ALCAR GROUP AT A GLANCE
ALCAR is an internationally operating industrial and trading group with a strategic product focus on:
• Steel and aluminium wheels
• Tire pressure monitoring systems
• Tires and complete wheels
The ALCAR Group is the market leader in the European passenger car aftermarket for aluminium and steel
wheels. Its core business includes both production and national & international wholesale. The companies
within the ALCAR Group are characterized by a strong customer and market orientation, offering
innovative designs, high-quality production, and service-oriented logistics.
Headquarter
Hirtenberg, located in the south of Vienna / Austria
Production
Aluminium wheels in Neuenrade (DE)
Steel wheels in Lugano (CH)
Distribution network
17 ALCAR companies and 20 importers in 35 countries
Main customers
The tire and automotive accessories retail sector,
vehicle importers, and car dealerships
Employees
approx. 800
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 2
1. PREAMBLE
Global business activity also entails the responsibility to pay particular attention to the basic rules of human
coexistence. We, at ALCAR Holding GmbH and affiliated companies (hereinafter referred to as „ALCAR“)
derive our requirements for responsible corporate governance from our corporate values as well as from
regulatory requirements, external initiatives and international guidelines to which we are committed. These
requirements are integrated into our sustainability strategy and our group-wide guidelines.
The foundations of our pledge are the International Bill of Human Rights, the UN Guiding Principles on
Business and Human Rights (UNGPs), the UN Global Compact Principles, the ILO (International Labour
Organization) Declaration on Fundamental Principles and Rights at Work and its Follow-up, the OECD
Guidelines for multinational enterprises and the OECD Due Diligence Guidance for Responsible Business
Conduct.
2. SCOPE
This Code of Conduct defines ALCAR’s principles and requirements for its business partners. Its purpose
is to ensure that the business practices of our partners align with ALCAR’s values, as well as with applicable
laws and regulations.
3. COMPLIANCE & RESPONSIBLE CORPORATE GOVERNANCE
3.1.COMPLIANCE WITH LAWS & DUE DILIGENCE OBLIGATIONS
The business partners agree to comply with all applicable national laws and international regulations.
They will implement due diligence processes to identify, prevent, and minimize risks of human rights
violations and environmental impacts in their supply chains.
3.2.PROHIBITION OF CORRUPTION
ALCAR does not tolerate any form of bribery, corruption, or other unfair trade practices.
The business partners must comply with applicable laws and regulations against corruption and bribery,
including those related to foreign bribery. They must reject all forms of corruption, bribery, theft,
embezzlement, or extortion. Illegal payments, particularly payments or other benefits intended to influence
a decision in violation of applicable laws, are not tolerated. Business partners are required to adhere to
legal provisions regarding compliance and anti-corruption.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 3
3.3. FAIR COMPETITION
Compliance with transparent and fair behaviour on the market is essential for ALCAR.
Therefore, illegal practices such as price fixing, market sharing, and bid rigging will not be tolerated.
Agreements and concerted practices with third parties, especially competitors, that restrict competition in
effect or purpose are prohibited and will not be tolerated by ALCAR. In addition to adhering to all
competition law provisions, we expect our business partners to fully comply with all economic sanctions
and export controls.
3.4.PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING
ALCAR and its business partners strictly adhere to all applicable laws to prevent money laundering and
terrorist financing and refrain from any such activities.
3.5.AVOIDANCE OF CONFLICTS OF INTEREST
The business partners are expected to disclose all conflicts of interest that could potentially influence the
business relationship with ALCAR or give the appearance of such an influence.
3.6.EXPORT CONTROLS AND SANCTIONS
The business partners ensure compliance with applicable laws regarding the import and export of goods,
services, and information, as well as all relevant embargoes and sanctions.
3.7.PROTECTION OF INFORMATION AND DATA
The business partners commit to adequately protecting all information owned by ALCAR and all intellectual
property of ALCAR. Specifically, business partners must ensure the confidentiality of ALCAR’s information.
Additionally, business partners must adhere to all applicable intellectual property laws, including patents,
trademarks, and copyrights. They must respect the intellectual property of third parties and avoid any
infringements of intellectual property rights, such as plagiarism.
Any processing of personal data of ALCAR’s employees, customers, and business partners (e.g., collection,
use, and storage) must be conducted in accordance with applicable data protection laws.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 4
4. SOCIAL RESPONSIBILITY
4.1.RESPECT FOR HUMAN RIGHTS AND LABOUR CONDITIONS
ALCAR fully recognizes international human rights standards and expects the same from its business
partners. The business partners undertake to respect and comply with human rights as fundamental values,
based on the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights,
and the principles of the UN Global Compact.
Furthermore, ALCAR ensures that fair labour practices are upheld. These include fair pay, nondiscrimination, prevention of child or forced labour, and freedom of association for employees. Consistent
with the UN Global Compact, promoting equal opportunities and treatment—regardless of skin colour,
nationality, social or ethnic origin, disabilities, sexual orientation, political or religious beliefs, marital
status, gender, or age—is also a prerequisite.
4.2. PROHIBITION OF CHILD AND FORCED LABOUR
The business partners must ensure that they do not engage in any form of child labour, forced labour,
modern slavery, or human trafficking. They must comply with all relevant national laws and international
agreements specifying a minimum age for employees.
Forced and compulsory labour includes any work or services coerced from individuals under threat of
punishment. This encompasses practices such as withholding identity cards and passports, restricting
movement, and subjecting individuals to debt bondage.
The business partners are prohibited from tolerating child labour within their own operations or at their
direct suppliers under any circumstances. They must comply with at least Convention No. 138 of the
International Labour Organization (ILO) concerning the minimum age for admission to employment, as
well as ILO Convention No. 182 concerning the prohibition and immediate action for the elimination of
the worst forms of child labour, adopted on 26 June 1973 and 17 June 1999 respectively.
4.3.PROHIBITION OF DISCRIMINATION
The business partners are prohibited from discriminating against employees or subjecting them to reprisals
based on gender, age, ethnic origin or descent, nationality, race, disability, sexual orientation, religion,
political views, or similar grounds. Additionally, any form of physical or psychological violence towards
employees and stakeholders, as well as sexual harassment, must not be tolerated.
4.4.COMPLIANCE WITH FREEDOM OF ASSOCIATION
The business partners must respect the freedom of association, the right to collective bargaining, and the
principles of equal opportunity in accordance with applicable laws and regulations.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 5
4.5.COMPLIANCE WITH LEGAL REQUIREMENTS REGARDING REMUNERATION
AND WORKING HOURS
The business partners must pay fair wages, adhere to maximum working hours as per local laws, and
ensure a living wage in accordance with local conditions.
4.6.SAFETY IN THE WORKPLACE
ALCAR’s business partners are expected to ensure the physical and mental well-being of their employees,
which includes providing a safe and healthy working environment and adhering strictly to safety
regulations. They must guarantee compliance with labour protection laws and adhere to health and safety
specifications. Additionally, they are responsible for providing suitable occupational safety equipment
and organizing occupational safety training courses for their employees. The business partners must ensure
the organization of a safe working environment and promote employee health. In the event of any incidents
contrary to safety measures, immediate countermeasures should be initiated.
5. ENVIRONMENTAL & CLIMATE PROTECTION
5.1.ENVIRONMENTAL PROTECTION IN THE WORKPLACE
ALCAR’s business partners are required to comply with all relevant laws and expected to adhere to
international environmental standards. They should use natural resources sparingly and responsibly,
striving to minimize the negative impact of their business activities on the environment, climate,
biodiversity, and water scarcity.
Additionally, business partners are expected to implement suitable management systems to mitigate
environmental and safety risks while enhancing existing environmental and safety standards. Compliance
with applicable legal provisions concerning product safety, integrity, handling of hazardous substances,
goods, and waste, as well as product labelling and packaging, is mandatory. Products should not contain
any features aimed at circumventing legal or regulatory requirements.
Furthermore, business partners are encouraged to promote the development and adoption of energyefficient and environmentally friendly technologies. They should strive to minimize waste and emissions
into the air, water, and soil, and utilize natural resources efficiently.
5.2.ANIMAL WELFARE
ALCAR and its business partners adhere to nationally and internationally applicable legal standards
regarding animal welfare and protection. They also follow recognized frameworks that define ethical
principles in this regard.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 6
5.3.CONFLICT MINERALS
The business partners must take appropriate measures to prevent the use of raw materials in their products
that directly or indirectly contribute to human rights violations, corruption, financing of armed groups, or
similar detrimental effects. They undertake to comply with all applicable laws and regulations regarding
conflict minerals and must be able to provide information on the origin and supply chain of conflict
minerals.
6. REGULAR AUDITS
ALCAR reserves the right to conduct inquiries, audits, or other procedures to assess its business partners.
7. LEGAL CONSEQUENCES FOR BUSINESS PARTNER IN THE EVENT OF
VIOLATIONS OF THE CODE OF CONDUCT
Violations of the standards outlined in this Code of Conduct for Business Partners, especially those
concerning human rights, environmental protection, and legal obligations, must be promptly rectified.
Our Business Partners are required to promptly notify ALCAR to identify appropriate remedial actions for
any identified risks or violations. They must adopt effective controls and measures to prevent their
recurrence. Should Business Partners fail to adequately address the issue within a reasonable period,
ALCAR reserves the right to terminate the business relationship for cause, without further notice, and
without prejudice to any other legal or contractual rights.
8. RESPONSIBILITY FOR COMPLIANCE
We expect our business partners to commit to complying with our principles and to develop and implement
appropriate and effective processes to address and prevent identified risks and violations, as well as to
identify potential risks. The Code of Conduct does not preclude ALCAR and its business partners from
establishing more detailed and stringent requirements, either contractually or individually through their
respective internal governance documents.
9. WHISTLEBLOWER AND GRIEVANCE PROCEDURES
The business partners are expected to facilitate their employees and stakeholders in raising concerns or
reporting potentially unlawful practices or violations of this Code of Conduct for business partners without
fear of retaliation. They may establish their own whistleblowing system or participate in an industry-wide
system.
Additionally, business partners are expected to inform their employees about ALCAR’s whistleblower and
grievance system, which can be accessed on the ALCAR website or by emailing human.rights@alcarwheels.com.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 7
BUSINESS PARTNER DECLARATION
We hereby confirm our shared commitment to respect, comply with, and apply the values outlined in this
ALCAR Group Business Partner Code of Conduct.
Should any point of this Code of Conduct be unfillable now or in the future, we undertake to promptly
inform ALCAR in writing.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 1
ALCAR GROUP AT A GLANCE
ALCAR is an internationally operating industrial and trading group with a strategic product focus on:
• Steel and aluminium wheels
• Tire pressure monitoring systems
• Tires and complete wheels
The ALCAR Group is the market leader in the European passenger car aftermarket for aluminium and steel
wheels. Its core business includes both production and national & international wholesale. The companies
within the ALCAR Group are characterized by a strong customer and market orientation, offering
innovative designs, high-quality production, and service-oriented logistics.
Headquarter
Hirtenberg, located in the south of Vienna / Austria
Production
Aluminium wheels in Neuenrade (DE)
Steel wheels in Lugano (CH)
Distribution network
17 ALCAR companies and 20 importers in 35 countries
Main customers
The tire and automotive accessories retail sector,
vehicle importers, and car dealerships
Employees
approx. 800
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 2
1. PREAMBLE
Global business activity also entails the responsibility to pay particular attention to the basic rules of human
coexistence. We, at ALCAR Holding GmbH and affiliated companies (hereinafter referred to as „ALCAR“)
derive our requirements for responsible corporate governance from our corporate values as well as from
regulatory requirements, external initiatives and international guidelines to which we are committed. These
requirements are integrated into our sustainability strategy and our group-wide guidelines.
The foundations of our pledge are the International Bill of Human Rights, the UN Guiding Principles on
Business and Human Rights (UNGPs), the UN Global Compact Principles, the ILO (International Labour
Organization) Declaration on Fundamental Principles and Rights at Work and its Follow-up, the OECD
Guidelines for multinational enterprises and the OECD Due Diligence Guidance for Responsible Business
Conduct.
2. SCOPE
This Code of Conduct defines ALCAR’s principles and requirements for its business partners. Its purpose
is to ensure that the business practices of our partners align with ALCAR’s values, as well as with applicable
laws and regulations.
3. COMPLIANCE & RESPONSIBLE CORPORATE GOVERNANCE
3.1.COMPLIANCE WITH LAWS & DUE DILIGENCE OBLIGATIONS
The business partners agree to comply with all applicable national laws and international regulations.
They will implement due diligence processes to identify, prevent, and minimize risks of human rights
violations and environmental impacts in their supply chains.
3.2.PROHIBITION OF CORRUPTION
ALCAR does not tolerate any form of bribery, corruption, or other unfair trade practices.
The business partners must comply with applicable laws and regulations against corruption and bribery,
including those related to foreign bribery. They must reject all forms of corruption, bribery, theft,
embezzlement, or extortion. Illegal payments, particularly payments or other benefits intended to influence
a decision in violation of applicable laws, are not tolerated. Business partners are required to adhere to
legal provisions regarding compliance and anti-corruption.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 3
3.3. FAIR COMPETITION
Compliance with transparent and fair behaviour on the market is essential for ALCAR.
Therefore, illegal practices such as price fixing, market sharing, and bid rigging will not be tolerated.
Agreements and concerted practices with third parties, especially competitors, that restrict competition in
effect or purpose are prohibited and will not be tolerated by ALCAR. In addition to adhering to all
competition law provisions, we expect our business partners to fully comply with all economic sanctions
and export controls.
3.4.PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING
ALCAR and its business partners strictly adhere to all applicable laws to prevent money laundering and
terrorist financing and refrain from any such activities.
3.5.AVOIDANCE OF CONFLICTS OF INTEREST
The business partners are expected to disclose all conflicts of interest that could potentially influence the
business relationship with ALCAR or give the appearance of such an influence.
3.6.EXPORT CONTROLS AND SANCTIONS
The business partners ensure compliance with applicable laws regarding the import and export of goods,
services, and information, as well as all relevant embargoes and sanctions.
3.7.PROTECTION OF INFORMATION AND DATA
The business partners commit to adequately protecting all information owned by ALCAR and all intellectual
property of ALCAR. Specifically, business partners must ensure the confidentiality of ALCAR’s information.
Additionally, business partners must adhere to all applicable intellectual property laws, including patents,
trademarks, and copyrights. They must respect the intellectual property of third parties and avoid any
infringements of intellectual property rights, such as plagiarism.
Any processing of personal data of ALCAR’s employees, customers, and business partners (e.g., collection,
use, and storage) must be conducted in accordance with applicable data protection laws.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 4
4. SOCIAL RESPONSIBILITY
4.1.RESPECT FOR HUMAN RIGHTS AND LABOUR CONDITIONS
ALCAR fully recognizes international human rights standards and expects the same from its business
partners. The business partners undertake to respect and comply with human rights as fundamental values,
based on the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights,
and the principles of the UN Global Compact.
Furthermore, ALCAR ensures that fair labour practices are upheld. These include fair pay, nondiscrimination, prevention of child or forced labour, and freedom of association for employees. Consistent
with the UN Global Compact, promoting equal opportunities and treatment—regardless of skin colour,
nationality, social or ethnic origin, disabilities, sexual orientation, political or religious beliefs, marital
status, gender, or age—is also a prerequisite.
4.2. PROHIBITION OF CHILD AND FORCED LABOUR
The business partners must ensure that they do not engage in any form of child labour, forced labour,
modern slavery, or human trafficking. They must comply with all relevant national laws and international
agreements specifying a minimum age for employees.
Forced and compulsory labour includes any work or services coerced from individuals under threat of
punishment. This encompasses practices such as withholding identity cards and passports, restricting
movement, and subjecting individuals to debt bondage.
The business partners are prohibited from tolerating child labour within their own operations or at their
direct suppliers under any circumstances. They must comply with at least Convention No. 138 of the
International Labour Organization (ILO) concerning the minimum age for admission to employment, as
well as ILO Convention No. 182 concerning the prohibition and immediate action for the elimination of
the worst forms of child labour, adopted on 26 June 1973 and 17 June 1999 respectively.
4.3.PROHIBITION OF DISCRIMINATION
The business partners are prohibited from discriminating against employees or subjecting them to reprisals
based on gender, age, ethnic origin or descent, nationality, race, disability, sexual orientation, religion,
political views, or similar grounds. Additionally, any form of physical or psychological violence towards
employees and stakeholders, as well as sexual harassment, must not be tolerated.
4.4.COMPLIANCE WITH FREEDOM OF ASSOCIATION
The business partners must respect the freedom of association, the right to collective bargaining, and the
principles of equal opportunity in accordance with applicable laws and regulations.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 5
4.5.COMPLIANCE WITH LEGAL REQUIREMENTS REGARDING REMUNERATION
AND WORKING HOURS
The business partners must pay fair wages, adhere to maximum working hours as per local laws, and
ensure a living wage in accordance with local conditions.
4.6.SAFETY IN THE WORKPLACE
ALCAR’s business partners are expected to ensure the physical and mental well-being of their employees,
which includes providing a safe and healthy working environment and adhering strictly to safety
regulations. They must guarantee compliance with labour protection laws and adhere to health and safety
specifications. Additionally, they are responsible for providing suitable occupational safety equipment
and organizing occupational safety training courses for their employees. The business partners must ensure
the organization of a safe working environment and promote employee health. In the event of any incidents
contrary to safety measures, immediate countermeasures should be initiated.
5. ENVIRONMENTAL & CLIMATE PROTECTION
5.1.ENVIRONMENTAL PROTECTION IN THE WORKPLACE
ALCAR’s business partners are required to comply with all relevant laws and expected to adhere to
international environmental standards. They should use natural resources sparingly and responsibly,
striving to minimize the negative impact of their business activities on the environment, climate,
biodiversity, and water scarcity.
Additionally, business partners are expected to implement suitable management systems to mitigate
environmental and safety risks while enhancing existing environmental and safety standards. Compliance
with applicable legal provisions concerning product safety, integrity, handling of hazardous substances,
goods, and waste, as well as product labelling and packaging, is mandatory. Products should not contain
any features aimed at circumventing legal or regulatory requirements.
Furthermore, business partners are encouraged to promote the development and adoption of energyefficient and environmentally friendly technologies. They should strive to minimize waste and emissions
into the air, water, and soil, and utilize natural resources efficiently.
5.2.ANIMAL WELFARE
ALCAR and its business partners adhere to nationally and internationally applicable legal standards
regarding animal welfare and protection. They also follow recognized frameworks that define ethical
principles in this regard.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 6
5.3.CONFLICT MINERALS
The business partners must take appropriate measures to prevent the use of raw materials in their products
that directly or indirectly contribute to human rights violations, corruption, financing of armed groups, or
similar detrimental effects. They undertake to comply with all applicable laws and regulations regarding
conflict minerals and must be able to provide information on the origin and supply chain of conflict
minerals.
6. REGULAR AUDITS
ALCAR reserves the right to conduct inquiries, audits, or other procedures to assess its business partners.
7. LEGAL CONSEQUENCES FOR BUSINESS PARTNER IN THE EVENT OF
VIOLATIONS OF THE CODE OF CONDUCT
Violations of the standards outlined in this Code of Conduct for Business Partners, especially those
concerning human rights, environmental protection, and legal obligations, must be promptly rectified.
Our Business Partners are required to promptly notify ALCAR to identify appropriate remedial actions for
any identified risks or violations. They must adopt effective controls and measures to prevent their
recurrence. Should Business Partners fail to adequately address the issue within a reasonable period,
ALCAR reserves the right to terminate the business relationship for cause, without further notice, and
without prejudice to any other legal or contractual rights.
8. RESPONSIBILITY FOR COMPLIANCE
We expect our business partners to commit to complying with our principles and to develop and implement
appropriate and effective processes to address and prevent identified risks and violations, as well as to
identify potential risks. The Code of Conduct does not preclude ALCAR and its business partners from
establishing more detailed and stringent requirements, either contractually or individually through their
respective internal governance documents.
9. WHISTLEBLOWER AND GRIEVANCE PROCEDURES
The business partners are expected to facilitate their employees and stakeholders in raising concerns or
reporting potentially unlawful practices or violations of this Code of Conduct for business partners without
fear of retaliation. They may establish their own whistleblowing system or participate in an industry-wide
system.
Additionally, business partners are expected to inform their employees about ALCAR’s whistleblower and
grievance system, which can be accessed on the ALCAR website or by emailing human.rights@alcarwheels.com.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 7
BUSINESS PARTNER DECLARATION
We hereby confirm our shared commitment to respect, comply with, and apply the values outlined in this
ALCAR Group Business Partner Code of Conduct.
Should any point of this Code of Conduct be unfillable now or in the future, we undertake to promptly
inform ALCAR in writing.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 1
ALCAR GROUP AT A GLANCE
ALCAR is an internationally operating industrial and trading group with a strategic product focus on:
• Steel and aluminium wheels
• Tire pressure monitoring systems
• Tires and complete wheels
The ALCAR Group is the market leader in the European passenger car aftermarket for aluminium and steel
wheels. Its core business includes both production and national & international wholesale. The companies
within the ALCAR Group are characterized by a strong customer and market orientation, offering
innovative designs, high-quality production, and service-oriented logistics.
Headquarter
Hirtenberg, located in the south of Vienna / Austria
Production
Aluminium wheels in Neuenrade (DE)
Steel wheels in Lugano (CH)
Distribution network
17 ALCAR companies and 20 importers in 35 countries
Main customers
The tire and automotive accessories retail sector,
vehicle importers, and car dealerships
Employees
approx. 800
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 2
1. PREAMBLE
Global business activity also entails the responsibility to pay particular attention to the basic rules of human
coexistence. We, at ALCAR Holding GmbH and affiliated companies (hereinafter referred to as „ALCAR“)
derive our requirements for responsible corporate governance from our corporate values as well as from
regulatory requirements, external initiatives and international guidelines to which we are committed. These
requirements are integrated into our sustainability strategy and our group-wide guidelines.
The foundations of our pledge are the International Bill of Human Rights, the UN Guiding Principles on
Business and Human Rights (UNGPs), the UN Global Compact Principles, the ILO (International Labour
Organization) Declaration on Fundamental Principles and Rights at Work and its Follow-up, the OECD
Guidelines for multinational enterprises and the OECD Due Diligence Guidance for Responsible Business
Conduct.
2. SCOPE
This Code of Conduct defines ALCAR’s principles and requirements for its business partners. Its purpose
is to ensure that the business practices of our partners align with ALCAR’s values, as well as with applicable
laws and regulations.
3. COMPLIANCE & RESPONSIBLE CORPORATE GOVERNANCE
3.1.COMPLIANCE WITH LAWS & DUE DILIGENCE OBLIGATIONS
The business partners agree to comply with all applicable national laws and international regulations.
They will implement due diligence processes to identify, prevent, and minimize risks of human rights
violations and environmental impacts in their supply chains.
3.2.PROHIBITION OF CORRUPTION
ALCAR does not tolerate any form of bribery, corruption, or other unfair trade practices.
The business partners must comply with applicable laws and regulations against corruption and bribery,
including those related to foreign bribery. They must reject all forms of corruption, bribery, theft,
embezzlement, or extortion. Illegal payments, particularly payments or other benefits intended to influence
a decision in violation of applicable laws, are not tolerated. Business partners are required to adhere to
legal provisions regarding compliance and anti-corruption.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 3
3.3. FAIR COMPETITION
Compliance with transparent and fair behaviour on the market is essential for ALCAR.
Therefore, illegal practices such as price fixing, market sharing, and bid rigging will not be tolerated.
Agreements and concerted practices with third parties, especially competitors, that restrict competition in
effect or purpose are prohibited and will not be tolerated by ALCAR. In addition to adhering to all
competition law provisions, we expect our business partners to fully comply with all economic sanctions
and export controls.
3.4.PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING
ALCAR and its business partners strictly adhere to all applicable laws to prevent money laundering and
terrorist financing and refrain from any such activities.
3.5.AVOIDANCE OF CONFLICTS OF INTEREST
The business partners are expected to disclose all conflicts of interest that could potentially influence the
business relationship with ALCAR or give the appearance of such an influence.
3.6.EXPORT CONTROLS AND SANCTIONS
The business partners ensure compliance with applicable laws regarding the import and export of goods,
services, and information, as well as all relevant embargoes and sanctions.
3.7.PROTECTION OF INFORMATION AND DATA
The business partners commit to adequately protecting all information owned by ALCAR and all intellectual
property of ALCAR. Specifically, business partners must ensure the confidentiality of ALCAR’s information.
Additionally, business partners must adhere to all applicable intellectual property laws, including patents,
trademarks, and copyrights. They must respect the intellectual property of third parties and avoid any
infringements of intellectual property rights, such as plagiarism.
Any processing of personal data of ALCAR’s employees, customers, and business partners (e.g., collection,
use, and storage) must be conducted in accordance with applicable data protection laws.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 4
4. SOCIAL RESPONSIBILITY
4.1.RESPECT FOR HUMAN RIGHTS AND LABOUR CONDITIONS
ALCAR fully recognizes international human rights standards and expects the same from its business
partners. The business partners undertake to respect and comply with human rights as fundamental values,
based on the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights,
and the principles of the UN Global Compact.
Furthermore, ALCAR ensures that fair labour practices are upheld. These include fair pay, nondiscrimination, prevention of child or forced labour, and freedom of association for employees. Consistent
with the UN Global Compact, promoting equal opportunities and treatment—regardless of skin colour,
nationality, social or ethnic origin, disabilities, sexual orientation, political or religious beliefs, marital
status, gender, or age—is also a prerequisite.
4.2. PROHIBITION OF CHILD AND FORCED LABOUR
The business partners must ensure that they do not engage in any form of child labour, forced labour,
modern slavery, or human trafficking. They must comply with all relevant national laws and international
agreements specifying a minimum age for employees.
Forced and compulsory labour includes any work or services coerced from individuals under threat of
punishment. This encompasses practices such as withholding identity cards and passports, restricting
movement, and subjecting individuals to debt bondage.
The business partners are prohibited from tolerating child labour within their own operations or at their
direct suppliers under any circumstances. They must comply with at least Convention No. 138 of the
International Labour Organization (ILO) concerning the minimum age for admission to employment, as
well as ILO Convention No. 182 concerning the prohibition and immediate action for the elimination of
the worst forms of child labour, adopted on 26 June 1973 and 17 June 1999 respectively.
4.3.PROHIBITION OF DISCRIMINATION
The business partners are prohibited from discriminating against employees or subjecting them to reprisals
based on gender, age, ethnic origin or descent, nationality, race, disability, sexual orientation, religion,
political views, or similar grounds. Additionally, any form of physical or psychological violence towards
employees and stakeholders, as well as sexual harassment, must not be tolerated.
4.4.COMPLIANCE WITH FREEDOM OF ASSOCIATION
The business partners must respect the freedom of association, the right to collective bargaining, and the
principles of equal opportunity in accordance with applicable laws and regulations.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 5
4.5.COMPLIANCE WITH LEGAL REQUIREMENTS REGARDING REMUNERATION
AND WORKING HOURS
The business partners must pay fair wages, adhere to maximum working hours as per local laws, and
ensure a living wage in accordance with local conditions.
4.6.SAFETY IN THE WORKPLACE
ALCAR’s business partners are expected to ensure the physical and mental well-being of their employees,
which includes providing a safe and healthy working environment and adhering strictly to safety
regulations. They must guarantee compliance with labour protection laws and adhere to health and safety
specifications. Additionally, they are responsible for providing suitable occupational safety equipment
and organizing occupational safety training courses for their employees. The business partners must ensure
the organization of a safe working environment and promote employee health. In the event of any incidents
contrary to safety measures, immediate countermeasures should be initiated.
5. ENVIRONMENTAL & CLIMATE PROTECTION
5.1.ENVIRONMENTAL PROTECTION IN THE WORKPLACE
ALCAR’s business partners are required to comply with all relevant laws and expected to adhere to
international environmental standards. They should use natural resources sparingly and responsibly,
striving to minimize the negative impact of their business activities on the environment, climate,
biodiversity, and water scarcity.
Additionally, business partners are expected to implement suitable management systems to mitigate
environmental and safety risks while enhancing existing environmental and safety standards. Compliance
with applicable legal provisions concerning product safety, integrity, handling of hazardous substances,
goods, and waste, as well as product labelling and packaging, is mandatory. Products should not contain
any features aimed at circumventing legal or regulatory requirements.
Furthermore, business partners are encouraged to promote the development and adoption of energyefficient and environmentally friendly technologies. They should strive to minimize waste and emissions
into the air, water, and soil, and utilize natural resources efficiently.
5.2.ANIMAL WELFARE
ALCAR and its business partners adhere to nationally and internationally applicable legal standards
regarding animal welfare and protection. They also follow recognized frameworks that define ethical
principles in this regard.
Code of Conduct Business Partners (EN) 2024 04 26v1
Page 6
5.3.CONFLICT MINERALS
The business partners must take appropriate measures to prevent the use of raw materials in their products
that directly or indirectly contribute to human rights violations, corruption, financing of armed groups, or
similar detrimental effects. They undertake to comply with all applicable laws and regulations regarding
conflict minerals and must be able to provide information on the origin and supply chain of conflict
minerals.
6. REGULAR AUDITS
ALCAR reserves the right to conduct inquiries, audits, or other procedures to assess its business partners.
7. LEGAL CONSEQUENCES FOR BUSINESS PARTNER IN THE EVENT OF
VIOLATIONS OF THE CODE OF CONDUCT
Violations of the standards outlined in this Code of Conduct for Business Partners, especially those
concerning human rights, environmental protection, and legal obligations, must be promptly rectified.
Our Business Partners are required to promptly notify ALCAR to identify appropriate remedial actions for
any identified risks or violations. They must adopt effective controls and measures to prevent their
recurrence. Should Business Partners fail to adequately address the issue within a reasonable period,
ALCAR reserves the right to terminate the business relationship for cause, without further notice, and
without prejudice to any other legal or contractual rights.
8. RESPONSIBILITY FOR COMPLIANCE
We expect our business partners to commit to complying with our principles and to develop and implement
appropriate and effective processes to address and prevent identified risks and violations, as well as to
identify potential risks. The Code of Conduct does not preclude ALCAR and its business partners from
establishing more detailed and stringent requirements, either contractually or individually through their
respective internal governance documents.
9. WHISTLEBLOWER AND GRIEVANCE PROCEDURES
The business partners are expected to facilitate their employees and stakeholders in raising concerns or
reporting potentially unlawful practices or violations of this Code of Conduct for business partners without
fear of retaliation. They may establish their own whistleblowing system or participate in an industry-wide
system.
Additionally, business partners are expected to inform their employees about ALCAR’s whistleblower and
grievance system, which can be accessed on the ALCAR website or by emailing human.rights@alcarwheels.com.
Code of Conduct Business Partners (EN) 2024 04 26v1
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BUSINESS PARTNER DECLARATION
We hereby confirm our shared commitment to respect, comply with, and apply the values outlined in this
ALCAR Group Business Partner Code of Conduct.
Should any point of this Code of Conduct be unfillable now or in the future, we undertake to promptly
inform ALCAR in writing.
ALCAR Code of Conduct Employees (EN) 2024 04v1
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DEAR COLLEAGUES,
Increasing globalization, rising competition, and worldwide socio-political and climate challenges: Never
before has it been so important for an international company to act according to uniform standards. For
the ALCAR Group, it is inherent to act correctly, responsibly, and as a role model. Therefore, in addition
to our corporate values, we have established a Code of Conduct, which provides binding principles and
rules for all employees of ALCAR.
As a reliable partner, we also feel responsible for how we conduct ourselves in our dealings with
customers, suppliers, employees, and other business partners. Our Code of Conduct supports the
employees of the ALCAR Group understand their individual responsibilities when carrying out their
business activities. It provides the basis for morally, ethically, and legally sound conduct by all employees
of the Group.
Our employees are an essential part of our corporate success and play an important role in furthering our
reputation and the trust placed in us. It is exactly for this reason that it is important for us to define
unequivocal guidelines and principles for business ethics and morals based, materially, on the present
Code of Conduct. When we all act in accordance with these guidelines, this Code of Conduct becomes
an integral part of our corporate culture.
Hirtenberg, April 2024
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1 PREAMBEL
The ALCAR Group operates in a complex landscape of social, political, and legal frameworks due to its
international activities, which must be adhered to. Violations of these frameworks, particularly those
against a country’s legal system, can incur significant financial losses for the company and severely
damage its reputation.
The current Code of Conduct serves as the foundation for all business actions and decisions within the
ALCAR Group. It establishes the basis for morally, ethically, and legally impeccable conduct by all
employees of the corporation.
In the event of a breach of legal regulations, internal policies, directives, or provisions of this Code of
Conduct, every employee must expect disciplinary consequences. Furthermore, violations may result in
criminal and civil repercussions, such as claims for damages and liability.
The Code of Conduct is subject to periodic review and may be supplemented with specific guidelines,
possibly applicable only to certain countries or regions, as needed.
2 SCOPE OF APPLICATION
This Code of Conduct applies to all employees of the ALCAR Group, including Members of the
Management Board, managing directors, and other executives of the ALCAR Group (hereinafter the
“employees”). In their employment contract, new employees must agree to comply with this Code of
Conduct.
The ALCAR Group comprises all companies in which ALCAR Holding GmbH directly or indirectly holds at
least 50% of the share capital or over which it exerts control in another manner.
In addition, this Code of Conduct shall be brought to the attention of any other company in which ALCAR
Holding GmbH directly or indirectly holds at least 25% of the share capital, but over which it has no
control, with the request that such company expressly acknowledge the Code of Conduct as part of its
corporate decision-making structures.
It is in ALCAR’s interest to demand morally, ethically, and legally impeccable behavior, not only from its
own employees, but also from suppliers of goods and services, business intermediaries, consultants, and
other business partners (hereinafter “business partners”). For this reason, ALCAR employees must work to
ensure that business partners accept and comply with the separate “Code of Conduct for Business
Partners.”
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3 RESPONSIBILITY FOR IMPLEMENTATION
Each individual employee is responsible for complying with and implementing the Code of Conduct.
The way the Group’s executives implement the Code of Conduct should serve as a role model for all
employees. They are also responsible for instructing their employees on how to handle the Code of
Conduct, monitoring compliance, and, when necessary, providing training with the support of the relevant
corporate authorities.
When interpreting the rules of the Code of Conduct, employees should also rely on common sense and
question whether a specific course of action could be subject to criticism based on reasonable ethical and
moral standards. Above all, the country-specific standards and customs must be considered. In the
presence of legal regulations, there is no room for discretion.
In case of uncertainties or questions, employees can seek advice and decision-making support from their
direct supervisors.
4 COMPLIANCE & RESPONSIBLE CORPORATE GOVERNANCE
4.1 COMPLIANCE WITH LAWS AND OTHER REGULATIONS
In all business actions and decisions, employees must strictly adhere to the applicable laws and other
external and internal regulations of the corporation.
All employees are required to thoroughly familiarize themselves with the laws, regulations, and internal
policies and directives applicable to their respective areas of responsibility. In cases of doubt, they should
contact the relevant authorities (see section 3).
4.2 COMPETITION & ANTITRUST LAW
Transparent and fair behaviour in the market ensures the interests of both individual group companies and
employees, as well as the overall competitiveness of the ALCAR Group in the long term. Restrictions on
free competition and violations of competition and antitrust laws are inconsistent with the corporate
philosophy, culture, and self-image of the ALCAR Group.
Violations of national or international antitrust laws can have serious consequences for the ALCAR Group
and the affected employees. They may lead to significant fines and damages payments, and in some
countries, even imprisonment for employees. Both oral agreements and coordinated behaviours are
subject to penalties, just as written agreements are.
As part of business activities, all employees are required to adhere to the following behavioural guidelines
in particular:
• No agreements with competitors may be made regarding business matters that determine or
influence competitive behaviour. This applies especially to agreements and arrangements aimed
at or resulting in the fixing of prices, price components, or production capacities, the allocation
of markets or customers, or the boycott of a customer or other market participants.
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• In conversations or other contacts with competitors, no information about confidential matters such
as prices, price components, sales conditions, costs, production capacities, utilization rates,
inventory levels, or similar confidential information should be exchanged, even unilaterally.
Membership and activities in associations, professional associations, or other industry organizations can
be an important basis for representing the interests of industry and business groups in national and
international legislation and for preparing standardization activities. However, members of such
associations, professional associations, or industry organizations are usually competitors.
Against this background, ALCAR has established strict rules for membership and activities in associations,
professional associations, or other industry organizations, regardless of whether they are voluntary or
mandatory memberships. These rules include, among other things, that memberships in such organizations
must be approved by the managing director of the respective sales company. Employees working in sales
require permission from the ALCAR Group management to participate in any kind of meetings or events
organized by such organizations.
4.3 PREVENTION OF BRIBERY, CORRUPTION, AND ACCEPTANCE OF GIFTS
All employees are strictly prohibited from both directly and indirectly offering or accepting advantages if
they are intended to influence business transactions in an impermissible manner or if such an impression
could arise. The only exceptions to this rule are gifts of nominal value and hospitality within the framework
of customary business practices. All other gifts must be declined or returned, and the supervisor must be
informed accordingly.
Offering or accepting money or monetary benefits is strictly prohibited under any circumstances.
Country-specific laws and customs must always be considered.
4.4 MONEY LAUNDERING
Various states, including the states of the European Union and the United States, have enacted laws
against money laundering. All employees are prohibited from taking actions alone or in collaboration
with third parties that violate anti-money laundering regulations. Money laundering specifically refers to
the infiltration (e.g., through exchange or transfer) of funds or other assets derived from criminal activities
into the legal financial and economic cycle.
4.5 CONFLICT OF INTEREST
In the course of business activities, it is possible for employees to encounter situations where their personal
or financial interests may conflict with the interests of the ALCAR Group or may potentially do so. In such
situations, ALCAR expects its employees to act solely in the interest of ALCAR. Since such conflicts of
interest cannot always be avoided, ALCAR obliges its employees to handle such issues transparently.
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Every employee is required to disclose any current or potential conflicts of interest promptly and fully to
their respective supervisor, even if only the appearance of such a conflict could arise, and to seek special
approval if necessary.
Conflicts of interest may arise particularly in connection with the following aspects:
• Secondary activities may contradict duties at ALCAR or lead to a conflict of interest. Therefore,
secondary activities with competitors, customers, or business partners are prohibited. In all other
cases, they require prior written approval from the supervisor with notification to the relevant HR
department.
• Financial involvement with competitors, customers, or business partners of ALCAR (excluding
minor shareholdings in publicly traded companies as long as they correspond to normal asset
management) is not permitted. Such investments by close relatives must be disclosed in writing to
the respective supervisor. Close relatives include the spouse or life partner of the employee, their
parents, siblings, and children, as well as other individuals who have lived in the same household
as the employee for at least one year.
• Transactions with customers or business partners of ALCAR, in which individuals involved in the
decision-making process on the side of the customers or business partners, or the direct negotiating
partners, are close relatives, must also be reported in a timely manner before commencing
contract negotiations.
4.6 DATA PROTECTION
Companies within the ALCAR Group process personal data of employees, customers, and business
partners as part of their business activities. ALCAR takes the protection of personal data very seriously.
The processing of personal data (such as collection, use, disclosure, publication, and storage) is only
permissible in compliance with legal provisions and ALCAR’s data protection policies. All employees are
required to handle personal data carefully and conscientiously.
4.7 TRADE CONTROLS AND SANCTIONS
International trade is a key component of the ALCAR Group’s business strategy. Therefore, it is essential
for group companies and all employees to conduct their activities in accordance with and in compliance
with relevant trade control and sanction regulations in all countries where group companies or their
employees operate. To ensure this, employees take necessary precautions to prevent violations of these
regulations and requirements – this includes measures to prevent circumvention by suppliers or customers,
in addition to applicable regulations on import, export, and customs.
4.8 CONFLICT MINERALS
Employees are also required to apply due diligence measures regarding conflict minerals (tin, tantalum,
tungsten, and gold) and to support the efforts of their customers and business partners to avoid the use of
raw materials whose proceeds directly or indirectly finance armed groups that violate human rights.
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4.9 SECRECY OF CONFIDENTIAL INFORMATION
Any confidential information obtained during professional activities, including information outside one’s
own area of responsibility, must not be used for pursuing personal interests or made accessible for the
benefit of third parties.
It is essential to ensure that all types of company information (documents, excerpts, files, drawings, plans,
forms, etc., including reproductions on paper as well as electronic or other storage media) are securely
stored at all times. If such information needs to be taken outside the company for business reasons, it must
be secured against access or inspection by third parties.
Strict confidentiality must be maintained regarding all operational and business secrets as well as group
and company-relevant matters, including research and development processes, acquisition strategies or
goals, significant investments, or divestments, regardless of their source of information. When involving
external customers or business partners (e.g., suppliers, consultants), appropriate confidentiality
agreements must be concluded.
Information from which operational and business secrets can be deduced must also be treated
confidentially and made accessible only to those employees who require it for their professional activities.
They must be securely stored by the employees. This also applies to information in which contractual
partners of the ALCAR Group have an interest in confidentiality, especially if a corresponding
confidentiality agreement has been concluded.
The obligation of confidentiality continues without restriction even after termination of the employment
relationship.
Furthermore, the relevant confidentiality provisions of the respective employment contracts apply.
4.10 INTELLECTUAL PROPERTY
Intellectual property (including patents, trademarks, know-how, copyrights, etc.) is among our most
valuable resources. To maintain our competitive edge, all employees are obligated to protect intellectual
property and prevent competitors or other unauthorized third parties from accessing this knowledge. At
the same time, ALCAR respects the intellectual property and know-how of our competitors, customers, and
business partners.
4.11 PROTECTION OF CORPORATE PROPERTY & IT USE
The property and resources of the ALCAR Group must be used properly and carefully by employees and
protected against loss, theft, or misuse. Communication facilities of the ALCAR Group, such as internet,
intranet, and email, as well as all work tools, are intended for business requirements. Separate regulations
for private use apply, as established by individual group companies.
In the context of IT usage, guidelines and security provisions must be adhered to limit general risks. IT
devices (PCs, notebooks, etc.) must always be stored appropriately and secured with access protection
ALCAR Code of Conduct Employees (EN) 2024 04v1
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(e.g., password) to the extent technically possible. Personal passwords must not be shared with other
employees or third parties. Clear and verifiable regulations must be established for substitutions.
If company-related data is stolen or cannot be found, an immediate report must be made to the respective
supervisor. In the case of electronic data, access permissions must be blocked, or other appropriate steps
taken promptly in consultation with the relevant IT department. In the case of personal data, the reporting
process established in the data protection organizational policy must also be followed.
4.12 CORPORATE COMMUNICATIONS
All press releases and other information intended for the public from the ALCAR Group or individual group
companies are exclusively issued by the respective managing directors or communication representatives.
This applies to both traditional and digital communication channels.
5 SOCIAL RESPONSIBILITY
5.1 RESPECTING HUMAN RIGHTS & WORKING CONDITIONS
The corporate culture of ALCAR acknowledges and embraces the uniqueness and value of every
individual, respecting their individual abilities. Based on the International Bill of Human Rights, the UN
Guiding Principles on Business and Human Rights, the principles of the UN Global Compact, and the core
labour standards of the International Labor Organization (ILO), we consider human rights as fundamental
values that all employees must adhere to.
5.2 PROHIBITON OF CHILD LABOR
The ALCAR Group is committed to combating all forms of child labour. Beyond the prohibition of child
labour, it must be ensured that the employment of young workers does not endanger their health, safety,
or development.
5.3 FORCED AND COMPULSORY LABOR, HUMAN TRAFFICKING, AND MODERN
SLAVERY
At ALCAR, we are strictly opposed to forced labour, compulsory labour, human trafficking, and modern
slavery. Forced and compulsory labour specifically refers to any work or services that are not voluntarily
performed, or are obtained through coercion, including the withholding of identification documents,
restrictions on movement, and debt bondage.
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5.4 COLLECTIVE BARGAINING AND THE RIGHT TO FREEDOM OF ASSOCIATION
Furthermore, depending on the applicable law, the ALCAR Group acknowledges the freedom of
association and the right of employees to join trade unions, form workers‘ representations, and negotiate
collective agreements or similar inter-company agreements.
5.5 DIVERSITY, EQUAL OPPORTUNITIES, AND BAN ON DISCRIMINATION
ALCAR stands for equal opportunities and respect. Therefore, we refrain from any form of discrimination
based on gender, marital or parental status, ethnic or national origin, age, disability, sexual orientation,
religion, or other personal characteristics. The principle of respect towards our fellow human beings also
extends to all forms of sexual harassment, such as overt advances, demeaning comments, jokes, vulgar
language, suggestive gestures, or the display of inappropriate material in the business and production
facilities of the group. Such behaviour may be considered harassment even if not intended as such.
5.6 REMUNERATION
Employee compensation must comply with applicable legal and collective bargaining regulations and be
sufficient to cover the basic needs of employees and their families, enabling them to achieve a decent
standard of living.
5.7 WORKING HOURS
Clear guidelines for employee working hours must be established, adhering to legal requirements and
mitigating excessive mental and physical fatigue among employees.
5.8 LOCAL COMMUNITIES AND INDIGENOUS PEOPLES
ALCAR expects all employees to support local communities and indigenous peoples in the vicinity of
ALCAR Group companies. Specifically, efforts should be made to avoid any negative impacts of ALCAR’s
business activities on the health, safety, and livelihoods of local communities and indigenous peoples.
5.9 SECURITY PERSONNEL
Wherever we employ security personnel to protect ALCAR Group facilities, we ensure that they respect
human rights and adhere to our code of conduct. When engaging public and private security service
providers, appropriate measures must also be taken to ensure that the rights of all parties involved are
upheld by the respective security service.
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5.10 DONATIONS AND SPONSORSHIPS
ALCAR is committed to social responsibility through various means. Companies within the ALCAR Group
are permitted to provide monetary and in-kind donations, primarily to support humanitarian and social
projects, as well as cultural and scientific institutions, and educational initiatives.
Such financial contributions must not be made to circumvent other provisions of the Code of Conduct or
applicable guidelines of the ALCAR Group. ALCAR does not make any donations or other financial
contributions to politicians, political parties, party-affiliated organizations, or organizations pursuing
political, non-exclusively social agendas. This includes advertisements in party media or media outlets of
party-affiliated organizations.
5.11 WORKPLACE SAFETY
Safety and health of employees are central core values for ALCAR and have top priority. Continuous
improvements of the working environment as well as diverse prevention and health measures form the
foundation of the successful health & safety corporate culture of the ALCAR Group. All employees are
responsible for promoting safety and health protection in their work environment and for adhering to safety
standards, guidelines, and regulations for occupational health and safety. This also applies to companies
and their employees acting on behalf of ALCAR.
5.12 HUMAN RIGHTS IN THE SUPPLY CHAIN
These principles also apply to our conduct towards customers and business partners. Furthermore, we are
committed to ensuring that our business partners—especially our direct suppliers—take appropriate
measures to identify and, if necessary, eliminate or minimize risks to human rights compliance.
6 ENVIRONMENT & CLIMATE PROTECTION
Sustainable production practices, responsible resource management, and the use of state-of-the-art
technologies are integral to the corporate philosophy and operational activities of the ALCAR Group. At
the same time, these principles form the basis for the claim to long-term leadership in product and service
quality. All areas of the production chain are geared towards the efficient use of resources (especially raw
materials and energy) and the minimization of environmental impacts of processes and products. Intensive
research into the development of environmentally friendly steel and aluminium processing processes and
products, measures to increase efficiency, reduce emissions, and save energy, as well as transparent and
efficient environmental management, enable the sustainable minimization of the environmental impacts of
the processes and products of the ALCAR Group.
Employees of the ALCAR Group are required to comply with all relevant environmental laws and
regulations as well as internationally recognized environmental standards.
ALCAR commits to the goals of the Paris Climate Agreement, improving its carbon footprint through a
commitment to low-carbon production and extensive research and development of new technologies, and
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aims for long-term carbon neutrality. However, the ALCAR Group not only ensures the minimization of
environmental impacts in its own plants and subsidiaries but also requires its business partners—especially
its immediate suppliers—to do the same.
7 REPORTING MISCONDUCT
Employees of the ALCAR Group may encounter violations of the Code of Conduct, other internal policies
and regulations, or legal requirements. The ALCAR Group encourages all employees who observe or
suspect such violations, without fear of retaliation, to report them to one of the following channels:
• Reporting to their immediate supervisor.
• Reporting to the management or the relevant legal or human resources department of the
respective group company.
• Reporting through the web-based whistleblowing system, which can be anonymously used by
both employees and external whistleblowers: https://alcar-group.hintbox.at/
In order to encourage trusted communication, it is expressly stated that employees who report violations
of laws, the Code of Conduct, or other internal rules and regulations in good faith will not face reprisals
or negative repercussions of any kind whatsoever as a consequence of their actions. The foregoing also
applies to any other person furnishing important information of this kind pertaining to the investigation of
misconduct. However, the ALCAR Group expressly reserves the right to take disciplinary action against
employees who raise false accusations deliberately or through gross negligence.
In principle, compliance violations should be openly identified, i.e., the name of the party reporting the
violation should be reported. Where requested, whistleblowers are assured full confidentiality when
reporting a violation under their name.
