Human Rights

As a global company, we acknowledge our responsibility to respect and protect human rights and our environment in all our business activities.

We are increasingly aware that, in addition to employees, customers, shareholders and business partners, people who are not directly connected to EFW through a business relationship can also be affected by our activities.

Only the cooperation of all those involved will ensure the long-term success of our company.

We base our actions on the 10 Principles of the UN Global Compact, the Universal Declaration of Human Rights and the 17 Sustainable Development Goals of the United Nations, as well as the international conventions for the protection of human rights and the environment in accordance with the Act on Corporate Due Diligence Obligation in Supply Chains (LkSG) of the Federal Republic of Germany.

Our Code of Conduct and Ethics represents the guiding values and key principles of our economic, sustainable and socially responsible actions.

— The Management of EFW

Our commitment to respecting human rights and protecting the environment is based on the knowledge that we have a special responsibility as a global company. For this reason, this declaration commits us to respecting and monitoring human rights and environmental due diligence and, in the event of violations, to providing those affected with access to a complaints procedure and remedial action.

EFW bases its actions amongst others on the following national and international guiding principles:

• the United Nations Universal Declaration of Human Rights,
• the Social Covenant and the Civil Pact of the United Nations,
• the 10 principles of the UN Global Compact,
• the 17 Sustainable Development Goals of the United Nations,
• the core labor standards of the International Labor Organization (ILO),
• the REACH principles for protection against hazardous chemicals,
• the Minimata Convention,
• the Stockholm Convention,
• the Basel Convention.

For us, human rights are universal rights of every human being. For this reason, there is no tolerance for the EFW when it comes to violations according to section 2 (2) number 1 to 12 LkSG and in particular the following human rights issues:

• Forced and child labor,
• All forms of slavery or servitude,
• Discrimination in any form (e.g. based on gender, age, ethnic and social origin, nationality, religion or ideology, physical or mental disability, sexual orientation),
• Failure to comply with occupational health and safety obligations,
• unlawful evictions and confiscation of land, forests and water.

We focus on our own employees, suppliers, other business partners and groups of people affected in our supply chain.

Our actions worldwide are based on our Code of Business Conduct and Ethics, our Leadership Principles and our Supplier Code of Conduct. Through internal training, we ensure that every member of our Group is sensitized to the content and that a corresponding awareness is developed throughout the company.

EFW has appointed a human rights officer in accordance with section 4 (3) sentence 1 LkSG to ensure adequate monitoring and compliance with corporate due diligence obligations and the resulting risk management. This officer works closely with a defined, cross-divisional team. This working group supports the officer in his activities and is made up of representatives from the Legal Department, Compliance, Finance, Purchasing and Logistics. This interdisciplinary cooperation enables EFW to identify, weight and prioritize risks on an ongoing basis. The ongoing risk analysis thus forms the basis for the appropriate risk management, which is appropriately anchored in all relevant business processes.

EFW has established processes to identify, analyze and evaluate the risks and effects of its economic activities along the supply chain. We have no tolerance for violations of human rights or environmental protection. For this reason, we have expanded our supplier management and our Business Partner Check with regards to corporate due diligence obligations. We continuously carry out a standardized risk analysis of our direct suppliers, involving the internal working group as well as external partners and groups of people affected. If necessary, remedial measures can be defined within an appropriate framework.

Our business activities are influenced by the results of this risk analysis, which enables us to check that new suppliers and business partners respect human rights as early as the selection stage. We continuously improve our management processes through regular and ad-hoc reviews.

By setting up a complaints procedure, we ensure that human rights and environmental risks as well as possible violations can be reported by whistleblowers appropriately. The procedure is accessible from inside and outside EFW via our public website. By using confidential channels, we ensure the anonymity of the whistleblower and protect them from discrimination. 
The receipt of a report is confirmed to the whistleblower. All reported matters are discussed appropriately. Substantiated suspicions are investigated by the Compliance Department together with the Human Rights Officer as part of the transparent complaints procedure.

EFW has no tolerance for violations of human rights and environmental protection in accordance with section 2 (2) number 1 to 12 LkSG and will immediately initiate appropriate remedial measures. In the case of direct employees of EFW, they will be immediately sanctioned accordingly for their violation. Business partners will be informed by EFW about compliance with human rights and measures to remedy the violation will be jointly developed. We endeavor to provide support in making appropriate reparations. 
In the event of repeated violations and if measures do not lead to remedial action, EFW may terminate the business relationship as a last resort.

Compliance with the due diligence obligations pursuant to section 3 LkSG is continuously recorded, documented and retained for a period of seven years.

At the end of the financial year, a report on the fulfillment of the corporate due diligence obligations pursuant to section 10 (2) LkSG is made available to the public and the Federal Office of Economics and Export Control. This report is written in German and English and is available for seven years on the EFW's public website.