Responsible Conduct
Responsible conduct is viewed holistically at Klöckner & Co. For us, an integral part of our corporate culture is the rule-compliant behavior of our employees and business partners, which forms the basis for corporate responsibility. Adherence to internationally applicable rules and fair dealings with our business partners and competitors are among the most important and competitors are among the most important principles of our company. In addition to consistent respect for human rights, compliance with the fundamental values and principles of our company is also of central importance to us. We have formulated these in our Code of Conduct. Compliance is the direct responsibility of each and every individual.
Key figures in 2022
Taking responsibility
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 from the Top" that antitrust violations and corruption are not tolerated at Klöckner & Co and any infringements are systematically pursued.
In this regard, it is a fundamental principle of Klöckner & Co that our employees act in accordance with the applicable competition law. We are committed to free competition and to the recommendations of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions of December 17, 1997. In addition, Klöckner & Co strives to comply with all anti-corruption laws of the countries in which we do business, including the UK Bribery Act and the US Foreign Corrupt Practices Act.
The Groupwide Code of Conduct and the Group's internal policies and procedures, e.g. on compliance with antitrust regulations, the involvement of intermediaries, money laundering prevention, export controls and combating corruption in business transactions, serve as a reference and guide for our employees. A Groupwide training program, which is mandatory for all employees of the Group, raises awareness of our Code of Conduct.
The training program is divided into various modules appropriate to the target group, which are updated at regular intervals by refresher training courses. The assignment and success monitoring of mandatory training courses is carried out in an IT-supported learning management system. We expect our external business partners to observe the ethical values and principles of our Code of Conduct or Supplier Code of Conduct or an equivalent code of conduct of their own and to implement them effectively in their organization.
It is possible to anonymously report indications of possible compliance violations to the Corporate Compliance Office. Employees and third parties can report possible violations of our Code of Conduct on the platform's homepage or via the company's website. In addition, a 24/7 telephone hotline is available free of charge worldwide.
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. Alongside observance of laws and human rights, these principles include, in particular, the prohibition of child labor and any form of forced labor, ensuring workforce health and safety, the freedom of association and assembly 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 expectation to our suppliers, we thoroughly revised our Group-wide Supplier Code of Conduct in 2022, among other things to take into account the requirements of the German Act on Corporate Due Diligence Obligations in Supply Chains. Our Supplier Code of Conduct now has an even stronger focus on the prevention of human rights and environmental risks, and formulates our clear expectation that our suppliers actively identify and assess such risks in their own operations and supply chains, and prevent or minimize them within their sphere of influence. Suppliers who refuse to recognize our Supplier Code of Conduct and who have not established an equivalent code of conduct within their own organization are systematically excluded from future purchases. Equivalence is established by the CCO.
Klöckner & Co pays particular attention to the prudent and responsible procurement of products. For example, a key objective in the procurement process is to ensure that the minerals contained in our products do not originate from conflict countries. The company ensures the fulfillment of due diligence requirements in the supply chain for raw materials from conflict and high-risk areas and the restriction of the use of certain hazardous substances in electrical and electronic equipment. Dual-use goods and the relevant foreign trade regulations are monitored centrally through systemic controls in the IT systems. Of particular interest are conflict minerals such as columbite-tantalite (coltan), cassiterite (tinstone), gold, wolframite and their derivatives, which include tantalum, tin and tungsten.
In fiscal 2022, the annual review of our product portfolio revealed that < 1% of our products may contain tantalum, tin or tungsten. Should our customers require proof of this, we use the Responsible Minerals Initiative's "Conflict Minerals Reporting Template" for all relevant suppliers to systematically query the origin of conflict minerals. We expect suppliers to work with their suppliers to trace conflict minerals back to at least the smelter and to commit to standard reporting processes. We also expect our suppliers to retain appropriate evidence for five years and to provide it to Klöckner & Co upon request. If a supplier fails to provide proof of the origin of conflict minerals, he will be systematically blocked from further purchases. The same applies if the supplier does not commit to the above principles regarding the origin of conflict minerals.
As a global company, Klöckner & Co does not only see the responsibility towards our employees, but also toward the regions in which our headquarters and branches are located. We consequently give our commitment to the immediate surroundings of our sites and, in this way, play our part in addressing social challenges.
Klöckner & Co has a clear long-term strategy for supporting non-profit projects: our aim is to long-term improve educational opportunities for disadvantaged children who live in our immediate vicinity. To achieve this goal, our contributions center on local projects to educate children and young people or to address their basic needs, with the aim of benefiting as many young people as possible. For over ten years now, we have focused on neighborhood work in 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 as well as additional regional partners.
In 2012, we joined forces with the Ruhr Piano Festival Foundation and created a multi-award-winning education project to foster children’s musical and artistic development, which was initially launched at two schools. Over 800 children and teenagers from five schools in Marxloh now participate. Since 2021, there has also been a program for daycare centers, with content closely based on a musical early education provided at elementary schools.
In 2022, Klöckner & Co also reaffirmed its social commitment to the ReDI School of Digital Integration (ReDI School), a non-profit coding school, and will continue to support the organization’s Kids and Youth Program in Duisburg’s Marxloh neighborhood as the main sponsor. The coding school has developed very positively since the joint inauguration of the Duisburg-Marxloh site in 2019:compared to the prior year, the number of participating students increased from 340 to 500.
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 in a framework of Group-wide procedural instructions through which we ensure that our activities have a common thrust while being tailored to individual local conditions. 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.
The United Nations 2030 Agenda for Sustainable Development lays the foundation for shaping global economic progress in harmony with social justice and within the Earth’s ecological limits. At its core are 17 Sustainable Development Goals (SDGs). We support the 2030 Agenda for Sustainable Development and the 17 Sustainable Development Goals. The goals defined by the United Nations are on an equal footing and mutually dependent – but in the context of our business activities, some of the goals and indicators have particular relevance for our economic activities. For these goals, we see a special responsibility and opportunities for influence that vary depending on the goal. We take into account the positive influence that Klöckner & Co has on the achievement of the goals. We support the goals by continuously improving our business processes and services while reducing the negative and maximizing the positive impacts of our business activities. Our areas of action for sustainability are reflective of the high relevance that the pursuit of these specific goals has for us. We evaluate our action areas on a regular basis, taking into account the views of internal and external stakeholders as well as the impact of our actions on the environment and society.
Sustainable Development Goals with particular relevance for sustainability management at Klöckner & Co:
A safe and healthy working environment
An important prerequisite for our success and sustainable development is the safety and well-being of our employees and business partners. With our Group-wide “Safety 1st” program, we aim to protect our employees, provide safe working conditions and minimize health risks. Klöckner & Co stands for safe, fair and clean labor standards and processes. For this reason, we use the lost time injury frequency (LTIF) indicator as a non-financial performance indicator.
As a Group operating globally, we pay special attention to respecting human rights as well as social and ecological aspects in our global supply chains. Our policy is to onlywork with partners who have equivalent standards and demand the same from their own suppliers. We have expanded our Supplier Code of Conduct further in 2022.
Future-proof employment based on diversity and high-quality training
Klöckner & Co is committed to providing an appreciative and prejudice-free working environment. We leverage different ways of thinking, experiences, perspectives and lifestyles for innovative strength and the Company’s long-term success. We want to drive sustainable economic growth through diversity and the efficient use of resources. In terms of equal opportunity, the inclusion of women in specialist and management positions is an important concern for us as well. We aim to increase the number of women in management roles throughout the Group.
We promote reasonable and fair labor and social standards. In addition, we assume social responsibility – for example through monetary and in-kind donations, knowledge transfer and the personal engagement of our employees.
Active climate change mitigation and the promotion of sustainable products and services
Klöckner & Co is the first company in the world to have all net zero carbon targets recognized by the Science Based Targets initiative (SBTi) as science-based targets in the regular process in accordance with the latest standards. The initiative previously already recognized our medium-term emission reduction targets for 2030 as science-based targets.
The sustainable strategic orientation of our business makes us pioneers in our industry and means we can actively drive the sustainable transformation of the economy and society. We are committed to reducing the environmental impact of our own business activities and increasingly establishing elements of a circular economy. We are also involved in climate change mitigation projects in countries where we do not have business activities.
Our other action areas
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