Code of Conduct

1 Introduction

The Code of Conduct and Ethics of G-SMT Hungary Kft. (company registration number: 20-09-074008; tax number: 24816184-2-20; registered office: HU-8315 Gyenesdiás, Toldi Miklós utca 5.; hereinafter: “the Company”) sets out the fundamental principles and behavioural standards applicable to all employees, managers, and suppliers (hereinafter collectively referred to as the Parties).

The Parties

  1. are required to comply with this Code and all applicable laws related to its subject matter in the course of any business or professional interaction with the Company, and
  2. must impose these same obligations on their own suppliers to ensure full compliance with every provision of the Code.

2 Core Principles

  • Integrity and honesty: All activities must be conducted transparently and ethically.
  • Responsibility: Employees and suppliers must act responsibly and safeguard the interests of the Company.
  • Respect: All colleagues, partners, and customers must be treated with dignity and respect.

Safety: Maintaining a safe working environment is a shared responsibility.

3 Scope and Validity

This Code shall remain in force from the date of its adoption until its revocation. Any amendments made in the meantime shall be incorporated into the Code in a uniform structure. The Code published by the Company shall in all cases be considered the Code currently in force.
This Code has been prepared in both Hungarian and English. In the event of any discrepancy between the two versions, the Hungarian version shall prevail.

4 Legal Compliance

It is a fundamental expectation and requirement of the Company that both the Company itself and all parties having a contractual relationship with it comply with all applicable laws and regulatory requirements relevant to their activities and act in accordance with this Code.

5 Freedom of Conviction

The involved people in the operation of the Company must, when expressing their personal convictions or opinions, avoid making references to the Parties and must refrain from presenting their views as representing the position of the Company or any of the Parties.

6 Provisions Specific to Suppliers

The Company operates as a determined and fair competitor, conducting its activities in accordance with both the written and unwritten rules of fair competition and in compliance with applicable competition law. Information about competitors is collected exclusively by lawful means and only from publicly available sources, for the purpose of understanding business, consumer, supplier, and technological trends, legislative developments, and the activities of suppliers and competitors.

  • The supplier confirms that all information provided to the Company during any stage of becoming an approved supplier is accurate and truthful.
  • The supplier must respond to any Company inquiries related to compliance with this Code. The Company has the right to verify compliance through supplier audits, with reasonable prior notice, and may involve third-party auditors if:
    1. the Company suspects non-compliance,
    2. required by the Company’s own audit or reporting obligations, or
    3. justified by any other reasonable and legitimate purpose.
  • The supplier must provide all necessary cooperation, information, and documentation required for the audit. Audits may cover topics beyond those explicitly set out in this Code, including matters directly or indirectly related to lawful and ethical operation.
  • If the supplier breaches any obligation under this Code, it must take reasonable corrective measures to remedy the deficiency. The Company may cooperate with the supplier in this process. If the deficiency is not remedied in a timely manner, the Company is entitled to terminate the contract with immediate effect.
  • The supplier acknowledges that the Company conducts its activities in accordance with the principles of fair competition and applicable competition law and expects its suppliers to adhere to the same principles.
  • Suppliers must refrain from any conduct that violates the principles of fair competition.

7 Anti-Corruption Requirements

  • The Parties must not offer, give, or promise money or anything of value—directly or through a third party—to obtain an undue advantage for themselves or for the Company. Example: paying a customs officer to overlook discrepancies in import documents.
  • The Parties may give only low-value gifts to Company employees in accordance with local customs, provided that the value of such gifts never exceeds EUR 50 and does not create the appearance of a conflict of interest or undue influence.
  • The Parties must not engage in business with the Company where an undisclosed conflict of interest exists. If a personal relationship (relative, partner, and friend) could create such a conflict involving the Company or its employees, the Party must immediately notify its Company contact and refrain from any business activity until the Company has reviewed and approved or resolved the situation.

8 Foreign Trade and Sanctions

  • The Parties must comply with all applicable trade and economic sanctions and restrictions.
  • They must obtain all required licences for the export of items subject to export control, including dual-use goods.
  • The Parties must follow international standards concerning the sourcing of conflict minerals (gold, tantalum, tin, and tungsten) originating from conflict-affected regions.

9 Data Protection

  • The Parties must comply with all applicable data protection laws and regulations when processing personal data relating to the Company or its employees. Personal data must be handled confidentially and securely and shared only with persons for whom such access is strictly necessary or required by law.

10 Climate and Environmental Protection

The Parties shall:

  • Take practical measures to minimise their environmental and climate impact.
  • Reduce pollution and other adverse environmental effects by limiting and controlling emissions to water, soil, and air, including air pollutants, ozone-depleting substances, gases, noise, vibration, odours, and light.
  • Use water efficiently and recycle it where possible, especially in water-scarce regions.
  • Reduce the use of hazardous chemicals, actively work to replace them, and where feasible substitute substances of very high concern (SVHCs) with more sustainable alternatives.

11 Health and Safety

The Parties must ensure a safe and healthy working environment for their employees by:

  • Proactively identifying hazards and risks.
  • Taking adequate preventive measures and providing all necessary protective equipment.
  • Investigating incidents and implementing corrective actions.
  • Providing simple, clear, and accessible safety instructions and the required protective gear.

12 Labour Rights, Non-Discrimination, and Harassment

The Parties must ensure that wages, working hours, and rest periods comply with applicable labour laws and international labour standards, and that equal opportunities are ensured, and all forms of discrimination and harassment are prohibited. To this end, the Parties must ensure that:

  • all forms of forced labour, slave labour, and child labour are prohibited; persons under the age of 15 may not be employed, and workers under the age of 18 may be employed only in accordance with applicable laws;
  • job applicants and employees are treated professionally, respectfully, and fairly, and their concerns are addressed accordingly;
  • no discrimination occurs on the basis of gender, age, origin, race or ethnic background, nationality, religion or belief, political opinion, family or personal relationship, disability, sexual identity or orientation, or membership in an employee representative organisation;
  • equal opportunities are guaranteed in recruitment, compensation, remuneration, access to training, promotion, termination of employment, and retirement; lawful positive discrimination may be applied only with due care;
  • all forms of sexual or other harassment, violence, intimidation, or threatening behaviour are strictly prohibited, regardless of how such conduct is manifested;
  • employees are free to participate in collective bargaining and/or to join or refrain from joining employee representative organisations without adverse consequences;
  • there is no involvement in human trafficking, including coercing individuals to relocate for work or transporting persons for illegal purposes;
  • the employer ensures, to the extent reasonably expected, a safe and healthy working environment, regularly monitors working conditions, and takes all necessary measures.

Any breach of this Code may result in employment-related, contractual, or other legal consequences, depending on the nature and severity of the violation.