Compliance Framework LEGIER BETEILIGUNGS MBH

1. Introduction

  • Purpose: This compliance framework ensures that LEGIER BETEILIGUNGS MBH (hereinafter referred to as "LEGIER", "we" or "us") and its affiliated brands SCANDIC ESTATE, SCANDIC PAY, SCANDIC TRUST, and SCANDIC TRADE (hereinafter "SCANDIC Brands") comply with legal requirements, ethical standards, and best practices, particularly regarding human rights and environmental due diligence obligations. The goal is to prevent, identify, and minimize risks in our business operations and supply chains.
  • Legal Basis: The framework is based on German laws, particularly the Supply Chain Due Diligence Act (LkSG), which mandates due diligence in supply chains to protect human rights and the environment.

2. Scope

  • Covered Entities: Applies to LEGIER BETEILIGUNGS MBH and all SCANDIC Brands.
  • Supply Chain Coverage: Includes all direct suppliers and, where necessary, indirect suppliers involved in the production and delivery of goods and services for LEGIER and SCANDIC Brands.

3. Risk Management

  • Risk Assessment Process:
    • Annual risk analysis to identify potential human rights and environmental risks in our activities and supply chains.
    • Assessment of risks based on severity, likelihood, and our ability to mitigate them.
  • Risk Mitigation Strategies:
    • Development and implementation of action plans for identified risks, including cooperation with suppliers, corrective actions, and, if necessary, termination of business relationships.
    • The Compliance Officer monitors the implementation of these strategies.

4. Policy Statement

  • Commitment: LEGIER is committed to respecting human rights and environmental standards in all business activities, including the prevention of forced labor, child labor, discrimination, and environmental destruction.
  • Supplier Expectations: Suppliers must adhere to the same standards and comply with our Supplier Code of Conduct.

5. Due Diligence Processes

  • Evaluation and Selection of Suppliers:
    • New suppliers undergo a due diligence assessment.
    • Existing suppliers are regularly reviewed through audits.
  • Monitoring and Audits:
    • Regular audits of high-risk suppliers, conducted internally or by third parties.
  • Corrective Measures:
    • In case of violations, suppliers must implement corrective actions within a given timeframe or face contract termination.

6. Grievance Mechanism

  • Channels for Submitting Complaints:
    • Implementation of a whistleblower system for anonymous reports from employees, suppliers, and external stakeholders.
    • Available channels:
      • Online Portal: Secure, multilingual system.
      • Email: [email protected]
      • Phone: +49 (0) 232 57 44 78
      • External Compliance Officer: Attorney Axel Kapust.
  • Handling Procedure:
    • Complaints are investigated confidentially by the Compliance Officer and relevant departments.
  • Protection for Whistleblowers:
    • Confidentiality and protection from retaliation for whistleblowers acting in good faith.

7. Reporting

  • Internal Reporting:
    • The Compliance Officer reports quarterly to management on compliance activities and complaints.
  • External Reporting:
    • Annual compliance report on our due diligence efforts.

8. Training and Awareness

  • Employee Training:
    • Annual mandatory training for all employees on human rights, environmental standards, and the whistleblower system.
  • Communication:
    • The framework is communicated via internal portals, supplier contracts, and public websites.

9. Monitoring and Review

  • Regular Reviews:
    • Annual review of the framework for effectiveness and legal compliance.
  • Continuous Improvement:
    • Adjustments based on feedback and emerging risks.

Key Roles and Responsibilities

  • Management (Tetiana Starosud): Overall responsibility and approval of the framework.
  • Compliance Officer (Attorney Axel Kapust): Oversight of the framework, management of the whistleblower system, and reporting to management.
  • Department Heads: Ensuring compliance within their areas of responsibility.
  • Employees: Adherence to the framework and reporting concerns.

Contact Information

  • LEGIER BETEILIGUNGS MBH Kurfürstendamm 195, 10707 Berlin, Germany
    Phone: +49 (0) 30 232 57 447 - 0
    Fax: +49 (0) 30 232 57 447 - 1
    Email: [email protected]

  • Compliance Officer Attorney Axel Kapust
    Jägerallee 29, 14469 Potsdam, Germany
    Phone: +49 (0) 232 57 44 78
    Email: [email protected]

This compliance framework ensures that LEGIER and SCANDIC Brands act ethically and in accordance with the law, with a focus on human rights and environmental standards.