DIE6 Code of Conduct

Code of Conduct under EU Supply Chain Due Diligence Act

(Deutsche Version)

DIE6 Promotion Service GmbH

(hereinafter: DIE6) is committed to ecologically and socially responsible corporate management. We expect the same behavior from all of our suppliers. We also expect our employees and shareholders to observe the principles of ecological, social and ethical behavior and to integrate them into corporate culture. Furthermore, we strive to continuously optimize our business activities and products and services in terms of sustainability and ask our suppliers to contribute to this in terms of a holistic approach.

Suppliers undertake compliance with the principles and requirements of the Code of Conduct. DIE6 is aware that responsible production and the associated corporate duty of care are dynamic processes that can only be managed together in dialogue between individual players in the supply chain. DIE6 therefore supports suppliers in their efforts towards a responsible supply chain.

The Code of Conduct is based on national laws and regulations such as the Supply Chain Due Diligence Act1 (LkSG) and international conventions such as the United Nations Universal Declaration of Human Rights2, the Guidelines on Children’s Rights and Business Conduct3, the United Nations Guidelines on Business and Human Rights4, the international labor standards of the International Labor Organization5 (ILO) and the United Nations Global Compact.

In the following, the Code of Conduct explains the most important steps to be taken when complying with due diligence requirements along the supply chain.

Reporting violations

Der Lieferant ist verpflichtet, jeden Verdacht auf einen Verstoß gegen diesen Verhaltenskodex zu melden. Die Mitteilung erfolgt unter Wahrung der berechtigten Interessen des Lieferanten oder seines Subunternehmens sowie unter Beachtung der Rechte seiner Mitarbeiterinnen und Mitarbeiter, insbesondere des Datenschutzes und des Schutzes von Geschäftsgeheimnissen.

Die Meldung kann an die Geschäftsleitung von DIE6 erfolgen (Mail) oder direkt hier.

¹ https://www.bmas.de/DE/Service/Gesetze-und-Gesetzesvorhaben/gesetz-unte…
² https://www.bmz.de/de/service/lexikon/allgemeine-erklaerung-der-mensche…
³ https://www.unicef.de/informieren/materialien/kinderrechte-unternehmeri…
⁴ https://www.bmz.de/de/service/lexikon/un-leitprinzipien-fuer-wirtschaft…
⁵ https://www.ilo.org/berlin/arbeits-und-standards/kernarbeitsnormen/lang…

The supplier is obliged to determine, analyze and prioritize the human rights and ecological impacts of his business activities and to define appropriate measures to remedy or mitigate them. The interests of rights holders should be taken into account, especially vulnerable groups such as children, women, indigenous communities or migrants.
A good risk management system requires the provision of human resources, the development of management systems, processes and guidelines in order to establish and monitor the requirements described here in his operations. In addition, compliance with the present and following principles should be guaranteed with regard to the company's own employees and suppliers.

This includes the possibility of a clear geographic allocation of the raw materials used for the products. This is also with a view to a complete representation of the supply chain (supply chain mapping) to be carried out by DIE6 if necessary. The supplier shall provide DIE6 with the data required for this if necessary and upon request in case of doubt.

Establishment of grievance and remedial mechanisms

The supplier is obliged to establish mechanisms for the prevention, determination, limitation and compensation of damage for employees that meet the following criteria in particular:
•    Accessible, trustworthy and fair grievance mechanisms
•    Informing all employees about the existence of grievance mechanisms
•    Transparent process for handling complaints
•    Opportunity for employees to make anonymous complaints
•    Consultation of employee representatives in case of need
•    Written documentation of the complaint case and his resolution
•   No sanctions against employees because they have lodged a complaint

If the supplier discovers that the requirements of the Code of Conduct have been violated in his business area or in his supply chain, he must immediately take appropriate remedial measures.

All employees must be informed in a comprehensible manner about their rights and conditions, such as remuneration, working time regulations and holiday entitlements, and have written employment contracts insofar as national regulations and laws provide for this.

Freedom of association and collective bargaining

The supplier shall respect the rights of his employees to form and join trade unions in a free and democratic manner and to engage in collective bargaining. In principle, the supplier may not deny employee representatives access to the employees or interaction with them.

Suppliers operating in countries where union activity is unlawful or where free and democratic union activity is not permitted respect the right to freedom of association and collective bargaining by allowing employees to represent their own representatives with whom the company works in are free to engage in dialogue about workplace issues.

Prohibition of discrimination

The supplier refrains from and prevents any form of discrimination against employees. In particular, no one is discriminated against on the basis of skin color, gender, age, religion or belief, social background, disability, ethnic origin, nationality, membership in employee organizations, political membership or beliefs or sexual identity. This applies in particular to the hiring of employees, their further training, promotion and remuneration.

Compensation and benefits

The supplier is obliged to pay his employees in accordance with the statutory minimum wage or, if higher, on the basis of industry standards approved in collective bargaining. The supplier respects the right of his employees to appropriate remuneration that is sufficient to enable them and their families to lead a decent life and protect the statutory social benefits. Remuneration is to be paid on time, regularly and in full in legal tender. Deductions are only permitted under the conditions prescribed by law or stipulated by collective agreements. Deductions from wages as a disciplinary measure are not permitted.

Working time

The supplier undertakes to comply with the statutory working time regulations, including overtime, breaks, rest and vacation times, as well as paid sick days and parental leave. The use of overtime must be voluntary or regulated by contract or collective agreement and be remunerated at a higher rate than regular working hours.

Prohibition of child labor

The supplier will not directly or indirectly employ children under the age of 15 or children who have not yet reached the legal minimum age for completing compulsory schooling, unless the exceptions recognized by the ILO apply.

As part of his recruitment process, the supplier shall set up reliable mechanisms for determining age, which under no circumstances may lead to degrading or unworthy treatment of employees.

If the supplier becomes aware of child labor, it must immediately take initiatives to identify and implement measures to ensure the protection of the children involved.

Prohibition of forced labor

The supplier does not use any form of forced labor, in particular of a physical, psychological or financial nature. The supplier grants his employees the right to terminate their employment relationship in compliance with the contractually agreed or statutory notice period. It is forbidden to retain identification documents from employees.

The supplier ensures that employees, especially migrant workers and migrants, are not required to make improper payments or deposits in order to get their jobs. If legal payments are made for the placement, these shall be borne by the supplier.

The supplier takes special care when making direct or indirect use of employment agencies. Only legal and responsibly working employment agencies may be commissioned. As far as possible, the supplier should use certified employment agencies.

Treating employees with respect

The supplier shall ensure that employees are not exposed to inhuman or degrading treatment, physical punishment, sexual harassment, psychological or physical coercion, abuse and/or verbal abuse at the workplace. Permitted disciplinary measures under labor law must always be set out in writing and, as far as possible, must be explained to the employees orally in clear and understandable terms.

Labor Protection

The supplier ensures safety in the workplace. To this end, he creates, where necessary, systems for identifying, evaluating, avoiding and combating potential hazards to the health and safety of employees. He takes effective measures to prevent potential accidents, injuries and illnesses of employees that are related to or occur in the course of work.

The supplier is also obliged to provide his employees with a healthy working environment. The minimum requirements include the provision of drinking water, appropriate lighting, temperature control and ventilation, adequate sanitary facilities and personal protective equipment as well as appropriately equipped workplaces and occupational health care and the associated facilities. In addition, the business premises must be built and maintained in accordance with the legally applicable standards.

Where accommodation is provided, it must be clean, safe and meet the basic needs of employees. The supplier respects the right of employees to leave the company premises in dangerous situations without having to ask for permission. All employees shall receive regular training in the areas of health, safety and workplace emergencies. The training must be documented.

Local community rights

The supplier respects applicable local, national, international and traditional land, water and resource rights, in particular those of indigenous communities. If legally permitted land use changes are implemented or water or resources of local communities are used or affected, the supplier must obtain the free, prior and informed consent of the affected communities and document this process. Illegal evictions are not permitted.

The supplier is obliged to limit the environmental consequences of his business activities to a minimum and to actively implement measures to promote environmental protection. The supplier recognizes and complies with local and internationally recognized environmental standards and laws. The supplier assumes his ecological responsibility across the entire supply chain and implements this with regard to both products and packaging. It is important to avoid or continuously reduce the environmental impact of resource and energy consumption, emissions of greenhouse gases and air pollutants, water consumption, application to soil and water and the resulting waste, to preserve biodiversity and to promote circular economy.

Environmental permits

The supplier shall ensure that all required environmental permits and approvals are obtained, kept up to date and followed in order to act in accordance with the law at all times.

Climate protection

The supplier is required to reduce his carbon footprint and thus contribute to the achievement of the goals agreed at the climate conference in Paris, in particular the 1.5 degree scenario presented by the IPCC in November 2018. It is required to find economical solutions to improve energy efficiency and to minimize energy consumption and greenhouse gas emissions. The aim is to use avoidance and reduction strategies that are in line with the specifications of the Science Based Target Initiative II to reduce greenhouse gas emissions as far as possible and only then compensate for residual emissions.
The strategies focus on the continuous improvement of ecological performance and activities to combat climate change. Protection of forests and biodiversity play a central role in mitigating climate change.

Hazardous materials and product safety

Supplier shall label hazardous materials, chemicals and substances and ensure their safe handling, movement, storage, recycling, reuse and disposal. All applicable laws and regulations regarding hazardous materials, chemicals and substances must be strictly observed. Supplier is required to comply with substance restrictions and product safety requirements set by applicable laws and regulations. Supplier shall ensure that key personnel are aware of product safety practices and have received appropriate training.

More environmentally friendly packaging

The supplier is required to use "more environmentally friendly packaging". It is important to avoid or reduce packaging wherever possible or to improve his environmental effects. These principles are to be applied in the order of precedence given here - the ecologically best packaging is the one that can be completely avoided. Packaging is considered to be more environmentally friendly if it is reusable, uses as little material as possible, is recyclable and consists of secondary raw materials or alternative materials or certified paper.

The supplier shall ensure that he documents his activities, structure and performance truthfully and accurately and discloses them in accordance with applicable regulations and industry standards. The supplier must conduct his business ethically and without bribery, corruption or any type of fraudulent business practice, complying at least with national laws and regulations.

Obligations under the Supply Chain Due Diligence Act

The supplier undertakes to comply with his obligations under the Supply Chain Due Diligence Act (LKSG). DIE6 is not directly affected by the obligations of the LKSG. Nevertheless, an increase in inquiries from larger, directly affected DIE6 business partners can be expected in the future. DIE6 will forward these inquiries directly to the affected suppliers. From the time this request is received, the supplier has six weeks to answer the request completely and truthfully to DIE6. The cost of preparing the response is to be borne by the supplier. For this reason, DIE6 has also developed the aforementioned Code of Conduct, which becomes part of this agreement. The supplier undertakes to comply with the principles laid down in the Code of Conduct. The Code of Conduct and updates are available on the DIE6 website at: https://die6.de/code-of-conduct.

DIE6 Promotion Service GmbH, 58093 Hagen, Juni 2022