well as for future genera­tions to come after us.

It goes without saying that we consis­t­ently comply with all appli­cable environ­mental laws and relevant environ­mental regulations.

Our rule is: Due to the nature of our business, our primary environ­mental focus is on the products we purchase, transport, store and supply.
They need to be handled in an absolutely appro­priate and safe manner – at any time and anywhere!

The existing national and inter­na­tional, legal, but also transport- and storage-specific requi­re­ments for the products we trade in, their labelling, highly profes­sional supple­mentary customer requi­re­ments, offer clear and strict speci­fi­ca­tions that create reliability.

We successfully meet these requi­re­ments on the basis of our conviction and expertise!

One thing is self-evident: We commission trans­ports in such a way that they deliver the best possible combi­nation of adherence to deadlines and low emissions.

Our concern for a protected environment becomes even more relevant by including the relevant preli­minary products, production facilities and production condi­tions in the overall view.

The end goal is the highest possible sustaina­bility on the part of our company and our business partners, because in the end we all have to live together and preserve the one planet we share.

Compliance in trade / conformity / intellectual property

We comply with all appli­cable inter­na­tional trade controls, including economic sanctions and export controls, and review all business oppor­tu­nities to ensure compliance.

Because inter­na­tional trade controls may change over time, it is our respon­si­bility to be aware of the current policies and ensure compliance with them.

In this context, we ensure that the specialist depart­ments master, observe and maintain/develop the existing level of training, documen­tation, subject-specific and systemic knowledge.

This is the respon­si­bility of the relevant organi­sa­tional units (if necessary with further technical/internal/external resource requi­re­ments on the part of the specialist segments), as they are the specia­lists of processes and therefore of requirements.

We strictly and without compromise oppose the purchasing and use of counterfeit parts, as well infrin­ge­ments of intellectual property (including patents etc.) and will immediately report any infrin­ge­ments detected by us.

Tough and fair in competition

We do not enter into agree­ments with compe­titors on the prices, condi­tions attached to our goods and services, or the location of our current and future services.

Similarly, we do not parti­cipate in any way in practices that appear, even in the slightest, to represent conduct that amounts to unfair compe­tition / cartels.

If other market parti­ci­pants approach us with prohi­bited requests, we will take a crystal-clear stance as soon as possible and insist that we do not wish to be supplied with relevant infor­mation and are unwilling to supply the same.

We expressly object and will immediately terminate (including in cases of doubt) the relati­onship with the party exhibiting objec­tionable conduct and contact the superiors straight away.

All employees of KHB are obliged to behave in this way, no exemp­tions made!

We fully rely on our own expertise in developing our business.

Anti-Money Laundering / Bribery / Corruption

We, the employees of KHB, do not engage in money laundering or terrorist financing, nor do we pay or accept any bribes (whether financial, non-financial or immaterial). All forms of active or passive corruption are banned at KHB.

It is self-evident that we do not support any other parties / third parties in these activities!

We actively and promptly pass on any detected warning indicators for inves­ti­gation and, where necessary, report any suspi­cious activity to official authorities.

We are imple­menting a strict zero tolerance policy!

Respect for the individual person

KHB condemns and does not tolerate disre­spectful behaviour or harassment of any kind.

The question whether the disre­spectful conduct or harassment was inten­tional is not always the autho­ri­tative point.

Harassment based on personal charac­te­ristics - known as protected charac­te­ristics - is illegal in many jurisdictions.

Even disre­spectful behaviour is illegal or punis­hable in many jurisdictions.

The ethical values of KHB go far beyond the legal requirements.

At KHB, we aim for a working environment that is free from disre­spectful behaviour or harassment, regardless of whether the behaviour is sanctioned by law or not.

What matters is how the behaviour is understood by the affected person.

Disre­spectful behaviour and harassment takes many forms and are met with zero tolerance at KHB.

Every instance is reported immediately!

Contri­buting our opinion / insights

We share our opinion – we get ourselves actively involved!

At KHB, we value dialogue, exchange and knowledge – in personal conver­sa­tions, discus­sions on specialist level and also across all organi­sa­tional levels!

Constructive, open friction is crucial for avoiding a standstill, and for reaching our common goals of “being the best we can, always”.

A crucial element is to under­stand the voices, opinions and insights from all the company’s role models – because everyone has an important role to play!

Only in this way can we see what we should “tackle” and thereby lift our game even further.

We take advantage of our company’s flat hierar­chies that allow contact persons to directly familiarise themselves with requests.
We are committed to taking each other seriously, we value the opinions of our counterpart, and we count on dialogue because we know that it will lead us to the goal!

Well, there might be a few excep­tions, i.e. things that are suppo­sedly more difficult to communicate.
But we also solve these issues together, because we can also address such concerns and infor­mation at any time, without fear of retaliation – also anony­mously via the internal whist­le­b­lower box.

For anonymous external comments, write to: violi[at]khboddin.com

If reports are made anony­mously, it is important to ensure that the issue is made as clear as possible, because follow up questions cannot be asked in the case of an anonymous report.
We expressly emphasise: KHB endorses a policy of zero tolerance for retaliation against anyone who raises their concerns in good faith.
Retaliation means any kind of unfair treatment, whether subtle or obvious.

Equal oppor­tu­nities / equality / no discrimination

As an inter­na­tional company, we enjoy working together internally and externally with people from different regions / cultures of the world, and we do so with great pleasure and success.
We gratefully perceive this as a stimu­lating personal, multi-faceted and inter­cul­tural gain!
We live every day in such a way that we value and complement each other humanly and profes­sio­nally – as different perso­na­lities, with different backgrounds, desires, prefe­rences and ways of life!
We value this diversity as a great asset.
As a result, we strongly oppose any discri­mi­nation on the basis of, for example , origin, religion, religious affiliation, skin colour, gender, pregnancy, maternity protection, civil status, age, physical or mental disability, ancestry, hereditary infor­mation, national or ethnic origin, natio­nality, sexual orien­tation, gender identity or expression of sexuality, political conviction, trade union membership or any other status protected under appli­cable local law,regardless of the reason!

Only objec­tively assessed perfor­mance counts for us

We are a company in the social market economy and therefore we evaluate employees at KHB solely on the basis of their demons­trable contri­bu­tions and skills with respect to them fulfilling the respective business requirements.
This applies without exception to all decisions, regardless of whether they concern remune­ration, recruitment, further training, promotion or freedom of decision, or aspects not mentioned here.

Political activities

We clearly distin­guish between our possibly existing private interests / invol­vement in politics and KHB’s position on the subject.

We are convinced that politics and systems only work with and through people who are free to contribute and engage, who struggle with each other in respectful disagreement for the best solution and then achieve it.

For KHB employees who have a corre­sponding political invol­vement in private, it is important to ensure (whether in personal dialogue, via the media, in writing or by other means) that it is made clear that their personal-private, political views and opinions are theirs only and do not represent KHB.

As a company supported by many different people and their diversity, we believe that the right thing to do is for the company to refrain from political activity and therefore steer clear entirely from monetary support for political parties or their representatives.

Individual-personal conflicts of interest

This concerns any

situation in which personal interests (which may well be interests of third parties) make it difficult to act in the best interests of KHB.
It may also be that these interests influence personal objec­tivity and in turn affect the loyalty to KHB.

Such a conflict of interest is usually easy to resolve (if necessary by official resolution/approval) if it is disclosed in a timely and pro-active manner.
Because we under­stand that there will always be profes­sional-private overlaps – such is life – openness is and remains the building block for trust!

At KHB, we always ensure that private and business interests are kept clearly separate.

Safety at work

Personal safety – what could be more important?
We are confident that we will deliver our services reliably and with the highest possibly quality if the working environment meets high safety requirements.
This is an environment that promotes excellent, sustainable work results.
We provide the framework condi­tions, including through a safe, clean and job profile-specific environment.
In doing so, we not only meet the national requi­re­ments of occupa­tional safety and health and safety, but exceed them wherever possible.
Regular training of all employees, exercises, accom­panying documen­tation, as well as maintenance and testing of the opera­tional equipment used are integral and self-evident comple­mentary components of our procedure.
Parti­cu­larly important for us: We report viola­tions directly and without delay – only in this way can we act and protect immediately.

Income and working time

Part and parcel of working at KHB: Income and benefits must be in an appro­priate balance. This is very important to us!
We therefore go beyond the legal requi­rement that wages and salaries meet the statutory minimum requirements.
Breaks and working hours must comply with the company regula­tions and in any case with the national regula­tions or the ILO (Inter­na­tional Labor Organization) conditions.

Freedom of association and the right to collective bargaining

KHB supports the right to freedom of association and assembly as well as the right to collective bargaining.
In cases or countries where the right to freedom of association and the right to collective bargaining are legally restricted, we expect our business partners to create alter­native possi­bi­lities for independent and free organization and negotiation.

Social standards

Unwavering and without compromise:
We neither induce nor tolerate any form of explo­itation, such as forced or child labour.
Child labour is defined in the ILO conven­tions, the United Nations conven­tions, and national laws. The most stringent of these standards must be followed.
At KHB, we attach the utmost importance to these standards.
We consis­t­ently decline to establish a coope­ration with any party that does not meet these requirements.

Data Protection

We process and protect confi­dential data, respect the protection of privacy and personal data as well as the intellectual property of third parties.

We act in accordance with the European data protection regulations.

There are internal policies, security systems, proper usage and access restric­tions, security proce­dures and stress test scenarios that verify positive resilience.
We comply with data protection laws at the time personal data is collected and processed, including in relation to our own employees and business partners.

We expressly state: Data protection laws confer certain rights to their personal data to individual persons.
A neutral data protection officer assesses our relevant activities.

All our financial reporting and disclo­sures are compiled accurately, completely and in a timely fashion.

KHB disclose financial and opera­tional infor­mation to, for example, public autho­rities, super­visory bodies and banks. They evaluate and validate the factual accuracy of the infor­mation we provide – KHB is respon­sible for the infor­mation provided in the disclosures.

We all make a decisive contri­bution to ensuring that business accounts are kept in line with requi­re­ments in our specific area of work.

This is done by ensuring that planning as well as invoicing to customers and from suppliers and service providers and time and cost state­ments are accurate, executed/checked in a timely and correct manner, and that the corre­sponding figures are correctly recorded and posted.

We store, manage and dispose of our financial reports in accordance with standard retention requi­re­ments, as well as contractual and other legal requi­re­ments, such as retention regula­tions from the internal organiza­tional requirements.