Slavery and Human Trafficking Statement

From the TÜV SÜD AG Board of Management

“TÜV SÜD recognises the fundamental importance of respecting human rights in its own business and its supply chains. We continue to monitor, review, and take reasonable steps to ensure that slavery and human trafficking do not contribute to any aspect of our business. We acknowledge our continued responsibilities under the UK Modern Slavery Act 2015 and, accordingly, have produced this Statement with respect to the prevention of slavery and human trafficking for the financial year ending 31 December 2022.”  

1. TÜV SÜD's Group Structure and Business

TÜV SÜD AG with its registered seat in Munich, Germany, is the management holding company of the TÜV SÜD Group (“TÜV SÜD”). TÜV SÜD stands for independence and impartiality on the basis of a specific legal structure: TÜV SÜD AG is not listed on the stock exchange. The beneficial owners of the TÜV SÜD AG shares are TÜV SÜD e.V. and the TÜV SÜD Foundation. 

In 2022, TÜV SÜD comprised a total of 43 German and 113 international entities. At year-end 2022, TÜV SÜD employed more than 26,000 people, nearly half of whom worked outside Germany. TÜV SÜD operates in the Testing, Inspection, Certification market as a technical services provider. TÜV SÜD’s range of services thus covers testing and certification, inspection, auditing and system certification, knowledge services and training. TÜV SÜD is active globally with a focus on Germany, China, the US, India, the UK, Spain and Italy. For more detailed information about TÜV SÜD’s group structure and business, please refer to TÜV SÜD’s latest Annual Report. 

2. TÜV SÜD's supply chains

As a technical service provider, TÜV SÜD’s supply chains are primarily related to the procurement of support services and, to a much lesser extent, materials to deliver specialist technical services. As a globally operating group of companies, TÜV SÜD accordingly has international supply chains with suppliers in more than 70 countries. TÜV SÜD seeks to maximize the benefits of local sourcing wherever possible and therefore uses regional or local suppliers for around 90 percent of the procurement needs. For more detailed information about TÜV SÜD’s sustainable sourcing, please refer to TÜV SÜD’s latest Sustainability Report.

3. TÜV SÜD's Policies in relation to slavery and human trafficking

TÜV SÜD has a Code of Conduct which sets out the basic rules that every employee must follow. It includes a chapter on compliance with human rights and emphasizes the prohibition of all forms of forced labor, slavery and human trafficking. The Code of Conduct can be viewed here.

The basic rules set out in the Code of Conduct are specified in group-wide guidelines, for instance in the guideline on Human Rights and Labour Law. These guidelines are reviewed regularly and adapted in line with new findings, changed legal provisions, and national and international standards. TÜV SÜD’s recruitment practices ensure that hired individuals are free to work. All employees benefit from working conditions and terms and conditions of employment that meet or exceed all applicable legislation including working hours, holiday, pay and equality. All offers of work made by TÜV SÜD are accepted on an entirely voluntary basis.

Further, TÜV SÜD has a Supplier Code of Conduct which is the core expression of a sustainability- and compliance-based procurement philosophy. It shapes the expectations and requirements TÜV SÜD has towards all suppliers which expressly include the prohibition of slavery, servitude, forced labour and human trafficking in any form in the supply chains. The principles set out in this Supplier Code of Conduct form an integral part of the supplier selection and assessment. The Supplier Code of Conduct can be viewed here.

In addition, TÜV SÜD offers a confidential whistleblowing system – the TÜV SÜD Trust Channel. It enables TÜV SÜD personnel as well as external parties to report potential or actual violations against compliance regulations and in particular also against human rights at TÜV SÜD or in TÜV SÜD’s supply chains. The TÜV SÜD Trust Channel can be accessed here. 

4. TÜV SÜD's Due Diligence Processes, Risk Assessment and Risk Management in relation to slavery and human trafficking

TÜV SÜD has adopted a uniform group strategy for compliance with human rights due diligence requirements, risk assessment and risk management in its own business operations and supply chains. It can be viewed here.

In 2022, TÜV SÜD has appointed a Global Human Rights Officer who oversees the risk management with respect to human rights and thus also regarding slavery and human trafficking. 

4.1 Within TÜV SÜD's own business operations  

Human rights risks in TÜV SÜD's own business operations are generally considered to be marginal – considering the fact that TÜV SÜD's business model is that of a technical service provider which is made up of an overwhelming majority of highly educated employees. In 2022, no instances of slavery or human trafficking were identified within TÜV SÜD’s business. 

4.2 Within TÜV SÜD's supply chains 

The first comprehensive analysis of human rights risks at TÜV SÜD's direct suppliers began in 2022; it has not been fully completed by the end of 2022. The aim is to subject all active suppliers from 2022 to such an analysis, which by its nature is only possible after the end of the calendar year. The initial results from the analysis show that individual direct suppliers from the region of Greater Asia and South America or South Africa involve the highest abstract human rights risks. The direct suppliers identified as potentially risky are contacted individually to agree on risk-mitigation action.  

5. TÜV SÜD's performance indicators in relation to slavery and human trafficking

TÜV SÜD has set several targets to measure the effectiveness of its action with regard to compliance in its own business operations and sustainable sourcing – and thus incidentally also with regard to the prevention of slavery and human trafficking in its business and supply chains. These targets include, for example, a quota of employees which undertook the annual compliance e-learning and a quota of suppliers which have signed a declaration of compliance with the Supplier Code of Conduct. For more detailed information about such performance indicators, please refer to the respective sections about compliance and sustainability across the supply chains in TÜV SÜD’s latest Sustainability Report.

6. TÜV SÜD's training for employees in relation to slavery and human trafficking 

All TÜV SÜD employees around the globe are required to participate in the annual compliance e-learning, which – since 2022 – has also included a learning card on human rights and thus the prohibition of slavery and human trafficking. Further, all procurement personnel are required to participate in a training focussed on human rights due diligence obligations with regard to TÜV SÜD’s supply chains. 

This Statement has been approved by the Board of TÜV SÜD AG on behalf of TÜV SÜD.

22 May 2023 

FROM THE TÜV SÜD AG BOARD OF MANAGEMENT 

“TÜV SÜD Group understands the fundamental importance of ethical business and supply chain operations. We continue to monitor, review, and take reasonable steps to ensure that slavery and human trafficking do not prevail in any aspect of our business. We acknowledge our continued responsibilities under the Modern Slavery Act 2015 and, accordingly, have produced this Statement with respect to the prevention of modern slavery for the financial year ending 31 December 2021.”  

TÜV SÜD GROUP STRUCTURE AND BUSINESS
TÜV SÜD AG is the parent company of the TÜV SÜD Group (“the Group"). TÜV SÜD’s range of services covers certification and testing, inspection, auditing and system certification, knowledge services and training. We operate in the Testing, Inspection, Certification market as a technical services provider.

At present, about 25,000 employees around the world are committed to providing value to our customers via our suite of services. TÜV SÜD AG is not listed on the stock exchange. lt is owned by TÜV SÜD e.V. and the TÜV SÜD Foundation, which hold 74.9 % and 25.1% of the shares respectively.   

This statement outlines the Group’s approach to tackling slavery and human trafficking.

SUPPLY CHAINS
As a service provider, our supply chains are primarily related to the procurement of support services and materials to deliver our specialist technical services. We expect our suppliers to adhere to our standard procurement terms and conditions which ensure that our supply chains are contractually obligated to comply with the Modern Slavery Act 2015. In addition to that, in 2021, we have rolled-out our Supplier Code of Conduct. This Supplier Code of Conduct is based on the most important international standards and regulations for human rights, such as the International Labour Standards (ILO), OECD Guidelines for Multinational Enterprises, ISO 45001, ISO 14001, United Nations Global Compact, United Nations Guiding Principles, United Nations Universal Declaration on Human Rights, United Nations against Corruption. We continue to engage with our suppliers regularly to collaboratively ensure compliance. 

GROUP POLICIES
The TÜV SÜD Code of Ethics describes the values and principles which employees and suppliers are expected to uphold. AII employees receive training on the Code of Ethics and yearly refreshers on Compliance. This is complemented by a robust Compliance organisational structure with representation at Local, Regional and Global levels. These values and principles are addressed in greater detail through specific local policies.

Our recruitment practices ensure that hired individuals are free to work. All employees benefit from working conditions and terms and conditions of employment that meet or exceed all applicable legislation including working hours, holiday, pay and equality. All offers of work made by the Group are accepted on an entirely voluntary basis.

DUE DILIGENCE
Since publishing its first Statement, the Company has made significant progress in standardising vendor questionnaires and ensuring these are fit for the purpose in meeting or exceeding its obligation under the Modern Slavery Act 2015.

EMPLOYEE AWARENESS 
TÜV SÜD conducts online and face to face training for its employees to emphasize the importance of acting with integrity and in line with our internal Code of Ethics. Key staff and employees are briefed on the existence of the Modern Slavery Act 2015 and of their individual and collective responsibilities.  

This statement has been approved by the Board of TÜV SÜD AG on behalf of TÜV SÜD Group.

February 2022 

 
Prof. Dr.-Ing. Axel Stepken
Chairman of the Board 
TÜV SÜD AG