The management of HEINRICHSTHALER MILCHWERKE GmbH, represented by the undersigned persons, establishes the following code for its purchasing organization:

Preamble

The business practices of HEINRICHSTHALER MILCHWERKE GmbH are based on values characterized by openness, honesty, clarity, commitment and responsibility. These five core values describe the principles that consistently guide our business activities.  

Based on these values, HEINRICHSTHALER MILCHWERKE GmbH is committed to ecologically and socially responsible corporate management. We firmly believe that a company founded on these values offers the guarantee of sustainable value creation and innovative products and application solutions for the challenges of the future. For us, being committed to these values means taking responsibility for our customers, our employees and protecting the environment.

We expect our employees* to observe the principles of ecological, social and ethical behavior in the course of their work, thereby integrating these principles into the corporate culture of HEINRICHSTHALER MILCHWERKE GmbH.

We also expect all those with whom we conduct business to accept these fundamental values and to behave in accordance with them.

For future cooperation with our contractual partners, we agree to the validity of the following provisions of a joint code of conduct. This agreement serves as the basis for all future deliveries. The contractual partners undertake to comply with the principles and requirements of the code of conduct and to endeavor to oblige their subcontractors to comply with the standards and provisions set out in this document. We expect our suppliers to share this commitment as their own and to make reasonable efforts to promote compliance with the principles of this code among their own suppliers and subcontractors.

Any violation of this code of conduct may ultimately constitute grounds and cause for HEINRICHSTHALER MILCHWERKE GmbH to terminate business relations, including all associated supply contracts.

* General note: The terms “employee” and “worker” refer to any gender in the following text.

Compliance with laws and regulations

The Code of Conduct is based on national 

laws and regulations such as the Supply Chain Due Diligence Act (LkSG) as well as international agreements such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children’s Rights and Business, the United Nations Guiding Principles on Business and Human Rights, the International Labor Organization’s international labor standards, and the United Nations Global Compact.

The provisions of these regulations and all other relevant legal provisions must be complied with. If legal provisions or other rules apply in individual countries in which the supplier operates that deviate from the requirements of the Code, the stricter requirements must be complied with.

Compliance and Integrity

HEINRICHSTHALER MILCHWERKE GmbH expects its suppliers to comply with all applicable laws and regulations concerning corruption, bribery, fraud and prohibited business practices. In particular, the following must be ensured:

Anti-corruption

The supplier shall ensure that its employees and subcontractors comply with anti-corruption laws and, in particular, do not offer, promise or grant any benefits to employees of HEINRICHSTHALER MILCHWERKE GmbH with the aim of obtaining an order or other preferential treatment in business transactions. Invitations, gifts, or other benefits may only be granted to employees* of HEINRICHSTHALER MILCHWERKE GmbH or persons close to them if they are of insignificant financial value and correspond to customary business practices.

Fair competition

HEINRICHSTHALER MILCHWERKE GmbH expects its suppliers to behave fairly in competition and to comply with applicable antitrust laws and in particular to refrain from agreements and other activities that influence prices or conditions when dealing with competitors. Furthermore, these regulations prohibit agreements between customers and suppliers that are intended to restrict customers’ freedom to determine their prices and other conditions autonomously when reselling. Individual suppliers shall neither participate in agreements with competitors that violate antitrust laws nor abuse any dominant market position they may have.

Money laundering

The supplier does not participate in money laundering activities and complies with the relevant legal obligations regarding money laundering prevention.

Confidentiality/Data Protection/Intellectual Property

HEINRICHSTHALER MILCHWERKE GmbH expects its suppliers to protect all private and business information about themselves, their suppliers, customers, consumers, and employees. When collecting, storing, processing, transmitting and disclosing personal information, the supplier must comply with data protection and information security laws and regulations. Intellectual property rights must be respected; technology and know-how transfer must be carried out in such a way that the intellectual property rights of the contracting parties and all information about customers and business content are protected. Suppliers must treat business correspondence with confidentiality.

Social and working conditions

With reference to the Code of Conduct of the international Business Social Compliance Initiative (BSCI) and the conventions of the International Labor Organization (ILO), HEINRICHSTHALER MILCHWERKE GmbH expects its suppliers to recognize the fundamental rights of their employees as defined therein and to commit to complying with them and treating their employees with dignity and respect, in accordance with the understanding of the international community. In particular, the following must be ensured:

Free choice of employment / exclusion of forced labor

All employment is voluntary. Forced labor, forced prison labor, compulsory labor or human trafficking are strictly prohibited. Furthermore, unacceptable treatment of workers, such as psychological abuse, sexual harassment and humiliation, is not permitted. The use of security forces is prohibited if it results in inhumane or degrading treatment or injury to persons or impairs freedom of association.

No child labor / Protection of young people

The use of child labor is strictly prohibited in accordance with the provisions of the ILO conventions, the United Nations Convention and/or national laws. Of these various requirements, the one that imposes the strictest requirements shall apply in each case.

The minimum age for employment is 15 years.

If young people under the age of 18 are employed, their working hours must not interfere with their participation in vocational training programs recognized by the competent authorities.

Remuneration and benefits

Remuneration for regular working hours and overtime must be in line with the national statutory minimum wage or the minimum standards customary in the industry, whichever is higher. Remuneration for overtime must, in any case, exceed the remuneration for regular hours. Employees* must be granted all benefits required by law. The supplier must ensure that employees* receive clear, detailed and regular written information about the composition of their remuneration. Deductions from remuneration or other benefits as a disciplinary measure are not permitted.

Working hours

Working hours must comply with applicable laws or industry standards. Overtime is only permitted if it is voluntary and does not exceed 12 hours per week, while employees must be given at least one day off after six consecutive working days. Weekly working hours must not regularly exceed 48 hours.

No discrimination

Any form of unequal treatment of employees* is prohibited unless it is justified by the requirements of the job. This applies, for example, to discrimination based on gender, national, ethnic, or social origin, skin color, disability, health status, political beliefs, ideology, religion, age, pregnancy, or sexual orientation. HEINRICHSTHALER MILCHWERKE GmbH expects the personal dignity, privacy and personal rights of each individual to be respected.

Freedom of association and the right to collective bargaining

The supplier recognizes the right of employees* to freedom of association and collective bargaining within the limits of the law.

Working conditions / Health and safety

The supplier must provide its employees* with a safe and healthy working environment in compliance with all applicable laws, regulations, and industry standards. Harassment in the workplace will not be tolerated. All health and safety regulations applicable to the supplier’s employees* must be observed.

Appropriate occupational safety systems must be established and implemented to take the necessary precautions against accidents and damage to health that may arise in connection with the work. Excessive physical or mental fatigue must be prevented by appropriate measures.

The supplier must provide its employees with adequate working facilities and in this respect must at least provide access to drinking water and sanitary facilities and ensure that fire safety, access to emergency medical care, adequate lighting and ventilation are guaranteed.

Environmental sustainability

HEINRICHSTHALER MILCHWERKE GmbH expects its suppliers to comply with all applicable laws and regulations, as well as internationally recognized standards for environmental protection. The supplier shall take appropriate measures, including with regard to its entire supply chain, to ensure that its activities do not have a negative impact on forests, moors and other protected areas; soil quality is preserved and its impact on these is limited as far as possible; biodiversity is preserved; the protection of animals and compliance with animal welfare are taken into account; its greenhouse gases are minimized in accordance with the Paris Agreement (December 2015) and the environmental impact of packaging is reduced as far as possible.

The following measures in particular are agreed for this purpose:

• Environmental permits

The supplier shall ensure that all necessary environmental permits and approvals have been obtained for its activities, that these are kept up to date and that the stipulations and requirements specified therein are complied with.

• Resource consumption, avoidance of environmental pollution 

The supplier undertakes to optimize the consumption and conservation of natural resources, including soil, air and water. Solid measures are taken and documented to reduce resource consumption, prevent pollution and minimize the generation of waste, wastewater, soil contamination and air emissions.

All changes to the soil, water and air pollution that significantly impair the natural foundations for the preservation and production of food or harm human health must be avoided.

Wastewater shall be treated appropriately in accordance with applicable laws and regulations prior to discharge into water bodies or disposal. Wastewater from operational processes, manufacturing processes and sanitary facilities shall be classified, monitored, checked and treated as necessary prior to discharge or disposal.

• Hazardous substances and product safety

The supplier undertakes to refrain from manufacturing and using prohibited chemicals. Hazardous materials, chemicals and substances must be labeled and safe handling, movement, storage, recycling, reuse and disposal must be ensured.

All applicable laws and regulations regarding hazardous materials, chemicals and substances must be strictly followed.

Compliance with substance restrictions and product safety requirements stipulated by applicable laws and regulations is mandatory.

• Waste

The supplier undertakes to handle, collect, store, transport and dispose of waste materials exclusively in an environmentally sound manner in accordance with the laws and regulations applicable to these materials.

The supplier shall follow a systematic approach to identifying, handling, reducing and responsibly disposing of or recycling waste. The prohibitions on the export of hazardous waste in the Basel Convention of March 22, 1989, as amended, must be observed.

• Animal welfare

The applicable national laws on animal protection and animal welfare must be fully complied with.

In addition, appropriate measures must be taken to adapt the husbandry and management systems for farm animals from birth to death to the needs of the animals as far as possible and to meet the (behavioral) physiological requirements of the respective species.

• More environmentally friendly packaging

The supplier shall always strive to use more environmentally friendly packaging. To achieve this, packaging shall be avoided, reduced, or improved in terms of its environmental impact wherever possible.

Packaging is considered more environmentally friendly if it is reusable, uses as little material as possible, is recyclable, or is made from secondary raw materials, alternative materials, or certified paper.

• Climate protection 

HEINRICHSTHALER MILCHWERKE GmbH expects

its suppliers to take appropriate measures at all stages of the supply chain to reduce their carbon footprint and thus contribute to achieving the targets agreed at the UN Climate Change Conference in Paris and the 1.5-degree target set by the Intergovernmental Panel on Climate Change (IPCC).

All suppliers are encouraged to find economical solutions to improve energy efficiency and reduce energy consumption and greenhouse gas emissions.

Audit

We expect our suppliers to identify risks within their supply chains and take appropriate measures. In the event of suspected violations and to safeguard supply chains with increased risks, the supplier shall inform the company promptly and, if necessary, regularly about the identified violations and risks as well as the measures taken.

The company will verify compliance with the standards and regulations set out in this document using a self-assessment questionnaire and risk-based audits at the suppliers’ production sites.

The supplier agrees that HEINRICHSTHALER MILCHWERKE GmbH may conduct such audits once a year or for specific reasons to verify compliance with the code at the supplier’s premises during normal business hours after giving reasonable advance notice by persons appointed by it.

The supplier may object to individual audit measures if these would violate mandatory data protection regulations.

If a violation of the provisions of this Code of Conduct is identified, the company will immediately notify the supplier in writing and set a reasonable grace period for the supplier to bring its conduct into line with these provisions. If a remedy is not possible in the foreseeable future, the supplier must notify the company immediately and work with the company to develop a plan with a timetable for ending or minimizing the violation.

If the grace period expires without result or if the implementation of the measures contained in the concept does not remedy the situation after the expiry of the schedule and no milder means are available, the company may terminate the business relationship and cancel all contracts.

A statutory right to extraordinary termination without setting a grace period, in particular in the case of violations that are considered very serious, remains unaffected, as does the right to compensation.

Continuous improvement 

If a supplier meets our expectations for value-driven and responsible procurement, they will join us on a path of continuous improvement. To achieve this goal,

we will work closely together to implement the action plans and specific improvement measures developed by HEINRICHSTHALER MILCHWERKE GmbH.

The improvement measures and recommendations do not constitute business or legal advice and do not release suppliers from their obligation to consult legal advisors. Furthermore, our improvement measures and recommendations do not prevent our suppliers from taking additional measures.

Reports of violations

In the event of violations of the principles of this Supplier Code, reports can be made to the company compliance officer or via the electronic whistleblower system. Contact details and company reporting systems can be found on the homepage at Supplier Code of Conduct.

Final provisions

This Supplier Code of Conduct shall enter into force on November 1, 2025.

HEINRICHSTHALER MILCHWERKE GmbH shall review this Code regularly and make changes where necessary and appropriate. Suppliers shall always be notified of any significant changes. The current version of the Code can be found on the website www.Heinrichsthaler.de/supplier-code/.

Radeberg, 01.11.2025

Management