In complying with our goal, responsible, sustainable and lawful action is a matter of course for us. We, Veonet GmbH, therefore commit ourselves to respecting human rights and environmental obligations within our supply chain and consider the protection of human rights as a central element. We implement applicable law, respect internationally recognized human rights and environmental obligations, and take care to prevent human rights violations and environmental pollution in our business activities.
In particular, we condemn all forms of child and forced labor, all forms of slavery and (modern) human trafficking, and all forms of discrimination. We are also committed to comply with the occupational health and safety regulations applicable at the respective place of employment, the payment of appropriate wages and the protection of our employees' freedom of association.
For us, equal rights for women and men are a matter of course and we do not discriminate against anyone on the grounds of gender, origin, race, language, country of origin, faith, religious or political views or disability.
We reject corruption as well as forced labor and human trafficking. In order to comply with our due diligence obligations under the German Act on Corporate Due Diligence in Supply Chains (LkSG), we have established LkSG-related risk management in our own business area and, where necessary, vis-à-vis our direct and indirect suppliers. When selecting direct suppliers and awarding contracts, we take account of the specific requirements of the LkSG in contract negotiations and invitations to tender, and contractually ensure compliance with these requirements.
As part of our risk management, we conduct annual and ad-hoc risk analyses to identify human rights and environmental risks along our supply chain.If risks are identified in the course of the risk analyses, measures are taken to ensure compliance with human rights within the supply chain.
Independently of the risk analysis, we have set up a complaints procedure which enables everybody to point out human rights and environmental risks as well as violations of human rights and environmental obligations. The complaints procedure is publicly available on our website and on the websites of our subsidiaries in the Netherlands, Switzerland, Spain and the United Kingdom.
The German Act on Corporate Due Diligence to Prevent Human Rights violations in Supply Chains (Lieferkettensorgfaltspflichtengesetz - LkSG) came into force on January 1, 2023, although the last sentence of Section 1 of the LkSG states that it will not apply to Veonet GmbH and its subsidiaries until January 1, 2024.
According to Section 2 (6) sentence 3 of the LkSG, the parent company's own business area includes a group company if the parent company exercises a decisive influence over the group company. Therefore, according to our current assessment, our business division also includes the business division of the 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 aim of the law is to improve the protection of human rights and the environment in the own business of a company and along the corporate supply chain. To achieve this goal, the LkSG imposes a number of due diligence obligations on the companies concerned, including measures to avoid the risks specified in the LkSG as well as documentation and reporting obligations.
In addition to measures for risk analysis and prevention, we, Veonet GmbH, have a Declaration of Principles and a Supplier Code of Conduct, which contain the human rights and environmental expectations that we have of our own employees and our direct suppliers. We require that our own employees and our direct suppliers fulfill the communicated expectations.
The LkSG also requires that an appropriate complaints procedure is in place within the company, through which both internal (i.e. employees) and external persons (in particular suppliers and their employees) can contact such company to report human rights and environmental risks or violations.
Any violation of human rights and environmental obligations under the LkSG in connection with our operational activities, products or services and those of our suppliers can be reported via our complaints portal. The riskmanagement@veonet-group.com is responsible for processing complaints.
The complaints process is structured as follows:
You can use our complaints portal to submit complaints that draw our attention to human rights or environmental risks and violations of the prohibitions of the LkSG in our own business area and in the supply chain. The term "supply chain" is broad and includes both our direct suppliers and indirect suppliers. According to Section 2 (2) and (3) of the LkSG, the risks and violations include in particular the following:
Complaints should be based on facts. Complaints can be submitted using the form provided either online or by post to the internal reporting office at Veonet GmbH, Claudius-Keller- Strasse 3a, 81669 Munich.
Complaints should initially contain as much relevant information as possible describing the facts of the case, insofar as the complainant has this information. Complaints should also state what result is to be achieved with the complaint. Complaints can be written in German, English, Dutch and Spanish.
Any person who becomes aware of risks or violations of human rights and environmental concerns within the meaning of the LkSG may submit a complaint. This applies in particular to our employees and the employees of our direct and indirect suppliers, but also to associations such as NGOs. It is also possible to submit a complaint anonymously. The complaint will be treated confidentially and will therefore only be processed by the Veonet department responsible for further processing, whose employees are subject to a strict confidentiality obligation and are independent and not bound by instructions when processing complaints.
In principle, the complaints process comprises the following procedural steps:
a. We will acknowledge receipt of the complaint to the person or organization making the complaint within 7 working days of receipt of the complaint (unless it was submitted anonymously).
b. We will then consider whether the complaint falls within the scope of the complaints procedure; if it does not, we will inform the person or organization making the complaint of this with a brief explanation (unless it was made anonymously). Such a review should not take more than 1 month.
c. Unless the complaint has been submitted anonymously, we will discuss the facts of the complaint with the complainant or organization within 3 months of receiving the complaint in order to better understand the complaint and the underlying facts. As part of this discussion, we will also determine with the complainant person or organization what expectations exist with regard to possible preventive or remedial measures on the part of the complainant person or organization.
In the event that a complaint proves to be justified, we will immediately take the necessary measures - if necessary in consultation with the supplier/business partner concerned - to end or minimize the identified risk or violation of human rights and environmental concerns. Which measures are suitable and appropriate to achieve this goal must be assessed on a case-by- case basis. We will inform the person or organization making the complaint of the action taken, unless the complaint was submitted anonymously. In the event of an unfounded complaint, the person or organization making the complaint will receive a letter summarizing the reasons.
We are legally obliged to maintain confidentiality and to protect the person or organization making the complaint. We stand behind these obligations with full conviction, as it is in our interest to uncover and remedy grievances.
If a complaint has been submitted anonymously, no measures will be taken to find out the identity of the person or organization making the complaint.
Complainants or organizations that submit complaints about human rights and environmental risks as well as violations of human rights or environmental due diligence obligations in good faith and to the best of their knowledge do not have to fear any adverse measures on our part as a result of the complaint. We therefore recommend only submitting information that the person or organization making the complaint believes, to the best of their knowledge, to be accurate. Knowingly providing false or misleading information may result in criminal prosecution.
We also protect the rights of any accused persons. The constitutional presumption of innocence applies until the opposite is proven.
Review: The effectiveness of the complaints procedure is reviewed at least once a year and on an ad hoc basis.
Entry into force / Publication: These Rules of Procedure enter into force on 01.01.2024. They will be published on the websites of Veonet, the Eyescan Group, the Miranza Group, the Ober Scharrer Group, the SpaMedica Group and the Vista Group.