Supplier Code of Conduct
DKS Dienstleistungsgesellschaft für Kommunikationsanlagen
des Stadt- und Regionalverkehrs mbH
I. Preamble and Scope
As a company within the Stadtwerke Köln Group, we strive for responsible, sustainable, and ethical business relationships to actively counter the risks posed by opaque supply chains, inadequate environmental and climate protection, and unfair business practices. We actively involve our business partners in the implementation of our
corporate values from the very beginning.
We expect our business partners to adhere to the principles of this SCoC:
- comply with all applicable and valid laws
- take appropriate and necessary measures to this end on their own initiative
- work to ensure that their business partners, along their own supply chain, as well as those engaged in fulfilling their contractual obligations, are aware of and comply with our principles to the extent possible through their own contractual commitments.
The following principles are based on the UN Guiding Principles on
Business and Human Rights (UNGP), as well as on the EU regulations relevant to our business (e.g., CSDDD, CSRD/ESRS, EUDR) and the ILO Core Labor Standards. Where national regulations provide stricter standards, these shall take precedence.
Purpose and Fundamental Principles
Our company is committed to ethical, sustainable, and legally compliant supply chains.
This SCoC defines the minimum standards for all business partners, based on international frameworks such as the UN Guiding Principles on Business and Human Rights, the Supply Chain Due Diligence Act (LkSG), and the ILO Core Labor Standards. The goal is to foster a collaborative partnership that protects human rights, minimizes environmental risks, and promotes fair business practices.
II. Principles for Business Partners
Respect for and promotion of human rights, fair and safe working conditions, active environmental and climate protection, and the fight against corruption and money laundering exemplify our company’s values and form the foundation of our principles.
We expect our business partners to uphold these corporate values as well. A company expects its suppliers to share its core values and comply with all legal requirements.
1.
1. Human Rights
To respect and uphold human rights, we specifically observe and comply with the Universal Declaration of Human Rights, the UN Convention on the Rights of the Child, the UN Convention on the Elimination of All Forms of Discrimination against Women,
and the core labor standards (conventions) of the International Labor Organization (ILO).
If a national regulation sets stricter standards, it must be given priority. Suppliers are also explicitly required to respect the human rights of their employees.
a. Prohibition of Child Labor, Forced Labor, Slavery, Human Trafficking, and Forced Eviction
- We distance ourselves from and strictly reject all forms of
child labor, forced labor, exploitation, modern slavery, slave-like practices, serfdom, or other forms of domination or oppression, as well as human trafficking
throughout the entire supply chain. We also expect this from our business partners.
- Business partners must distance themselves from such practices toward their business partners and throughout the entire supply chain, and must combat them through appropriate measures, if possible, through their own contractual commitments.
- Business partners are expected not to be involved in, participate in, or profit from such practices, including through business relationships with third parties.
- Business partners must refrain from unlawful evictions and the unlawful seizure of land, forests, and water bodies in connection with the acquisition, development, or other uses of land, forests, and water bodies whose use secures a person’s livelihood. A company expects suppliers to comply with laws against child labor.
b. Diversity and Equal Treatment in the Workplace, Fair Working Conditions, Freedom of Association
- Treating employees with respect, appreciation, and support is an indispensable prerequisite for a responsible and sustainable business relationship.
- Business partners must respect general personal rights and human rights and combat discrimination, violence, sexual harassment, intimidation, bullying, or other violations in the workplace that infringe upon a person’s dignity.
- Unequal treatment of employees for example, by paying unequal wages for work of equal value or discriminating on the basis of national or ethnic origin, social background, health status, disability, sexual orientation, age, gender, marital status, political opinion, union membership, religion, or belief provided that such discrimination is not justified by the requirements of the job is prohibited.
- Employees must be paid fairly and on time. Fair pay is at least the minimum wage established by applicable law and is otherwise determined in accordance with the law of the place of employment.
- Business partners shall respect their employees’ right to freedom of association and provide both individuals and groups with appropriate grievance mechanisms at the workplace level.
c. Occupational Safety and Health
- Business partners are expected to comply with at least the fundamental labor rights set forth in the laws governing occupational safety and health applicable at the respective place of employment and recognize the core labor standards of the International Labor Organization (ILO).
- Business partners shall establish appropriate measures to prevent accidents and occupational diseases to ensure the safety and health of employees.
- They regularly assess hazards and potential health risks and take the necessary measures to address them.
- Business partners support continuous improvement to enhance workplace safety. A company expects suppliers to take responsibility for the health and safety of their employees.
2. Environmental and Climate Protection, and Raw Material
Procurement
- We view environmental and climate protection as a fundamental prerequisite for our business and business relationships. We therefore expect our business partners to protect the natural foundations of life and to use available resources responsibly. A
- company expects suppliers to comply with relevant environmental protection laws and standards.
- This applies to the efficient use of non-renewable or scarce resources, for example by promoting recycling solutions.
- Business partners should use the raw materials, energy, water, and other resources required for their operations as sparingly and purposefully as possible to contribute to environmentally sustainable development.
- Business partners must commit themselves to the goal of environmental and climate protection for present and future generations and take appropriate measures to this end.
- In compliance with applicable laws, they must take appropriate measures to protect the environment and climate, to prevent harmful soil degradation, water pollution, air pollution, harmful noise emissions, or excessive water consumption.
- This also includes compliance with the prohibition on the environmentally unsound handling, collection, storage, and disposal of waste in accordance with the provisions of the POPs Convention (Stockholm Convention on Persistent Organic Pollutants).
- If hazardous waste is imported or exported, compliance with the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal of March 22, 1989, is expected.
- When handling mercury, compliance with the provisions of the Minamata Convention on Mercury October 10, 2013, is expected.
- Business partners comply with applicable laws regarding conflict minerals throughout their own supply chains and within their business relationships. They strive for responsible sourcing of raw materials and provide proof of the origin or source of the raw materials used in their products, to avoid the use of conflict minerals.
3. Conduct in the Business Environment
We expect our business partners to compete fairly, honestly, and with integrity, and to act in a legally sound and compliant manner. We do not tolerate any form of corruption, white-collar crime, antitrust violations, or money laundering. A company expects its suppliers to refrain from corruption.
a. Compliance Measures
- An effective and appropriate Compliance Management System (CMS) is required, which supports the business unit in assessing and combating risks related to, among other things, corruption, white-collar crime, antitrust violations, and money laundering.
- The CMS must be capable of identifying risks of non-compliant behavior by executives and employees and of supporting compliance with statutory due diligence obligations.
- Business partners must have an appropriate, binding set of internal rules and guidelines in place to ensure impeccable and legally compliant conduct.
b. Anti-Corruption
- Business partners or persons acting on their behalf may neither offer, promise, or grant benefits (bribes, favors, etc.), nor may they themselves demand, accept, or be promised such benefits in order to obtain a contract or other preferential treatment.
- Gifts or other benefits that are socially inappropriate must not be given to employees of our company.
- Business partners shall comply with the conventions of the United Nations, in particular the United Nations Convention against Corruption and the Organization for Economic Cooperation and Development (OECD) Convention on Combating Bribery, as well as relevant anti-corruption laws, and shall ensure internal compliance.
- In dealings with their business partners and government institutions, the interests of the business partner and the private interests of employees on both sides are strictly separated. Actions and decisions are made free from irrelevant considerations and personal interests.
- To this end, business partners must adopt a binding guideline for dealing with business partners, which includes, among other things, rules for handling conflicts of interest as well as for accepting and giving gifts, invitations to meals, and events. This also includes, among other things, compliance with the requirements regarding public officials.
c. Conduct Toward Competitors (Antitrust Law)
- Business partners respect and promote fair competition. Therefore, they comply with applicable laws, in particular antitrust laws and other laws governing competition that protect and promote competition.
- In dealings with competitors, these regulations specifically prohibit agreements and other activities that influence prices or terms, allocate sales territories or customers, or impermissibly hinder or influence free and open competition.
- Furthermore, these regulations prohibit agreements between customers
- and suppliers that are intended to restrict or ly limit customers’ freedom to autonomously determine their prices and other terms and conditions upon resale (price and terms determination).
d. Money Laundering and Terrorist Financing, Controls, and Sanctions
- Business partners must comply with the applicable regulations on the prevention of money laundering and terrorist financing and take appropriate measures.
- We expect our business partners to obtain their own financial resources exclusively from lawful sources.
- Business partners shall observe and comply with the applicable laws governing the import and export of goods, services, and information, as well as any embargoes, sanctions, and export restrictions relevant to them in international trade.
e. Data Protection and Handling of Information and Intellectual Property
- Business partners shall comply with the applicable laws and regulations governing the protection of personal data and information, particularly that of customers, business partners, and employees.
- Business partners shall require their employees to observe and comply with trade and business secrets and the applicable national laws and regulations governing them. Confidential information and confidential documents may not be disclosed to third parties without authorization or made accessible in any other way, unless authorization has been granted or the information is publicly available.
- Business partners shall safeguard and respect intellectual property rights and shall carry out technology and/or know-how transfers in compliance with intellectual property rights and the protection of personal data and confidential information.
III. Compliance and Cooperation by the Business Partner
We expect business partners to comply with and implement the above principles on their own initiative.
- Obligation to Maintain Records: Regardless of current changes to formal reporting requirements at the national level (LkSG Amendment of September 3, 2025), business partners are required to maintain the evidence, records, and documentation necessary to fulfill due diligence obligations (including supply chain mapping, risk analyses, audit reports, remediation plans, and proofs of origin). This documentation serves both internal audits and preparation for the implementation of the EU CSDDD (to be transposed by member states by July 26, 2026) and reduces liability and reputational risks.
- In accordance with our due diligence obligations, we reserve the right to conduct a risk-based review of our business partners and their business areas as part of a risk analysis, and we expect the business partner to cooperate as required in a permissible manner.
- If, during or as a result of the business relationship, we become aware of or have reasonable suspicion of a breach or a (potential) violation of our principles, we specifically reserve the right to request information regarding the relevant facts in a permissible manner.
- Depending on the severity of the non-compliance, the violation, or the human rights- or environment-related risk, we reserve the right to review the business relationship and, after carefully weighing the interests involved in each individual case and within the bounds of proportionality, are entitled, as a last resort, to terminate the business relationship with immediate effect.
IV. No Third-Party Rights
Third parties cannot derive any rights of their own from the provisions of the SCoC. In particular, this is not a contract for the benefit of third parties. Accordingly, neither the business partner’s employees, its business partners or their employees, nor any other third parties have any rights of their own against us under the SCoC, nor can they compel us to enforce any provisions based on the SCoC.
V. Precedence of Individual Agreements
The principles of our SCoC constitute minimum standards. Individual provisions shall take precedence if agreed upon in writing, provided that they do not under any
circumstances fall short of the principles set forth in this SCoC.
This SCoC summarizes the key expectations and requirements for suppliers as set forth in the documents provided.
As of: 12/2025