弗兰德公司的合规体系:
弗兰德的合规体系是所有商业决策和活动的一个组成部分,这就是为什么合规行为是我们所有员工的第二天性。因此,指导原则是:对违反规则的行为零容忍,如果真的发生违规行为,弗兰德会采取严格的行动。
然而,在弗兰德,合规不仅仅意味着对法律或规则的遵守。我们始终努力做正确的事情,甚至比规则和制度的要求更为严格的正确的事情。这就是为什么我们的价值观和信仰深深地嵌入我们的组织和企业文化中。
为了支持我们的员工,我们建立了《弗兰德商业行为准则》,为全球所有员工的行为提供指导和实用建议。
我们的员工可以通过我们的事件报告工具 "Tell Us"来报告违反规则和法律的行为。商业合作伙伴、客户或其他第三方也有机会通过 "Tell Us"报告违反规则的具体迹象,或者直接联系合规组织。
弗兰德也希望其商业合作伙伴各自遵守当地适用的法律、公认的社会责任标准和基本的诚信原则。这一承诺体现在我们的《弗兰德集团 —— 供应商及第三方中间人行为准则》以及与商业合作伙伴沟通的多种方式中。
弗兰德合规管理体系包含各种措施,以确保我们的业务始终完全遵守法律和我们的内部原则和规则。同时,我们希望将负责的行为永久地刻画在所有弗兰德员工的思想和行动中。
弗兰德合规管理体系的结构分为四个行动级别:预防、检测、回应和纠正。
预防措施包括合规风险管理,提供政策和程序,以及员工咨询和培训。
定期审计和检查以及专业和公正的调查,对于发现和彻底调查不当行为至关重要。为了了解任何不当行为,弗兰德有多个报告渠道供内部和外部举报人使用。因此,可以当面、通过电话或电子邮件,以及通过事件报告工具 "Tell Us"来举报违规行为,“Tell Us”可提供全天候、各种语言的服务,如果举报人愿意,还可以选择匿名举报。
你可以在这里找到事件报告工具 "Tell Us"。
此外,所有利益相关者还可以以保密方式直接与合规组织联系(电子邮件:compliance@flender.com)。
所有举报都将得到保密处理。
为了确保我们的合规管理体系继续符合最高标准,我们的合规组织不断监测立法、司法裁决和学术研究的当前发展。
为了对经证实的违反合规行为作出适当的回应,任何不当行为都会受到惩罚。在这方面,弗兰德公司奉行零容忍的做法。
最后,纠正薄弱环节可以确保我们的合规管理体系得到持续改进和调整,并防止进一步的合规违规发生。
这四个层次,加上每位员工和管理层的责任,构成了我们合规管理体系的全部要素。
我们在合同中规定,我们的供应商和具有中介职能的商业合作伙伴有义务遵守统一的行为准则,即《弗兰德集团 —— 供应商及第三方中间人行为准则》。该行为准则以《联合国全球契约》的十项原则为基础。它涵盖了对一般法律的遵守,特别是我们的反腐败原则。此外,它还包含禁止违反竞争法和避免利益冲突的规定。定期审计有助于我们系统地识别供应链和与商业伙伴合作中的潜在风险,并核实他们是否遵守我们的行为准则。
弗兰德集团的《弗兰德集团 —— 供应商及第三方中间人行为准则》可以在这里找到。
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)
Status: 19.12.2023
Version: 1.0
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.