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Code of Conduct
of LMT Tools Group

Foreword by the Management Board
At LMT Tools Group, we are a partner and provider of solutions for our customers in the development and manufacture of special tools. With our tools and customized solutions, we want to make our contribution to the success of our customers. 

We understand that we can only be the best partner for our customers in the rapidly transforming industrial production sector if we put precision first in every aspect of our thoughts and actions. And that is exactly what we do – because it is in our genes.

An outstanding customer experience is at the heart of LMT Tools. Reliability and fast action create an uncomplicated and trust-based business relationship between LMT Tools and our customers.

Shared values are the basis for our responsible actions. They shape the way we work together, respect each other, communicate, perform, pursue our goals, and assume management responsibility. 

Our actions are based on the core values in the company: I care – I act – I trust. 

In order to be successful together, the trust of our employees, customers, business partners and society in us as a company is a fundamental prerequisite.

We are very aware of this responsibility. Our Code of Conduct translates our values into standards and principles of behavior. They ensure compliance with standards and internal guidelines throughout the company, provide a clear orientation for us and our employees, and create a working environment characterized by integrity, respect, and fair and responsible conduct. 

We expect ourselves as management, our managers and our employees to act with integrity when making decisions and to conduct our business in accordance with national and international laws as well as generally recognized ethical principles. And we expect the same of our business partners. 

Each individual at LMT Tools Group contributes with their behavior to ensuring that this trust is maintained and that we continue to stand for I care – I act – I trust in the future.

Management Board LMT Tools Group

iel Ehmans        Roland Benter


Scope and purpose 
As an internationally active company, LMT Tools GmbH & Co. KG and its affiliated companies (hereinafter referred to as "LMT Tools Group”) are obliged to observe a wide range of social, political and legal conditions in Germany and abroad. Even supposedly minor violations of the law by employees and executive bodies can significantly damage the reputation of the company and cause it great damage, including of a financial nature. 

This Code of Conduct describes the values, principles and practices that govern LMT Tools Group’s corporate behavior. Its main objective is to ensure compliance with standards and internal guidelines throughout the company and to create a working environment characterized by integrity, respect, and fair and responsible conduct. The Code of Conduct is also a pledge to the outside world for responsible, inclusive and environmentally-conscious behavior in general, toward business partners and the public.

It applies to all employees and bodies of LMT Tools Group worldwide. All employees bear responsibility.

1. Corporate guidelines/values at LMT Tools Group
At LMT Tools Group, we have committed ourselves to a common consensus of values, which is expressed in our corporate guidelines.

The corporate guidelines are intended to guide and motivate LMT Tools Group as a whole and its individual members. We make it clear what we stand for as a company and thus convey an idea of the corporate identity, goals and strategy of the company.

We are passionate about the interests of LMT Tools Group and take responsibility for our decisions (“Acting with passion and accountability”).

We are prepared to make changes for continuous improvement (“Willpower to drive change for continuous improvement”).

We are open-minded and always strive toward collaboration based on trust (“Open-minded to foster trustful collaboration”).

We endeavor to achieve the best possible performance while maintaining the corporate culture of LMT Tools Group based on our values. (“Committed to performance and a recognizing culture”).

We put our customers and their satisfaction at the center of everything we do. We want our customers to perceive us as a reliable, fair partner with high ethical standards (“Caring for our customer experience”)

... and always keep an eye on the environment around us (“… and our environment”).

We expect all employees to internalize these corporate guidelines and take them into account in their daily work. These corporate guidelines are also based on our core values in the company: I care – I act – I trust. We actively oppose any violations of our self-image expressed in these guidelines or any other discrimination, harassment or derogatory behavior by or toward our employees.

2. Compliance with applicable laws and regulations 
Compliance with all applicable laws and other regulations (including internal company guidelines) is an indispensable basis for all actions within LMT Tools Group. 

It is made clear that this Code of Conduct cannot cover all laws and regulations that the bodies and employees of LMT Tools Group are obliged to observe worldwide. However, it sets out the essential principles for the responsible and legally compliant conduct of LMT Tools Group, including its employees and executive bodies. 

The Code of Conduct is supplemented by internal company guidelines and training for individual legal areas such as anti-corruption, cartel prevention and the avoidance of conflicts of interest. 

3. Fair competition 
LMT Tools Group is unconditionally committed to fair competition, compliance with antitrust and copyright law and all related legal regulations, and expects the same from its competitors, suppliers, customers and other business partners.

In competition, the company focuses exclusively on performance, customer orientation, and the quality of its products and services. Agreements on prices or conditions with competitors are therefore to be avoided, as are agreements with competitors for the purpose of market or customer allocation. It is clarified that agreements prohibited under antitrust law may not be replaced by concerted practices with competitors or by coordination within associations. 

Intellectual property of LMT Tools Group must be protected; conversely, the intellectual property of third parties must be respected.

4. Avoiding corruption 
LMT Tools Group rejects corruption in its business dealings in Germany and abroad and has standardized detailed rules of conduct in its anti-corruption guideline. This applies in relation to public officials and in relation to bodies and employees of other companies. In connection with the activities of LMT Tools Group in Germany and abroad, no personal advantages may be promised or granted to the executive bodies and employees of other companies or to public officials in return for preferential treatment. 

The employees and executive bodies of LMT Tools Group are not corruptible and do not derive any profit from their activities – apart from the remuneration paid by the company. They therefore do not accept any gifts or invitations that go beyond customary practices or constitute any other direct or indirect granting of advantages outside the requirements and value limits standardized in LMT Tools Group’s anti-corruption guidelines. They also refrain from granting such benefits to competitors, consultants, customers, suppliers, service providers and other business partners of LMT Tools Group. 

5. Conflicts of interest 
One of the contractual obligations of all bodies and employees of LMT Tools Group is to avoid conflicts of interest between their private interests (directly or indirectly, or through related persons or companies) and the interests of LMT Tools Group as far as possible. 

The avoidance of conflicts of interest also requires that the bodies and employees of LMT Tools Group avoid even the appearance of preferential treatment in business dealings with competitors, consultants, customers, suppliers, service providers and other business partners of LMT Tools Group due to personal proximity to individual members of the aforementioned groups of people. 

Examples of conflicts of interest include the private exploitation of business opportunities, property or employees of the company or the acceptance of secondary employment that does not correspond to the interests of LMT Tools Group (e.g., consultancy work for a competitor).

If conflict situations cannot be avoided in individual cases, they must be made transparent and resolved in accordance with the law and the company’s internal guidelines. 

In any case, business decisions must always and exclusively be based on the interests of LMT Tools Group. 

6. International trade and due diligence in the supply chain
For LMT Tools Group, the legal provisions on international trade applicable to its products and services are binding and are recognized without reservation. The companies of LMT Tools Group therefore comply with all export or import bans and official approval requirements applicable under national or international law. From a German perspective, this applies in particular to the regulations on the export of goods issued by the Federal Office of Economics and Export Control (BAFA). LMT Tools Group is also a secure supply chain company in the area of aviation security and complies with all relevant regulations as well as the necessary security provisions and security measures.    

In addition, LMT Tools Group takes the greatest possible care to safeguard human rights and environmental due diligence obligations within international supply chains. Further details are regulated in the “Declaration of principles for the protection of human rights” and in the “Supplier Code of Conduct” of LMT Tools Group, which is binding for all suppliers.

7. Human rights, working conditions and social responsibility
LMT Tools Group is unreservedly committed to respecting and complying with internationally recognized human rights.

The business success of LMT Tools Group depends to a large extent on its employees. The company is therefore committed to the principles of social responsibility within the context of its business activities. 

It is in the company’s interest that fair working conditions apply at LMT Tools Group worldwide. LMT Tools Group considers it its duty to treat its employees with respect and fairness. In particular, this means complying with all applicable occupational health and safety regulations to ensure the safety of employees in the workplace. Further details can be found in the current version of LMT Tools Group’s Occupational Health and Safety Policy.

The requirement for fair working conditions supports diversity and inclusion, ensures equal rights for all employees and therefore prohibits any form of discrimination based on gender, sexual orientation, origin, skin color, religion or other personal characteristics. 

All forms of child labor, forced labor and slavery are strictly prohibited. 

LMT Tools Group recognizes the right to freedom of association and collective bargaining. The company promotes cooperation with works councils and undertakes not to discriminate against or disadvantage employees on the basis of their membership of a works council. Furthermore, the company does not prevent works councils from contacting and interacting with the workforce. 

LMT Tools Group also expects its employees and managers to treat each other with respect in verbal and written communication, especially in meetings and emails. In addition to consideration for the social customs of a country, this includes unconditional respect for the personal integrity of the other person and refraining from personal insults, degradation or sexual harassment. Such behavior will not be tolerated and will have consequences under employment law.

8. Financial integrity and reporting 
Business transactions and business records of LMT Tools Group companies must be complete, accurate and correct. There is an obligation to record, document and submit to authorities all business transactions, assets and liabilities in accordance with legal requirements. 

Documents relevant to financial accounting may not be provided with deliberately false or misleading entries. Any form of balance sheet manipulation is strictly prohibited.

For LMT Tools Group, honest and transparent reporting is also essential between companies within LMT Tools Group. All bodies and employees of LMT Tools Group are therefore obliged to provide conscientious, complete, loyal and timely reporting within LMT Tools Group. 

Bodies and employees of LMT Tools Group who are obliged to report to third parties (e.g., auditors, authorities) must adhere to the same principles. This is essential for the credibility of LMT Tools Group in business and social contexts. 

9. Sustainability and product safety 
LMT Tools Group is constantly striving toward developing innovative products of high quality for its customers. Product safety is always the top priority here. At the same time, LMT Tools Group also supports its customers in their sustainable production, e.g., by improving the efficiency of material and resource consumption.

LMT Tools Group pays equal attention to sustainability in both the development and manufacture of products. 

Protecting the environment and the climate as well as resource efficiency are of great importance to LMT Tools Group. As part of its business activities, LMT Tools Group takes care to protect the environment and natural resources. Every employee has a responsibility to treat natural resources with care and to contribute to protecting the environment and climate through their individual behavior.

Companies in LMT Tools Group always attach importance to avoiding or reducing environmental pollution by reducing energy and water consumption, emissions and waste. In doing so, the company relies on the use of eco-efficient technologies and materials for environmental protection, economy and reusability. 

Sustainable business practices and environmentally-conscious behavior on the part of managers and employees are encouraged.

Details can be found in the current version of LMT Tools Group’s environmental guidelines. 

10. Trade and business secrets 

The knowledge and information acquired within LMT Tools Group is an essential element for business success. LMT Tools Group invests considerable human and financial resources in the development of innovative products and services. Protecting the innovations developed in this way ensures LMT Tools Group’s competitive success. 

All employees and bodies of LMT Tools Group are obliged to prevent knowledge and information, insofar as they represent trade or business secrets of the company, from becoming known outside LMT Tools Group, e.g., through unauthorized dissemination of confidential data and information in discussions with third parties or in trade journals. In addition, every employee involved with such knowledge and information should obtain information about the extent to which the acquisition of industrial property rights for this knowledge and information is possible. 

To the same extent, trade or business secrets of business partners of LMT Tools Group must be protected against unauthorized disclosure. 

11. Data protection and communication
LMT Tools Group takes the greatest possible care when processing the personal data of employees, customers or other third parties and complies with applicable laws and regulations. 

In case of doubt, the advice of the company’s data protection officer is sought.

LMT Tools Group is committed to the security of all IT systems, including by informing and training employees on these topics. In this way, LMT Tools Group ensures the security of information with regard to confidentiality, integrity and availability as well as the protection of internal and external data.

The right to freedom of expression and the protection of employees’ personal rights and privacy are respected. However, every employee should be aware that they can also be perceived as part of and representative of the company in the private sphere. All employees are therefore required to protect the reputation of LMT Tools Group through their behavior and appearance in public. Therefore, no confidential or sensitive company information is communicated in social networks.

12. Compliance management and internal reporting office
As part of its compliance management, LMT Tools Group actively promotes communication of the rules set out in this Code of Conduct. 

Managers have a special role model function and are the first point of contact for questions about understanding the rules. As part of their management duties, they prevent unacceptable behavior and take appropriate measures to prevent breaches of the rules in their respective area of responsibility. 

If employees have any questions about this Code of Conduct, they can also contact the responsible Compliance Officer of the relevant company in LMT Tools Group. 

Violations of this Code of Conduct, legal regulations or internal company requirements can have far-reaching consequences. In addition to financial consequences and a loss of trust, violations can also have consequences under labor law for the employee concerned or even result in criminal prosecution.

LMT Tools Group expressly encourages all employees to openly address issues and problems. Employees who raise concerns in good faith about matters within the company will therefore not suffer any disadvantages. If they so wish, their identity as a whistle-blower will be protected and not disclosed. 

Information can also be submitted anonymously via our “Speak Up” compliance hotline. These anonymous reports will also be investigated.

The following link can be used to submit reports and additional information on the relevant process can also be found here:

To the Compliance Hotline

In addition, information can of course also be submitted to the management of the company concerned within LMT Tools Group and to the responsible Compliance Officer.

Schwarzenbek, January 31, 2024 
Management Board of LMT Tools GmbH & Co.KG