Supply Chain Due Diligence Act (LkSG)

Human rights are universal.

We, the Gemeinnützige Gesellschaft der Franziskanerinnen zu Olpe mbH (GFO) and all companies affiliated with us (within the meaning of Section 15 AktG) are committed to respecting human rights and related environmental aspects - summarised below as human rights. We regard the protection of human rights within our own business area and within our supply chain as a central element.

We respect internationally recognised human rights and take care to prevent human rights violations in the course of our business activities. In particular, we condemn all forms of child and forced labour, all forms of slavery and human trafficking and all forms of discrimination.

In accordance with the United Nations Guiding Principles on Business and Human Rights, we base our actions on the following internationally recognised human rights conventions and agreements:

• United Nations Universal Declaration of Human Rights
• International Covenant on Political and Civil Rights of the United Nations
• International Covenant on Economic, Social and Cultural Rights of the United Nations
• Core labour standards of the International Labour Organization (ILO)
• Principles of the United Nations Global Compact (UNGC)
• Charter of Fundamental Rights of the European Union
• Minamata Convention (Mercury Convention)
• Stockholm Convention on Persistent Organic Pollutants
• Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal

To guarantee human rights, we implement the due diligence obligations of the Supply Chain Due Diligence Act (LkSG). The due diligence obligations under the LkSG include in particular

• The establishment of a risk management system
• The definition of internal responsibility for the protection of human rights / appointment of a human rights officer
• Carrying out regular and ad hoc risk analyses
• Establishing preventive measures in their own business area and vis-à-vis direct suppliers
• Taking remedial action in the event of violations of human rights-related obligations
• The establishment of a complaints procedure including rules of procedure
• Compliance with due diligence obligations towards indirect suppliers in the event of substantiated knowledge of a violation of a human rights-related obligation
• The fulfilment of documentation and reporting obligations

By implementing the LkSG, we fulfil applicable law and do not tolerate violations of human rights either in our business area or in our supply chain.

We expect our employees to always observe the principles set out in this declaration in their day-to-day work. This declaration of principles serves as a guide for them.

We also expect our suppliers to comply with the aforementioned human rights conventions and agreements and the due diligence obligations set out in the LkSG. In order to communicate our expectations of our suppliers transparently, we have developed a Code of Conduct for Suppliers, which forms part of all supplier contracts.

We continuously implement LkSG-related risk management processes to identify, prevent, remedy or minimise human rights violations or their effects. As part of our risk management, we carry out regular and ad hoc risk analyses to identify human rights risks in our business area and along our supply chain. We follow a risk-based approach to identify relevant focal points. In our risk analysis, we consider potential risks on the basis of country- and industry-specific as well as division-specific information. We prioritise risks according to severity, reversibility of the breach, probability of occurrence, contribution to causation and opportunities to exert influence.

If we identify human rights-related risks as part of the risk analysis, we immediately take preventive or remedial measures to prevent, eliminate or minimise human rights risks. The preventive or remedial measures are determined individually and appropriately for each identified risk.

We are aware of the importance of open communication. We will follow up internal and external reports and complaints appropriately to protect human rights and improve our business processes. To this end, we have set up a complaints office and maintain the confidentiality of identity in the complaints procedure.

Complaints procedure including rules of procedure

We continuously and comprehensibly document the implementation of the due diligence obligations from the LkSG. The documentation serves as the basis for the preparation of reports in accordance with the LkSG. We publish these reports on our homepage.

The management of the GFO is responsible for compliance with the due diligence obligations under the LkSG. It defines the strategy, necessary measures and operational responsibilities for the protection of human rights in accordance with the LkSG.

To monitor the effectiveness of our measures to identify, prevent, minimise and eliminate human rights violations, we regularly review our risk management processes, our complaints procedures and our preventive and remedial measures.