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.
Veonet GmbH rules of procedure with regard to the complaints procedure pursuant to Section 8 LkSG
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: