Code of Conduct (CoC)

Preamble

Odenthal, 10 March 2026

ntm logistics GmbH considers itself part of an internationally interconnected economy and, through its locations, an integral part of the countries and societies in which it operates. ntm logistics GmbH follows the guiding principle of the “honourable merchant” and acknowledges its responsibility as a company.

  • ntm logistics GmbH observes the direct and indirect impact of its business activities on the environment and society and strives to balance economic, ecological and social interests appropriately.

  • ntm logistics GmbH acts in accordance with generally accepted values and principles, complies with applicable laws and regulations, and in particular respects internationally recognised human rights and labour standards as outlined below.

  • ntm logistics GmbH is committed to the goals and content of this Code of Conduct and will make all appropriate and reasonable efforts, within its legal and operational capabilities, to fulfil this voluntary commitment continuously across all its locations, both domestically and internationally.

Where existing national regulations conflict with the provisions of this Code of Conduct or where the local context makes full compliance impossible, ntm logistics GmbH will seek ways to uphold the principles of this Code of Conduct to the greatest extent possible.


Ethical / Moral Commitment and Integrity

ntm logistics GmbH pursues exclusively lawful business objectives and practices and maintains business relationships only with reputable partners.

ntm logistics GmbH treats business partners and customers fairly and with respect. It respects differing legal, economic, social and cultural backgrounds, as well as the specific conditions of the countries and regions in which it operates. In doing so, ntm logistics GmbH complies with the laws and regulations applicable in those countries and regions.

ntm logistics GmbH aligns its business conduct with universally accepted ethical values and principles, including integrity and respect for human dignity.

ntm logistics GmbH supports free and fair global trade.


Corruption, Trade Control, Money Laundering

ntm logistics GmbH rejects all forms of bribery and corruption. We avoid even the appearance of such conduct, whether in the form of granting or accepting improper advantages.

ntm logistics GmbH acts in accordance with applicable import and export control regulations and complies with all legal requirements for the prevention of money laundering.


Fair Competition

ntm logistics GmbH is committed to free and fair competition. It does not tolerate anti-competitive agreements and ensures compliance with applicable antitrust laws.

ntm logistics GmbH rejects any competitive advantages gained through unfair business practices.


Handling of Personal Data, Protection of Confidential Information and Intellectual Property

ntm logistics GmbH respects the personal rights of its employees, business partners and customers and complies with applicable legal and regulatory requirements regarding the processing of personal data and information security.

ntm logistics GmbH protects entrusted trade secrets and other confidential information of its business partners and customers against unauthorised acquisition, use or disclosure, at least in accordance with the relevant legal provisions governing the protection of trade secrets.

ntm logistics GmbH respects the intellectual property of its business partners, customers and other third parties and ensures that appropriate measures are taken to protect intellectual property rights when exchanging know-how and technologies.


Environmental Responsibility and Commitment

The protection and preservation of natural resources concerns and obliges us all. With this awareness, ntm logistics GmbH conducts its business activities in an environmentally responsible manner and is committed to the goal of a climate-neutral future.


Protection of the Environment and Climate

ntm logistics GmbH fulfils its environmental responsibility by complying with applicable legal requirements and recognised standards for the protection of the environment and climate.

ntm logistics GmbH works continuously to reduce the negative impact of its business activities on the environment and the climate.

ntm logistics GmbH complies with applicable law and takes appropriate measures aligned with legal and internationally recognised standards, including in particular:

  • Measures to reduce or avoid waste

  • Minimisation of emissions from operations (e.g. wastewater, exhaust air, noise, greenhouse gases)

  • Conservation of natural resources, for example through reducing the use of water, chemicals and other raw materials and promoting circular economy principles

  • Use of climate- and environmentally friendly technologies, processes, raw materials and products

  • Measures to improve energy efficiency and increase the share of renewable energy in energy consumption at company sites


Human Rights and Labour Standards

Human dignity is inviolable. ntm logistics GmbH therefore respects internationally recognised human rights as set out in the United Nations Universal Declaration of Human Rights.

ntm logistics GmbH follows internationally recognised labour standards of the International Labour Organization (ILO), as outlined in this Code of Conduct.

In all business activities, ntm logistics GmbH strives neither to cause nor to contribute to human rights violations. It expects the same from its business partners and, where necessary and possible, supports its suppliers in this regard.


Employment Relationships

ntm logistics GmbH treats its employees with respect. It rejects any form of unlawful punishment, abuse, harassment, intimidation or other degrading treatment.

ntm logistics GmbH applies applicable labour law to all employment relationships and expects the same from its contractual partners.

Employees are provided with clear and understandable information at the beginning of their employment regarding key working conditions, including their rights and obligations, working hours, remuneration and payment and invoicing arrangements.

ntm logistics GmbH respects and protects the right of employees to terminate their employment in accordance with the applicable notice periods.


Prohibition of Child Labour and Protection of Young Workers

ntm logistics GmbH does not tolerate child labour and complies with the applicable legal minimum age for employment.

In any case, ntm logistics GmbH does not employ persons below the age at which compulsory education ends under the law of the place of employment, and never below the age of 15.

Internships are organised in accordance with legal requirements.

ntm logistics GmbH expects its contractual partners to implement appropriate age verification measures to prevent child labour.

If child labour is identified, all necessary measures must be taken immediately, prioritising the welfare, protection and development of the child.

For persons under the age of 18, the rights of young workers must be respected. They may only be employed if it is ensured that their working conditions do not pose a risk to their health, safety or moral development.


Prohibition of Forced Labour

ntm logistics GmbH rejects all forms of forced or compulsory labour.

This includes all forms of debt bondage, servitude, slavery or practices similar to slavery, human trafficking, and all forms of involuntary labour or services that are incompatible with internationally recognised labour and social standards.


Principles of Remuneration

ntm logistics GmbH applies statutory or, where applicable, collectively agreed provisions for remuneration.

It ensures that employees are paid at least the legally applicable minimum wage, or where relevant, the collectively agreed or industry-standard minimum wage.

In countries or regions without such frameworks, ntm logistics GmbH ensures that wages are sufficient to meet the basic needs of employees working regular full-time hours.

Unlawful wage deductions, including deductions used as disciplinary measures, are not tolerated.


Working Hours

ntm logistics GmbH complies with statutory or applicable collectively agreed regulations on working hours, including overtime, rest breaks and annual leave.

ntm logistics GmbH ensures that:

  • the regular weekly working hours, including permissible overtime, are not exceeded

  • applicable working time regulations are observed


Freedom of Association

ntm logistics GmbH respects employees’ rights to freedom of association, assembly and collective bargaining, insofar as these rights are legally permitted in the respective country of employment.

Where this is not possible, ntm logistics GmbH seeks appropriate solutions for its employees.


Diversity and Inclusion, Non-Discrimination

ntm logistics GmbH values diversity among its employees and promotes an inclusive working environment.

It is committed to equal opportunities and rejects any form of discrimination or unequal treatment based on national or ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion or belief.

ntm logistics GmbH upholds the principle of equal pay for work of equal value.


Occupational Health and Safety

ntm logistics GmbH complies with national and international occupational health and safety standards.

It ensures a safe and health-promoting working environment (preventing accidents, injuries and work-related illnesses) in order to protect the safety and health of its employees and third parties.