Preliminary remark
As a globally active company, the Schnellecke Group is committed to its social responsibility. Our self-image is characterized by the idea that sustainable economic success is only possible if ecological and social concerns are taken into account. For us, respect for human rights is a fundamental component of sustainable corporate management. We are committed to respecting human rights in our own business activities as well as in our global supply and value chains and to providing access to remedy for those affected by human rights violations. In doing so, we align our business activities with the internationally recognized United Nations Guiding Principles on Business and Human Rights and implement the requirements of the National Action Plan for Business and Human Rights. Our understanding and our human rights due diligence processes are based on the following international human rights reference instruments, to which we are committed:
We expect our business partners to also commit to respecting human rights, to establishing appropriate due diligence processes and to passing on these expectations to their own suppliers. These expectations are set out in our Code of Conduct for Business Partners and form the basis for trusting cooperation.
Explanation
We recognize that our business activities and our global supply and value chains have the potential to cause adverse impacts on human rights. We are committed to respecting all internationally recognized human rights and focus our human rights due diligence processes on the human rights issues that we have identified as material for our company through a risk analysis. In these areas, we see the greatest risks of adverse impacts on people that are directly or indirectly related to our business activities at our locations and in our global supply and value chains:
In our efforts to respect human rights, we focus on the following groups of people:
Within these groups of people, we have identified individuals who are at higher risk of adverse human rights impacts. We include the following particularly vulnerable groups:
Implementation of the due diligence obligations
For us, respect for human rights is a continuous process. The implementation of human rights due diligence in line with changing contextual conditions, the type of business activity and the size and structure of the company is constantly reviewed and continuously developed. We have therefore anchored human rights due diligence processes as an integral part of our organization and in our relationships with our business partners.
Risk analysis
We consider it part of our duty of care to be aware of potential and actual adverse human rights risks and impacts of our business activities on people along the entire value chain. We therefore use an established management process to identify and assess the relevant human rights issues and those potentially affected by our business activities as well as our direct and indirect business relationships. This includes analyzing both human rights risks and the impact of using our products and services. To this end, we have systematically added human rights issues to our company-wide risk and supplier management system. In our management process, we also take into account human rights criticism from third parties and reported incidents. The analysis of human rights risks and impacts is updated annually and whenever there are significant changes to the company's profile or business activities. To this end, we involve internal and external human rights experts, business partners and selected stakeholders, including representatives of actually or potentially affected groups. The results of the analysis of human rights risks and impacts are incorporated into our corporate decision-making processes with regard to supplier selection, business partner management, product responsibility and development as well as mergers and acquisitions. The risk analysis forms the basis for identifying appropriate measures. The management regularly discusses human rights conflicts of interest and relevant findings from our human rights due diligence processes. In addition, we use the results as a basis for creating and, where necessary, adapting internal regulations, processes and training in order to meet the changing requirements of our due diligence processes.
Actions
In order to fulfill our responsibility to respect human rights, we rely on a combination of different measures. The aim is to protect those (potentially) affected and to prevent or at least minimize adverse human rights impacts on them. We have established standardized processes for this purpose. Outside of our company, we contractually oblige our direct business partners in the supply chain to comply with the laws applicable in the respective country and the core labor standards of the ILO, to respect human rights and to address human rights-related risks appropriately with their own business partners.
Effectiveness control
We review the effectiveness of our measures to prevent and mitigate adverse human rights impacts at least once a year and on an ad hoc basis. We also check whether our requirements are being met. We also carry out risk-based audits within our company and follow up on any indications of potential human rights violations. In our value chain, we check the effectiveness of measures by monitoring the results of our continuous analysis of human rights risks and impacts with the help of our supplier management. We also reserve the right to conduct risk-based audits of our direct suppliers, e.g. in the form of document reviews, online assessments and on-site inspections.
Complaints mechanism
We counter all forms of human rights violations. Appropriate and effective grievance management is therefore an important part of our due diligence processes in order to effectively prevent and remedy any potential adverse human rights impacts caused by our company and our business activities. We have set up a company grievance management system that is accessible both inside and outside the company. We operate a whistleblower system that provides a confidential communication channel for internal and external stakeholders and all potentially affected parties worldwide to report possible violations of human rights. Access to the whistleblower system is communicated proactively and in appropriate language to these groups. Reports can also be made anonymously. All reports of possible human rights violations are processed as part of a transparent process. The confidentiality and anonymity of whistleblowers is respected. We ensure, as far as possible and within our sphere of influence, that whistleblowers are protected from discrimination and punishment in connection with the complaints they submit.
Remedial action
In the event that we as a company have directly caused a violation of human rights, we work quickly to prevent the business activities that caused this or to make them compliant with human rights. If our employees behave in a way that is incompatible with human rights, appropriate sanctions are introduced. In the event that we contribute to potential or actual human rights violations through our business activities or are indirectly associated with them, we endeavor to remedy the situation appropriately. If we have a well-founded suspicion or concrete indication of possible human rights violations in our company or along our upstream and downstream value chain, we investigate this carefully and consistently. We oblige our business partners to support us in clarifying the facts and to cooperate fully within a reasonable timeframe. Depending on the severity of the violation, we reserve the right to take appropriate action in connection with our business partners, ranging from a request to remedy the violation immediately to legal action and termination of the business relationship.
Reporting
In our sustainability report, we inform the public about our human rights commitments and due diligence processes and their effectiveness. To this end, we report on the material human rights risks and impacts we have identified as a result of business activities along our global supply and value chains and describe the preventive and remedial measures we have implemented.
Responsibilities
We have defined clear responsibilities for the exercise of and compliance with our human rights due diligence obligations. The Management Board receives regular and ad hoc internal reporting on the results of our continuous risk analysis relevant to human rights, information from our grievance mechanisms and information on the effectiveness of our remedial and preventive measures.
Trainings
In order to sensitize all our employees to respect human rights and to impart the necessary expertise for the effective implementation of human rights due diligence processes in the relevant business areas, we will carry out regular, mandatory training and further education measures in the form of training courses within our company in the future.
