Complaints procedure (rules of procedure) in accordance with Section 8 LkSG on human rights and environmental due diligence obligations

On 1 January 2023, the German Supply Chain Due Diligence Act ("LkSG") came into force, which applies to all companies in Germany with more than 3,000 employees, regardless of sector. For the first time, the LkSG enshrines due diligence obligations with regard to human rights within the supply chain and the company's own business area as a corporate responsibility and codified law.

Due to its number of employees, this also obliges the STI Group since 01.01.2024 to prevent or at least minimise human rights and environmental rights violations along the supply chain and in its own business area. The STI Group is therefore obliged to implement the due diligence obligations defined in the LkSG, such as setting up a risk management system, conducting a risk analysis, adopting a policy statement on human rights strategy, deriving and implementing preventive and remedial measures, setting up a complaints procedure and preparing and publishing a report for its own business units and for suppliers.

Derived from the prioritised risks, our policy statement describes the STI Group's human rights strategy. The policy statement is supplemented by the STI Group Code of Conduct for suppliers and business/cooperation partners, which formulates corresponding expectations and requirements for them.

Information on the STI Group's complaints procedure and rules of procedure can be found here. This enables both internal and external stakeholders, i.e. individuals, companies and other organisations (anyone), to report human rights and environmental risks or violations (e.g. child or forced labour). (e.g. child or forced labour) human rights or environmental due diligence obligations in writing or in text form by email, verbally/by telephone or in person using the contact details provided in our Code of Conduct, which are protected by the LkSG and have arisen through the economic activities of (i) STI in its own business area or (ii) a direct supplier or (iii) an indirect supplier. The submission of information is confidential, secure and is also possible as a digital complaint using the complaint form.

The final component of the LkSG is documentation and reporting. We will fulfil our reporting obligation at this point and make our report publicly available free of charge for a period of at least seven (7) years.