1. LABOR AND HUMAN RIGHTS

1.1 Freedom of Association and Collective Bargaining

We uphold workers’ rights to freely associate, join or form unions, and engage in collective bargaining.

• UDHR: Article 20(1) – Right to freedom of peaceful assembly and association
• UDHR: Article 23(4) – Right to form and join trade unions
• ILO Conventions:
  • No. 87 (Freedom of Association and Protection of the Right to Organise, 1948)
  • No. 98 (Right to Organise and Collective Bargaining, 1949)
  • No. 135 (Workers’ Representatives, 1971)
  • No. 154 (Collective Bargaining, 1981)

1.2 Prohibition of Forced Labor

All employment must be voluntary. Forced, bonded, and involuntary prison labor is strictly forbidden.

• UDHR: Article 4 – Prohibition of slavery and servitude
• ILO Conventions:
  • No. 29 (Forced Labour, 1930)
  • No. 105 (Abolition of Forced Labour, 1957)

1.3 Prohibition of Child Labor

We prohibit the use of child labor. Employees must meet the minimum legal working age and must not be engaged in hazardous work if under 18.

• UDHR: Article 25(2) – Special care and assistance for childhood
• ILO Conventions:
  • No. 138 (Minimum Age Convention, 1973)
  • No. 182 (Worst Forms of Child Labour, 1999)
  • No. 79 (Night Work of Young Persons, 1946)
  • ILO Recommendation No. 146

1.4 Fair Wages and Working Hours

We ensure fair wages, reasonable working hours, and paid leave. Wages must meet at least legal or industry minimums, and overtime should be voluntary and compensated.

• UDHR: Article 23(3) – Right to just and favorable remuneration
• UDHR: Article 24 – Right to rest, leisure, and limitation of working hours
• ILO Conventions:
  • No. 1 (Hours of Work – Industry, 1919)
  • No. 14 (Weekly Rest – Industry, 1921)
  • No. 131 (Minimum Wage Fixing, 1970)

1.5 Non-Discrimination and Anti-Harassment

Discrimination and harassment in the workplace are prohibited. We promote equal opportunity and diversity.

• UDHR: Article 2 – Non-discrimination
• UDHR: Article 7 – Equality before the law
• ILO Conventions:
  • No. 100 (Equal Remuneration, 1951)
  • No. 111 (Discrimination – Employment and Occupation, 1958)
  • UN Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW)
  • International Covenant on Civil and Political Rights (ICCPR), Article 7

1.6 Regular Employment

Employment should be stable and legally recognized. Short-term or informal contracts must not be used to avoid obligations to workers.

• UDHR: Article 23(1) – Right to work and protection against unemployment
• ILO Conventions:
  • No. 95 (Protection of Wages, 1949)
  • No. 158 (Termination of Employment, 1982)
  • No. 175 (Part-Time Work, 1994)
  • No. 177 (Home Work, 1996)
  • No. 181 (Private Employment Agencies, 1997)

2. ETHICS

2.1 Gifts and Hospitality

Extrudan prohibits bribery and any form of undue influence. Gifts or hospitality that aim to influence business decisions are not acceptable.

• UDHR: Article 10 – Right to a fair hearing (foundation of procedural fairness)

2.2 Conflicts of Interest

Employees and suppliers must avoid conflicts between personal interests and their professional duties. All potential conflicts must be disclosed.

• UDHR: Article 21(2) – Equal access to public service; integrity in public responsibilities

2.3 Fair Competition

We respect antitrust laws and support fair market competition. Collusion, price fixing, and market manipulation are not tolerated.

• ILO Conventions: (indirectly addressed via governance practices and corporate ethics)

2.4 Anti-Corruption

We reject all forms of bribery and corruption in line with the UN Convention Against Corruption. No employee or business partner may offer or accept bribes, kickbacks, or unlawful incentives.

• UDHR: Article 21(3) – The will of the people shall be the basis of the authority of government

3. ENVIRONMENT

We are committed to reducing our environmental footprint through responsible practices across the value chain. We comply with all applicable environmental laws and regulations.

• UDHR: Article 25(1) – Right to a standard of living adequate for health and well-being
• ILO Guidelines:
  • While not formally codified in a Convention, sustainability is embedded in ILO’s Decent Work Agenda

3.1 Conflict Minerals

We implement due diligence on sourcing minerals in compliance with the EU Conflict Minerals Regulation and OECD guidelines to avoid contributing to human rights abuses.

4. HEALTH AND SAFETY

We provide a safe, clean, and healthy working environment for all employees. Appropriate preventive measures and emergency protocols must be in place.

• UDHR: Article 3 – Right to life, liberty, and security of person
• UDHR: Article 25(1) – Right to health and well-being
• ILO Conventions:
  • No. 155 (Occupational Safety and Health, 1981)
  • ILO Recommendation No. 164

5. PRIVACY AND DATA SECURITY

We protect the personal data of our employees, customers, and partners in compliance with the EU General Data Protection Regulation (GDPR) and other applicable privacy laws.

• UDHR: Article 12 – Protection from arbitrary interference with privacy, family, home, or correspondence

6. COMPLIANCE AND MONITORING

Suppliers and partners must:

• Read and acknowledge this Code of Conduct
• Cooperate with audits and inspections
• Implement corrective actions as required
• Accept that failure to comply may result in contract termination