Code of conduct

Implement and apply principles and values continuously

“From one generation to the next, our entrepreneurial family has dedicated itself to the goal of offering our customers the right solutions while acting responsibly towards society. We have been living up to this claim for four generations now. We are proud to help shape the global competition as an innovative provider and we rely on lasting commitment.”

Marion Freifrau von Cetto

The Gesellschaft für Wolfram Industrie mbH in Nußdorf and Bayerische Metallwerke GmbH in Dachau have been developing, producing and processing metallurgically superior, technically intelligent products from tungsten and molybdenum since 1911. As a family-managed company with our own production facilities in Germany, we strive to be the global market leader for premium tungsten-based products in terms of service and quality.

In this family-managed company in the fourth generation, the owner takes personal responsibility for quality and is committed to our performance, unchanged from 112 years ago.

For us, compliance is a fundamental component of sound and sustainable corporate governance. It signifies far more than simply abiding by laws and regulations. Compliance, to us, is a mindset and a matter loyalty to our fundamental pursuits, underpinned by innovation, technical expertise and by upholding and further developing our economic autonomy through cooperation with our business partners and staff. Values such as reliability, sincerity, credibility and integrity are no empty phrases to us. They are our fundamental watchwords at Wolfram Industrie.

Our current written Code of Conduct anchors this value-oriented cooperation within the company, with partner companies, suppliers and our international customers. It is a key part of our value culture.

Wolfram Industrie Verhaltenscodex

1. Basic understanding of socially responsible corporate governance

This Code of Conduct is based on a common basic understanding of socially responsible corporate governance. This means that Wolfram Industrie takes responsibility by considering the consequences of corporate decisions and actions in economic, technological, as well as social and ecological terms, and taking into account the respective interests.

Within the scope of its possibilities and as far as feasible, Wolfram Industrie voluntarily contributes to the well-being and sustainable development of society at all its locations. We are guided by universally accepted ethical values and principles, in particular integrity, honesty and respect for human dignity.

2. Applicable scope

2.1 This Code of Conduct applies to the following companies:

  • Wolfram Industrie GmbH, D-Nußdorf
  • Bayerische Metallwerke GmbH, D-Dachau
  • Wolfram Industrie GmbH, CH-Winterthur

2.2 Companies are encouraged to adopt this Code of Conduct in its entirety, taking into account country-specific characteristics.

2.3 Wolfram Industrie undertakes to promote compliance with this Code of Conduct, also among its suppliers and along the value chain, within the scope of its respective possibilities and scope of action.

Wolfram Industrie Verhaltenscodex

3. Key points of socially/legally responsible corporate governance

Wolfram Industrie actively strives to ensure effective observance of and compliance with the following values and principles.

3.1 Compliance with applicable law
Wolfram Industrie complies with the prevailing laws and other legal regulations of the countries in which it operates. However, the laws and legal regulations of the Federal Republic of Germany always represent the minimum standard for action, even in other countries.

3.2 Integrity and organizational governance

3.2.1 Wolfram Industrie bases its actions on universally valid ethical values and principles, in particular integrity, honesty, respect for human dignity, openness and recognition of any religion, ideology, gender and sexual orientation.

3.2.2 Wolfram Industrie rejects any form of corruption, bribery, competition violations as well as other violations of applicable law and promotes transparency, acting with integrity and responsible management and control in the company in an appropriate manner.

3.2.3 Wolfram Industrie follows clean and accepted business practices and stands for fair competition. In competition, Wolfram Industrie is guided by professional conduct and work of high quality. Wolfram Industrie maintains a cooperative and trusting relationship with the relevant authorities. We do not allow personal or other external interests to influence our business decisions. Conflicts of interest can impede business success through uneconomical decisions, by driving away customers or by disclosing important information.

3.2.4 We consistently follow generally accepted accounting principles in our bookkeeping. Business partners are carefully chosen and no activities of any kind that could be associated with money laundering are supported. Information and documents pertaining to financial activities are stored and archived securely in a structured and comprehensible form. We and our suppliers are consistently committed to truthfulness in the dissemination of such information. Reports to business partners and public authorities are prepared and submitted according to the principles of transparency and integrity.

3.3 Consumer interests
As far as consumer interests are concerned, Wolfram Industrie complies with consumer protection regulations as well as appropriate sales, marketing and information practices. Particularly vulnerable groups enjoy special attention.

3.4 Communication and confidential information
Wolfram Industrie communicates openly and engages in dialogue with employees, customers, suppliers and other stakeholders about the requirements of this Code of Conduct and its implementation. All documents and records are dutifully prepared, not unfairly altered and properly stored in accordance with statutory retention periods.

Confidential information means information that is not to be made public. This includes our own non-public information and that of suppliers, customers, employees, consultants and other third parties that is protected in accordance with legal and contractual requirements. We never wrongfully obtain third-party confidential information or use it in illegitimate ways, for example, in our quoting process. Trade secrets and business information of partners are considered sensitive and kept confidential in compliance with the German Act on the Protection of Business Secrets (GeschGehG).

Wolfram Industrie Verhaltenscodex

3.5 Intellectual property
Our intellectual property including patents, brands, copyrights and confidential expertise are essential to our business success. Its protection and preventing its abuse are therefore of great importance. We respect the intellectual property rights of third parties and report probable violations of intellectual property rights to the respective owners. We use computer software exclusively in accordance with the license terms and conditions, and ensure compliance with all licensing requirements of integrated third-party, commercial and open-source software.

3.6 Export control and customs
Complying with export control and customs regulations applicable for national and international trade is essential for us. We take great care to ensure that applicable customs and foreign trade provisions are reviewed, implemented and observed in the trade and transportation of goods, the delivery of services and other transfers of technical know-how. Extended reviews are performed for business conducted in sanctioned countries. We ensure compliance with all applicable export control regulations in our business activities.

3.7 Human rights
Wolfram Industrie is committed to the promotion of human rights and, in particular, upholds the following human rights as set out in the Universal Declaration of Human Rights:

3.7.1 The preservation and protection of privacy

3.7.2 Health and safety: Maintaining health and safety at work, in particular ensuring a safe and healthy working environment to prevent accidents and injuries.

3.7.3 Harassment / protection of employees from physical, sexual, psychological or verbal harassment or abuse.

3.7.4 Freedom of opinion / protection and granting of the right to freedom of opinion and expression.

3.8 Working conditions
Wolfram Industrie complies with the following core labour standards of the International Labour Organisation (“ILO”):

3.8.1 Child labour / the prohibition of child labour, i.e. the employment of persons younger than 15 years, unless local legislation sets higher age limits.

3.8.2 Forced labour / Wolfram Industrie rejects any form of forced labour.

3.8.3 Remuneration / the labour standards with regard to remuneration, in particular with regard to the level of remuneration in accordance with the applicable laws and regulations

3.8.4 Workers’ rights / Wolfram Industrie respects the rights of workers to freedom of association, freedom of assembly and collective bargaining.

3.8.5 Prohibition of discrimination / the treatment of employees free from any form of discrimination.

3.9 Working hours
Wolfram Industrie complies with labour standards on the maximum permissible working hours.

3.10 The social and economic development of the country and the region is important to Wolfram Industrie. We therefore support corresponding voluntary activities of our employees.

4. Environmental protection

Wolfram Industrie complies with current, applicable environmental protection regulations and standards, and acts in an environmentally conscious manner at all of its sites. In the course of its activities, Wolfram Industrie uses natural resources responsibly and is guided by the principles of the 1992 Rio Declaration on Environment and Development.

4.1 Greenhouse gases, sustainable resource management and waste management
Our processes are designed to conserve resources throughout the product life cycle, to reduce waste disposal and to make our business activities CO2 neutral. Our environmental portfolio is our answer to climate change, resource scarcity and environmental exposure. Through the development of future-oriented, resource-efficient products, our company meets the ecological demands of its partner companies. Consistent, innovative environmental protection management is an integral part of our business processes.

4.2 Energie
Climate protection is closely linked to energy consumption. We use energy economically and efficiently, and are always striving to improve energy efficiency. Where possible, we prioritise the use of renewable energy sources.

4.3 Air and water
We design our processes to achieve the best possible environmental compatibility of our products, to prevent unnecessary air and noise pollution, and to conserve and avoid the pollution of water.

4.4 Chemicals
We ensure that hazardous substances and chemicals are stored, used and transported properly and safely. All documents required for proper documentation are included with products containing hazardous substances.

5. Whistleblowing Policy

This Code of Conduct sets out the essential values of Wolfram Industrie. Ensuring that these values are upheld is the responsibility of all Wolfram Industrie employees. We have established a whistleblowing policy in accordance with the legal requirements of the Act on Corporate Due Diligence in Supply Chains (LkSG) and the Whistleblower Protection Act (HinSchG).

5.1 Input from employees
Should employees become aware of issues and facts that could contradict the essential values, we urge everyone to contact their superior, company management and/or the Compliance Officer of Wolfram Industrie in confidence. The involvement of a member of the works council is of course possible at any time. Company management guarantees all employees that the protection of whistleblowers is essential for Wolfram Industrie and that no negative measures will be taken on the part of the company. Punitive measures against complainants or whistleblowers are not tolerated.

5.2 Input from external parties
Should any external parties become aware of issues and facts that could contradict the essential values of Wolfram Industrie, they can contact our Compliance Officer and/or company management directly at any time.

5.3 Reporting
Aside from the option of contacting company management and/or the superior, we offer the following reporting channels: by eMail:

5.4 Handling inputs
We take all reported issues seriously, conduct investigations and take appropriate action. Regarding inputs according to the Act on Corporate Due Diligence in Supply Chains (LkSG), we provide rules of procedure for the handling of inputs in a separate document on our website.

6. Implementation and enforcement

Wolfram Industrie shall make all appropriate and reasonable efforts to continuously implement and apply the principles and values described in this Code of Conduct.

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