Our commitment to respect human rights and fulfil our environmental due diligence obligations 

We are aware of our corporate responsibility to respect, abide by and implement human rights and protection for the environment in our own company and along our supply chain. 

We are committed to respecting and monitoring human rights and fulfilling environmental due diligence obligations in our own business activities and in our supply and value chains, and to providing those affected by breaches with access to remedial action. 

We fully respect and abide by all international conventions* listed in the Appendix to Section 2(1) and Section 7(3)(2) of the German Supply Chain Due Diligence Act (LkSG) and uphold them in our day-to-day actions. 

We expect our employees at all levels to do the same consciously and unreservedly. We also expect them to report breaches without undue delay and in full. We also expect managers to act in accordance with their responsibilities and actively prevent and counteract breaches. 

We expect our suppliers to also commit to respecting human rights and fulfilling their environmental due diligence obligations, to commit to establishing appropriate due diligence processes and to pass these expectations on to their own suppliers. 

Details of our human rights strategy 

Our human rights strategy includes strict and binding compliance with the following points in accordance with the definitions set out in the LkSG: 

• Prohibition of forced labour or any other form of modern slavery 
• Prohibition of the employment of children under the legally permitted age 
• Respecting the rights of children 
• Respecting, safeguarding and complying with all health and safety obligations applicable at the respective work locations 
• Respect for employees’ freedom of association 
• Prohibition of unequal treatment 
• The payment of an appropriate living wage or the collectively agreed or minimum wage applicable at the respective place of work 
• Prohibition of unlawful eviction and the prohibition of unlawful taking of land, forests and bodies of water 
• Prohibition of the hiring or use of private or public security forces to protect business projects if this could result in human rights violations due to a lack of instruction or checking by us 
• Consistent avoidance of all environment-related risks within the meaning of the LkSG 
• Prohibition of the import or export of hazardous waste 
  

How we ensure respect for human rights and fulfil our environmental due diligence obligations 

To ensure that all legal requirements are met in the supply chain, we proceed as follows: 

Responsibility 

We have appointed a Human Rights Officer to carry out and monitor our due diligence so that as management we fulfil our direct responsibility. Quality management and auditing are effective tools available to the Human Rights Officer for creating, reviewing and optimising the necessary and relevant processes. The Human Rights Officer reports regularly, at least once a year, and directly to management. 

Risk management 

We have a Risk Management department. Risk Management performs a regular risk analysis on an annual or ad hoc basis, if we anticipate a significant change or significant increase in the risk situation in the supply chain, for example due to the introduction of new products, projects or a new business area, in the event of significant changes to the company profile or if there are specific indications, the results of which are immediately presented to management so that it can take preventive measures. 

Risk analyses 

The risk analyses performed are used to identify and prevent all human rights and environmental risks along our supply chain and to be able to respond appropriately if a breach of our human rights or environmental due diligence obligations has already occurred. 

Complaints system 

To enable us to respond quickly and appropriately to breaches, we have set up a complaints system that is accessible to everyone and which anyone affected can use to inform us of breaches quickly, easily and, if desired, anonymously. This includes not only breaches within our own business area, but explicitly also at direct and indirect suppliers. Complaints are processed immediately. The situation raised is investigated neutrally, regardless of the persons involved or their hierarchical position in our company. The persons involved in the situation are listened to and a resolution is found. We work with our business partners to follow up any reports of breaches at our indirect suppliers and take the necessary measures depending on the severity of the breach. 

Preventive measures 

In order to prevent human rights and environmental risks from occurring, internal guidelines are established, appropriate procurement strategies and purchasing practices are implemented and developed and all managers and employees receive in-depth and regular training on the relevant topics to ensure compliance with this policy statement. 

Managers are made aware of the need to pay particular attention to the risks prioritised in their business area and to minimise them in a targeted manner. 

We review the effectiveness of the preventive measures to ensure adherence to the human rights strategy contained in the policy statement through our quality management/auditing. 

Preventive measures in respect of direct suppliers 

Direct suppliers are subjected to an individual risk analysis during the selection process. 

Our direct suppliers are contractually obliged to comply with our policy statement or to issue a comparable statement. 

The contractual obligation stipulates that the direct supplier must perform its own risk analyses, set up a complaints mechanism or provide access to our complaints system, implement preventive measures, take remedial action if necessary and inform us appropriately about these steps in order to ensure that the requirements are implemented. The direct supplier must provide evidence of the above accordingly. 

If we receive substantiated information about a breach at a direct or indirect supplier, we will proceed as follows: 

• Perform an ad hoc risk analysis and adjust our risk management 
• Impose appropriate preventive measures on the originator, such as the implementation of control measures, support with the prevention and avoidance of a risk or the implementation of industry-specific or cross-industry initiatives that the company has joined 
• Cooperation: Develop a joint concept to prevent, stop or minimise the breach 
• If the aforementioned measures are unsuccessful, we reserve the right to terminate the business relationship 
• Where appropriate: Update our policy statement 

Remedial measures 

In the event of specific reports of a breach of human rights or environmental due diligence obligations or if a breach is identified through an ad hoc risk analysis, we respond quickly and without bureaucracy in order to eliminate the shortcoming through appropriate measures and immediately prevent any continuation of the misconduct. 

We then investigate what led to the breach so that we can adapt our processes in order to prevent future breaches due to the same or similar causes. 

Documentation and reporting obligations 

Our actions to fulfil our due diligence obligations are constantly documented, stored and published by us in accordance with Section 10 LkSG. 

We take responsibility 

As implementing human rights due diligence is an ongoing process, this policy statement and its implementation are reviewed, optimised and updated regularly and on an ad hoc basis. 

Responsibility for the implementation of this policy statement is borne and managed by the managing directors of the company (and its affiliated companies) for their areas of responsibility in each case. This ensures that each of our companies is aware of its own responsibility for respecting human rights, environmental due diligence obligations and their day-to-day implementation. 

Priority human rights and environmental risks 

In our industry, national and international HR services in contracts for services and contract staffing, we generally see the most significant risks in the procurement of workers, especially abroad, recruitment procedures (for example, by local agencies), safe transportation to the place of work, appropriate accommodation fit for human beings, fair and full payment, correct recording of working hours, ensuring instruction and training (also in foreign languages), occupational health and safety instruction (also in foreign languages), informing workers about their rights and obligations (also in foreign languages) and equal treatment during their work for us and our customers. 

We have established clear and unambiguous internal regulations aimed at preventing all of these risks, which our managers receive regular training on and are obliged to follow. 

We have based our specific risk analyses on this portfolio of risks. 

How we counter these risks 

To counter the risks identified and ensure they do not materialise, we proceed as follows: 

Training 

The content of training for managers and employees in high-risk processes and procedures is reviewed, supplemented where necessary and training stepped up. 

Where no evidence was previously required, such evidence will be introduced. 

Review 

The delivery and effectiveness of training will be checked and documented by quality management/auditing. Reports on this will be regularly submitted to management. 

Improvement 

In our processes, we focus on continuous improvement through education, support and training for all employees, from part-time workers through to managers. 

Adhering to, monitoring and improving our processes creates a helpful and effective framework for this. 

Version: 4 December 2023 

 * ILO Convention No. 29/No. 87/No. 98/No. 100/No. 105/No. 111/No. 138/No. 182, Protocol of 11 June 2014 to Convention No. 29 of the International Labor Organization of 28 June 1930 concerning Forced or Compulsory Labour; International Covenant of 19 December 1966 on Civil and Political Rights; International Covenant of 19 December 1966 on Economic, Social and Cultural Rights; Minamata Convention; Stockholm Convention of 23 May 2001 on Persistent Organic Pollutants; Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal – in each case in the most recent or supplemented/amended version.