Declaration on the Prevention of Slavery and Human Exploitation


Introduction


This statement summarizes the actions that LEGIER Beteiligungs mbH and its brands - SCANDIC FLY, SCANDIC YACHTS, SANDIC ESTATE, SCANDIC TRADE, SCANDIC PAY, SCANDIC COIN and SCANDIC TRUST - have taken to comply with the requirements of the Modern Slavery Act 2015.


Overriding objective


LEGIER Beteiligungs mbH is committed to best business practices and ethical values. We act ethically and with integrity in all business relationships and processes, in line with our corporate values and policies. In addition, we take all reasonable measures to ensure that the members of our supply chains also adhere to these standards. This includes, in particular, the prevention of modern slavery and human trafficking.

Our employees are expected to report concerns about non-compliance with our values and policies through established reporting channels. The LEGIER Beteiligungs mbH management and Board of Directors are committed to responding promptly to all reported concerns.


Business and organizational structure


Established 30 years ago, LEGIER Beteiligungs mbH is a global conglomerate. We offer a variety of services, including:

  • Media: 115 own daily newspapers on all continents
  • Aircraft charter and aviation security solutions: through ScandicFly
  • Yacht charter: through Scandic Yachts
  • Real estate: through Sandic Estate
  • Trade services: through Scandic Trade
  • Payment services: through Scandic Pay
  • Cryptocurrency services: through Scandic Coin
  • Fiduciary services: through Scandic Trust


Extension of the services offered by ScandicFly Jet Charter


ScandicFly Jet Charter offers customized flight solutions for private and business customers. Our fleet includes a wide range of aircraft, from small jets for short distances to large aircraft for long-haul flights. We offer additional services such as catering, ground transportation and concierge services. In the area of aviation safety, we provide comprehensive solutions, including risk assessments, safety audits and flight crew training, to ensure the safety of our customers and employees.


Our supply chain


Our suppliers consist mainly of our own brands and professional service providers. These service providers are typically large companies with their own supply chain policies and ethical standards. Due to the nature of our services, our main locations and the suppliers we use, we consider the risk of modern slavery in our supply chain to be low.


Guidelines


We reinforce our policy on ethical business practices through regular training for new and existing employees. Our business ethics policy stipulates that we only work with suppliers who meet high standards in terms of social and ethical responsibility. When entering into new business relationships or expanding into new business areas, we carry out appropriate due diligence to ensure that the same standards are maintained throughout the Group. We strive to obtain assurances from all suppliers that they comply with our standards. We also consider the health and safety of all stakeholders and the public in all our activities.

Our employees are encouraged to report concerns, alerts, losses and near misses confidentially within a clearly defined risk management framework as described in LEGIER Beteiligungs mbH's Annual Report and Accounts. An overall risk register and all concerns raised by employees are regularly reviewed by the management team and Board. Supply chain issues, including those relating to modern slavery and human trafficking, are addressed within this framework and resolved promptly.


Recruitment


As a global company, we recruit employees in many countries, including the UK, Europe, the US, the Middle East and Asia. We carry out thorough checks during the recruitment process, including right to work checks, to ensure that our employees are working for us voluntarily and are not affected by modern slavery or human trafficking. We pay all employees at least the legal minimum wage for their location and review this regularly. Our diversity and inclusion policy prohibits any form of discrimination or victimization. All employees are paid by bank transfer and we do not allow payments to third parties. We require all recruitment agencies we work with to have policies against modern slavery and human trafficking or to commit to eliminating such practices.


Process improvement


We will continuously improve our due diligence processes and carry out more training and awareness-raising measures for all employees.


Legal compliance


As a global company, LEGIER Beteiligungs mbH is subject to various national and international laws to combat modern slavery and human trafficking. In the UK, we comply with the requirements of the Modern Slavery Act 2015 by publishing an annual statement outlining our actions to prevent slavery and human trafficking in our supply chain. In Germany, we comply with the Supply Chain Due Diligence Act, which requires us to implement due diligence in our supply chain and report on our efforts. We strive to comply with all relevant laws and regulations in the countries in which we operate.


Approved by the company


This statement has been made pursuant to section 54(1) of the Modern Slavery Act 2015 and approved by the Board of LEGIER Beteiligungs mbH. It will be updated annually in accordance with the reporting requirements of the Act.


Tetiana Starosud,
Chief Executive Officer