Compliance

CODE OF BUSINESS CONDUCT

HeidelbergCement provides materials to construct buildings which give people shelter, offer them space to work and live, which serve education and health care and enable people to travel and meet each other. Where people come and stay together, we need rules that organize society and ensure a peaceful cooperation. These rules come as laws, regulations, policies, guidelines, processes, or principles. They are the basis of freedom, trust, collaboration and are like the concrete that forms the foundation of the highest skyscrapers.

This Code of Business Conduct is the foundation of HeidelbergCement. In effect, it is HeidelbergCement’s constitutional code. These are the rules we give ourselves and this means that everybody within the HeidelbergCement family is committed to them- the CEO, top management, middle management, and each employee. My management board colleagues, and I lead by example by practicing compliant behavior and we expect all management to act as role models for their staff.

We want to follow these rules because we are convinced that they are the right rules and not only because we are obliged to comply with them as a matter of law. Behaving in a legally and ethically compliant manner must be normal and natural to us all and become part of our HeidelbergCement DNA. Additionally, if we don't have existing written rules for a particular behavior, we follow our own internal compass or seek advice from our compliance staff and apply ethical standards that are consistent with our Code of Business Conduct.

If we all adhere to the principles of our Code of Business Conduct this will safeguard HeidelbergCement’s business success, promote the basis for a fulfilling work environment for us all and lead to greater satisfaction of all stakeholders in our Group

Dr. Dominik von Achten

CHIEF EXECUTIVE OFFICER

GROUP BOARD AND SECRETARIAT

HEIDELBERG MATERIALS' SUPPLIER CODE OF CONDUCT

January 2022

In general, our business activities are subject to the respective national laws and regulations dealing with environmental protection, product safety and social welfare matters. Over and above, it is Heidelberg Materials’ policy to formally request that all our suppliers respect the principles of our Supplier Code of Conduct and adopt practices that are consistent with it.

Building on our Heidelberg Materials "Code of Business Conduct", our Supplier Code of Conduct seeks compliance with international social accountability standard SA 8000, environmental standard ISO 14001, the German Act on Corporate Due Diligence Obligations in Supply Chains and the core labour standards1 of the International Labour Organization in our upstream supply chain.

Heidelberg Materials values close and productive cooperation with its suppliers. This globally applicable Supplier Code of Conduct acts as a basis for all our contractual relationships. Therefore, all suppliers shall adhere to this Supplier Code of Conduct. Furthermore, suppliers shall take responsibility to require adherence to these principles from their direct suppliers and exercise diligence in verifying that these principles are being adhered to in their supply chains.

Working Conditions/Labour

  1. Suppliers shall not use child labour in any stage in their operations. Suppliers are obliged to follow the ILO conventions recommendation of minimum age for admission to employment and shall adhere to the ILO Worst Forms of Child Labour Convention.
  2. Compensation and benefits shall comply with fundamental principles relating to minimum wages, working time, overtime hours and legally mandated benefits.
  3. Any form of forced or compulsory labour as defined by the ILO Forced Labour Convention including forced overtime, debt bondage, human trafficking, slavery or forced prison labour shall not be used and employees shall be free to leave employment after reasonable notice.
  4. Suppliers shall adhere to the right of employees to freedom of association and recognition of employees’ rights to collective bargaining, where allowable by law.
  5. Suppliers shall ensure safe and healthy working conditions that meet or exceed applicable standards for occupational health and safety. This includes, at minimum, compliance with applicable laws and regulations in the country and holding the required permits, licenses and permissions. Suppliers shall have appropriate procedures in place as well as safety infrastructure and equipment and shall continuously improve their health and safety performance.

Environmental Standards

  1. Supplier operations shall include, at minimum, compliance with all applicable laws and regulations in the country concerned and shall be carried out with due diligence and care for the environment and people. Environmental impacts regarding, but not limited to, emissions, energy, water, waste and biodiversity shall be managed systematically. Suppliers shall avoid and minimize impacts or compensate such impacts, including environmental impacts that deny a person access to food, drinking water and sanitary facilities or harm a person’s health. Suppliers shall moreover have appropriate environmental procedures in place and shall continuously improve their environmental performance.
  2. Suppliers shall promote safe and environmentally sound sourcing, manufacturing, transport, distribution, use and disposal of their products and services.
  3. The supplier shall respect any applicable local, national and international land, water and resource rights. Unlawful forced evictions are not permitted. 
  4. If the supplier’s operations include:        
  • mercury and mercury compounds, mercury-added products or mercury wastes, suppliers shall comply with the Minamata Convention on Mercury;
  • chemicals and chemical wastes and stockpiles, suppliers shall comply with the Stockholm Convention on Persistent Organic Pollutants;
  • hazardous and other waste shipments as defined by the Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal, suppliers shall comply with Article 4 (2), (5) and (8) of this Convention.

See  Conventions and Recommendations (ilo.org) for more information.

Business Ethics 

  1. Business shall be conducted with integrity. There shall be no payments, services, gifts, entertainment, or other advantages offered or given to any Heidelberg Materials employee or third party which are intended to influence the way in which the Heidelberg Materials employee or third party goes about his or her duties. Similarly, Heidelberg Materials shall not offer or give such payments, services, gifts, entertainment, or other advantages to any supplier which are intended to influence the way in which the supplier goes about his or her duties.
  2. In case suppliers are employing private or public security service providers, they shall be instructed and controlled properly to avoid any kind of unlawful force or repression.
  3. There shall be respect for internationally recognized human rights and suppliers shall ensure that they are not complicit in any human rights violations. Harassment or discrimination against employees as defined by the ILO Violence and Harassment Convention and the ILO Discrimination Convention in any form is not acceptable regarding any employment-related treatment (including, but not limited to recruitment, promotion, layoff). This includes, but is not limited to gender, ethnic origin, skin colour, religion, sexual orientation, disability or age.

Safeguarding of these principles is a long-term learning and development process. Heidelberg Materials is obliged by law to conduct regular risk assessments in different forms. In case of identified risks at a supplier, the supplier agrees that Heidelberg Materials or individuals authorized by Heidelberg Materials have the right to establish action plans that include distinct measures, such as but not limited to self-assessments, trainings and audits of the supplier to verify that the principles herein are being adhered to and to mitigate identified risks. Heidelberg Materials will work together with its suppliers towards compliance, but also reserves the right to discontinue the relationship with a supplier if all efforts to remedy an identified non-compliance with this Supplier Code of Conduct fail.

Suppliers may submit any concerns regarding non-compliant behaviour, either to applicable laws or to internal Heidelberg Materials regulations, via our compliance hotline “SpeakUp”: https://www.speakupfeedback.eu/web/heidelbergcement/

 

 

René Aldach                                                          Dr. Ines Ploss
Member of the Managing Board                       CPO, Director Group Procurement
Rene.Aldach@heidelbergcement.com          Ines.Ploss@heidelbergcement.com