1.    Preamble

TKG in proizvodnja vijakov d.o.o. (hereinafter “TKG”) is a manufacturing company specialising in cold forming and precision parts, headquartered in Ljubljana, Slovenia. We produce fasteners and special turned parts for customers in the furniture fittings industry, automotive supply chain and general mechanical engineering.

Our business conduct is based on long-term thinking, financial prudence and the principle that economic success and responsible action are inseparable. We expect our business partners to share these principles.

This Supplier Code of Conduct defines the minimum requirements that TKG places on its suppliers, subcontractors and service providers. It applies to all companies in the TKG supply chain and supplements existing contractual agreements. Compliance with this Code is an essential precondition for entering into and maintaining a business relationship with TKG.

2.    Legal Compliance

Our suppliers shall comply with all applicable national and international laws, regulations and official requirements. Where this Code exceeds statutory minimum requirements, the stricter provisions of this Code shall apply, unless applicable law provides otherwise.

3.    Human Rights and Labour Standards

3.1    Prohibition of Child and Forced Labour

Any form of child labour is strictly prohibited. The minimum age for employment shall correspond to the higher of the applicable national law and ILO Conventions 138 and 182. Forced labour, debt bondage, involuntary prison labour and any form of modern slavery are prohibited.

3.2    Non-Discrimination and Equal Opportunity

Suppliers shall ensure a working environment free from discrimination on grounds of age, gender, ethnic origin, religion, belief, disability, sexual orientation, gender identity, political conviction or any other legally protected characteristic. Diversity and tolerance shall be actively promoted.

3.3    Fair Working Conditions and Remuneration

Applicable statutory and collectively agreed rules on working hours, breaks, rest periods and remuneration shall be observed. Remuneration shall at least correspond to the statutory minimum wage or the industry-specific collective wage, whichever is higher.

3.4    Freedom of Association

The right of employees to freedom of association, freedom of assembly and collective bargaining is recognised and respected. Employee representative bodies shall neither be obstructed nor disadvantaged.

3.5    Occupational Health and Safety

Suppliers shall ensure a safe and health-promoting working environment. This includes compliance with all applicable occupational health and safety regulations, provision of personal protective equipment, regular training and measures to promote mental health in the workplace. Risks shall be systematically identified, assessed and minimised.

3.6    Social Security

Suppliers shall contribute to the social security of their employees within the framework of the applicable statutory or local social insurance systems — in particular with regard to illness, accidents, unemployment and old age.

4.    Environment and Climate Protection

TKG considers economic action and environmental responsibility as inseparable. We expect an equivalent commitment from our suppliers.

4.1    Resource Conservation and Energy Efficiency

Suppliers commit to the economical use of natural resources, energy and water. Production processes shall be continuously optimised with regard to energy and material efficiency. Where technically and economically feasible, the use of renewable energy shall be pursued.

4.2    Emissions and Environmental Impact

Emissions to air, water and soil shall be reduced to the technically unavoidable minimum. Where environmental impacts cannot be avoided, appropriate technical and organisational measures shall be taken to mitigate them.

4.3    Waste Management and Circular Economy

Waste shall primarily be avoided and secondarily recovered materially or energetically. Proper disposal of hazardous waste in accordance with applicable law shall be ensured. Suppliers shall strive to close material cycles.

4.4    Hazardous Substances and Substance Restrictions

Suppliers shall comply with all applicable regulations on hazardous substances, in particular REACH, RoHS and customer-specific Restricted Substances Lists (RSL). The use of Substances of Very High Concern (SVHC) shall be declared and, where possible, replaced by safe alternatives.

4.5    Management Systems

Suppliers are encouraged to implement and maintain certified environmental and energy management systems (e.g. ISO 14001, ISO 50001). TKG itself is preparing for certification to ISO 14001 and ISO 50001 and aims to pursue this path together with its suppliers.

5.    Product Quality and Safety

Suppliers shall ensure that all products and materials delivered to TKG conform to the agreed specifications, quality standards and statutory safety requirements. Quality management systems (e.g. ISO 9001, IATF 16949) shall be maintained. Deviations and potential risks shall be disclosed without delay.

6.    Integrity and Anti-Corruption

6.1    Prohibition of Corruption and Bribery

Any form of corruption, bribery, extortion and embezzlement is strictly prohibited. Suppliers shall not offer, promise or grant any advantage to employees of TKG or their business partners that is likely to improperly influence business decisions. The same applies to public officials and government representatives; particular care is required in this regard.

6.2    Gifts and Invitations

Gifts and invitations are only permissible if they are customary in the industry, of low value and free from any intention to exert influence. When in doubt, restraint is advised.

6.3    Conflicts of Interest

Potential and actual conflicts of interest shall be disclosed to TKG promptly and transparently. In case of doubt, the interests of the company shall take precedence over personal interests.

7.    Fair Competition

Suppliers shall comply with all applicable competition and antitrust laws. Agreements on prices, quantities, market allocation or other anti-competitive arrangements are strictly prohibited. In the event of official investigations, cooperation shall be provided; documents and data shall not be destroyed.

8.    Sanctions, Export Control and Anti-Money Laundering

Suppliers shall comply with all applicable trade and economic sanctions, export control regulations and customs laws. Business relationships with sanctioned persons, entities or countries are not permissible. Suppliers shall take appropriate measures to prevent money laundering and terrorism financing and shall ensure that payment flows are transparent and traceable. Third-party payments are generally not permitted.

9.    Confidentiality and Intellectual Property

Confidential information, trade secrets and personal data obtained in the course of the business relationship with TKG shall be treated as strictly confidential and used exclusively for the agreed purpose. Disclosure to third parties requires prior written consent or a non-disclosure agreement. Intellectual property rights — both those of TKG and of third parties — shall be respected. Applicable data protection laws, in particular the GDPR, shall be observed.

10.    Proper Accounting and Taxation

Suppliers shall maintain their accounts properly, correctly and transparently. All business transactions shall be recorded completely and truthfully. Balance sheet manipulation of any kind is prohibited. Taxes and levies shall be regarded as a contribution to social development and paid duly.

11.    Regionality and Local Value Creation

TKG prefers, where economically and qualitatively justifiable, to source raw materials and services from the region. We encourage our suppliers to likewise promote short transport routes and regional value chains.

12.    Supply Chain Cascade

Suppliers of TKG are obliged to pass on the principles of this Code to their own suppliers and subcontractors in an appropriate manner and to promote compliance therewith. TKG expects the essential requirements of this Code to be observed throughout the entire supply chain.

13.    Reporting, Monitoring and Consequences

Suppliers shall establish internal procedures that enable employees and third parties to report violations of this Code or of applicable law confidentially and without fear of retaliation.

TKG reserves the right to verify compliance with this Code by means of self-assessment questionnaires, audits or supplier visits. Suppliers commit to providing the necessary documentation and access for this purpose.

In the event of violations of this Code, TKG shall initially seek an amicable solution and the agreement of specific corrective measures. In the case of serious or repeated violations, TKG reserves the right to terminate the business relationship.

14.    Contact

For questions regarding this Supplier Code of Conduct or to report potential violations, please contact:

TKG in proizvodnja vijakov d.o.o.
Quality and Sustainability, E-Mail: info@tkg.si
Web: www.tkg.si

This Code does not establish any third-party rights. It supplements existing contractual agreements and does not replace them. In the event of discrepancies between language versions, the German version shall prevail.