Our commitment to respecting human rights and environmental due diligence 

We are aware of our corporate responsibility to respect, observe and implement human rights and environmental protection in our own company and along our supply chain. 

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

We fully respect and abide by all international conventions* listed in the Annex to Section 2 (1), Section 7 (3) sentence 2 of the LkSG and support them in our daily actions. 

We expect our employees at all levels to do the same consciously and unreservedly. We also expect them to report violations immediately and in full. We also expect managers to act in accordance with their responsibilities and actively prevent and counteract violations. 

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

Details of the human rights strategy 

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

• The prohibition of forced labor or any other form of modern slavery 
• The ban on employing children under the legally permitted age 
• Respecting the rights of children 
• Respecting, safeguarding and complying with all occupational health and safety obligations applicable at the respective work locations 
• Respect for employees' freedom of association 
• The prohibition of unequal treatment 
• The payment of an appropriate wage or the collectively agreed or minimum wage applicable at the respective place of work 
• The prohibition of unlawful eviction and the prohibition of unlawful seizure of land, forests and waters 
• The prohibition of commissioning or using private or public security forces to protect business projects if this could result in human rights violations due to a lack of instruction or control by us 
• The consistent avoidance of all environment-related risks within the meaning of the LkSG 
• The ban on the import or export of hazardous waste 
  
  

How we ensure compliance with human rights and environmental due diligence obligations 

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

Responsibility 

We have appointed a Human Rights Officer to implement and review our due diligence obligations so that we as the company management can fulfill our direct responsibility. With quality management and auditing, he has effective tools at his disposal to create, review and optimize necessary and relevant processes. The Human Rights Officer reports regularly, at least once a year, directly to the company management. 

Risk management 

We have established a risk management system. This carries out a risk analysis regularly on an annual basis and whenever we have to expect 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 the company management so that it can take preventive measures. 

Risk analyses 

The risk analyses carried out serve to identify and avoid all human rights and environmental risks along our supply chain and to be able to respond appropriately if a violation of human rights or environmental due diligence obligations has already occurred. 

Complaints system 

To enable us to respond quickly and appropriately to violations, we have set up a complaints system that is accessible to everyone and which anyone affected can use to inform us of violations quickly, easily and, if desired, anonymously. This includes not only violations in our own business area, but also explicitly violations at direct and indirect suppliers. The matter will be dealt with immediately. The matter in question is investigated neutrally, regardless of the persons involved and their hierarchical position in our company. The persons involved in the matter are heard and a solution is found. We follow up information on violations at our indirect suppliers in cooperation with our business partners and take the necessary measures depending on the severity of the violation. 

Preventive measures 

In order to prevent human rights and environmental risks from occurring, internal guidelines are established, suitable procurement strategies and purchasing practices are implemented and developed and all managers and employees receive detailed and regular training on the relevant topics to ensure compliance with this declaration of principles. 

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

We review the effectiveness of the preventive measures to ensure compliance with the human rights strategy contained in the Declaration of Principles through our quality management/audit.

Preventive measures vis-à-vis direct suppliers 

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

Direct suppliers are contractually obliged by us to comply with our declaration of principles or to issue a comparable declaration. 

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

If we receive substantiated knowledge of an infringement at a direct or indirect supplier, we will proceed as follows: 

• Carrying out an event-driven risk analysis and adapting our risk management system 
• Establishment of appropriate preventive measures vis-à-vis the polluter, such as the implementation of control measures, support in the prevention and avoidance of a risk or the implementation of industry-specific or cross-industry initiatives to which the company has signed up 
• Cooperation: Development of a joint concept to prevent, stop or minimize the violation 
• If the aforementioned measures are unsuccessful, we reserve the right to terminate the business relationship 
• If necessary: update our policy statement 

Remedial measures 

In the event of specific indications of a breach of human rights and environmental due diligence obligations or if a breach is identified through an incident-related risk analysis, we react quickly and unbureaucratically in order to remedy the deficiency 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 to prevent future breaches due to the same or similar causes. 

Documentation and reporting obligations 

Our actions to comply with the duty of care are continuously documented, stored and published by us in accordance with §10 LkSG. 

We take responsibility 

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

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

Priority human rights and environmental risks 

In our industry, national and international personnel services in work contracts and temporary employment, we see the most important risks generally in the procurement of workers, especially abroad, the recruitment procedures (e.g. through local agencies), safe transportation to the place of work, appropriate and humane accommodation, fair and full payment, correct recording of working hours, ensuring instruction and training (including foreign We see the most important risks in our industry generally in the procurement of workers, especially abroad, the recruitment procedures (e.g. through local agencies), safe transportation to the place of work, appropriate and humane accommodation, fair and full payment, correct recording of working hours, ensuring instruction and training (also in foreign languages), occupational health and safety instructions (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 prevention regulations for all of these risks, which our managers are regularly trained in and obliged to follow. 

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

How we counter these risks 

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

Training 

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

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

Review 

The implementation and effectiveness of the training courses is checked and documented by the quality management/auditing department. Reports on this are regularly submitted to the management. 

Improvement 

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

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

Status: 04.12.23 

 * 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 of 23 May 2001 on the Control of Transboundary Movements of Hazardous Substances. December 1966 on Economic, Social and Cultural Rights; Minamata Convention; Stockholm Convention of May 23, 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.