Policy statement on the human rights strategy

Date: January 2024

Content
Introduction
Risk management
Risik analysis
Human rights and environmental risks
Prevention measures
Remedial measures
Complaints procedure
Expectations of employees, suppliers and business partner
Contact

The SIEGENIA GROUP is a fourth-generation, family-run, internationally active company. Our entrepreneurial activities are linked to social and ecological responsibility, which has always been, is and will continue to be an indispensable part of our corporate culture. Respect for human rights and the environment in particular is a fundamental component of responsible corporate governance for SIEGENIA. 

Our commitment to the protection of human rights and the environment applies both to our own business activities and to our value chains towards our suppliers and customers. We refer to internationally recognized human rights standards when defining the content of human rights, -conventions, principles and guidelines, in particular the International Bill of Human Rights and the ILO core labor standards. 

Accordingly, we follow the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. 

This policy statement on respect for human rights and the environment complements our current Code of Conduct for Suppliers and the principles of our compliance management system. This policy statement provides a framework for action for all our employees and employees of our business partners along the supply chains.

Best regards

Wieland Frank

Managing Director of SIEGENIA-AUBI KG 

The monitoring of and compliance with human rights is part of the SIEGENIA Compliance Management System (CMS) and company-wide risk management. These two systems are continuously monitored and - if necessary - adapted. The measures derived from the CMS and risk management are integrated into specific work processes throughout the Group and reported to the SIEGENIA Executive Board in a structured manner.

We use established risk analysis processes to identify human rights and environmental risks in our business area and in the business area of our direct contractual partners on an annual basis. The identified risks are prioritized based on their severity, irreversibility, probability of occurrence and our ability to influence them.

If there is knowledge of risks or specific breaches at indirect contractual partners, we carry out an incident-related risk analysis and initiate appropriate remedial measures. The results of the risk analyses directly influence business decisions and result in adjustments to our internal regulations, processes and training.

Based on the risk analysis, we have prioritized the following human rights and environmental issues at SIEGENIA:

• No child labor

We strictly reject child labor. We respect the respective country-specific regulations on the minimum age for taking up employment. 

• No forced labor 

We strictly reject all forms of forced labor, slavery and human trafficking. We only accept employment relationships that are based on voluntariness. 

• No discrimination 

We do not accept any form of discrimination. Unequal treatment on the basis of gender, age, skin color, culture, ethnic origin, sexual identity, disability, religious affiliation or ideology is not tolerated. 

• Occupational health and safety

The health and safety of our employees and business partners is a top priority for SIEGENIA. We attach great importance to compliance with statutory regulations and industry standards on occupational health and safety. 

• Environment

SIEGENIA attaches great importance to sustainability in the production processes and the entire supply chain. We implement targeted sustainability measures as part of our environmental management system and the SIEGENIA sustainability program.

Based on the risks identified by the risk analyses, we at SIEGENIA implement appropriate preventive measures. We oblige every supplier to accept and comply with our Supplier Code of Conduct. We carry out supplier evaluations that cover the topics of human rights and sustainability as well as ecological criteria. We regularly sensitize and train our employees on the topics of human rights, the environment and responsible purchasing practices.  

We have also set up a complaints procedure. Reports are subjected to a risk assessment and - if necessary - appropriate preventive measures are implemented. Information on this can be found under "Complaints procedure". 

To ensure the effectiveness of the preventive measures, we regularly review our guidelines, work instructions and processes and adapt them as necessary. 

If we become aware of violations of human rights and/or environmental regulations, we take immediate and consistent remedial action, regardless of whether the violation occurs in our business area or in one of our supply chains. In the latter case, we contact the business partner concerned and work towards a consistent remedy. 

In the event of serious violations, we reserve the right to take legal action and/or, as a last resort, to terminate business relationships.

SIEGENIA offers employees, suppliers, customers, other business partners and persons potentially affected by human rights violations and environmental violations a reporting channel to report possible risks and violations. This is done while maintaining the confidentiality of the identity of the reporter(s) and the content of the report. 

Every report is processed immediately and - if necessary - remedial action is taken without delay. 

The SIEGENIA complaints procedure can be found on the SIEGENIA homepage in the section german supply chain act.

SIEGENIA expects all employees and managers throughout the company to comply with the principles of this declaration of principles and to live by them in their day-to-day work. The principles apply between employees and towards all business partners. 

At the same time, we expect our business partners to integrate and observe the principles of this Declaration of Principles with regard to human rights and the environment in their business activities and business processes. Measures appropriate to the respective organization are to be implemented both in their own business area and in the respective supply chain in order to ensure these principles. We expect a trusting cooperation between SIEGENIA and the contractual partners. 

We expect that any positive knowledge of human rights violations will be reported via the SIEGENIA complaints procedure. This is the only way we can prevent unlawful behaviour.

SIEGENIA-AUBI KG
Industriestraße 1 - 3
57234 Wilnsdorf
Deutschland

Tel.: +49 271 3931-0
Fax: +49 271 3931-1333

E-Mail: human-rights@siegenia.com