Supplier Code of Conduct

Veonet GmbH and its subsidiaries eyescan Group in the Netherlands, the Miranza Group in Spain, the Ober Scharrer Group in Germany, the SpaMedica Group in the UK and the Vista Group in Switzerland (the "Company" or "we") is committed to an ecologically and socially responsible corporate management. We strive to optimize our business activities and our services in terms of sustainability and ask our suppliers to contribute to this in terms of a holistic approach.

In connection with the continuing cooperation, the Company and its suppliers (each the "Supplier") agree on the validity of the following regulations for a joint code of conduct (the “Code of Conduct”).

The Code of Conduct shall be the basis for all future deliveries. The Supplier
ndertakes to comply with the principles and requirements of the Code of Conduct. A breach of this Code of Conduct may be grounds and cause for the Company to terminate the business relationship, including all related supply contracts.

The Code of Conduct is based on the German Supply Chain Due Diligence Act
(Lieferkettensorgfaltspflichtengesetz – “LkSG”) and, in accordance with Sec. 2 LkSG, on national laws and regulations as well as international conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children's Rights and Business Conduct, the United Nations Guiding Principles on Business and Human Rights, the international labor standards of the International Labor Organization, and the United Nations Global Compact. We expect our suppliers to be in compliance with the obligations laid down in the LkSG, especially to exercise due diligence with regard to human rights and the environment with the aim of preventing or minimizing human rights or environmental risks or ending violations of human rights or environmental
Furthermore, following the entry into force of the Corporate Sustainability Reporting Directive (“CSRD”) in the EU on 5 January 2023, we expect our suppliers to be in compliance with the obligations set forth in the directive.

The obligations laid down in the LkSG with regard to human rights and the environment are especially the following ones:

  • Prohibition of child labor (Sec. 2 para. 2 no. 1,2 LkSG);
  • Prohibition or slave of forced labor (Sec. 2 para. 2 No. 3,4 LkSG);
  • Prohibition of disregarding the applicable occupational health and safety obligations (Sec. 2 para. 2 no. 5 LkSG);
  • Prohibition of disregarding the freedom of association (Sec. 2 para. 2 no. 6 LkSG);
  • Prohibition of unequal treatment in employment (Sec. 2 para. 2 no. 7 LkSG);
  • Prohibition of withholding an appropriate wage (Sec. 2 para. 2 no. 8 LkSG);
  • Observance of the ban on the use of mercury and mercury compounds including mercury waste (Sec. 2 para. 3 no. 1 - 3 LkSG);
  • Observance on the ban on the non-environmentally sound handling, collection, storage and disposal of waste as well as the export/import of hazardous waste (Sec. 2 para. 3 no. 5 - 8 LkSG);

Further Requirements for Suppliers:


Supplier complies with the previously articulated requirements and standards within its supply chain by engaging and evaluating its contractors in a consistent manner.

Supply Chain Regulation

The Supplier complies with all applicable laws and regulations, especially regarding the management of its supply chains. This applies, among other things, to all social and environmental due diligence obligations as well as specific requirements, such as the LkSG and the CSRD.

Prohibition of corruption and bribery

The Supplier does not tolerate any kind of corruption, bribery or extortion, nor does it participate in any form. This also includes any illegal offers of payment or similar benefits to public officials in order to influence their decision-making. Our employees will not be offered gifts or personal benefits that could be construed as a bribe. In no case will gifts or entertainment be offered to improperly influence a business relationship or in violation of applicable law or ethical standards.

Anti-Money Laundering

The Supplier shall comply with all applicable anti-money laundering laws and implement the measures required by law to prevent money laundering. We only accept funds from legitimate sources.

Sustainability Information

The Supplier shall disclose all sustainability data that we require in our reasonable discretion as part of the risk analysis and for preventive and remedial measures under applicable law and shall report on its business activities truthfully and fully and in accordance with the relevant disclosure requirements.

The Supplier must prepare and publish sustainability reports in accordance with the CSRD and other
applicable legal requirements. Further, the Supplier must have an assessment performed by a certified third-party CSRD rating service, to provide assurances of compliance with the CSRD’s reporting obligations. Such third-party assessments reports must be provided to the Company, upon reasonable request.

Identification of Concerns

Supplier shall encourage and provide a means for employees (which shall include confidential reporting options) to report concerns, complaints, or potentially unlawful activities in the workplace or business activities without threat of reprisal, intimidation, or harassment. The Supplier shall investigate such reports and take corrective action as necessary.
To ensure that no occurrence goes unnoticed and that everyone involved is given the opportunity to report any misconduct, business concerns or potential violations of this Code of Conduct may be reported to the Company without any fear of retaliation through the form provided on the website.

Implementation of the requirements

We expect our suppliers to implement management systems to meet the obligations stipulated herein, to identify risks within their supply chains and to take appropriate measures. In the event of suspected violations and to safeguard supply chains with increased risks, the Company may at any time require disclosure of the supply chains (including a complete representation of the supply chain
(supply chain mapping) through to the source).

The Company reserves the right to take appropriate measures against suppliers who do not meet these requirements, which may ultimately lead to the suspension or termination of a supply relationship.