With this policy statement, we, lawcode GmbH, reflect our human rights strategy.
1. Priority human rights and environmental risks identified for us
We have carried out a risk analysis in our own business area. As a RegTech company and SaaS provider, we have determined that the following topics are a focus for us:
2. Expectations of our suppliers
We expect our suppliers to comply with human rights and environmental standards in accordance with Section 2 (2) and (3) LkSG. We will not commission a supplier who does not comply with these standards.
3. Responsibilities
To ensure compliance with human rights and environmental standards, we have implemented a risk management system for compliance with due diligence obligations. We first defined the responsibilities. This policy statement was drafted and published by the entire management of lawcode GmbH. The operational implementation of due diligence obligations in accordance with the Supply Chain Due Diligence Act is ensured by the Purchasing department, the specialist department involved and Legal & Compliance. We analyze our suppliers according to a risk assessment. We use the digital supply chain module of the lawcode Suite for this purpose
4. Risk analysis
We implement the due diligence obligations in accordance with Section 3 LkSG at lawcode GmbH. We assess the risks for our own business area annually and on an ad hoc basis. In addition, our suppliers are subjected to an abstract and, if necessary, concrete risk analysis. This is carried out using the Supply Chain module of the lawcode Suite. This risk assessment for human rights and environmental risks is carried out annually and on an ad hoc basis. It is always carried out for the first time at the start of a new supplier's contract. If a supplier - based on transparent calculation methods - has an increased risk score or otherwise presents a risk, questionnaires are sent to the suppliers, which the supplier must answer truthfully. These answers are in turn given a risk score. This can then be used to define and implement any further measures that may be required. This is documented in the Supply Chain module of the lawcode Suite in a comprehensible manner. The results of these risk analyses are reported to the management on an ongoing basis.
5. Preventive measures
With regard to prevention measures, we ensure that our suppliers comply with human rights conditions in our procurement and purchasing activities. Each supplier is selected and checked through a procurement process in a digital solution - including for human rights and environmental standards. Where possible, the contractual provisions explicitly ensure that the supplier complies with human rights and environmental expectations.
The decision-makers involved in our company receive regular training on this. Furthermore, we have also implemented a complaints channel with the Hintbox so that we can identify, assess and prevent or limit any human rights violations at an early stage. We evaluate these measures internally on an annual and ad hoc basis.
6. Remedial measures
In the event of a human rights violation, we will immediately initiate appropriate remedial measures. These are recorded and documented in our digital supply chain module. These measures are also assigned to responsible persons in our company and time tickets are issued. The consequences of an actual violation range up to termination of the contractual relationship and depend on the individual case.
7. Complaints procedure
We have implemented a complaints procedure with the Hintbox. This is available on our website. This means that complaints about indirect suppliers can also be submitted. Whistleblowers can also submit complaints anonymously. We approach and review these complaints confidentially, neutrally and impartially. We also carry out a risk analysis following a complaint and initiate remedial measures.
8. Documentation and reporting obligations
Compliance with the due diligence obligations is documented internally in our supply chain module. For our internal purposes, in particular for review and improvement, we draft a report on the fulfillment of its due diligence obligations in accordance with the Supply Chain Due Diligence Act.
Koblenz, January 2, 2025