German Act on Corporate Due Diligence Obligations in Supply Chains ("LKSG")

Our strategy to comply with human rights and environment-related due diligence obligations – Policy Statement as per Section 6 (2) of the German Act on Corporate Due Diligence Obligations in Supply Chains (“LkSG”)

Respecting human rights, labor and social standards, and protecting the environment are key components of responsible and sustainable corporate governance at TÜV SÜD. Companies bear responsibility for the sustainable development of the economy, environment, and society. This is particularly pertinent for TÜV SÜD, whose social mandate has been an integral part of its corporate statutes from the outset. This has been TÜV SÜD's corporate purpose, since its establishment more than 150 years ago: We protect people, the environment and assets from technology-related risks. We mitigate the risks associated with the latest technologies so as to ensure that innovations in science and technology are accepted in society and people and the environment can derive maximum benefits from them. This way, we accompany and shape technological change and continually adapt our services with the aim of ensuring optimum safety and thus accomplish our mission at all times. Our services help to contribute to sustainable development around the globe.

TÜV SÜD is a globally active company. In approx. 50 countries around the world, more than 26,000 employees ensure safety. They come from more than 100 countries with different cultures, are of different ages, have different lifestyles, and bring with them a wide range of skills, views, and interests - all of which make us strong as a company and give us additional impetus in developing our services. Our suppliers are just as diverse and international as us. We are aware that there can occur human rights violations, particularly with a view to the intricacy of international supply chains. However, human rights, labor and social standards, as well as environmental protection standards must be observed at all times, both within TÜV SÜD's own business operations and in our supply chains around the globe.

We are explicitly unwilling to tolerate any type of forced labor and child labor, are particularly committed to taking a consistent stance against any and all types of discrimination and committed to respecting the freedom of association as well as the right to collective bargaining, to ensuring the observance of fair employment standards, the provision of a safe and healthy work environment, and to payment of fair-market wages that are enough for workers to make a living.

TÜV SÜD has adopted a uniform group strategy based on the principles set out in para. 3.-8. for compliance with human rights and environment-related due diligence requirements in its own business operations and supply chains. It applies to all TÜV SÜD group companies in which TÜV SÜD AG directly or indirectly owns a majority of shares or in which TÜV SÜD AG otherwise has a decisive influence. The uniform group strategy also applies to the subsidiaries of TÜV SÜD AG, which – like TÜV SÜD AG – are subject to the scope of application of the LkSG since January 1, 2023 or from January 1, 2024, namely TÜV SÜD Auto Service GmbH, TÜV SÜD Industrie Service GmbH, TÜV SÜD Product Service GmbH and TÜV Technische Überwachung Hessen GmbH; the same strategy and procedures described below apply throughout the group.

1. Outcome of risk analyses and related measures

The following primary human rights and environment-related risks have been identified through the analysis of risks in TÜV SÜD's own business operations and the analysis of risks at TÜV SÜD's direct suppliers:

1.1. Primary risks in TÜV SÜD's own business operations and related measures

Human rights and environment-related 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. Nevertheless, issues relating to discrimination and health & safety issues connected to work load due to tight schedules or overtime have been identified as primary abstract risks across our various countries.

With respect to health & safety, a pronounced awareness of the problem can be observed for the most part, which is reflected in existing measures within the framework of company health management and in the increased focus on the various fields of action relating to the issue of human resources planning (including management of skills, strategic human resources planning, recruitment). Further, in October 2023, the Mental Health Initiative was launched. This new TÜV SÜD-wide campaign emphasizes the special importance of both physical and mental health for general well-being and, in particular, for resilience in stressful times.

With respect to risks of discrimination, however, there is, to some extent, still a need for offering training and taking action. As part of our "Diversity Boost" project which was launched in 2021 with a long-term sustainability focus, we have taken various steps which are primarily to promote diversity and thus counteract behavior and structures perceived as discriminatory. A global proportion of females at management level has been adopted throughout the group as a uniform quality benchmark across all countries. In addition, each region has committed itself to implement two further key performance indicators and corresponding regional targets by the end of 2026, depending on their relevant perspectives on the framework conditions, initial situation and key spheres of action. The measures to achieve these targets are correspondingly diverse: They range from group initiatives (global process specifications, managed succession planning, talent programs, etc.) to local measures tailored to the respective area (e.g., very specific training courses taking into account the respective focus areas and local as well as cultural circumstances and examples).

1.2. Primary risks at TÜV SÜD's direct suppliers and related measures 

The annual analysis of human rights and environment-related risks carried out in 2023 among TÜV SÜD's active direct suppliers from 2022 revealed a focus on abstractly risky suppliers from China and India. In the more specific risk assessment based on self-assessment questionnaires and on-site audits, very few specific findings were made to improve the human rights and/or environment-related risk situation. The suppliers concerned will soon be contacted individually to agree on customized appropriate measures to reduce the risks.

2. Expectations vis-à-vis TÜV SÜD's employees and suppliers

Based on the outcome of the risk analyses available, TÜV SÜD has the following human rights and environment-related expectations of its own employees and suppliers: 

2.1. Expectations vis-à-vis TÜV SÜD's own business operations 

TÜV SÜD expects everyone in its own business operations to comply at all times with the requirements as to equal treatment regardless of ethnic origin, religion, ideology, age, disability, gender or sexual identity, and for health & safety. These requirements can be found in the Code of Conduct and in group guidelines, such as in particular the guideline on Human Rights and Labor Law, Diversity and Inclusion, Fair and Equal Remuneration, and Global Health and Safety Management. Any notices with regard to potential wrongdoing can be reported via the TÜV SÜD Trust Channel so as to ensure that misconduct can be prevented or stopped immediately. 

2.2. Expectations vis-à-vis TÜV SÜD's suppliers 

TÜV SÜD expects all of its suppliers to consistently adhere to the standards set out in the TÜV SÜD Supplier Code of Conduct and to contact TÜV SÜD in the event of human rights or environment-related difficulties - either via the contact person from the Purchasing Group Department or via the TÜV SÜD Trust Channel.