The compliance system of Flender is an integral element of all business decisions and activities, which is why compliant behavior is second nature to all our employees. The guiding principle is therefore: zero tolerance for breaches of the rules, and if they do occur, Flender takes rigorous action.
However, compliance at Flender means more than mere adherence to the law or rules. We strive to always do the right thing, even beyond rules and regulations, which is why our values and beliefs are deeply embedded in our organizational and corporate culture.
To support our employees, we have adopted the Flender Business Conduct Guidelines, which provide guidance and practical recommendations for conduct for all employees worldwide.
Our employees can report violations of rules and laws via our incident reporting tool "Tell Us". Business partners, customers or other third parties also have the opportunity to report specific indications of violations of rules via "Tell Us" or they can contact the compliance organization directly.
Flender also expects its business partners to comply with the respective locally applicable law, generally accepted standards of social responsibility and the essential principles of integrity. This commitment is reflected in our Flender Group Code of Conduct for Suppliers and Third-Party
Intermediaries as well as in a comprehensive approach to dealing with our business partners.
The Flender Business Conduct Guidelines is a company-wide guideline that provide guidance and practical recommendations for conduct to all Flender employees worldwide. The contents are based on our values and are binding for all employees. At the same time, they provide valuable assistance and answers to important questions.
You can find the Flender Business Conduct Guidelines here:
The Flender Compliance Management System bundles measures to ensure that our businesses are always in full compliance with the law and our internal principles and rules. At the same time, we want to anchor responsible behavior permanently in the thinking and actions of all Flender employees.
The Flender compliance management system is structured into four levels of action: Prevent, Detect, Respond and Correct.
Preventive measures include compliance risk management, the provision of policies and procedures, and employee counseling and training.
Regular audits and checks as well as professional and fair investigations are essential for the
detection and thorough investigation of misconduct. In order to become aware of any misconduct, Flender has several reporting channels available to internal and external reporters. Compliance violations can therefore be reported in person, by phone or e-mail, and via the incident reporting tool "Tell Us" - around the clock, in various languages, and anonymously if preferred.
You can find the incident reporting tool "Tell Us" here.
In addition, all stakeholders can also contact the compliance organizational unit directly in a confidential manner (e-mail: email@example.com).
All reports will be treated confidentially.
To ensure that our compliance management system continues to meet the highest standards, our compliance organization continuously monitors current developments in legislation, judicial decisions and academic research.
In order to respond appropriately to proven compliance violations, any misconduct is consistently punished. In this regard, Flender pursues a zero-tolerance approach.
Finally, correcting weaknesses ensures continuous improvement and adaptation of our compliance management system and leads to the prevention of further compliance violations.
These four levels, together with the responsibility of each employee and management, form the overall element of our compliance management system.
We contractually obligate our suppliers and business partners with an intermediary function to comply with a uniform code of conduct, the Flender Group Code of Conduct for Suppliers and Third-Party Intermediaries. This Code of Conduct is based on the ten principles of the United Nations Global Compact. It covers compliance with the law in general and our anti-corruption principles in particular. In addition, it contains provisions prohibiting violations of competition law and avoiding conflicts of interest. Regular audits help us to systematically identify potential risks in our supply chain and in our collaboration with business partners and to verify whether they abide by our Code of Conduct.
The Flender Group Code of Conduct for Suppliers and Third-Party Intermediaries can be found here:
Policy statement of Flender Group GmbH
on human rights and environmental due diligence obligations in accordance with Section 6 (2) of the Act on Corporate Due Diligence Obligations in Supply Chains of 16 July 2021 (Supply Chain Due Diligence Act - LkSG)
The Flender Group GmbH, including its affiliated companies (hereinafter referred to as "Flender"), is aware of its corporate responsibility to respect human rights. We are therefore committed to respecting human rights in our own business area as well as in our global supply and value chains and to provide access to remedy for those affected by human rights violations. We recognize that human rights are inherent to all people, regardless of their nationality, place of residence or gender. They are universal, indivisible and inalienable.
As part of our commitment to sustainable and responsible business practices, we have integrated the ten principles of the United Nations Global Compact into our strategies and activities. As a participant in the United Nations Global Compact, we have committed ourselves to respecting human and labor rights and protecting the environment, among other things.
In addition, our understanding and our human rights due diligence processes are based on the following international human rights reference instruments to which we are committed: The International Bill of Human Rights, i.e. the United Nations Universal Declaration of Human Rights, as well as the Civil and Social Covenants, which define civil, political and social rights to which all people are entitled for the sake of their dignity. The core labour standards of the International Labour Organization (ILO) with their four basic principles on freedom of association and the right to collective bargaining, the elimination of forced and child labor and the prohibition of discrimination in respect of employment and occupation.
In the coming years, we will regularly review and improve our human rights and environmental due diligence processes to protect and embed human and environmental rights in all business areas. Furthermore, we will endeavour to expand our review of the human and environmental rights beyond the requirements of the LkSG.
The following describes how we fulfill our obligations in accordance with section 4(1), section 6(3-5) and section 7 to 10 of the LkSG:
1. Risk Management
For us, respect for human rights is a continuous process. The implementation of human rights due diligence in line with changing contextual conditions, the type of business activity and the size and structure of the company is constantly reviewed and continuously developed. We have therefore anchored human rights due diligence processes as an integral part of our organization and in our relationships with our business partners.
Flender's management sees itself as responsible for monitoring and enforcing human rights and environmental due diligence obligations. In 2023, the Corporate Social Responsibility (CSR) Board was therefore appointed as the body responsible for monitoring the implementation of the LkSG. The CSR Board is made up of the management of the Flender Group as well as the presidents of the business units and the heads of the Group Functions. This ensures that every area of our company is aware of its own responsibility for respecting human rights and implementing them on a daily basis.
2. Risk Analysis
We consider it part of our duty of care to recognize potential and actual adverse human rights risks and the impact of our business activities on people along the entire value chain. We therefore identify and assess the relevant human rights issues and those potentially affected by our business area as well as our direct and indirect business relationships.
We systematically take human rights and environmental risks into account in our supplier management. The analysis of human rights risks and impacts is updated annually and whenever there are significant changes to the company's profile or business activities.
The results of the risk and impact analysis are incorporated into our corporate decision-making processes with regard to supplier selection, business partner management, product responsibility and product development. The risk analysis forms the basis for identifying appropriate measures. We also use the results as a basis for creating and, where necessary, adapting internal regulations, processes and training in order to meet the changing requirements of our due diligence processes.
3. Expectations of Employees and Suppliers
In order to live up to the standards we set ourselves, Flender has implemented group-wide guidelines to ensure human rights and environmental due diligence are considered. These include, for example, our own code of conduct - the Flender Business Conduct Guidelines - and the Flender Human Rights Policy. The Flender Business Conduct Guidelines are company-wide guidelines that apply to all Flender employees. The content is based on our values, including environmental protection, human rights, occupational safety and social standards, and is binding to all employees. At the same time, these Guidelines provide valuable assistance and answers to our employees.
We communicate our position to our business partners through the Flender Group Code of Conduct for Suppliers and Business Partners with Intermediary Functions and we contractually oblige our suppliers and business partners with an intermediary function to comply with this standardized code of conduct, which is based on the ten principles of the United Nations Global Compact.
We will continue to communicate our internal policies and to inform and sensitize our employees and suppliers about these issues.
4. Preventive and Remedial Measures
In order to fulfil our responsibility to respect human rights, we rely on the interaction of various measures. The aim is to protect the (potentially) affected persons and to prevent or at least minimize adverse human rights impacts on them. We have established standardized processes for this purpose.
In our own business area, we cooperate with the relevant stakeholders to promote the realization of human rights. The rights and concerns of rights holders, local stakeholders and experts as well as civil society are taken into account.
Outside our company, we contractually oblige our direct suppliers and our business partners with an intermediary function through our Code of Conduct for Suppliers and Business Partners with Intermediary Functions to comply with the laws applicable in the respective country and the core labor standards of the ILO, to respect human rights and to appropriately address human rights-related risks vis-à-vis their own business partners.
In the event that we as a company or a supplier have (partly) caused a violation of human and environmental rights, we will work immediately to ensure that these violations are remedied or that their effects are at least minimized.
5. Complaints Procedure
We consider appropriate and effective grievance management to be an important part of our due diligence processes in order to effectively prevent potential adverse human rights impacts from our business activities and effectively remedy them. We have set up a whistleblower system (´Tell Us´) that is accessible both internally and externally. It provides a confidential communication channel for reporting possible violations of human rights and environmental rights. Tell Us is available around the clock and reports can be communicated in various languages. Reports can also be made anonymously.
6. Documentation and Reporting
We document and report on the implementation of our due diligence obligations in an appropriate manner in order to fulfil the requirements of the ïnternal and externally reporting obligations pursuant to Section 10 LkSG. In our annual sustainability report, we also inform the public about our human rights commitments and due diligence processes and their effectiveness.
7. Further Development
Flender will regularly monitor and review the effectiveness of its measures at global and local level. Changes will be made when appropriate and necessary to further develop risk management and ensure the fulfilment of our human rights obligations. If changes are necessary, they will be implemented.