Corporate Compliance
Code of Conduct for the companies
of the Currenta Group
Principles and rules of conduct
Conduct within the company and interaction with each otherr
- Fair and respectful working conditions in a non-discriminatory environment
- Promotion of diversity and inclusion in everyday work
- Protection of the property of the Currenta Group and the resources that are provided
Integrity and behaviour for the Currenta Group in the course of business and all other activities
- Fairness in competition, no prohibited cartel arrangements
- Integrity in business transactions, no corruption – especially when dealing with customers and public officials
- Dealing with public statements relating to the Currenta Group
Social and environmental responsibility in the Currenta Group and its supply chains
- Respect for and protection of human rights and environmental due diligence
- Protection of the health of our employees and prevention of accidents and injuries
- Negative impacts on nature and the climate must be reduced as much as possible
Protection of company interests, secrets and personal information
- Decisions must be taken without conflict of interests and exclusively in the interest of the Currenta Group
- Documents and information of the Currenta Group must be protected against unauthorised access and loss
- Business operations must comply with data protection regulations
Dealing with authorities
- Constructive cooperation with authorities
- Safeguarding of the legal positions and interests of the Currenta Group
- Dealing with and behaviour in the event of a search operation
Implementation
- CURRENTA appoints a Compliance Officer. The same applies to the compliance officers of the subsidiaries.
- CURRENTA ensures the functionality of this Corporate Compliance Guideline by implementing the necessary framework conditions and providing the required resources.
- Functionality and effectiveness are reviewed on a regular basis. Permanent monitoring with ongoing evaluation and reporting is intended to ensure the ongoing improvement of this Corporate Compliance Guideline. In addition, the Audit Department may review the effectiveness of this Corporate Compliance Guideline at regular intervals on behalf of the Executive Board.
Policy Statement On Human Rights And Environmental Due Diligence Obligations
Our values
The Currenta Group considers corporate compliance to be an essential part of its corporate culture. In this regard, special attention is paid to the protection of human rights and compliance with environmental due diligence.
This responsibility is notably set out in the Currenta Code of Conduct and the Currenta Code of Conduct for Suppliers. In these documents, the Currenta Group has committed to legal and ethical principles that go beyond the legal requirements. The expectations set out in these documents apply in equal measures to the Management Board and all managers and employees of the Currenta Group.
The Currenta Group is committed to respecting internationally recognised human rights in our own business operations and along the value chain. We base our commitment to respecting human rights on international standards, in particular the United Nations Universal Declaration of Human Rights and the standards of the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work.
When it comes to environmental due diligence obligations, there are specific risks in the chemical industry. The Currenta Group is aware of these risks and places high demands on itself regarding the integrity and protection of the environment.
It is the responsibility of every employee of the Currenta Group to behave in accordance with this policy statement.
We also communicate this expectation to our suppliers and business partners and expect them to commit to the protection of human rights and environmental due diligence obligations, and to implement appropriate processes.
What are the due diligence obligations?
Respect for and protection of human rights and adherence to environmental due diligence obligations form an integral part of the Currenta Group’s understanding of corporate values.
In particular, this includes the prohibition of child and forced labour, the prohibition of all forms of slavery and discrimination, and the strengthening of freedom of association.
We are also committed to protecting occupational health and safety, paying appropriate wages, prohibiting forced evictions and banning the use of security forces that disregard human rights. We endeavour
to reduce negative impacts on the environment and the climate.
Our values apply to our employees, the employees of our supply chain and our business partners, as well as to our local community, and is demonstrated via the following principles and instruments.
We reject child labour within the Currenta Group, in our supply chain and among our business partners. We do not tolerate slavery, servitude, forced labour – in any form – or human trafficking. By the same token, we do not accept bonded or indentured labour or involuntary prison labour. Practices such as the unreasonably withholding of personal property, passports, wages, training certificates, work documents or other documents for inappropriate reasons are not acceptable.
Protecting the health and safety of our own employees, employees in our supply chain, visitors and everyone in the surrounding area of CHEMPARK is a top priority for the Currenta Group.
This includes implementing high safety standards to prevent accidents. In this regard, we pursue a “zeroaccident vision”, which requires everyone to comply with the required safety regulations and instructions, report unsafe situations, learn from incidents, and look out for each other. Safety-related regulations are laid down in the Currenta Group’s Safety Management System. These are continuously monitored by internal and external bodies and are reviewed for effectiveness.
The Currenta Group also provides a comprehensive health programme for employees. For example, there are workplace health campaigns and corresponding counselling centres to promote and maintain health.
We promote diversity and inclusion in our everyday work, support people with disabilities or limitations and create working conditions in a non-discriminatory environment characterised by respect and appreciation amongst colleagues. This is underlined by the Diversity Charter that we signed in October 2022.
We prioritise fair remuneration, flexible working hours and part-time models, work-life balance and competitive benefits as well as compliance with fundamental labour standards.
We guarantee the rights of our employees to form trade unions, respect collective bargaining and involve employee representatives in decision-making processes lived as a social partnership.
The aim of our responsible procurement strategy is not only to prevent environmental damage and human rights violations within the supply chain, but also to encourage our contractual partners to actively implement standards of sustainable business operations. Therefore, we adapt our contractual bases, have our own processes and those of our suppliers assessed for their sustainability performance and take the results into consideration in our decisions, e.g. when selecting and awarding suppliers.
We are aware that companies in the chemical industry pose risks to the environment, the climate and natural resources. With this in mind, our behaviour is determined by reducing negative effects, e.g. by paying attention to the protection of our natural resources and the reduction of greenhouse gases. We endeavour to reduce the impairment and consumption of natural resources to a minimum for the benefit of all – including future generations. “No environmental damage” is part of our vision for safety, health and environmental
protection and underpins this aspect.
For instance, we align energy supply and waste disposal sustainably, minimize environmental risks, and, as manager and operator of CHEMPARK, collaborate with CHEMPARK based companies to create an efficient network. Our targeted investments in technology, infrastructure, and logistics further promote this alliance.
As manager and operator of CHEMPARK, the Currenta Group places particular importance on promoting dialogue with the local community of our neighbourhood. For this, the Currenta Group offers dialogues at its sites, e.g. through our CHEMPARK neighbourhood offices, as well as other projects and collaborations. Encouraging social and sustainable commitment in our neighbourhoods is a high priority.
How do we implement our due diligence obligations?
The Management Board of the Currenta Group is responsible for adhering to the principles outlined in this policy statement and ensuring their compliance. In this context, it has appointed a Human Rights Officer for the Currenta Group.
The Currenta Group has implemented a risk management system for the identification of human rights and environmental risks, following the aforementioned principles. Based on a risk analysis, effective and
appropriate preventive and remedial actions are taken to protect and prevent, end or at least minimise violations of human rights and environmental due diligence obligations.
The Currenta Group regularly conducts risk analyses for its own business area and the supply chain, both as a matter of routine and on an ad hoc basis when necessary. The risk analysis for the company’s own business operations and for the supply chain is conducted across all functions, involving relevant organisational units and departments, and is based on the identification, assessment and prioritisation of risks.
The risk analysis is regularly updated in collaboration with the risk owners – at least once a year, or on an ad hoc basis – and the appropriateness and effectiveness of the preventive and corrective actions that are taken are reviewed. This ensures that our risk management system is continuously developing.
Building upon the risk analysis, the Currenta Group has established preventive and remedial actions to counteract human rights and environmental risks. In the event of violations of due diligence obligations, actions are taken. Preventive and remedial actions are coordinated and form a consistent system. In some cases, the same action can be a preventive or remedial action.
Within this context, we raise awareness, inform, and train our employees, suppliers and other business partners on general human rights and environmentally related due diligence obligations, as well as specific topic-related due diligence obligations.
Our Human Rights Officer is responsible for complying with the human rights obligations outlined in this policy. The Human Rights Officer is in regular dialogue with our Management Board and reports at least once a year and as required on risks, measures and activities regarding human rights.
A key task of the Human Rights Officer is to monitor the Currenta Group’s risk management regarding potential violations of human rights or environmental due diligence obligations. In this context, the Human Rights Officer monitors the annual or event-driven risk analysis, the effectiveness of preventive and remedial actions, and the effectiveness of the systems and reporting channels established for risk assessment.
The corresponding specialist departments are responsible for operative implementation.
The Currenta Group has established a group-wide system for reporting violations of legal regulations and code of conduct, which is also available to customers, suppliers and the local communities. In this way, we ensure that any violations are detected at an early stage and that effective measures can be derived. The implemented complaints procedure is a key component of the Currenta Group’s compliance management system.
We take all suggestions and complaints very seriously, follow up on them and implement solutions. The procedures for dealing with complaints and suspected compliance cases within the Currenta Group are specified in the rules of procedure accessible on the Internet.
Projects and measures for fulfilling existing due diligence obligations, as well as the results of risk management, are continuously documented. The Currenta Group provides information on the implementation of this policy statement and the ongoing development of risk management in an annual report.
In this way, we ensure the necessary transparency as a basis for exchange and dialogue – for the purpose. of this policy statement – with all stakeholders mentioned.
Report violations
If violations of these principles, in particular human rights and environmental due diligence, are observed, they must be reported immediately either to the supervisor, alternatively to the responsible Compliance Officer or to the management of CURRENTA’s Human Resources Department. The report can be made anonymously.
CURRENTA has also set up a hotline to Ethicspoint, a fully independent organization based in the UK. This is staffed around the clock and can be reached at 0800-1800042 (NOTE: For calls from the CHEMPARK, dial the additional 0 for the outside line). Ethicspoint operators answer the calls and greet the caller in English. The caller is asked to stay on the line until the interpreter has joined the conversation. It is possible to report problems in Ethicspoint’s online reporting system, at the following web address: EthicsPoint – Currenta GmbH & Co. OHG.
You can find the data protection declaration for the whistleblower system here. Any employee who contacts the hotline or a contact person directly for the purpose of reviewing an issue is assured that he or she will not be harmed or disadvantaged as a result.
The rules of procedure for dealing with complaints and suspected compliance cases can be found here.
In addition, we refer to the possibility of reporting to the external federal reporting office at the Federal Office of Justice.