Supply Chain Law

The LkSG obliges German companies of a certain size to comply with human rights and environmental standards along their global supply chains. It focuses on transparency, risk management and the integration of due diligence. Companies must analyze risks of human rights violations and environmental impacts, take countermeasures and document this in regular reports. The law also requires companies to set up complaint mechanisms and reporting channels to counteract possible violations.

The EU whistleblower protection law serves to protect whistleblowers and to report maladministration in companies. The law provides that employees who report violations are protected from reprisals by a high degree of confidentiality and reliability. It obliges ARDEX to set up an Internal Reporting Office to act as a secure point of contact for reporting violations. The Internal Reporting Office must ensure that the identity of the whistleblower is protected and that an appropriate investigation of the reported violations is carried out. The law thus promotes transparency, integrity and accountability in companies and public institutions in the EU. The Corporate Compliance Officer is appointed at ARDEX for the function of the Internal Reporting Office.

What is the purpose of the appeal procedure?
An essential part of the due diligence obligations defined in the LkSG and HinSchG is the establishment of a suitable complaint procedure. According to §§ 8 and 9 LkSG and § 16 HinSchG, every company is obliged to establish a complaint procedure. This process allows Internal and External Persons to alert the Company to potential human rights or environmental risks or violations within their own business unit and supply chain.

The aim of a complaint procedure is to assume an important function as an early warning system in order to identify problems and, ideally, to solve them before people or the environment actually get harmed.

What violations are relevant?
The complaint procedure can be used to alert ARDEX to human rights or environmental risks and violations in its own business unit and supply chain, or to report other serious violations. The concept of the supply chain is broad and includes both the direct suppliers of ARDEX, with whom ARDEX has a contract, and the indirect suppliers, i.e. the "suppliers of the suppliers". The most relevant human rights and environmental risks include:

• All forms of slavery, economic exploitation and forced or child labor;
• Risk or injury to occupational health and safety, e.g. due to inadequate safety standards, lack of protective measures or inadequate training and instruction;
• Unjustified unequal treatment in the employment relationship, e.g. on the basis of national or ethnic origin or gender;
• Violations of minimum wage laws;
• Improper storages or disposal of hazardous waste.

This list is not exhaustive. If you wish to point out risks or violations, it is better to provide the notice and the assessment of whether the notice falls within the scope of the law will be carried out and communicated by ARDEX.