Toradex Code of Conduct

The foundation of the Toradex Code of Conduct are the following personal commitments of Toradex employees worldwide:

Always comply with all applicable laws and regulations worldwide.
Conduct business in an ethical and legal manner.
Be honest, fair, reliable, respectful, and trustworthy in all of Toradex’s activities and relationships.
Appreciate diversity, the difference and uniqueness of individuals from all around the world.
Foster an environment that supports fair employment practices.
Provide a working environment that is free of harassment, unlawful discrimination, or abusive conduct.
Strive to create a safe working place.
Avoid conflicts of interest between work and personal affairs.
Act in a manner that is protective of the environment.
Through leadership at all levels, sustain a culture where ethical conduct is recognized, valued, and exemplified by all employees.

In case of uncertainty how to respond to a specific situation, please refer to Appendix: Ethical Decision-Making Guide” may provide a guidance for all Toradex employees. Employees’ questions and concerns may also be anonymously addressed on the Feedback Form.

Introduction

Applicability

The Toradex Code of Conduct defines the way Toradex is doing business and is applicable to all employees, including senior management, and the board of directors.

In third-party relationships, the Toradex Business Partner Code of Conduct is applicable.

Variations to the Code of Conduct may be necessary to consider differences in regulatory and business environments in countries where Toradex is active. In case of conflicts between the Code of Conduct and applicable law, applicable law takes precedence.

Purpose

This Code of Conduct is the base for ensuring social and environmental responsibility as well as ethical conduct of all Toradex employees worldwide. The principles outlined herein serve as the cornerstone of our relationship with customers, suppliers, service providers, partners, society, and environment. The Toradex Code of Conduct is the binding guideline for Toradex employees in daily business.

In general, common sense, use of good judgment and integrity will guide one on the lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed openly with the line manager, the human resources, or the compliance team. Employees’ questions and concerns may also be anonymously addressed through the Feedback Form.

Toradex does not tolerate any violation of this Code of Conduct. In case of violation, Toradex reserves the right to take appropriate actions, up to the point of immediate employee dismissal. Furthermore, the right for additional legal action or civil claim damages is expressly reserved.

Manager level and above

Managers directly influence employees with their actions, their words and non-verbal behavior. Therefore, employees in a manager or lead role are expected to fully line up with Toradex’s Code of Conduct by

Always leading by example.
Offering guidance and support to their employees.
Not retaliating against anyone for raising concerns to management.
Ensuring all concerns raised by employees are taken seriously and addressed timely.
Ensuring employees have read and understood the Toradex Code of Conduct.

Corporate Law and Statutes

Toradex employees are obliged to follow all applicable laws.

Fair Competition and Antitrust

Toradex employees do respect fair competition and adhere to existing laws that uphold and promote competition, in particular prevailing antitrust laws as well as laws that regulate competition.

In dealing with competitors, the above provisions particularly do prohibit collusion or other activities aimed at influencing prices or conditions, dividing up sale territories or costumers or using prohibitive means to inhibit free and open competition.

In case of any uncertainty with regard to competition and antitrust laws, regulations or practices, the legal department of Toradex should be consulted.

Anti-Corruption and Anti-Bribery

Toradex employees must always act compliant with anti-corruption laws. While dealing with business partners (customers, suppliers) and state institutions, the interests of the parties involved and the private interests of employees on both sides shall be kept strictly separate.

Personal benefits in exchange for a favored position in business dealings may not be offered, promised, granted or approved, nor may personal benefits be demanded or accepted in dealings with business partners. The same conduct is required when dealing with public officials.

In case of any uncertainty with regard to anti-corruption or anti-bribery laws, regulations or practices, the legal department of Toradex should be consulted.

Confidential Information and Information Handling

In principle, any confidential information Toradex employees may have access while doing their job may not be shared outside the company. Details are defined in the Toradex Employee Handbook and the employment contract.

In case of uncertainty with regard to the handling of confidential information, the legal department of Toradex should be consulted.

Data Privacy

Toradex employees must comply with all relevant data privacy and data protection laws. Details are defined in the Toradex Employee Handbook and the employment contract.

In case of uncertainty or questions concerning data privacy, the legal department of Toradex should be consulted.

Conflict Minerals

Toradex ensures responsible business conduct and sourcing and is committed to avoid in their products any sourcing metals and minerals that contribute to armed conflict or human right abuses in conflict affected and high-risk areas, through its own operations, business relationships or supply-chain. Toradex’s approach is to promote the traceability and transparency of supply chains and move towards a conflict-free global supply chain.

Export Controls

Toradex has a clear policy on compliance with export controls and refrains from transactions recognized as not being permissible by the applicable national or international export control regulations or the internal directives. In particular, Toradex ensures that there is no respective entry on the applicable national or international sanctioned party lists. Before processing an export of commodities, software or technology, physically or electronically, it must be ensured that the item is not controlled and does not require an export/re-export license from the authorities. Some destinations are subject to embargoes or sanctions and require additional control prior to proceeding.

Labor Law and Statutes

Everyone deserves to be treated with dignity and respect. Toradex respects the uniqueness of each individual and commits to create and maintain a work environment free of any violence, abuse, mental of physical coercion, unlawful discrimination, or harassment. Toradex strictly refuses any form of discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, religion, political affiliation, union membership or other distinctive features.

Fair Working Conditions

Toradex shall not require workers to work more than regular and overtime hours allowed by the laws of the country where the workers are employed or perform work.

Compensation paid to workers should comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits.

Discrimination and Harassment

Toradex is providing an environment in which employees are provided opportunities to succeed in their roles without fear of prejudice or abuse. Any forms of discrimination or harassment are strictly prohibited. Particularly, this applies to unfair treatment based on gender, race, disability, ethnic or cultural origin, religion or worldview, age, sexual orientation, or any other status protected under applicable laws.

Forced Labor and Human Trafficking

Toradex does not use or tolerate forced labor or human trafficking practices in its own operations or along its supply chain. Toradex does adhere to the regulations of the United Nations on human rights, which prohibit any form of forced labor and all forms of human trafficking, as such behavior takes advantage of people who are not in a position to consent to their actions.

Child Labor

Toradex does adhere to the regulations of ILO Minimum Age Convention No. 138, the ILO Worst Form of Child Labor Convention No. 182, and respective Recommendations, or to other internationally recognized equivalent regulations (e.g. Swiss Ordinance on Due Diligence and Transparency in relation to Minerals and Metals from Conflict-Affected Areas and Child Labor “DDTrO”). If a national regulation concerning child labor provides stricter measures, this regulation has precedence within its territorial scope.

Health and Safety

Toradex guarantees protection of workers in the workplace and workplace health protection within the scope of national laws and provisions, including physiological and psychological issues arising from, among others, dangerous equipment, work practices and hazardous substances. The goal is to limit exposure to occupational hazards and prevent emergencies.

Freedom of Association

Toradex shall respect its employees’ right of freedom of association within the scope of national laws and provisions.

Environmental Protection

Toradex is committed to protecting the environment and controlling the usage of natural resources in its daily business and operations. Toradex takes a proactive approach to reducing environmental and resource impacts in all areas of its business. This includes the management of waste, emissions, use of water and energy.

To achieve these goals, environmental management programs will comply with relevant environmental laws and regulations in the countries where Toradex is active.