Corporate Principles

IWG Ing. W. Garhöfer GesmbH Code of Business Principles

Since the family-owned and managed company of IWG Ing. W. Garhöfer GesmbH was
founded 60 years ago, it has been geared towards long-term growth and stability.

Profit generation is no end in itself, but serves to secure our future. We want to be as
profitably as possible, to have the economic strength which we particular need to cover the
remuneration of the staff, for our future visions und for realisation of the targets outlined
here.

Our Corporate Business Principles are:
1. We obey the laws and regulations
2. We conduct our operations with honesty, integrity and openness, and with respect for the
human rights and interests of our employees.
3. Our respect is the same for all employees - regardless of ethical origin, race, sex, religion,
ideology, disability, age or sexual identity.
4. We are committed to providing both a safe and healthy working environment for all our
employees and others affected by our activities; including customers, contractors, visitors
and the public at large.
4.1 Violence is unacceptable and is not tolerated. Harassment, bullying of colleagues, clients,
customers, suppliers, or simply people who visit our company, as well as violent,
threatening or degrading behaviour is considered as offensive action and lead to disciplinary
measures.
4.2 We do not torerate any kind of sexual or other harassment at the workplace, this covers
among other things derogatory statements and derogatory behaviour, and herewith creating
an intimidating, hostile, offensive or disturbing working environment.
4.3 We condemn gender-based violence and promote awareness of our manager to recognize
domestic, family and gender-based violence.
4.4 We provide our employees a drug-free working environment. It is strictly forbidden to report
to work under the influence of alcohol, illegal drugs or prescribed medications, if they lead
to work deterioration.
5. We firmly reject all forms of forced and compulsory labor and child labor and demand the
same from our suppliers.
6. We do not offer, give, accept or receive bribes or other improper advantages, whether
directly or indirectly, for business or private gain, whether for ourselves or for others.
7. Every employee shall ensure that his/her private interests do not come into conflict with his
responsibilities as an employee or company officer or with major interests of the company
and/or the Group

Within the scope of the annual management review the adherence to the principles is
monitored and improvements are managed by the plan of measures if required

Disciplinary action company policy
Our Disciplinary Action company policy explains how we address our employees'
misconduct or inadequate performance. Employees must be aware of the consequences of
their actions. This policy applies to all our employees.

Stages of Disciplinary action
1. Verbal warning
2. Written reprimand
3. Final written warning
4. Suspension
5. Termination
The nature of the offense must be explained to the employee from the beginning of the
procedure. The verbal warning may take the form of a simple oral reprimand but also a full
discussion if that is necessary.
The employee must read and sign the written reprimand and final written warning. These
documents include the time limit in which an employee must correct their conduct before
we take further disciplinary action.

The following scenarios indicate where the disciplinary procedure starts depending on the
violation:

Performance issues:
Disciplinary procedure starts at stage 1. It includes but is not limited to:
· Failure to meet performance objectives
· Attendance issues
· Failure to meet deadlines

Misdemeanors/One-time minor offense:
Disciplinary procedure starts at stage 1. It includes but is not limited to:
· Rude behavior to customers or partners.
· On-the-job minor mistakes.
· Involuntary Discrimination.
Ordnungswidrigkeiten/einmaliges minderschweres Vergehen:

Misconduct/Frequent offender:
Disciplinary procedure starts at stage 3. It includes but is not limited to:
· Lack of response to counseling and corrective actions.
· Lost temper in front of customers or partners.
· On-the-job major mistakes.
· Unwillingness to follow health and safety standards.

Severe offensive behavior/Felony.
Disciplinary procedure starts at stage 4. It includes but is not limited to:
· Corruption/ Bribery.
· Breach of employment agreement.
· Harassment/ Voluntary discrimination.
· Workplace Violence.
· Embezzlement/Fraud.
· Substance Abuse.

Managers may choose to repeat stages of our disciplinary procedure as appropriate. This
decision depends on employees' reaction to our disciplinary procedure, whether they repent
their behavior and the nature of their offense.

Our disciplinary procedure begins when there is sufficient evidence to justify it. When there
is suspicion or hints of misconduct, managers must investigate the matter first.

Appeals are allowed and must be filed to the next line of management as soon as possible.
Managers should document every stage of our disciplinary procedure (except the verbal
warning.) If appropriate, include necessary information like evidence, testimonies and
employee’s progress or improvement.

We have the right to modify this policy or act in any other legal or reasonable way as each
case demands.

Grievance Procedure
It is a formalized approach to deal with specific matters of grievance and complaints at work
or concerning the work place.

A written and well publicized grievance procedure ensures that every one knows exactly
what steps need to be taken when faced with situations that adversely affect the well-being
of individual employees in terms of work relationships and work environment.

We emphasize that no retaliation or victimization will be meted on a grievant
who applies this procedure.

Rationale for a Grievance Procedure
There are few avenues for the employees to initiate expression of their dissatisfaction with
regard to their work situations. This grievance procedure is therefore meant to give
employees an opportunity to alert the management of difficult situations to allow for
intervention and search for solutions so as to make the working environment conducive for
sound performance by all employees.

Application of the Procedure
The grievance procedure is intended for employees who have a grievance or complaint
about:
· Their work or conditions of employment
· Harassment and bullying
· Management act or failure to act which affects them individually
· Discrimination on the basis of gender, ethnicity, disability or other unjustified
grounds in the workplace.

Main stages of the procedure:
Stage 1: Grievance at head of department
An employee who has any grievance or complaint should raise it with his/her Head of
Department in writing by completing the Grievance Form. The Head of the Department will
give an answer as soon as possible and within a maximum of seven working days.

Stage 2: Final Appeal Level
If the matter is unresolved at stage 1 the aggrieved employee can appeal in writing to the
CEO. The CEO will at his discretion arrange a personal interview with the aggrieved officer
and will give a written reply to the latter within fourteen working days.
The personnel department is responsible for monitoring the effectiveness of the grievance
procedure.In addition it will receive the grievance forms at the conclusion of the grievance
procedures, for records and for future reference if need arises.

OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk Areas

1. While sourcing from, or operating in, conflict-affected and high-risk areas, we will
neither tolerate nor by any means profit from, contribute to, assist with or facilitate
the commission by any party of:
i) any forms of torture, cruel, inhuman and degrading treatment;
ii) any forms of forced or compulsory labour, which means work or service
which is exacted from any person under the menace of penalty and for which
said person has not offered himself voluntarily;
iii) the worst forms of child labour;
iv) other gross human rights violations and abuses such as widespread sexual
violence;
v) v) war crimes or other serious violations of international humanitarian law,
crimes against humanity or Genocide.
2. We will immediately suspend or discontinue engagement with upstream suppliers
where we Identify a reasonable risk that they are sourcing from, or linked to, any
party committing serious abuses as defined in paragraph 1.
3. We will not tolerate any direct or indirect support to non-state armed groups through
the extraction, transport, trade, handling or export of minerals. “Direct or indirect
support” to non-state armed groups through the extraction, transport, trade,
handling or export of minerals includes, but is not limited to, procuring minerals
from, making payments to or otherwise providing logistical assistance or equipment
to, non-state armed groups or their affiliates who:
i) illegally control mine sites or otherwise control transportation routes, points
where minerals are traded and upstream actors in the supply chain; and/or
ii) illegally tax or extort6 money or minerals at points of access to mine sites,
along transportation routes or at points where minerals are traded; and/or
iii) illegally tax or extort intermediaries, export companies or international
traders.
4. We will immediately suspend or discontinue engagement with upstream suppliers
where we identify a reasonable risk that they are sourcing from, or linked to, any
party providing direct or indirect support to non-state armed groups as defined in
paragraph 3.
5. We agree to eliminate, in accordance with paragraph 10, direct or indirect support to
public or private security forces who illegally control mine sites, transportation routes
and upstream actors in the supply chain; illegally tax or extort money or minerals at
point of access to mine sites, along transportation routes or at points where minerals
are traded; or illegally tax or extort intermediaries, export companies or international
traders.
6. We recognise that the role of public or private security forces at the mine sites
and/or surrounding areas and/or along transportation routes should be solely to
maintain the rule of law, including safeguarding human rights, providing security to
mine workers, equipment and facilities, and protecting the mine site or transportation
routes from interference with legitimate extraction and trade.
7. Where we or any company in our supply chain contract public or private security
forces, we commit to or we will require that such security forces will be engaged in
accordance with the Voluntary Principles on Security and Human Rights. In
particular, we will support or take steps, to adopt screening policies to ensure that
individuals or units of security forces that are known to have been responsible for
gross human rights abuses will not be hired.
8. We will support efforts, or take steps, to engage with central or local authorities,
international organisations and civil society organisations to contribute to workable
solutions on how transparency, proportionality and accountability in payments made
to public security forces for the provision of security could be improved.
9. We will support efforts, or take steps, to engage with local authorities, international
organisations and civil society organisations to avoid or minimise the exposure of
vulnerable groups, in particular, artisanal miners where minerals in the supply chain
are extracted through artisanal or small-scale mining, to adverse impacts associated
with the presence of security forces, public or private, on mine sites.
10. In accordance with the specific position of the company in the supply chain, we will
immediately devise, adopt and implement a risk management plan with upstream
suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect
support to public or private security forces, as identified in paragraph 5, where we
identify that such a reasonable risk exists. In such cases, we will suspend or
discontinue engagement with upstream suppliers after failed attempts at mitigation
within six months from the adoption of the risk management plan.8 Where we
identify a reasonable risk of activities inconsistent with paragraphs 8 and 9, we will
respond in the same vein.
11. We will not offer, promise, give or demand any bribes, and will resist the solicitation
of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees
and royalties paid to governments for the purposes of mineral extraction, trade,
handling, transport and export.9
12. We will support efforts, or take steps, to contribute to the effective elimination of
money laundering where we identify a reasonable risk of money-laundering resulting
from, or connected to, the extraction, trade, handling, transport or export of minerals
derived from the illegal taxation or extortion of minerals at points of access to mine
sites, along transportation routes or at points where minerals are traded by upstream
suppliers.
13. We will ensure that all taxes, fees, and royalties related to mineral extraction, trade
and export from conflict-affected and high-risk areas are paid to governments and,
in accordance with the company’s position in the supply chain, we commit to
disclose such payments in accordance with the principles set forth under the
Extractive Industry Transparency Initiative (EITI).
14. In accordance with the specific position of the company in the supply chain,
we commit to engage with suppliers, central or local governmental authorities,
international organisations, civil society and affected third parties, as appopriate, to
improve and track performance with a view to preventing or mitigating risks of
adverse impacts through measureable steps taken in reasonable timescales. We will
suspend or discontinue engagement with upstream suppliers after failed attempts at
mitigation.