Pressure Hydraulics & Controls (PHC) Code of Conduct

PHC continues to develop its global business and commits to operating in compliance with all applicable laws and regulations. PHC will apply the highest ethical standards and treat others with respect and integrity, according to the principles laid down in this Business Partner Code of Conduct. This Code applies to distributors, wholesalers, resellers and other Partners.

This Code explains what PHC expects from Partners with regards to business ethics, human rights, business practices, employee relations, health and safety and other topics related to sustainable and responsible business practices. It defines what customers, consumers, investors, and other stakeholders can expect from PHC. Choosing responsible Partners is important to us. We will work together with our Partners to make improvements with respect to social and ethical performance.

PHC’s Partners are expected to adopt and comply with the ethical business standards and values set out in this Code.

Jim Hickey (PHC Managing Director)

Introduction

Background and Scope of the Code

This Code is applicable for distributors, wholesalers, resellers, sales agents and other Partners.

The Code comprises the requirements for responsible business operations with which Partners to PHC must comply. It refers to international standards and defines specific PHC requirements. This Code may be supplemented from time-to-time by other documents containing additional requirements.

PHC’s own Code of Conduct defines the principles that PHC regards as fundamental for business ethics and socially responsible behaviour. It also constitutes the basis for this Code, addressing requirements that Partners to PHC must satisfy within the areas of business ethics, human rights, health and safety, employee relations, business practices and community involvement.

Business Partner evaluation and compliance

PHC or an external auditing company, selected by PHC, shall have the right to assess the Business Partner´s compliance with this Code.

Confidentiality

PHC may disclose certain of its confidential information to Partners during their business relationship. The Business Partner may only provide access to PHC confidential information to persons within its organisation having a need to know the information. As appropriate, Partners may be requested to enter into separate confidentiality agreements with PHC.

Sub-contractors

All PHC Partners are expected to adopt and comply with the ethical business standards and values set out in this Code, and to actively use such standards when dealing with their own sub-contractors.

The Business Partner Practices

Ethical business practices

Integrity

Partners are always expected to conduct their business in a professional manner. At minimum, Partners and all persons acting on their behalf must act with integrity, honesty and fairness in all aspects of their business.

Fair Competition

Partners and all persons acting on their behalf shall comply with national and international antitrust and competition laws. They shall not enter directly or indirectly into any illegal agreements with their competitors nor exchange sensitive information, e.g. regarding markets, customers, strategies, prices and the like.

Conflicts of Interest

Partners must inform PHC if any PHC employee has an interest in the Partner’s business which might cause a conflict of interest. Partners and persons acting on their behalf must avoid conflicts of interest with respect to their private activities, entities in which they or their close relatives or associates have an interest.

Anti-Corruption and Bribery

Partners and all persons acting on their behalf shall comply with all applicable anti-corruption laws while conducting business with PHC. Bribery and any other form of corrupt business practice are strictly prohibited.

Partners are required to comply with the legal regulations concerning the prevention of money laundering.

Gifts and entertainment

PHC Partners must not provide any gift, meal or entertainment to an PHC employee that might influence, or appear to influence, the PHC employee’s decision in relation to PHC’s business with the Partner.

PHC representatives are not allowed to accept gifts or hospitality if this may influence or appear to influence a business decision.

Books, records and tax

Keeping accurate books and records as well as declaring taxes and duties is part of running a lawful and transparent business in a sustainable way. PHC expects its Partners to comply with all applicable laws and accounting rules in this respect.

Data protection

Partners shall comply with all applicable data protection laws in collecting, processing, storing or otherwise handling personal data of any individuals, including, without limitation, their own employees and employees of their customers, suppliers and Partners.

Occupational health and safety

Partners must take the necessary steps to ensure a safe and healthy working environment for all their employees.

As part of this effort, Business Partner must have in place a documented Health and Safety Management System providing for continuous monitoring and improvement of the working environment. Each Partner must also have a senior manager within its organisation who is responsible for Health and Safety.

Fair labour practices

PHC expects its Partners will treat their employees and all persons acting on their behalf with the highest ethical standards. Partners must adhere to international and national conventions and laws in the area of fundamental rights, including, but not limited to, non-discrimination, freedom of association, the right to collective bargaining, protection of children and mothers and the right to form works’ councils.

If required by local law, all employees of a PHC Partner must have an employment contract. Partners’ working hours shall comply with national laws and local industry standards, and wages and other benefits provided by a Partner must be fair and at least equal to the minimum relevant legal and industry standards.

Child labour and forced labour

Partners shall take measures to ensure they do not engage in or support the use of child, forced or bonded labour. This includes all forms of human trafficking and working against one’s own will or choice. No employee shall be required to lodge deposits or identity papers when commencing employment. If a Business Partner uses a staffing recruiter or agency, in no event shall workers be charged fees or expenses related to their recruitment.

Discrimination

PHC Partners are expected to adopt and enforce policies which effectively prohibit discrimination or harassment on the grounds of gender, marital or parental status, ethnic or national origin, sexual orientation, religious belief, political affiliation, age, disability, or membership in a trade union or employee organisation.

Grievance mechanisms

PHC expects its Partners will have in place effective grievance channels through which employees can report complaints and grievances about their working conditions without fear of retaliation.

Respect for the environment

At all times, PHC Partners are expected to act in an environmentally responsible manner, and to respect applicable legislation. PHC requires its Partners to make continuous improvements in environmental protection and to minimise the environmental impact of and pollution generated by their activities.

Community relations

PHC encourages Partners to be a positive influence within and act with respect for the communities in which they operate.

Reporting of deviations

Each Partner must report to their PHC representatives any suspicions of a material breach of any of the Business Partner’s obligations under this Code including any breach by the Partner’s sub-contractors. If a Partner or any of its own sub-contractors fails to comply with the requirements set forth in this Code, the Partner must take appropriate action to remedy the breach and prevent a recurrence of such breach in the future. PHC reserves the right to terminate the business relationship with any Partner who deviates persistently from or breaches this Code.

Revised 01/09/2020