Governance topics

At Comet, business conduct reflects our corporate culture and the way we manage relationships across our value chain.

Corporate culture directly influences Comet’s ability to attract, engage and retain qualified employees in a competitive labor market, which is critical for delivering our strategy and sustaining long-term value creation. Insufficient investment in this area may lead to increased employee turnover, reduced appeal to qualified professionals in the long run, and erosion of know-how and capacity for innovation, which in turn could negatively impact business performance and stakeholder trust.

Along our value chain, we rely on numerous resources to manufacture our products and provide our services. Our aim is always to use these resources as efficiently as possible and minimize the risks associated with their procurement. We view the responsible management of supplier relationships as an integral part of sound business conduct.

Our interactions with suppliers can generate both positive and negative impacts: fair payment terms and delivery terms can, for example, positively affect our suppliers, while unfair treatment can have the opposite effect. Inadequate management of supplier relationships may also result in reputational damage and the loss of existing partnerships, potentially leading to supply chain disruptions. Such developments would pose a significant risk to our business operations.

At Comet, corporate culture is the combined expression of our purpose, values, ethical principles, vision, mission and behaviors. It is grounded in the values and principles of our Code of Conduct, which form the non-negotiable basis for all actions and decisions and shape how we interact with colleagues, customers, suppliers and other stakeholders. Our culture is anchored in three core values – customer orientation, a mindset to challenge and empower, and trustful collaboration – which guide everyday behavior and decision-making and create the conditions for innovation to thrive.

All employees are required to complete mandatory Code of Conduct training to ensure they understand the Group’s values and behavioral expectations, as well as their core compliance duties. Additionally, Comet introduced an updated Anti-Bribery and Corruption (ABC) Policy in 2025, supported by targeted training sessions for specific roles and functions to strengthen the practical application of ABC rules in day-to-day business.

In 2025, Comet further strengthened its cultural foundation by refining the Group’s vision and mission as a core pillar of its strategy to 2030. Within this strategic framework, Comet explicitly embeds people and culture, recognizing their critical role in achieving long-term objectives. The Group’s values and expected behaviors form the foundation of the strategy and guide how it is implemented across the organization.

Management ensures that the corporate culture aligns with Comet’s values and strategic objectives, creating a cohesive framework for success. Leadership teams oversee and monitor key initiatives to drive continuous improvement. At the team level, supervisors facilitate participation in these initiatives and implement measures to ensure alignment with company-wide goals. Regular engagement surveys, such as the Employee Voice Survey conducted in late 2024, provide insight into the employee experience.

Responsible management of supplier relationships means that Comet applies its own standards of lawful, fair and transparent conduct to all interactions with suppliers, embedding these expectations in its Supplier Code of Conduct (Supplier CoC), supplier selection, and ongoing monitoring processes. Through this approach, Comet seeks to prevent human rights violations and environmental harm in its supply chain, reduce climate impacts together with suppliers, and safeguard business continuity by prioritizing reliable, compliant long-term partners.

We are dedicated to maintaining a supply chain that not only meets product performance requirements but also adheres to ethical and sustainable practices, with the Supplier CoC—based on the Responsible Business Alliance (RBA) Code of Conduct—setting clear expectations on legal compliance, the prohibition of corruption and bribery, respect for workers’ fundamental human rights, and the prohibition of child labor, which suppliers formally commit to by signing the document and notifying Comet of any known or suspected violations.