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FROM Our company
Our company recognises the fundamental importance of respecting human rights in its own business and its supply chains. We continue to monitor, review, and
take reasonable steps to ensure that slavery and human trafficking do not contribute to any aspect of our business. We acknowledge our continued
responsibilities under the UK Modern Slavery Act 2015 and, accordingly, have produced this Statement with respect to the prevention of slavery and human
trafficking for the financial year ending.
Company Structure and Business
Here state where you operate (China, Europe etc.)
Specify your supply chains
Describe your policies in relation to slavery and human trafficking
Basic rules that every employee must follow. It includes a chapter on compliance with human rights and
emphasizes the prohibition of all forms of forced labour, slavery and human trafficking.
The basic rules set out in the Code of Conduct are specified in group-wide guidelines, for instance in the guideline on Human Rights and Labour Law. These
guidelines are reviewed regularly and adapted in line with new findings, changed legal provisions, and national and international standards.
Company recruitment practices ensure that hired individuals are free to work. All employees benefit from working conditions and terms and conditions of
employment that meet or exceed all applicable legislation including working hours, holiday, pay and equality. All offers of work made by Company are
accepted on an entirely voluntary basis.
Further, company has a Supplier Code of Conduct which is the core expression of a sustainability- and compliance-based procurement philosophy. It shapes
the expectations and requirements company has towards all suppliers which expressly include the prohibition of slavery, servitude, forced labour and human
trafficking in any form in the supply chains. The principles set out in this Supplier Code of Conduct form an integral part of the supplier selection and
assessment.
In addition, company offers a confidential whistleblowing system – the TÜV SÜD Trust Channel. It enables company personnel as well as external parties to
report potential or actual violations against compliance regulations and in particular also against human rights at company or in companies supply chains.
Due Diligence Processes, Risk Assessment and Risk Management in relation to
slavery and human trafficking
has adopted a uniform group strategy for compliance with human rights due diligence requirements, risk assessment and risk management in its
own business operations and supply chains.
Company has performed various comprehensive risk assessments with respect to human rights and thus also regarding slavery and human
trafficking.
Supply chains
Risky suppliers are usually from China and
India. In the more specific risk assessment based on self-assessment questionnaires and on-site audits, very few specific findings were made to improve the
human rights and/or environment-related risk situation. The suppliers concerned are contacted individually to agree on customized appropriate measures to
reduce the risks.
Performance Indicators in relation to slavery and human trafficking
Targets to measure the effectiveness of its action with regard to compliance in its own business operations and sustainable sourcing
– and thus incidentally also with regard to the prevention of slavery and human trafficking in its business and supply chains. These targets include, for
example, a quota of employees which undertook the annual compliance e-learning and a quota of suppliers which have signed a declaration of compliance
with the Supplier Code of Conduct. For more detailed information about such performance indicators, please refer to the respective sections about compliance
and sustainability across the supply chains.
Training for Employees in relation to slavery and human trafficking
employees around the globe are required to participate in the annual compliance e-learning, which has also included a learning card on human
rights and thus the prohibition of slavery and human trafficking. Further, all procurement personnel are required to participate in a training focussed on human
rights due diligence obligations with regard to companies supply chains. In addition, the Global Compliance Office has published an info sheet on forced
labour in the company intranet.
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