Responsible Conduct | Klöckner & Co SE
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RESPONSIBLE CONDUCT

Klöckner & Co takes a holistic approach to responsible conduct. Consequently, although it is defined here as a single action area, responsible conduct may also be regarded as an overarching concept that embraces all other action areas. This is because, for Klöckner & Co, responsible conduct based on ethical convictions paves the way for long-term business success and hence also for sustainability.

COMPLIANCE

As an international Group with numerous supplier and customer relationships worldwide, Klöckner & Co aims to ensure integrity and responsibility both within the Company and in interactions with business partners, as well as to establish responsible relationships.

Klöckner & Co expects employees at all levels of the Company, regardless of their hierarchical position, to comply with prevailing competition rules and antitrust laws. The Management Board has unequivocally expressed in its "Tone at the Top" that antitrust violations and corruption are not tolerated at Klöckner & Co and any infringements are systematically pursued.

Our employees are provided with a frame of reference and guidance in the form of our Group-wide Code of Conduct together with internal Group guidelines and procedural instructions on topics such as adherence to antitrust rules, the engagement of intermediaries, anti-money laundering, export controls and anti-corruption in business dealings. We expect external business partners to comply with the ethical values and principles enshrined in our Code of Conduct, Supplier Code of Conduct or a comparable code of their own and to implement them effectively in their organization.

Classroom training and e-learning programs familiarize new employees with the content of the Code of Conduct and raise awareness of, for instance, compliance-related issues such as antitrust law, corruption risks, money laundering risks and fraud. We first separate employees into different target groups which receive training tailored to their specific areas of work. We also conduct refresher e-learning sessions throughout the Group to keep our employees up to date and address specific compliance-related issues with examples from their day-to-day work.

Our employees and business partners additionally have the option of directing information on potential compliance violations and/or breaches of our Code of Conduct directly to the Corporate Compliance Office. A telephone and web-based whistleblower system operated by an external service provider is available for this purpose. The whistleblower system can be accessed free of charge from anywhere in the world and can also be used anonymously.

HUMAN RIGHTS IN THE SUPPLY CHAIN

Klöckner & Co SE and its country organizations pay attention to ethically correct and compliant behavior in business dealings. As stated in our Code of Conduct and moreover in our Group human rights policy, Klöckner & Co does not tolerate any violation of the principles set out in them under any circumstances. Alongside observance of laws and human rights, these principles include the prohibition of child labor and ensuring workforce health and safety, as well as compliance with the statutory minimum wage and working hours.

This concerns both our own Company and all upstream parts of our value chain. We expect everyone in our supply chain to follow the same principles. In order to clearly convey this expectations, we introduced a Group-wide Supplier Code of Conduct in fiscal year 2018.

Prudent and responsible product procurement is of special importance to Klöckner & Co. For example, a key goal in the procurement process is to ensure that minerals contained in our products are not from conflict states. The importance of this topic is also reflected in requirements laid down by our international customers, who expect us to provide clear proof of origin. Of special interest in this regard are conflict minerals such as columbite tantalite (coltan), cassiterite, gold, wolframite and their derivatives, which include tantalum, tin and tungsten. The annual review of our product portfolio in fiscal year 2018 showed that less than 1% of our products possibly contain tantalum, tin or tungsten.

Since the entry into force of the Dodd-Frank Wall Street Reform and Consumer Protection Act and notably the Conflict Minerals Rule, Klöckner & Co analyzes with due care every year whether conflict minerals are used in the manufacture of the products concerned and, if so, whether they originate from the Democratic Republic of the Congo or neighboring states. Those neighboring states today comprise Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

If suppliers manufacture components, parts or products using the minerals in question, we require that those materials are not sourced from the aforementioned states. We use the Responsible Reporting Initiative’s “Conflict Minerals Reporting Template” to systematically track the provenance of conflict minerals for all relevant suppliers if our customers request corresponding proof. We expect our suppliers, together with their subcontractors, to trace conflict minerals at least to where they were smelted and to commit to standard reporting processes. Klöckner & Co reserves the right to demand supply chain verification from its suppliers and, where appropriate, to trace conflict minerals back to the mine of origin. For their part, suppliers should also formulate and implement conflict minerals policies and principles. If possible, they should require their upstream suppliers to adopt and follow corresponding policies and principles.

CORPORATE CITIZENSHIP

As a tradition-rich company, Klöckner & Co also regards it as its duty to contribute to the well-being of society. Active involvement in the immediate vicinity of our headquarters and branches is a key aspect and an identitybuilding factor for our Group.

Our goal is for the financial support we provide to benefit those who really need it. Donation and sponsoring activities are conducted autonomously by our country organizations as they are best placed to judge individual needs in their region. They are provided with a framework in the form of Group-wide procedural instructions through which we ensure a uniform thrust in corporate citizenship activities while catering to the individual circumstances of our markets. The focus of our activities is on supporting selected scientific, sports, art and cultural projects along with ongoing promotion of education initiatives and the integration of refugees into our society.

Klöckner & Co has a clear strategy for supporting non-profit projects in Germany: Our aim is to improve educational opportunities for disadvantaged children who live in our immediate vicinity over the long term. To achieve this goal, our contribution centers on local projects to educate children and young people or cater to their basic needs in Duisburg, where our headquarters are located. 

We focus on the Marxloh area of Duisburg, where a large number of residents have a migrant background. In this area, we work with schools, children’s and youth services, and regional charities. Through our five-pillar strategy, we aim to support tomorrow’s young professionals and thus make a significant contribution to strengthening the region.

1. BASIC NEEDS
Klöckner & Co helps organizations in Marxloh to prepare healthy meals so that children and young people are able to concentrate at school and socialize with each other by sharing a meal, irrespective oftheir backgrounds. 

2. ESSENTIAL RENOVATION WORKS
In the past, we have already renovated a youth center and renewed the school yard canopy at an elementary school in cooperation with the City of Duisburg. In 2018 the Henriettenstrasse elementary school was fitted out with five multifunctional classrooms with the support of Klöckner & Co. Due to its location in Marxloh, a very large proportion of the school’s students are new arrivals in Germany. To ensure students are given the best opportunity to learn, they require differentiated support, including to learn the language. The new multifunctional classrooms represent a significantly improved environment for learning and the provision of support

3. STRONG NETWORK
Klöckner & Co frequently makes use of its strong network to enable Marxloh organizations to participate in exclusive projects, such as Bayreuth Festival’s costume competition: Katharina Wagner, the composer Richard Wagner’s great-granddaughter, visited Klöckner & Co’s partner schools in Duisburg. She and the students together designed costumes for the popular children’s opera in Bayreuth. One of the partner schools organized a trip to Bayreuth for the premiere of the children’s opera, where students got to see their costume designs on stage.

4. SCHOOL EDUCATION PROJECTS
Since 2013, Klöckner & Co has supported the German National Scholarship awarded by Roland Berger Foundation. This program promotes gifted children with a strong will to learn who come from socially disadvantaged families, with the aim of guaranteeing them the best possible education opportunities and enabling them to complete upper secondary education and/or go on to university. In this way, we significantly contribute to removing barriers to equal opportunities among people of different social backgrounds. A partner school in Marxloh is also a beneficiary of Teach First Deutschland gemeinnützige GmbH’s "Fellow" project, through which college graduates provide support to disadvantaged school students in their regular lessons and thus make everyday school life easier through their own projects.

5. MUSIC AND CREATIVE DEVELOPMENT
Joining forces with the Ruhr Piano Festival Foundation, we developed an education project to foster children’s musical and artistic development at different types of schools. This was implemented for the first time with two schools in 2012. No fewer than six schools with over 600 children took part in 2018. Our musical education work has since earned supraregional recognition: After garnering the “Echo Klassik” award presented by Deutsche Phono-Akademie in the “Fostering Young Talent” category in October 2016, as well as the “Junge Ohren Preis” in November 2014, the education program was awarded the renowned “MIXED UP Preis” in 2018. The prize awarded by the Bundesvereinigung Kulturelle Kinder- und Jugendbildung e.V. (German Federation for Cultural Youth Education) and the Federal Ministry for Family Affairs, Senior Citizens, Women and Youth praised the long-term cooperation across institutions and sectors in the “Long-runner” category. These and other awards are proof positive of our successful cooperation, which is to remain part of our activities going forward.

The integration of refugees into our society is another major concern for us. This notably includes creating employment opportunities. One area with an especially large number of vacancies is the IT sector, which often makes it hard for companies to find qualified programmers. To help refugees with IT skills onto the career ladder, the knowledge they bring with them needs to be enhanced and supplemented in line with the needs of the German labor market in general and our business in particular. Under the umbrella of the "We together" German Industry Integration Initiative, Klöckner & Co therefore supports the ReDI School of Digital Integration in Berlin as main sponsor and provides premises for the project.

ReDI is short for Readiness and Digital Integration. Students are provided with laptops and can take part in free beginners and advanced programming courses. Additionally, students are each assigned a mentor to help them take the course content to a deeper level. Organized networking events make for lively contact with the Berlin and Munich start-up scenes. We also have our own presence in Berlin with kloeckner.i, our Group Center of Competence for Digitalization. When filling new positions, we place special emphasis on recruiting ReDI School graduates. Internships prepare ReDI students for potential permanent employment at kloeckner.i, our digital subsidiary in Berlin.

Klöckner & Co also supports a Stifterverband program targeting the "integration of refugees through education" as part of "Kiron Open Higher Education, Track Computer Science". The program aims to offer refugees access to a course of study leading to an accredited bachelor’s degree.

In Germany, we maintain close contact with the European Business School (EBS) and the University of Duisburg-Essen. As well as high-ranking executives from our Company giving lectures at these two higher education institutions, we also take part in dialog events and answer students’ questions. Furthermore, we offer students internships during which they can apply content from their studies to real business situations.

For some years now, we have supported the Germany Scholarship in collaboration with the German Federal Ministry of Education and Research. Primarily directed at talented and high-achieving college students, the scholarship gives consideration to specific family and social circumstances. Our aim here is to provide support so that students can excel both academically and socially as well as within the family.

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