11/23/2024
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Due Diligence - Policy Statement

Remmers Group SE and all domestic companies affiliated with it within the meaning of Art. 15 AktG (hereinafter collectively referred to as Remmers) are committed to respecting human and environmental rights in their own business operations. The same applies along our global supply chains. We therefore base our business activities on the following internationally recognised standards and guidelines:

  • Universal Declaration of Human Rights of the United Nations (UN)

  • Forced Labour Priority Principles of the Consumer Goods Forum (CGF)

  • International Covenant of 19 December 1966 on Civil and Political Rights

  • International Covenant of 19 December 1966 on Economic, Social and Cultural Rights

  • Conventions and recommendations of the International Labour Organization (ILO) on labour and social standards

  • United Nations Guiding Principles on Business and Human Rights (UNGP)

  • Guidelines of the Organisation for Economic Co-operation and Development (OECD) for multinational enterprises

  • Principles of the United Nations Global Compact (UNGC)

  • Minamata Convention on Mercury of 10 October 2013 (Minamata Convention)

  • UN Women's Empowerment Principles

  • UN Convention on the Rights of the Child

  • UN Convention on the Elimination of All Forms of Discrimination against Women

1. Scope of this Declaration of Principles

The standards and commitments formulated in this declaration of principles are binding for our employees throughout Germany and in all areas of the company. They oblige all employees to behave appropriately and lawfully towards colleagues, suppliers and partners.

Remmers also obliges its suppliers to recognise the Supplier Code of Conduct published alongside this Declaration of Principles as binding and to comply with it. Remmers asks its suppliers to pass on this expectation to their own sub-suppliers and business partners. If necessary, Remmers also supports its suppliers and partners, for example by providing training, in recognising the need for action in accordance with this Code of Conduct and the Supplier Code and implementing appropriate measures.

2. Commitment to primary and fundamental human rights

Following an initial analysis of potential human rights and environmental risks in our own business area and in the business areas of our direct suppliers in 2024, we are paying particular attention to the human rights described below:

2.1 Equal opportunities and equal treatment

Remmers rejects any form of unequal treatment, discrimination or harassment based on gender, ethnic origin, nationality, social background, religion, age, disability, sexual orientation and identity or other characteristics protected by law.

Instead, we promote and support all forms of diversity and inclusion in the working environment and are expressly committed to equal opportunities and equal treatment.

2.2 Forced labour and child labour

Remmers rejects any form of debt bondage or forced labour through indentured labour, slavery or prison labour and any form of human trafficking.

We also strictly reject any form of child labour. We therefore do not employ any persons who have not reached at least the legal minimum employment age. The minimum employment age determined by Remmers itself is in any case fifteen years. Persons who have not yet reached the age of eighteen also only carry out activities under working conditions and working hours that take into account their training and education and are permissible according to the legal requirements.

2.3 Working conditions at Remmers

Remmers complies with all labour laws, in particular the regulations on rest periods, overtime, sick pay and paid holidays. We observe the minimum wage legislation as well as the conditions and obligations of any applicable collective labour agreements. We enter into clear, comprehensible and documented employment agreements with our employees and pay remuneration on time.

We ensure that our employees are provided with a safe working environment in which the health of all employees is protected and the risk of occupational accidents and work-related illnesses is reduced. In particularly hazardous working environments (such as in our laboratories and production halls), we provide protective equipment and organise regular occupational safety and accident prevention training.

2.4 Right to freedom of association and unionisation

Remmers respects the right of its employees to join or not join an employee representative body or trade union without disadvantage. We respect the right of our employees to engage in collective bargaining and to form works councils. Employees who are active as employee representatives are neither disadvantaged nor favoured.

2.5 Privacy and data protection

Remmers respects the privacy of its employees and the confidentiality of their personal data.

3. Commitment to environmental obligations

In its business activities, Remmers assumes responsibility for the mitigation of global warming, for the avoidance and proper disposal of waste, for the reduction of air pollution and for the economical use of energy and water.

4. Risk analyses in the Remmers business area and along the supply chains

Remmers conducts risk analyses on human rights and environmental risks in its own business area and along the supply chains at any time as required, but at least once a year. This is intended to identify and assess the potential and actual effects of our own business activities as well as the activities of our direct suppliers within the meaning of Section 2 (7) LkSG.

Based on an abstract risk assessment, we initially analyse industry-specific risks in our own business area and also country-specific risks in the business area of our direct suppliers. In a second step, we define priority human rights and environmental risks for those direct suppliers for which there is an increased risk disposition as part of a concrete risk analysis and analyse these in more detail. In doing so, we take into account the direct and indirect effects of our own business activities on our suppliers by analysing contractual conditions, sales volumes and opportunities to influence the actions of our suppliers. The content of these regular analyses includes all of the standards and guidelines listed at the beginning and all of the legal positions mentioned in sections 2 and 3.

The results of these risk analyses are continuously incorporated into our corporate decision-making processes and have an impact not only on our business strategies and purchasing decisions, but also on the selection of our suppliers.

5. Risk analyses as the basis for appropriate preventive and remedial measures

The risk analyses carried out form the basis for determining and developing appropriate preventive and corrective measures.

5.1 Preventive measures

By adopting internal behavioural guidelines, regularly training our own employees and continuously reviewing the suitability of our risk management objectives and measures, we enable our employees to identify and prevent risks in our own business area and in the companies of our direct suppliers and to minimise their probability of occurrence.

When selecting its direct suppliers, Remmers already takes into account the absence of human rights and environmental risks through the internal definition of purchasing practices. Through constant and open communication with direct suppliers, the formulation of requirements and expectations of direct suppliers in a supplier code of conduct and, if necessary, the performance of audits and on-site inspections by us or third parties commissioned by us, risks are recognised at an early stage and suitable preventive measures are defined in close consultation with the direct suppliers.

5.2 Remedial and restorative measures

If the risk analyses carried out show that Remmers' business activities lead to potential or actual human rights violations or give rise to such violations, Remmers endeavours to develop appropriate remedial measures to end these violations or risks.

If human rights-related legal positions have been violated at a direct supplier, Remmers will define measures - with the establishment of a concrete timetable - to remedy these violations and prevent further violations. Future co-operation with Remmers can also be made dependent on the taking of appropriate remedial measures. In its Supplier Code of Conduct, Remmers reserves the right to contractually oblige its direct suppliers to assist in clarifying the facts of the case and to cooperate fully within a specified timeframe in order to remedy the infringements.

A continued refusal to co-operate may also result in the termination of the business relationship, as may a serious violation of protected legal positions.

6. Whistleblower department regarding violations of the law and grievances (whistleblower portal)

Remmers attaches great importance to compliance with all applicable laws, regulations and the self-imposed compliance principles of conduct in its own behaviour and business decisions and actions in Germany and abroad. Our aim is to exclude any risks that could jeopardise our integrity and harm our company, our employees, business partners or third parties. In order to fulfil this responsibility, it is important that we become aware of any violations.

Remmers offers all employees and other third parties the opportunity to do so and expressly encourages them to report any violations of the law and irregularities to Remmers. If they wish, they can do so while maintaining their own identity. All reports received are investigated immediately. Suspected cases are investigated and offences are followed up.

Remmers ensures within its sphere of influence that whistleblowers are not penalised or discriminated against in connection with the information they provide.

7. Complaints procedure regarding human rights and environmental risks

Complaints regarding violations of Remmers' principles set out in this Declaration of Principles or the Supplier Code of Conduct, in particular regarding human rights violations, illegal business practices or environmental risks, can be submitted via Remmers' complaints system. The complaints system also enables completely anonymous communication with the Remmers complaints office if desired.

  • Complaints, especially regarding the violation of human rights or environmental obligations within the meaning of the LkSG, can be submitted via the complaints procedure in this portal.

Remmers ensures within its own sphere of influence that complainants are not disadvantaged or sanctioned in connection with the complaint they have submitted.

If we determine that there is a risk in terms of human rights or the environment that has been caused or favoured by our business activities, we will adapt and change our business activities accordingly.

The Management Board of Remmers Group SE

September 2023