Policy Statement on Human and Environmental Rights
Company Objectives and Vision
Excelitas respects the human rights of employees in its supply chain and treats them with dignity.
Environmental responsibility is an integral part of our business practices. Negative impacts on the community, the environment and natural resources are minimized.
The Excelitas executive management in Germany is responsible for the actions set out in this policy statement to comply with our human rights and environmental due diligence obligations.
The human rights strategy set out in this policy statement applies to Excelitas companies in Germany:
- Qioptiq Photonics GmbH & Co. KG with the sites in Göttingen, Feldkirchen and Regen
- Excelitas PCO GmbH with the Kelheim site, and
- Excelitas Technologies GmbH & Co. KG with the Wiesbaden site
Our Core Values
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Integrity: Do What’s Right
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Collaboration: Working Together Achieving Goals
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Expectations on Employees, Suppliers and Business Partners
We expect our employees, suppliers and business partners to comply with our standards. Our standards are based on international conventions and are defined in the following documents:
- Standards of Business Conduct
- Human and Environmental Rights Code Excelitas Germany
- Supplier Code of Conduct
Implementation of Due Diligence Obligations
We implement our due diligence obligations with the following processes:
Risk Management
Excelitas has introduced a risk management system for human rights and environmental risks for our German companies. As part of risk management, a risk analysis is conducted in two stages once a year and as required:
- Firstly, an abstract risk analysis is conducted using freely available sources. We use the CSR risk check provided by the German Agency for Business and Development for this purpose.
- In the second step, we use data to assess the risk of our own business area, and the direct suppliers exposed to risk in the specific risk analysis.
Preventive Measures
We have implemented the following preventive measures:
- Adaptation of our HR management and purchasing processes to address human rights and environmental risks.
- Our HR and purchasing departments and our auditors are regularly trained in relevant risks and internal procedures.
- We incorporate the results of the risk analysis into the selection of our suppliers.
- We contractually oblige all high-risk suppliers to comply with the standards defined in our Supplier Code of Conduct.
- Where appropriate, we train and review our suppliers regarding our Supplier Code of Conduct.
We review the effectiveness of the preventive measures and compliance with our due diligence obligations as part of our audit program.
Remedial Action
If we discover that human rights violations have been caused by our business activities, we will take effective remedial action. These remedial measures must take effect promptly and lead to an end to the grievances. If an immediate end is not possible, we will develop a concept with a schedule for ending or minimizing the violation.
Complaints Procedure
Excelitas has established a whistleblower system in which internal and external stakeholders can report violations.
The reporting channels and our rules of procedure can be found on our website at:
https://www.excelitas.com/reporting-compliance-violation.
Indirect Suppliers
If there are indications that human or environmental rights violations are being committed by an indirect supplier, the following is conducted on an ad hoc basis:
• a risk analysis, and
• preventive measures and remedial actions.
Report
Once a year, we report on the fulfilment of our due diligence obligations in the format provided by BAFA. The reports can be downloaded from the Excelitas website: https://www.excelitas.com/regional-legislation-compliance.
The effectiveness of the above stated processes is monitored by our Human Rights Officer, who informs the managing directors at least once a year about his activities and the process results.
Priority Human Rights and Environment-Related Risks
With companies operating in Germany within the optics industry, we are aware of the country- and industry-specific risks associated with our business activities. As part of our risk analysis, we have identified the following risks for our own business area and our supply chain, which we consider to be a priority due to their potential severity and (irreversibility) as well as our ability to influence them:
| Climate & Energy | |
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Germany is one of the world's largest emitters of greenhouse gases (GHG).
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Our measures:
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| Discrimination | |
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In PwC's Women in Work Index, Germany is in the bottom half of the countries surveyed. It was assessed according to criteria such as the pay gap between men and women. |
Our measure: |
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According to studies, around 10% of all employees in Germany were affected by sexual harassment in the workplace. Women were affected twice as often as men. The rate of racial discrimination against people of African origin when looking for work (>50%) is particularly high in Germany (compared to the rest of the EU). A study by the European Union Agency for Fundamental Rights found that around 20% of LGBTIQ people in Germany have experienced discrimination in the workplace or when applying for a job. |
Our measures:
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Foreign employees are overrepresented in the German low-wage sector and often work under precarious conditions.
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Our measures:
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