Code of Conduct

Code of Conduct

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Code of Conduct

Ethical - Legal - Flawless

Our reputation with customers, suppliers and partners is a cornerstone of our success. For more than 30 years, ComSIT has built a strong reputation in the global electronic components market by operating sustainably and standing behind our products. It is therefore important that we maintain our credibility and continue to conduct our business ethically and legally. Although we are active at different locations and in different countries around the world, we operate under the common ComSIT brand.

Due to our global orientation, our business is subject to a large number of legal regulations and standards. In order to meet the requirements of ourselves, our customers, suppliers and partners and to further expand our success, we must never lose sight of our values and must always conduct our business in accordance with all laws, regulations and standards, including ethical, social and environmental standards.

GLOBALER CODE OF CONDUCT

1. Preamble
The ComSIT Group has operated internationally for more than 30 years in the electronics and electromechanical components sector. Our locations in Europe, the United States and Asia/China face diverse legal, environmental and social frameworks. We commit to integrity, transparency, responsible conduct, the protection of human rights, data and the environment, and sustainable business operations. This global Code of Conduct is binding for all employees, managers, suppliers and business partners.
This Code applies worldwide to all employees, facilities, subsidiaries and business units, as well as all suppliers, agents and service providers. Regional specifics are set out in Addenda (USA, China). Where local laws are stricter, they prevail.
Our global values include integrity, responsibility, respect, transparency, compliance and safety. These apply across all locations.
We maintain fair, respectful and professional relationships. Partners must comply with applicable laws, protect human rights and the environment, ensure fair labor conditions, maintain transparency and adhere to anti-corruption principles. Due diligence includes EU CSDDD, UFLPA, UK Modern Slavery Act and OECD guidelines.
We comply with AWG/AWV/EU Dual-Use, EAR/ITAR/OFAC, Chinese export control law and UN/WCO standards. Prohibited: sanctions evasion, false end-use statements, illegal re-exports, unauthorized technology transfers. Export processes include classification, screening, end-use checks, licensing analysis and documentation.
Relevant laws: GDPR/BDSG, CCPA/CPRA/State Acts, PIPL/DSL/CSL. We ensure secure data processing, encryption, need-to-know access and IT security aligned with ISO 27001/NIST. Confidential information must be protected – even after employment ends.
Standards: UN, OECD, UK Bribery Act, FCPA. Prohibited: bribery, kickbacks, concealed payments, facilitation payments, improper gifts. Allowed: low-value, transparent hospitality.
Conflicts may involve financial interests, family relationships, secondary employment or private use of internal information. Disclosure required.
We uphold human rights, fair labor conditions, health and safety, equal treatment and prohibit harassment, forced or child labor.
We follow ISO 14001, EU Green Deal objectives, RoHS/REACH, emission reduction, circular economy and responsible waste management.
We prevent money laundering, terrorist financing and unclear financial flows. KYC, documentation and transparent payment routes are mandatory.
We provide protected, anonymous reporting channels. Protection under EU Whistleblower Directive, US Dodd-Frank and Chinese reporting safeguards. Retaliation is prohibited.
Officers, annual training, audits and management duties.
Compliance-relevant documentation must be kept as required by local law.

This Code is reviewed and updated annually.

USA ADDENDUM

1. Purpose and Scope
This Addendum complements the global ComSIT Code of Conduct with U.S.-specific legal and regulatory requirements. It applies to all employees of ComSIT Inc., all U.S.-based business operations, and all suppliers or partners conducting business with or through the United States.
ComSIT complies with the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and OFAC sanctions. Prohibited activities include unlicensed exports, deemed exports, reexports of controlled items, and transactions with sanctioned parties (SDN List, Entity List).
The Foreign Corrupt Practices Act prohibits bribery of foreign officials, improper payments, kickbacks, and falsified accounting records. Low-value, transparent hospitality is allowed under strict conditions.
ComSIT must not participate in or support unauthorized foreign boycotts. Any boycott-related request must be reported to U.S. authorities.
We comply with Title VII, ADA, ADEA, FMLA, Equal Pay Act, and FLSA. Discrimination, harassment, and retaliation are strictly prohibited.
ComSIT ensures a safe workplace, proper training, incident reporting, and use of protective equipment as required by OSHA regulations.
ComSIT Inc. complies with CCPA, CPRA and state privacy laws. Requirements include notice obligations, opt-out rights, data minimization and secure handling of personal data.
ComSIT complies with the Sherman Act, Clayton Act, and FTC Act. Price-fixing, market allocation, bid-rigging, and exchange of sensitive competitive information are prohibited.
Employees must disclose personal, financial, or professional interests that could influence business activities.
Unauthorized use, disclosure, copying or distribution of confidential or proprietary data is prohibited.
ComSIT performs KYC checks, monitors unusual financial transactions, and ensures transparent payment processes.
Accurate, complete, and timely financial reporting is mandatory. Shadow accounts, fictitious invoices, or misleading entries are strictly prohibited.
Whistleblowers are protected under SOX and Dodd-Frank. Anonymous reporting is permitted, and retaliation is strictly forbidden.
No employee may be disadvantaged, threatened, or dismissed for reporting concerns in good faith.
This Addendum supplements the global Code of Conduct and is reviewed annually.

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