Compliance

Below you will find our compliance principles and other important information in this area.

The following additional terms and conditions apply to all transactions that Pikatron concludes with customers:

1. The Importer/ Buyer shall not sell, export, or re-export, directly or indirectly, any goods supplied under or in connection with this Agreement to the Russian Federation or for use in the Russian Federation, as covered under Article 12g of Council Regulation (EU) No 833/2014.
2. The Importer/ Buyer shall ensure that the prohibitions in paragraph (1) are not circumvented by any third parties in the commercial chain, including by possible resellers.
3. The Importer/ Buyer shall establish and maintain effective monitoring mechanisms to detect and prevent any actions by third parties that would contravene paragraphs (1) or (2). This includes keeping detailed records and documentation of compliance efforts, which must be retained for at least 10 years after this Agreement's termination.
4. The Importer/ Buyer shall promptly inform the Exporter/ Seller of any difficulties in applying paragraphs (1), (2), or (3), including any relevant third-party activities that could undermine the objectives of paragraphs (1) or (2).
5. The Importer/ Buyer shall provide the Exporter/ Seller with the necessary information and documentation to prove its compliance with its obligations stated in this clause within two weeks upon request.
6. The Exporter/ Seller may audit the Importer/ Buyer's business and production premises at any time to verify the Importer/ Buyer's compliance with its obligations stated in this clause. Audits shall be conducted with reasonable notice and within the Importer/ Buyer's usual business hours. The  Exporter/ Seller shall protect any confidential information or business secrets encountered during such audits.
7. Any violation of paragraphs (1) to (5) constitutes a material breach of this Agreement, and the Exporter/ Seller may seek appropriate remedies, including, but not limited to:
   1. termination of this Agreement without notice; and
   2. liquidated damages of 25% of the total value of this Agreement or the price of the goods exported, whichever is higher, unless the Importer/ Buyer is not responsible for the breach.

Current situation

We have been active on various aspects of sustainability for decades and have been actively involved in regional sustainability projects since 2008 (e.g. Ökoprofit). Since October 2022, we have additionally engaged external consulting to support us with know-how from the OECD and its guidelines for multinational enterprises on responsible business conduct. Sustainability measures already implemented to date include,

• Purchase of 100% renewable energy in conjunction with more than 400 kWp photovoltaic systems
• Active energy monitoring and heat recovery
• Hybrid heating with heat pump
• Usage of daylight and presence-dependent LED-lighting
• Recycling of active waste materials, guarantee for return of end-of-life products
• Electrification of the corporate vehicle fleet

We also implement measures for circular economy, preservation of biodiversity, sustainable use of water resources, and pollution prevention.

Further perspectives

In order to achieve our goal of greenhouse gas neutrality by 2039, we are currently drawing up a comprehensive strategy for achieving the sustainability goals as proclaimed by the European Commission and the CSRD. In 2023 we joined the German Sustainability Codex (DNK) and are a signatory of the UN Global Compact, from 2024 we have started annual reporting on both initiatives. We also have achieved the certification of an energy management system according to ISO 50001 in 2024.

Recycled Material Content

We regret to inform you that we do not have corresponding information from our suppliers regarding all components used for manufacturing of our products. Therefore, as of today we cannot provide information on recycled material content.

Carbon Footprint

We cannot yet provide information on the carbon footprint (according to ISO 14067, GHG Protocol or PAS 2050 e.g.) for our products, but we are working towards detailed carbon footprint reporting across Scope 1,2 and 3 in the future.

Life Cycle Assessment / EPD (Environmental Product Declaration)

Currently, we can not provide an EPD according to ISO 14025 for our products. Furthermore, we are not yet able to provide information on life cycle assessment (according to ISO 14040/ ISO14044).

With the LkSG, companies above a certain size are required to comply with the human rights and environmental due diligence obligations set out in sections 3 to 10 of the Act in an appropriate manner with the aim of preventing or minimizing human rights or environmental risks or ending the violation of human rights or environmental obligations. The due diligence obligations with regard to the prevention of human rights or environmental risks include, in accordance with Section 3 (1) Sentence 2 LkSG:

• the establishment of a risk management system (§ 4 Para. 1),
• the definition of an in-house representative (§ 4 Para. 3),
• the performance of regular risk analyses (§ 5),
• the issuing of a policy statement (§ 6 Paragraph 2),
• the establishment of preventive measures within the company's own business unit (§ 6 Paragraphs 1 and 3) and vis-à-vis direct suppliers (§ 6 Paragraph 4),
• the taking of corrective action (§ 7 Paragraphs 1 to 3),
• the establishment of a complaint procedure (§ 8),
• implementing due diligence with regard to risks at indirect suppliers (§ 9) and documentation (§ 10 (1)) and reporting (§ 10 (2)).

Due to the size of our company, as an SME we are not directly affected by the regulations of the LkSG, but indirectly through our business relationships, and we take the responsibility enshrined in the law seriously. This is also reflected in our Code of Conduct, which is available at the top of this page.
We also expect our suppliers and service providers to comply with comparable standards in their conduct and to implement them in their own supply chain. Within the scope of our respective capabilities and scope for action, we actively work to ensure that the relevant values and principles are observed and complied with on a sustainable basis.

We strive to respond to our customers' material compliance inquiries according to their specific requirements. However, we reserve the right not to comply with every request for certain customer-specific reporting formats, as this involves a high level of effort that goes beyond meeting legal requirements.

Full Material Declaration

We hope for your understanding, that we usually cannot provide information on the substances contained in our products that exceeds the legal reporting requirements, in particular information on substance contents below any prescribed thresholds, as we generally do not have full material declarations from our suppliers at our disposal.

MSDS

The articles manufactured and supplied by us are not subject to the obligation to prepare safety data sheets according to the European Regulation (EC) No. 1907/2006 (REACH). Since the offered articles are not chemical substances or mixtures, the products are exempt from the obligation to prepare a MSDS.

Measures in the face of Russia's actions destabilizing the situation in Ukraine

Pikatron GmbH is committed to comply with the legal requirements from Regulation EU 833/2014 (restrictive measures in view of Russia's actions destabilizing the situation in Ukraine) in all operating sites and within the scope of its business relations.

Measures with regard to the situation in the middle east

At present, we do not anticipate any serious interventions in our supply chain. The specific impact on global supply chains cannot be estimated at this time. We hope for your understanding, that it is also not possible for us to make a statement on the potential impact of the mentioned export controls on this basis. Furthermore, it is not possible for us to answer specific inquiries regarding the review of our supply chains for source materials of individual products.

Chinese Export Controls on Gallium and Germanium

On July 3, 2023, the Ministry of Commerce and the National Customs Administration of China jointly issued an announcement to implement export controls on gallium and germanium and their compounds on August 1, 2023. Gallium and germanium are elements used in the semiconductor industry (e.g., GaAs LEDs), among other applications. Due to China's dominant role in the production of germanium and gallium, possible export restrictions by China could impact global supply chains (see BGR - Homepage - Chinesische Exportkontrollen für Gallium und Germanium könnten sich auf die globale Halbleiterindustrie auswirken (bund.de)). The specific impact on global supply chains cannot be estimated at this time. We hope for your understanding, that it is also not possible for us to make a statement on the potential impact of the mentioned export controls on this basis. Furthermore, it is not possible for us to answer specific inquiries regarding the review of our supply chains for source materials of individual products.