Policy Statement – Due Diligence in Supply Chains*
(As of: January 2025)
Preamble
As an internationally active company, we are aware of our responsibility to respect and protect human rights and environmental standards along our entire supply chain. Our business activities aim to contribute to sustainable and equitable global economic practices, with a firm commitment to the fundamental values of respect for human dignity, fair working conditions, environmental protection, and combating corruption.
Compliance with the legal requirements of the Supply Chain Due Diligence Act (“LkSG”) is not only a legal obligation for us but also an expression of our corporate ethos. This policy statement outlines the measures and principles we implement to fulfill our corporate due diligence obligations. Our goal is to identify human rights and environmental risks in our supply chain at an early stage, to counteract them, and to continuously improve our processes to contribute positively to a sustainable and equitable value chain.
We expect our business partners to also respect these principles and to work closely with us to uphold human rights and environmental standards. This commitment encompasses all levels of the supply chain and underscores our endeavor to create long-term value for all stakeholders through responsible action.
This policy statement applies to Asterix HoldCo AG (“Asterix HoldCo”) and all affiliated companies (together referred to as the “TQG Group”).
What We Stand For
We are aware of our social and ecological responsibility and, as a corporate group, it is important to us to integrate these attitudes into the TQG Group’s business model. This statement encompasses all activities of the TQG Group.
Respect for Human Rights and Environmental Concerns
We are committed to minimizing the environmental impact of our actions, conserving resources, and reducing environmental pollution. What we can control ourselves, we approach ambitiously, worldwide, and at all locations. We expect the same from our partners. Our actions are guided by internationally recognized frameworks and standards, which we unreservedly support:
- UN Guiding Principles on Business and Human Rights
- Core Labor Standards of the International Labour Organization (ILO) and their fundamental principles, covering the four areas of freedom of association, prohibition of discrimination in employment and occupation, elimination of child labor, and abolition of forced labor
- OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
- UN Convention on the Elimination of All Forms of Discrimination Against Women
- UN Convention on the Rights of the Child
Our Expectations of Employees and Business Partners
We expect our employees and business partners to comply with applicable laws and to uphold the corporate values we have defined. We require transparency from our suppliers and their subcontractors and adherence to social and environmental standards. Dignified working conditions, in particular, are non-negotiable for us.
These expectations are reflected in our Code of Conduct. Compliance with this Code of Conduct is mandatory for our employees. Our Supplier Code of Conduct further specifies the ethical, social, and environmental standards we expect from our suppliers and business partners. Both the Code of Conduct and the Supplier Code of Conduct are accessible in their current versions on our website at any time.
Human Rights and Environmental Risk Management
As a globally active company with complex supply chains, we place great emphasis on addressing human rights and environmental protection with the utmost care to prevent risks and violations at an early stage. Our goal is to identify these risks early, minimize them through targeted measures, and respond promptly and appropriately in the event of violations. To this end, we implement various measures across different business areas.
We continuously review our risk management and corporate processes, focusing on the effectiveness of our preventive measures, remedial actions, and complaint procedures. We thoroughly and regularly examine the results of our risk analysis.
Risk Analysis
As part of a comprehensive risk analysis, we systematically investigate potential risks. We utilize the extensive solutions offered by Scrioo, a renowned platform for supplier management. We analyze general risks annually, based on geographic and industry-specific factors, as well as specific risks on an ad hoc basis. Subsequently, we evaluate and prioritize identified risks to derive appropriate preventive and, if necessary, remedial measures for our business areas and supply chain. All relevant decision-makers are informed of the results of the risk analysis.
Priority Human Rights and Environmental Risks
In examining the risks within our own business area, we analyzed all entities for their potential exposure to human rights and environmental risks.
In our business activities, human rights and environmental risks are primarily found in the areas of procurement and temporary employment. Relevant entities were subsequently examined in greater detail, and preventive measures were implemented where necessary.
The TQG Group also has preventive internal control measures for the area of temporary employment.
Preventive and Remedial Measures
At the TQG Group, we implement various preventive measures within our own business area and with our direct suppliers. Protecting human rights and the environment is an integral part of our procurement process and embedded in our procurement guidelines. In addition to our Code of Conduct and Supplier Code of Conduct, we have taken further measures.
To protect against workplace accidents and work-related health risks, we have established comprehensive measures to ensure workplace safety and health. Our risk management includes abstract and contractual control mechanisms and regulates their risk-based implementation. For raw materials and packaging materials, we have established specific quality assurance agreements.
Moreover, we continuously raise awareness among our employees, suppliers, and business partners about the importance of human rights and environmental protection, offering need-based consultations. In cases of (potential) violations of protected legal positions, the TQG Group will promptly take appropriate remedial measures. Clear processes with defined responsibilities are established for this purpose.
The TQG Group conducts risk analysis using Scrioo. The Scrioo risk analysis of direct suppliers and business partners is carried out based on the legal provisions of the LkSG and the corresponding guidelines of the Federal Office for Economic Affairs and Export Control (BAFA).
First, supplier and business partner data from various areas, subsidiaries, and branches are collected and integrated into Scrioo. In the initial step, the abstract risk in terms of country and industry risks is determined using a system-based approach. Statistical data and established indices are used for this assessment. Subsequently, suppliers undergo detailed scrutiny as part of the specific risk analysis and are subjected to continuous media monitoring and analysis, as well as dynamic risk scoring. Identified risks are evaluated and prioritized. For potentially relevant risks, a questionnaire is sent to the supplier/business partner to determine whether and what measures need to be taken concerning the specific supplier/business partner.
Furthermore, Scrioo ensures continuous monitoring regarding suppliers/business partners and conflict minerals, as well as sanctions list entries.
The effectiveness of preventive measures is reviewed annually and on an ad hoc basis.
Responsibilities
The management board is responsible for ensuring compliance with this policy statement.
The independent Human Rights Officer is responsible for managing and overseeing the procedures through which the TQG Group fulfills its obligations under the LkSG. The officer reports to management at least once a year and proposes improvements as needed.
Complaint Mechanism
To combat violations of legal regulations and/or internal compliance rules as well as violations of human rights and environmental due diligence obligations, the TQG Group has appointed an external attorney as an ombudsperson and contact for our whistleblower system. The ombudsperson is available to all whistleblowers who wish to provide confidential information about irregularities within the TQG Group.
The TQG Group encourages its employees and business partners to report any activities that indicate a violation of applicable laws or our Code of Conduct or that are inconsistent with ethical business practices. The link to the complaint mechanism can be found here: Compliance.
Documentation and Reporting
Based on documentation, the TQG Group will fulfill all applicable reporting obligations on time. The Human Rights Officer assumes a supportive and coordinating function in this regard. Compliance with our human rights and environmental due diligence obligations is documented and retained for seven years from the date of creation.
Signed:
Board of Asterix HoldCo AG
(Date of Initial Publication: December 2024)
* For the sake of readability, male forms are used for personal designations and nouns. Corresponding terms apply equally to all genders within the meaning of equal treatment. The shortened linguistic form is for editorial reasons only and does not imply any valuation.