Code of Conduct - Compliance - Digital whistleblower system
This whistleblower system is used by employees and third parties to report suspected cases within Coolenvi and affiliated companies. It enables the anonymous reporting of violations of rules and related suspected cases in order to prevent, clarify and resolve non-compliant circumstances. As a family business, taking responsibility is firmly anchored in our company philosophy. In terms of compliant and law-abiding behavior, we set very high standards for ourselves, which usually go beyond the legally required level. Preventing damage (material and immaterial) caused by disregarding legal regulations and/or internal company rules is therefore of the utmost interest. We encourage all interest groups (suppliers, service providers, buyers, employees, applicants and others) to report compliance violations to us, because this is the only way to identify and remedy misconduct at an early stage. This digital whistleblower system is available to all whistleblowers. It is a secure reporting channel that can be used anonymously and thus guarantees the legally required protection of the whistleblowers and their sensitive data. All reports submitted are checked, evaluated and processed by specially trained compliance management employees.
Our system can be used to submit reports relating to violations of the Supply Chain Due Diligence Act (LkSG), as well as other suspected cases that indicate corruption, financial crime or related activities: (See at the bottom of this page)
Declaration of Human Rights
Declaration of Principles of the Coolenvi Group V 1.0 Status: July 21, 2024
Preamble
Coolenvi is committed to ecologically and socially responsible corporate governance. Our sustainability mission statement includes compliance with ethical business practices, the implementation of environmentally friendly processes and the promotion of social responsibility. Our focus is primarily on projects in Africa.
A. Basic attitude
Coolenvi is aware of its responsibility to respect human rights and to prevent any kind of human rights violations both in our company and along our supply chains. We ensure relevant standards in working conditions and respectful interaction with one another. The well-being of all people involved is of considerable importance to us.
Human rights standards refer to the rights set out in the United Nations (UN) Universal Declaration of Human Rights, the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, the European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR) and recognized regional and national systems for the promotion and protection of human rights.
The purpose of this policy statement is to confirm our ongoing commitment to respecting human rights in the conduct of all our business activities in our own business area but also in relation to our indirect and direct suppliers. In addition, it is intended to set out the mechanisms that have been put in place to implement our strategy for preventing the human rights risks relevant to the company in order to prevent or minimize these risks and thus ensure a high level of human rights protection.
This policy statement clarifies our approach to identifying all types of behavior that could result in a human rights or environmental risk within the meaning of the Supply Chain Due Diligence Act and to establish monitoring, due diligence and training mechanisms as well as communication and complaint mechanisms to promote and protect human rights that include all relevant areas of the company and its affiliates.
B. Scope and Responsibility
\nThis policy statement applies to Coolenvi and all subsidiaries from January 1, 2024. Companies and investments in which we directly or indirectly hold shares or otherwise exercise a decisive influence. Through this statement of principles, our company management hereby clearly positions itself to pay particular attention to and support compliance with the following human rights and environmental obligations:
B.1 Prohibition of child and forced labor, slavery, and human trafficking:
We reject any form of forced or child labor without exception and expressly commit ourselves to the prohibition of modern slavery or human trafficking.
B.2 Equal treatment of employees and zero tolerance of discrimination:
We ensure equal opportunities and do not tolerate discrimination based on, for example, race, gender, religion, national origin, political opinion, professional title, sexual orientation, social origin, age, and physical or mental characteristics.
B.3 Freedom of association and collective agreements:
We respect the right of our employees to join a union. In addition, we support and initiate intensive dialogues with the respective employee representatives.
B.4 Health and safety:
Health protection and occupational safety are our top priorities. We comply with applicable occupational health and safety laws worldwide and also establish our own occupational health and safety standards at all our locations.
B.5 Fair working conditions and remuneration:
We ensure fair working conditions, fair remuneration, and working hours by the national and international laws and guidelines applicable to our companies.\nProhibition of illegal evictions, prohibition of violence by security forces. Our planet and its resources oblige us to reduce the impact of our business activities on the environment, conserve our natural resources, and seek solutions that help protect our environment. We also have these expectations of our suppliers, which are also set out in this Code of Conduct for Suppliers.
We place particular emphasis on the following aspects:
Protecting the environment and avoiding unlawful environmental impacts, including in the context of the Basel Convention (regarding the handling of hazardous substances and waste) and the Minamata Convention (minimizing the release of mercury). Prohibition of causing harmful soil changes, water pollution, air pollution, harmful noise emissions or excessive water consumption, as well as any human rights violations through environmental damage.
Our supply chain
We also expect our business partners, including our indirect and direct suppliers, to be aware of their human rights, and environmental and social responsibilities and to always follow certain basic ethical principles in their activities by this policy statement. With this policy statement, we pass on the expectations of the Coolenvi Group to its suppliers and the entire supply chain. We expect all business relationships to be conducted by this code of conduct.
C. Implementation of our human rights due diligence
Risk analysis and measures in our business area.
To ensure adequate protection of human rights in its business area, Coolenvi has established the necessary processes in company principles, guidelines, and procedural instructions, which generally apply and are implemented throughout the entire group of companies. All employees have unrestricted access to a person of trust, and employees and third parties have access to an anonymous and fair complaints procedure. Training courses are also held on dealing with relevant human rights and environmental risks.
Risk analysis and measures in the area of business partners
We have integrated a comprehensive compliance program, which we implement with particular emphasis into account our risk profile, for example, our industry, our product portfolio, and our business activities in countries with an increased risk of corruption or human rights. As part of the risk analysis, we have implemented strict monitoring and control activities to ensure that our compliance standards and requirements are met in day-to-day business. At the same time, we regularly carry out risk analyses to continuously update and further develop our assessment mechanisms. An integral part of this risk assessment is, for example, a risk indicator for potential human rights violations based on internationally used indices. In cases where risks are identified, appropriate measures are initiated, whereby an informed decision on the business opportunity is necessary, especially in the case of serious risks. Coolenvi is prepared to reject a business opportunity even if it is legally permissible but it poses an unacceptable risk to Coolenvi's values. Risk analysis and measures along the supply chain. Coolenvi has identified relevant immediate suppliers and asked them to provide a comprehensive self-disclosure. In the first step, suppliers with high sales and importance were considered. In addition, a regular media check is carried out to include all relevant existing suppliers in this continuous monitoring process. The process of supplier selection and prequalification has been adapted to ensure human rights screening right at the start of new business relationships. The supplier evaluation is based on a detailed survey with various topic-related questionnaires. The core topics are environmental protection, human and labor rights, occupational safety, anti-corruption and bribery, and responsibility in the supply chain. In addition, suppliers must submit relevant certificates and update them if necessary. This data forms the basis for the necessary monitoring and evaluation activities and a corresponding risk analysis. The risk analyses carried out have shown that there could be potential risks in the supply chain regarding working conditions, the environment, and occupational safety. There are also increased risks due to the location in so-called "very high-risk" countries. To minimize and mitigate risks, appropriate preventive and countermeasures have been defined and integrated into a multidisciplinary process that also provides for an escalation procedure. Coolenvi will also take appropriate action if it becomes aware of a violation of human rights or environmental obligation by an indirect or direct supplier.
D. Basic preventive and remedial measures, as well as communication complaints
The Coolenvi complaints mechanism, consisting of a web-based whistleblower system, is a confidential contact point that is available to everyone as an additional communication channel. Concerns or indications of possible violations of human rights and environmental due diligence obligations can also be raised anonymously. We investigate all reports based on binding internal regulations. Each investigation is carried out independently and objectively with the involvement of the compliance function. All reports and the respective investigations are regularly reported to management in a standardized procedure. Coolenvi does not tolerate discrimination against anyone who contacts us through the complaints mechanism or other communication channels.
E. Training and awareness-raising
We offer training for our employees covering topics such as human rights, sustainability, health and safety, the environment, equal opportunities, and much more. Our training program also includes mandatory training on our Code of Conduct and various other compliance training courses. In addition, we are continuously working to expand our training offering. This includes, for example, offering training on human rights and environmental due diligence for selected target groups. In addition to our employees, we also inform our suppliers about appropriate training offers.
Communication, documentation, and reporting
In our annual report, we report on our activities, progress, and ambitions in all human areas. We report transparently on key risks, our measures, and the progress we have made to protect human rights and environmental protection. A concept for the most complete documentation possible for traceable traceability has been implemented for this purpose.
Remedial measures
If violations of human or environmental rights are identified that were caused by Coolenvi or to which Coolenvi contributed, we undertake to prioritize and process these incidents according to impact and severity. This also includes making efforts to provide appropriate redress to those directly affected.
Improvement and further development
We firmly believe that tackling human rights and environmental challenges in our global supply chains is an ongoing task that requires systemic changes in addition to our company initiatives. Cooperation with our suppliers and business partners is essential. Coolenvi will therefore regularly critically review its role and the implementation of human rights due diligence obligations and continuously develop them further. This also applies to our various internal guidelines and processes relating to human rights.
F. Responsibilities
The overall responsibility for human rights and environmental due diligence lies with the managing directors who participate in the Coolenvi franchise system. It includes at least the control and monitoring of the LkSG-related measures. In implementing this policy statement, the managing director must regularly, at least once a year, inform himself about the work of the person or persons responsible. Every company in the group is obliged to adhere to this policy statement and to implement these principles. The responsibility for the respective implementation of human rights due diligence lies with the respective heads of the departments. The Human Resources department is responsible for coordinating measures to respect human rights and fair working conditions. Processes for maintaining due diligence within our supply chain are developed and defined by the Purchasing department. The Compliance department supports, advises, and is involved within the scope of its specialist responsibilities, in particular about any corruption risks, but also functionally, for example in the context of investigating reports of potential human rights or other relevant violations. In high-risk cases, our Human Rights Officer also takes on an advisory role and participates in the final decision-making process. Coolenvi will regularly and critically review this policy statement and its implementation and update it as needed.
Here you can download the sustainability report for each financial year as soon as it is available.