Declaration of principle
As a service provider with over 120 years of history and tradition, we are committed to respecting human rights and the environment and to taking responsibility for our supply and value chain. Our identification with a traditional value system and ethical principles of conduct ensure that we work in an environmentally conscious and sustainable manner at all levels of the company.
We are aware of our role as a responsible member of society and thus of our responsibility towards customers, business partners and employees. That is why we are committed to principles of conduct that are strictly derived from this awareness. These principles form the framework for our business and social activities.
Our Code of Conduct is a corporate principle that has been in place for many years. It is regularly reviewed as part of an ongoing process and, where necessary, adapted to new legal requirements and other findings and demands we place on ourselves. By signing the Code of Conduct (2022), all members of management have voluntarily committed themselves to complying with it and will pass on this responsibility to their employees.
We are committed to respecting human rights and environmental concerns within our own business activities and in our supply chain, and to ensuring that human rights and environmental violations are prevented and that those affected have access to remedies. We also require our suppliers and business partners to sign the Supplier Code of Conduct.
1. STANDARDS AND GUIDELINES
The company is committed to complying with internationally recognised human rights and environmental laws and regulations and to making the minimum requirements transparent in this regard.
We respect – among others – the following framework agreements and conventions:
• UN Universal Declaration of Human Rights
• UN Guiding Principles on Business and Human Rights
• OECD guidelines
• ILO core labour standards
• ILO Declaration on Fundamental Principles and Rights at Work
• MiLoG – Minimum Wage Act
• GDPR / BDSG – General Data Protection Regulation
• ArbSchG – Occupational Health and Safety Act
• AGG – General Equal Treatment Act
• Diversity Charter
• European Convention for the Protection of Human Rights and Fundamental Freedoms
• Minamata Convention on Mercury
• Stockholm Convention on Persistent Organic Pollutants (POPs Convention)
• LkSG – Supply Chain Due Diligence Act
In addition to these laws and regulations, the guidelines of the Stölting Group form the basis for successful, fair and environmentally conscious conduct, in particular:
• Company policy
• Code of Conduct
• Supplier Code of Conduct
• Compliance policy
• Sustainability policy
• Working Conditions Directive
• Equal Treatment Directive
• Occupational health and safety policy
• HSE policy
If the regulations and applicable laws differ from the requirements in this policy statement, the stricter requirement shall apply.
This policy statement applies to our employees in all divisions and subsidiaries.
The accountability and transparency of this statement are ensured through regular audits, government control measures, management reviews and sustainability reports.
guaranteed.
2. RELEVANT HUMAN RIGHTS ISSUES
We uphold human rights through excellence in both our business development and ethical conduct. We respect human rights within our sphere of influence and conduct our business in a manner that makes us an exemplary employer and contractor.
We respect the dignity of all people and support compliance with internationally recognised human rights. We reject all forms of physical, sexual, psychological or verbal abuse of our employees. We respect freedom of opinion and expression, as well as freedom of association.
We oppose any violation of internationally recognised human rights and working conditions. The Stölting Group is particularly committed to the following human rights:
• Prohibition of child labour
• Prohibition of slavery and forced labour
• Prohibition of discrimination
• Fair remuneration for work performed
• Safeguarding labour rights and occupational safety
• Fair working conditions
• Free choice of workplace
• Safeguarding the right to form coalitions, associations and collective action
• Lawful deployment of private and public security forces
• Preservation of land and municipal rights
3. RELEVANT ENVIRONMENTAL LAW ISSUES
The Stölting Group is committed to a diverse, vibrant and healthy environment. The Group is therefore committed to promoting environmental protection and conserving natural resources, and supports international efforts to combat climate change.
For this reason, the company is committed to the responsible use of natural resources and to avoiding and reducing environmental impacts such as emissions, energy and water consumption, and waste, so as not to endanger the environment.
To ensure that we pose as little risk to the environment as possible, measures are being introduced in the following areas:
• Climate change
• Waste
• Water
• Hazardous substances
• Air pollution
• Noise
• Emissions
• Soil degradation
• Loss of biodiversity
4. IMPLEMENTATION OF HUMAN RIGHTS AND ENVIRONMENTAL OBLIGATIONS
Respect for human and environmental rights is an ongoing process. The implementation of specific measures is subject to regular review and further development in line with changing conditions and our business practices. We have decided to apply the following measures to comply with the requirements of the LkSG:
4.1 RESPONSIBILITIES
The Stölting Group has clearly defined responsibilities in risk management for the perception and compliance with all human rights and environmental due diligence obligations. At the highest management level, the respective management teams of the individual companies are responsible for respecting human and environmental rights in our business activities as well as in the upstream and downstream supply and value chains. In addition, Stölting has appointed a menschenrechtsbeauftragter@stoelting-gruppe.de as of 1 January 2023, who monitors risk management in accordance with the LkSG and ensures operational implementation through coordination and monitoring activities in cooperation with the IMS team, purchasing and legal departments. The Human Rights Officer reports to the holding company's management at least once a year.
Several departments are involved in the operational implementation of human rights and environmental due diligence processes. They report on their findings regularly and as required to ensure compliance with the LkSG.
4.2 RISK ANALYSIS
Knowledge of potential and actual risks is an essential part of our duty of care along the entire value chain. Our primary goal is to protect those who may be affected and to identify, prevent or at least minimise any adverse human rights and environmental impacts on them.
This includes, in particular, analysing the risks and impacts of all procured products and services. To this end, company-wide risk and supplier management is being expanded and extended to include human rights and environmental due diligence obligations. Where necessary (e.g. in the case of a supplier with increased risk), further relevant processes and measures will be initiated, and new risk areas in our business areas and relationships will be identified, classified or categorised.
Reported complaints and criticism from third parties are taken into account in the risk management processes. The results serve as a basis for the creation and adaptation of preventive and remedial measures, as well as regulations, work instructions, procedural instructions, processes and training topics.
4.3 PREVENTIVE MEASURES
In order to fulfil our responsibility to respect human rights, we rely on the interaction of various preventive measures within our own business area and among our direct suppliers. The Stölting Group regularly has the conformity of its internal processes confirmed by external auditors. These include, for example, certifications according to DIN EN ISO 9001 (quality management), DIN EN ISO 14001 (environmental management), DIN EN ISO 50001 (energy management), DIN 77200 (standard for security services), SCC**-VAZ 2021 (safety certificate for contractors) and reporting in accordance with the German Sustainability Code (DNK) and greenhouse gas (GHG) reporting in accordance with the GHG Protocol.
We will regularly communicate this policy statement and the human rights strategy behind it both internally (e.g. to employees) and externally (e.g. to suppliers and customers). The values of this policy statement are reflected in the Code of Conduct and in the integrity clause of the Stölting Group's procurement contracts. A zero-tolerance policy is applied with regard to respect for nationally and internationally recognised human rights and the relevant legal provisions.
4.4 COMPLAINTS MECHANISM & ACCESS TO REMEDIES
The prevention of human rights violations and environmental damage is our top priority. An appropriate and effective complaints management system is a fundamental part of our due diligence processes to prevent violations within our company or in our value chain and to initiate corrective measures.
Stölting takes violations of human and environmental rights seriously and provides publicly accessible and confidential reporting channels through which anyone can report actual or suspected violations by our holding company and subsidiaries, business partners and suppliers at any time. Depending on the severity of the violation, we reserve the right to take appropriate action. Our contact form on the homepage (https://www.stoelting-gruppe.de/) and our email address (menschenrechtsbeauftragter@stoelting-gruppe.de) are available to anyone, regardless of the existence or nature of any contractual or business relationship. The system can be used to submit all kinds of reports and complaints about the conduct of Stölting and our direct and indirect suppliers. Access options in English are also available.
The reports or complaints are handled by the Human Rights Officer, who is impartial, independent and bound to confidentiality. In addition, the company's management is informed of the complaint. Processes are defined, documented and communicated internally for the whistleblower system, which are incorporated into future procedural instructions. The effectiveness of our complaints procedure is reviewed regularly, at least once a year, and as required, and adjusted if necessary.
4.5 EFFECTIVENESS CONTROL
The effectiveness of our grievance procedure and all associated due diligence processes are reviewed regularly, at least once a year, and as needed, and adjusted if necessary to continue to identify, prevent and remedy adverse human rights or environmental impacts.
4.6 REPORTING
We report on progress in the implementation and development of human rights and environmental due diligence obligations to the public in our annual sustainability report in accordance with the German Sustainability Code (DNK).
5. CONTACT FOR QUESTIONS AND INFORMATION
If you have any questions about this policy statement or other human rights or environmental law-related topics, please email our Human Rights Officer at menschenrechtsbeauftragter@stoelting-gruppe.de or contact us using the contact form on our website https://www.stoelting-gruppe.de/.
6. FINAL PROVISIONS
The policy statement on the perception and observance of human rights and environmental due diligence obligations shall enter into force on the date of its signing. It was adopted by the management of Stölting Service Group GmbH in December 2022.
Gelsenkirchen, 15 December 2022
