Grundsatzerklärung zur Menschenrechtsstrategie

1.    Foreword by the Management Board of Michael Weinig AG

We are aware of our corporate responsibility to respect human rights. We are therefore committed to respecting human rights in our own business activities and in our global supply and value chains and to providing access to remedy for those affected by human rights violations.

In doing so, we align our business activities with the internationally recognized United Nations Guiding Principles on Business and Human Rights (UNGP) and thus implement the requirements of the German National Action Plan for Business and Human Rights (NAP) and the German Supply Chain Due Diligence Act (LkSG).

In addition, our understanding and our human rights due diligence processes are based on the following international human rights reference instruments, to which we are committed:

• The International Bill of Human Rights, i.e. the United Nations Universal Declaration of Human Rights as well as the Civil and Social Covenants, which define civil, political and social rights to which all people are entitled for the sake of their dignity.
  
  
• The core labor standards of the International Labor Organization (ILO) with its four basic principles on freedom of association and the right to collective bargaining, the elimination of forced labor and child labor, and the prohibition of discrimination in respect of employment and occupation.

We expect our business partners to also commit to respecting human rights, to establishing appropriate due diligence processes and to passing these expectations on to their own suppliers.

2.    Human Rights Issues and Potentially Affected Groups of People

We are aware of the fact that our business activities and global supply and value chains can potentially have a negative impact on human rights.

WEINIG’s human rights due diligence focuses in particular on the following human rights issues, which were identified as essential in a risk analysis. This is where we see the greatest risk of detrimental effects on people who are directly or indirectly affected by our business activities and our global supply and value chains:

• Forced labor and child labor
• Restrictions on freedom of assembly and association
• Discrimination in any form
• Inadequate occupational health and safety
  
• Non-compliance with data protection
• Corruption and bribery
• Restriction of the rights of local communities and indigenous people
• Damage to health, home or economic assets required for livelihoods, for example through water, soil or air pollution or deforestation

In our efforts to respect human rights, we focus on the following groups of people, as their human rights are potentially jeopardized by business activities along our global supply and value chains:

• our own employees at national and international locations
• employees of business partners
• groups of people in our direct and indirect supply chain
• groups of people in our downstream value chain
• groups of people regardless of their location in the value chain: people in precarious employment, trade union representatives and local trade unionists
• groups of people indirectly linked to the value chain: members of local communities and residents near company sites, family members, employees in public authorities.

Within these groups of people, we have identified individuals who are at higher risk of being impacted by human rights violations. These potentially affected parties occupy a special position within our due diligence processes. These are groups of people who have special needs, who are isolated in society or who find it difficult to make their concerns heard. The groups of people who are particularly at risk include

• children
• poor people
• sick people
• people with disabilities
• ethnic/religious/sexual minorities
• representatives of the interests of certain groups (in particular human rights defenders, trade unionists)
• whistleblowers.

3.    Procedures and Responsibilities

3.1     Responsibilities within the Company

The ongoing management and monitoring of the human rights policy is the responsibility of the WEINIG Group’s Human Rights Officer. He or she coordinates activities, sets priorities and leads the WEINIG Group’s company-wide efforts to respect human rights. Responsibility for implementation lies with the individual companies (operating units), which ensure the integration of this policy in their respective regions.

3.2     Risk Management System

Risks are identified and assessed across the Group every quarter. To this end, Risk Officers have been appointed for each operating unit to identify and assess the risks relevant to their location and report them to the WEINIG Group’s Risk Management Officer. On the basis of the information received, he or she prepares a risk report for each quarter, which is distributed to the management board and supervisory board of Michael Weinig AG. The risk reports are also the subject of the supervisory board meetings that take place several times a year.

In the past, when recording risks, the focus tended to be on the impact of strategic, operational, financial and market risks on the company. However, the LkSG requires a change of perspective in this respect: the effects of risks to which the WEINIG Group’s own employees, employees along the supply chain or other affected persons are exposed as a result of the WEINIG Group’s business activities must be verified.

We therefore introduced a risk analysis in 2024 that meets the requirements of the LkSG and is described in more detail in the following section.

3.3    Risk Analysis

From 2024, the WEINIG Group will carry out a separate risk analysis in accordance with the LkSG. This will be carried out annually for direct suppliers and the company’s own business area (regular risk analysis). Furthermore, an event-driven risk analysis will be carried out either on the basis of substantial knowledge and/or a change in business activities. If there is substantial knowledge, the risk analysis will also be extended to indirect suppliers.

The first step is an abstract analysis of the risks, in particular sector- and country-specific risks. Based on this, we will determine which specific risks exist at the company’s own locations and at suppliers and which risks should be primarily addressed and where.

We see the highest country-specific risks for the WEINIG Group in Turkey, China, Mexico, Belarus and Brazil. Also, the risks associated with suppliers of forged metal, cast and electrical parts as well as parts with surface treatment are considered high due to the production processes required and/or the raw materials used.

3.4     Preventive Measures

Several years ago, the WEINIG Group introduced a Code of Conduct that applies to employees at all locations. This document is regularly adapted to current requirements and developments as necessary; most recently, new chapters on the topics of supply chains and the whistleblower system were added. The Code of Conduct clearly states, among other things, that all companies in the WEINIG Group must comply with the relevant laws and applicable regulations, that fair and equitable competition must be ensured, that corruption in any form is rejected, that fair working conditions must be created everywhere and that environmental protection must be observed.

In addition to the Code of Conduct, there are detailed guidelines on individual topics. For example, a Group-wide anti-corruption guideline was introduced in 2016. We consider the issue of corruption to be very important, as the existence of corruption and bribery can be an indication of human rights violations.

We have the Supplier Code of Conduct, which outlines what we expect from our suppliers with regard to the avoidance of human rights risks and violations, and which must be confirmed by signature.

Before entering into new business relationships, we carefully check our suppliers.

A complaints procedure has also been set up and a Human Rights Officer has been appointed. The existing e-learning program is another prevention measure: All employees with an active e-mail address are required to complete an online course once a year. The main topics are adapted to current circumstances. The current version also contains explanations of the whistleblower system and provides instructions on how to use it.

3.5     Remedial Action

In the event that we as a company have directly caused a violation of human rights, we work quickly to prevent the business activities that caused this or to make them compliant with human rights and work towards rectification.

If our employees behave in a way that is inconsistent with human rights, appropriate sanctions will be introduced. In the event that we contribute to potential or actual human rights violations through our business activities or are indirectly associated with them, we endeavor to contribute to appropriate remediation and prompt rectification by the responsible parties.

If we have a well-founded suspicion or concrete indication of possible human rights violations in our company or along our upstream and downstream value chains, we investigate this carefully and consistently. We oblige our business partners to cooperate fully within a reasonable timeframe. Depending on the severity of the violation, we reserve the right to take appropriate action in connection with our business partners, ranging from a request to remedy the violation immediately to legal action and termination of the business relationship. Irrespective of this, we are working to make amends for the violation.

3.6    Effectiveness Controls

We investigate all reports of potential human rights violations. We also test the effectiveness of the e-learning program with a quiz. In the Supplier Code of Conduct, we reserve the right to carry out appropriate control measures, such as audits, at our business partners. The Head of Strategic Group Purchasing or a deputy inspects the suppliers with the highest risk assessments on site.

4.    Documentation and Reporting

The implementation of human rights and environmental due diligence obligations is an ongoing process. We will prepare an annual report on the fulfillment of these obligations in the previous financial year. We will keep this available on our website for at least seven years.

5.    Concluding Remarks

The management board of Michael Weinig AG is responsible for the implementation of and compliance with this Policy Statement. It receives support from the Head of Strategic Group Purchasing, the Human Rights Officer and the Compliance Officer. Their task is to inform the management board about risks and measures taken.

Tauberbischofsheim, December 19, 2024

The management board

Gregor Baumbusch                              Dr. Georg Hanrath

Chairman                                             CTO