Compliance
Declaration of Human Rights and Environmental Policies
Corporate Goal
Our commitment to respecting human rights is enshrined in
Article 1 of the Basic Law of the Federal Republic of Germany: Human dignity shall be inviolable.
We are aware of our corporate responsibility to respect human rights. We are hence committed to respecting human rights in our own business activities as well as in our supply and value chains and to providing those whose human rights are violated with access to redress.
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). This also includes the law on corporate due diligence obligations in supply chains (Supply Chain Due Diligence Act, LkSG).
We also expect our business partners 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.
We acknowledge that our business activities and supply and value chains may potentially have a negative impact on human rights.
We are committed to the respect of all internationally recognised human rights and focus our human rights due diligence processes on the following human rights issues in particular, which we believe are material to our company.
It is in these areas that 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
We focus our efforts for the respect of human rights on the following groups, as their human rights are potentially jeopardised by business activities along our supply and value chains:
- 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
- Handling, collection, storage and disposal of waste without due consideration of the environment
- Import or export of hazardous waste
Risk Management
Risk analysis and implementation
Respect for human rights is crucial for us and the implementation of human rights due diligence obligations is therefore continuously monitored. The analysis is adjusted as necessary to reflect changing circumstances and our business activities:
- We have enshrined respect for human rights in the relationships with our suppliers and ensure that they are observed.
- When selecting new suppliers, risks to human rights are determined and evaluated based on a self-assessment and, if necessary, an audit.
- We apply the processes we have introduced to identify relevant human rights issues and those potentially affected by our business activities and direct business relationships. The analysis of human rights risks and the impacts of our services is an integral part of our enterprise-wide risk and supplier management system.
- Training is provided to communicate the changed requirements for our due diligence processes and obligations.
We require contractual undertakings from our suppliers to comply with national and international laws that relate to human rights and also to give due consideration to risks relating to human rights among their own business partners. In doing so, we pass on our commitment to compliance.
Redress:
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.
We consult with all relevant stakeholders and respond as necessary whenever we suspect that our work for customers is leading to violations of human rights.
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 efficacy of measures introduced is reviewed 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. Mechanisms used for the performance of these reviews include supplier evaluations and, in special cases, supplier audits. We use the findings of these investigations as a basis for creating the necessary adjustments to internal policies and processes, as well as for the provision of training in the necessary duties of care both internally and for our suppliers.
Complaints procedure:
We have established an appropriate and effective complaints management system to receive information about human rights violations. It is designed to permit both internal and external access. Reports sent to us via the complaints system are processed without delay by a trained team. Both the whistleblower and the business partner concerned shall be involved in establishing the facts and a solution shall be determined collaboratively.
Documentation and reporting obligations:
Sielaff continuously documents the fulfilment of its human rights and environmental due diligence obligations within the company and prepares an annual report on the fulfilment of due diligence obligations, which is available free of charge in the Compliance section on the company website.
Rules of procedure for complaints under the Supply Chain Due Diligence Act (LkSG)
The Sielaff Group takes responsibility for respecting and strengthening internationally recognised human rights within its own business areas and through appropriate management of its supply chains.
Accordingly, the fulfilment of human rights and environmental due diligence obligations is a high priority for the Sielaff Group.
Violations may have serious consequences for our Group, employees, business partners and other stakeholders and must therefore be identified at an early stage in order to initiate appropriate countermeasures and avert potential damage.
We have therefore established an effective complaints procedure that can be used to report human rights and environmental risks or violations. This system builds on standardised and fast processes as well as the confidential and professional processing of reports by internal experts.
The key aspects of the complaints procedure are presented below in clear and comprehensible language and with the greatest possible transparency.
1. For which kinds of complaints and reports can our complaints procedure be used?
The complaints procedure can be used to report all indications of potential violations of laws and/or regulations, including human rights or environmental risks or violations relating to the company's own business activities and along the entire supply chain.
2. Which complaint channels can be used to submit complaints?
Complaints can be submitted at any time via various complaint channels. All reports are processed directly and in the same way, regardless of which complaint channel was used.
- 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 personal meeting, which shall take place within a reasonable period.
- Digital whistleblower system: https://sielaff.hintbox.eu
3. Suitability and qualification of internal primary contacts
All information is processed by selected and specially trained members of the complaints team. They are impartial and independent in the fulfilment of their duties and bound to secrecy. Moreover, they are obliged to comply with data protection regulations, to operate with the greatest possible transparency and to safeguard the rights of all data subjects.
4. How does the complaints procedure work?
4.1. Receipt of reports
We treat all information confidentially, irrespective of the communication channel that is used.
Once a report has been received, it is documented internally and the person submitting the report shall receive confirmation of receipt within one week.
4.2. Review of the complaint
The complaints office first checks whether sufficient information is available to examine and investigate the reported circumstances.
If this is not the case, the complaints team will, if possible, contact the whistleblower to obtain further information. The case is closed if sufficient information is not available and attempts to contact the whistleblower fail.
4.3. Investigation of the matter
If sufficient information on the complaint is available, the complaints team investigates the matter and – with due consideration of confidentiality and data privacy – forwards it to the relevant internal department for further investigation. The matter is discussed with the whistleblower if necessary.
The case is closed if the investigation leads the complaints teams and the competent department to the reasonable conviction that human rights or the environment are neither at risk, nor have there been violations, in the company's own business area or at suppliers.
4.4. Preparation of a solution
A proposal for further action (in particular preventive and remedial measures) shall be prepared if the investigation substantiates that there are human rights and environmental risks or violations of human rights or environmental obligations in the company's own business area or at suppliers. The whistleblower will be involved in this process where possible and appropriate.
Preparation of this solution should be concluded 4 weeks after receipt of the complaint.
4.5. Remedial measures
The circumstances of the submitted complaint and the resulting remedial measures are forwarded to the affected business unit or supplier with a request for their statement.
This statement shall be required within one to four weeks, depending on the severity of the complaint and the urgency of the remedial measures.
4.6. Review and conclusion
The statement received from the internal business unit or the supplier is reviewed by the complaints team together with the functional unit that is working on the solution and a review of the statement is then sent to the sender.
Where the statement received is adequate, an entry shall be made in the risk analysis for the business unit or supplier that was the subject of the complaint and the implementation of remedial measures shall be tracked.
The whistleblower will be informed of the conclusion of the complaints procedure, provided this person can be contacted.
5. Protection against discrimination or sanction based on a complaint
Protecting whistleblowers from sanctions or discrimination due to complaints or information provided is an important part of our complaints procedure. Attempts at intimidation and reprisals against persons who, acting in good faith, report actual or suspected misconduct will not be tolerated.
If you, as the whistleblower, believe that you are suffering intimidation or reprisals as a result of your report, please contact the complaints office again; any such intimidation or reprisals will also be reviewed and investigated in accordance with the procedure described above.
The company shall endeavour to make appropriate contractual arrangements with the supplier to protect whistleblowers who are employees of a direct supplier.
6. Efficacy review
The efficacy of the complaints procedure is reviewed after the conclusion of each complaints procedure, but at least once a year.
To this end, all information received to date is reviewed to determine whether the relevant target groups are reached and whether there are clusters of complaints and/or necessary remedial measures. Depending on the findings, the company shall clarify whether the accessibility of the complaints procedure needs to be changed or whether it must exert influence on certain suppliers or industry associations in order to create appropriate remedial measures in the event of known violations of obligations.
