The IMR Group is active worldwide. In the course of their activities, IMR Group companies come into contact with numerous different legal systems and regulations. In this Code of Conduct, the management of IMR Group GmbH sets out guidelines for the behaviour of all management bodies, executives and employees of the IMR Group companies. In case of doubt about the meaning of the following guidelines, every employee is required to seek advice from their line manager.

Our mission

is to trade, manufacture, stock, distribute and refine metals and alloys, as well as to take back the residues from our customers’ ongoing production processes. This specialisation in a dynamic market environment has enabled us to operate at different levels of the value chain in the non-ferrous metals industry. The security of supply of metals in combination with technical and solution-orientated expertise creates an essential link to our business partners. The development of trading and the expansion of our production facilities are at the centre of the work of our management and all of our employees.

Corporate governance with integrity

Our decisions are based on accurate and precise accounting records and financial data in our accounting system, which are presented and audited in accordance with recognised principles. High standards ensure high quality. Our ISO 9001-certified management system helps us to work towards achieving our goals in planned stages. Our environmental management and occupational safety aspects are integrated into our management system.

Compliance with applicable law

Compliance with applicable law is the fundamental basis for all of IMR Group companies’ actions in all of their activities worldwide. We respect human rights and strictly reject any kind of child or forced labour without exception and expect the same of our business partners. IMR Group employees are expected to familiarise themselves with the legal provisions applicable to their area of responsibility and to keep themselves up to date in this regard, with managers having a particular responsibility for informing their employees.

Fair competition

The IMR Group is fully committed to fair competition and expects the same of its business partners. It goes without saying that we comply with the rules of competition law and antitrust law in our dealings with our customers, suppliers and competitors, and we also comply with all applicable regulations relating to international trade (relevant import and export regulations) as amended from time to time. No IMR Group employee is permitted to offer, demand or accept benefits that are likely to unfairly influence any commercial decision.

The company and its employees

Mutual respect is a fundamental principle of the IMR Group’s corporate culture. We are committed to fair working conditions and equal opportunities. Discrimination of any kind is not tolerated in the companies belonging to the IMR Group. Fair working conditions also mean that we allow flexible working hours and working from home and promote the work/life balance of our employees. We place great importance on training and further education for our employees. Pay and other benefits are at least in line with the respective national standards. The company recognises the rights of employees to freedom of association, to form or join labour organisations and the right to conduct collective bargaining in accordance with the respective national laws. Conflicts of interest between the interests of the IMR Group and the personal interests of employees must be avoided, and any conflicts that do arise must be disclosed and subsequently resolved. All employees are obliged to handle the property and all assets of the IMR Group with care and to protect them.

Information and privacy policy

All of our employees are obliged to protect the business secrets and other confidential information of the IMR Group companies and their business partners. Confidential information of any kind (e.g. contracts, correspondence and technical information, etc.) is intended for internal use only. All employees are obliged to respect and protect the intellectual property and know-how of the IMR Group and its business partners. Unauthorised disclosure or use of confidential information is strictly prohibited. This also applies, in particular, to intellectual property and expertise.

The companies belonging to the IMR Group comply with all provisions governing the protection of personal data (including the EU General Data Protection Regulation and all relevant national regulations) and require their employees to do the same.

Concerns, complaints, whistleblowers

Concerns and/or complaints relating to EU Regulation 2017/821 can be reported via an e-mail address published on our website or via a telephone number, which can also be found there, and will be processed by the responsible person.

A dedicated email address has been set up for reporting internal concerns and complaints, but they can also be reported directly to the management. The respective safety officers act as additional contacts on the topic of occupational safety. Whistleblowers have no need to fear reprisals.

Safety

Safety has high priority in every respect for the IMR Group. This applies both to the operational safety of our production facilities as well as to occupational health and safety, which is why the companies within the IMR Group observe all safety regulations for their equipment and facilities (machine safety), the provisions of dangerous goods legislation and the regulations for employee protection, health and fire protection.

Regular training sessions are held to show how to use the personal protective equipment provided by the company.

We record occupational accidents and near misses and evaluate the reasons and risk factors involved so that we can develop continuous improvement measures. Fire safety plans, information on what to do in the event of a fire and emergency telephone numbers are provided on the information board at all times.

The environment

At IMR, protecting the environment is just as important as safety, which is why the companies in the IMR Group pay particular attention to the relevant environmental protection regulations. Our environmental objectives include sustainable use of raw materials, systematic recording and improvement of the environmental impact of our activities and further development of our processes. Environmental aspects are considered in advance when making changes to systems and/or products.

The company and its business partners

We develop our customer and supplier relationships to form long-term partnerships based on ethical behaviour, which is why we expect the standards defined in this Code of Conduct not only from ourselves, but also from our business partners.

The Management, November 2022