Declaration of Human Rights and Environmental Policies

Rules of procedure for complaints under the Supply Chain Due Diligence Act (LkSG)

Corporate Goal

Our commitment to respecting human rights is enshrined in
Art. 1 Basic Law of the FRG: Human dignity shall be inviolable.

We are aware of our corporate responsibility to respect human rights. We are therefore committed to respecting human rights in our own business activities and in our supply and value chains.

In doing so, we align our corporate activities with the internationally recognised 10 principles of the UN Global Compact and the requirements of the United Nations Sustainable Development Goals (SDG).
 

In our efforts to promote the respect of human rights, we focus on the following groups:

• Our own employees at our locations, including trainees, temporary workers and interns
• Employees of business partners
• Groups of people in our direct supply chain: Employees of service providers and direct suppliers
• Groups of people in our downstream value chain: Employees of customers, people in the environment of the products and services
   

Furthermore, we are committed to respecting the environment while taking environmental risks into account. Our focus in this respect is on the following environmental issues in particular.

• Production, processing and use of mercury
• Waste handling, collection, storage and disposal without due consideration of the environment
• Import or export of hazardous waste

Scope

This policy statement applies to Sielaff GmbH & Co. KG Automatenbau Herrieden and all associated national and international subsidiaries.
 

Responsibilities and risk Management

Zur Umsetzung und Überwachung der Einhaltung unserer menschenrechtlichen und umweltbezogenen Sorgfaltspflichten wurden entsprechende Verantwortlichkeiten festgelegt. Für die Umsetzung ist im Ergebnis die Geschäftsleitung verantwortlich, wobei verschiedene Fachbereiche (z. B. Einkauf, QM etc.) operativ unterstützen. Um die unternehmensweite Einhaltung der Sorgfaltspflichten sicherzustellen haben wir einen Menschenrechtsbeauftragten benannt.

Unser umfassendes Risikomanagement betreffend der menschen- und umweltrechtlichen Sorgfaltspflichten soll gewährleisten, dass etwaige menschenrechts- oder umweltbezogene Risiken erkannt werden, die durch unsere unternehmerische Tätigkeit verursacht werden. Die Achtung von Menschenrechten sehen wir als einen kontinuierlichen Prozess, in dem wir laufend Verbesserungen anstreben.
 

Risk analysis:

We believe that risk analysis is a crucial to the fulfilment of our due diligence obligations and is part of our company-wide risk and supplier management system. The aim of the risk analysis is to identify the potential and actual human rights impacts of our business activities.

Risk analysis of our own business area and direct suppliers is described as follows:

Abstract risks are examined first. The criteria used here include sector, country of origin, etc. Where a corresponding risk is identified, specific risks are then reviewed, including child or forced labour, health and safety violations or discrimination, the processing of harmful substances or the handling of harmful waste. This analysis is repeated regularly.
 

Priority human rights and environmental risks

The following lists the areas in which we see the greatest risks of negative impacts on people that are directly or indirectly involved in our business activities at our locations and in our supply and value chains:

• Forced and child labour
• Restrictions on freedom of assembly and association
• Discrimination in any form (e.g. based on gender, age, ethnic and social origin, nationality, religion or ideology, physical or mental disability, sexual orientation)
• Health and safety hazards in the workplace
• Precarious employment and working conditions
   

Prevention and remedial measures

This policy statement on the human rights strategy is made available internally and externally.

Risk analysis is an important part of our procurement processes. It ensures that once identified, human rights and environmental risks are adequately taken into account.

With regard to our direct suppliers, any human rights and environmental risks are taken into account before entering into a new contractual relationship.

Moreover, further preventive measures can be taken or appropriate adjustments made in individual cases.

We conduct investigations whenever concerns or violations are communicated to us by our stakeholders. Our response will be appropriate and remedial action will be taken.

Where there is suspicion of violations within our organisation, we assign a dedicated team to conduct a thorough investigation and propose any necessary measures. Suspected cases at our suppliers are addressed and a thorough and collaborative investigation is performed within a reasonable time frame.
However, we reserve the right to terminate the business relationship without notice if the violation of human rights is so serious that we must demand its immediate remedy, but the supplier fails to respond.
 

Efficacy review

The measures introduced are performed once a year or on an ad hoc basis to verify whether our measures to prevent the violation of human rights have been implemented and are effective. Our tools also include various supplier assessments and, in special cases, audits. We also incorporate our findings from the processing of information received.

We also use the findings of our analyses as a basis for creating any necessary adjustments to internal regulations and processes, as well as for training courses to communicate the necessary duties of care both internally and to our suppliers.
 

Complaints procedure:

We have established a complaints procedure in order to obtain information about potential or actual human rights violations. It can be used by employees, but also anyone outside our company, to submit reports confidentially – even anonymously if they wish. Our complaints system is managed by the atarax Group. The following communication channels are available:

• Whistleblower hotline: +49 160 96210839 (Monday – Friday from 8.30 AM – 5.00 PM, apart from public holidays)
• Email: compliance(at)atarax.de
• Postal address: 
  atarax Unternehmensgruppe, Luitpold-Maier-Str. 7, D-91074 Herzogenaurach

At the request of the whistleblower submitted via these channels, it is also possible to make a report during a confidential face-to-face meeting, which shall take place within a reasonable period.

Digital whistleblower system: https://sielaff.hintbox.eu
 

Documentation and reporting obligations

The fulfilment of human rights and environmental due diligence obligations is documented internally by Sielaff on an ongoing basis and stored for at least seven years in accordance with legal requirements. The annual report on the fulfilment of due diligence obligations is made available free of charge in the Compliance directory on the company's website.
 

Expectations placed in employees and suppliers in the supply chain

We expect our employees and business partners, suppliers in particular, to commit to respecting human rights and protecting the environment, to establishing appropriate due diligence processes and to passing these expectations on to their own suppliers.