Supply Chain Due Diligence Act - Complaints Portal

Our commitment to the highest standards in the supply chain

The purpose of the Nexans Deutschland GmbH Complaints Procedure in accordance with LkSG Section 8 (2) is to provide a transparent presentation of the company's own complaints procedure. The complaints procedure is intended to enable employees, business partners and other third parties to draw attention to human rights and environmental risks as well as violations of human rights and environmental due diligence obligations arising from the business activities of Nexans Deutschland GmbH or its suppliers along the supply chain. Nexans Deutschland GmbH is committed to complying with internationally recognised human rights standards in its global supply chains.

In accordance with the German Supply Chain Due Diligence Act (LKSG), the following rights are protected:

Human rights

1. Prohibition of child labour: Nexans Deutschland GmbH rejects any form of child labour and expects its suppliers and business partners to strictly comply with this requirement.
2. Prohibition of forced labour and slavery: All forms of forced labour and slavery are unacceptable and will not be tolerated.
3. Occupational health and safety: Nexans Deutschland GmbH guarantees safe and healthy working conditions for all employees in its own business area and requires that its business partners also comply with the statutory regulations.
4. Freedom of association: Nexans Deutschland GmbH respects the right of employees to freedom of association and promotes dialogue with employee representatives.
5. Prohibition of unlawful expropriation of land, forests and waters: Nexans Deutschland GmbH stands against unlawful evictions and the expropriation of land, forests and waters and expects business partners to respect these principles.
6. Adequate wages: Nexans Deutschland GmbH ensures that all employees in its own business area receive fair wages and complies with statutory minimum standards.
7. Protection from violence or torture: Nexans Deutschland GmbH protects employees from violence or torture, whether by private or public security forces.
8. Prohibition of unequal treatment in the workplace: Nexans Deutschland GmbH ensures that all employees are treated equally, regardless of gender, skin colour, religion, nationality or other personal characteristics.
9. Prohibition of harmful environmental impacts: Nexans Deutschland GmbH prevents harmful soil changes, water or air pollution as well as harmful noise emissions and excessive water consumption in its operational activities and supply chains in order to maintain an environment worth living in.

Environmental aspects

Nexans Deutschland GmbH is committed to the sustainable use of natural resources and the reduction of negative environmental impacts. The following environmental principles are of central importance within the framework of the LKSG:

• ban on the export of hazardous waste: Nexans Deutschland GmbH undertakes not to export hazardous waste in accordance with the Basel Convention.
• ban on the manufacture and use of products containing quicksilver: Nexans Deutschland GmbH complies with the provisions of the Minamata Convention.
• compliant handling of persistent organic substances: Nexans Deutschland GmbH complies with the provisions of the Stockholm Convention.

Complaints

Who will process my complaint?

The complaints procedure is carried out by the OSR. They are responsible for the management and processing of complaints received by Nexans Deutschland GmbH and guarantee the confidentiality and protection of the whistleblower

 

How can I submit a complaint?

Employees and external persons within the supply chain can submit complaints regarding human rights and environmental risks or violations caused by the business activities or a direct supplier of Nexans Deutschland GmbH. Complaints can be submitted using the tool provided by OSR. Contact details and further information on submitting complaints are publicly available. The procedure ensures that information is confirmed, the facts are discussed with the whistleblowers and an amicable settlement is reached. The confidentiality and protection of whistleblowers is guaranteed.

How does the complaints procedure work?

To protect the whistleblower, Nexans Deutschland GmbH has handed over the whistleblower system to an independent external law firm, which acts as an ombudsperson. The following steps are planned in the procedure:

Submitting a complaint

Whistleblowers can submit their complaint anonymously 365 days a year. The whistleblower will not be charged for submitting the complaint. Receipt of the complaint is documented by OSR and confirmed either immediately or within five days, depending on the channel of receipt.

 

​​​​​​​Examination of the complaint

The facts of the case can be discussed by the whistleblower with an OSR lawyer if the whistleblower wishes to be contacted. Each complaint is carefully examined. If it is plausible, it is forwarded to the Reporting Centre. The Reporting Centre works independently and impartially to clarify the facts of the case. The investigation is carried out confidentially. The Reporting Centre may hold confidential discussions with employees, contractors or other persons it deems relevant to the investigation.

 

Processing of the complaint

After all the results of the investigation have been examined, a decision is made as to whether an offence has been committed. If this is the case, corrective measures are taken. Otherwise, the complaint including corrective measures will be rejected for lack of validity.  The whistleblower will be informed by OSR of the results of the investigation and, if applicable, of the remedial measures taken within 3 months of receipt of the confirmation of receipt at the latest.

 

Effectiveness

The effectiveness of the procedure is reviewed annually and on an ad hoc basis. Adjustments are made where necessary. Key figures, such as the number of complaints, are collected to ensure continuous improvement.

Confidentiality and protection

Nexans Deutschland GmbH is committed to the confidentiality and protection of the whistleblower. It is in the express interest of Nexans Deutschland GmbH to prevent, uncover and remedy grievances, and the anonymity of whistleblowers is protected throughout the entire process of handling a complaint, provided that the person making the report states that they wish to remain anonymous. No measures are taken to establish the identity of a whistleblower. This is additionally guaranteed by OSR, who act as ombudspersons, through corresponding contractual and legal regulations. whistleblowers who report possible compliance violations and/or provide information on human rights and environmental risks as well as on violations of human rights or environmental due diligence obligations to the best of their knowledge and in good faith do not have to fear any adverse measures as a result of the complaint.

Nexans Deutschland GmbH reserves the right to take legal action or disciplinary measures against whistleblowers in the event of recognisable misuse of the whistleblower system and also protects the rights of the accused person and assumes their innocence in the context of an investigation until the contrary is proven

Declaration of principle

We, Nexans Deutschland GmbH and its subsidiaries, are aware of our responsibility to respect human rights. We respect human rights in our global supply and value chains and it is our endeavour to ensure compliance, prevent violations and bring about improvements where abuses are identified.
Together with our employees*, business partners* and stakeholders*, we are committed to promoting human rights and contributing to good working and living conditions in our supply chains.

On this basis, we have drawn up our declaration of principles for all associated companies of Nexans Deutschland GmbH. It supplements existing corporate principles and guidelines and applies to our activities at all locations.

The basis of our commitment to respecting human rights is formed by the following
internationally recognised frameworks:

• UN Convention on the Rights of the Child
• UN Human Rights Charter 
• UN Guiding Principles on Business and Human Rights 
• UN Women's Rights Convention 
• Core labour standards of the International Labour Organization (ILO) 
• OECD Guidelines for Multinational Enterprises 
• The ten principles of the Global Compact

The overall responsibility for human rights due diligence lies with the management of Nexans Deutschland GmbH.
Responsibility for the implementation of human rights due diligence lies with the respective management of the individual divisions in their own business area and is monitored by a supply chain committee in the capacity of human rights officer.

Responsibility of Nexans Deutschland GmbH

We respect the human rights of our employees and expect our business partners to do the same towards their employees by complying with local laws and ILO core labour standards. This includes in particular

• Compliance with the ban on child and forced labour
• Equal treatment of all employees
• Ensuring health and safety in the workplace
• Remuneration at least in the amount of legally guaranteed minimum wages with working hours in accordance with applicable standards
• Protection of personal data
• Recognition of the formation of employee representative bodies and collective bargaining
• Working conditions.

These principles are also anchored in our Nexans Code of Ethics and Business Conduct and are part of contractual agreements with our business partners. We recognise that respecting human rights in global supply chains requires long-term commitment with a step-by-step approach to preventing violations, eliminating abuses and continuously driving improvements, even with the caveat that it may not always be possible to achieve all goals.

 

Implementation of the human rights due diligence obligations
We see the implementation of our human rights due diligence obligations as a continuous process, in the course of which reassessments and adjustments will always be necessary.

Risk analysis
Nexans Deutschland GmbH carries out annual risk analyses as part of its business activities. In the event of a change in the risk situation and substantiated knowledge, an event-related risk analysis is initiated. The risk classification is carried out according to business partners and products based on analyses of recognised indices and studies concerning countries of origin and raw materials. This information is supplemented by specially compiled questionnaires to be completed by the business partners, as well as specific empirical values and background checks.

Preventive and remedial measures:
The findings are used to derive specific measures to prevent or minimise the negative impact of our business activities. If violations by direct suppliers cannot be remedied immediately, specific plans are drawn up to minimise and avoid them. Measures for violations by indirect suppliers are taken on an ad hoc basis, also with the aim of eliminating or at least minimising and avoiding them in the future.
Violations against employees identified within the company are always terminated immediately.
 

Complaints procedure and access to redress
Effective grievance mechanisms play an important role for those affected by and observers of human rights violations. Nexans Deutschland GmbH has set up an online reporting system for the confidential (and, if necessary, anonymous) reporting of human rights violations in various languages, which can be found on the homepage. In addition, complaints can also be reported by telephone or in person to the OSR lawyers appointed as ombudspersons for this purpose. A code of procedure can also be found on the website, which describes the procedure for receiving information or complaints.

Findings from these reports and complaints are used to further develop our mechanisms and recognise risks. If violations are actually identified, Nexans Deutschland GmbH will endeavour to provide redress and remedy for those affected within the scope of its influence.

 

Reporting
Nexans Deutschland GmbH will publicly report annually on its activities to protect human rights in its supply chains from the end of the 2024 financial year.
The annual report will be published on the website www.nexans.de and kept there available free of charge for at least seven years in accordance with legal requirements.

 

Effectiveness monitoring
As part of its responsibility under the LkSG, Nexans Deutschland GmbH has established a comprehensive risk management system to ensure that all human rights due diligence obligations are met. This is reviewed annually, as are all its components, to ensure its effectiveness. Furthermore, all measures taken are reviewed and adjusted if necessary.