As a responsible family business, it is our goal to strengthen human and environmental rights and to prevent, minimize and, as far as we can influence, successfully prevent their violation. Only then will the Mederer Group be successful in the long term.
The following policy statement covers all activities of the consolidated companies of the Mederer Group worldwide.
1.1. Commitment to international standards
The Mederer Group is committed to the following internationally applicable human rights standards:
It is our goal and our duty to ensure the best possible compliance with internationally recognized standards.
1.2. Zero-tolerance for discrimination, violence, harassment and abuse
Appreciation, openness and respect are practiced in the Mederer Group. Discrimination on the basis of nationality, citizenship, pregnancy or parenthood, marital status, sexual orientation, skin color, gender, disability, veteran status, religion or belief, age, racist reasons, social/ethical origin or political views, insofar as the latter are based on democratic principles and tolerance, or other legally protected reasons, is not tolerated.
The Mederer Group has a zero-tolerance policy with regard to exploitation and abuse, violence, harassment and abuse of power in all business activities and responsibilities.
Violations of this policy are unacceptable and will be assessed on a case-by-case basis. As a result of the assessment, appropriate measures are initiated, which can range from raising awareness to consequences under employment law.
1.3. Declaration on the implementation of the Supply Chain Due Diligence Act
As a company operating in Germany, Trolli GmbH is subject to the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, LkSG) and the human rights and environmental due diligence obligations associated with the Act from January 1, 2024 onwards.
1.4. Complaints management
As part of the implementation of the LkSG, we have implemented a management system for recording, processing and evaluating complaints regarding possible or actual breaches of due diligence.
The system and a detailed process description can be found here.
The anonymity of the complainants is guaranteed at all times.
1.5. Code of Conduct of the Mederer Group
The Mederer Group is committed to responsible and sustainable corporate governance. To this end, a Code of Conduct has been developed that applies equally to the employees of the Mederer Group and its business partners. You can find the current version of the Mederer Code of Conduct here.
The employees and business partners of the Mederer Group are requested to report violations of the Code of Conduct to the Compliance Officer or via the whistleblower/complaint management system.
2.1. General responsibility
The Mederer Group expressly recognizes its responsibility to respect human rights and environmental due diligence obligations along its supply chains.
Compliance with this policy statement and the implementation of the requirements of the German Supply Chain Due Diligence Act (LkSG) are firmly anchored in the company organization.
An internationally active specialist department is responsible for the operational implementation of the LkSG. In close cooperation with the managers of the Mederer Group, the specialist department coordinates the implementation of the legal requirements and is supported by a cross-departmental "Due Diligence Team". This ensures that all areas of the company are aware of and actively fulfill their respective tasks and obligations under the LkSG.
2.2. Social responsibility
As an internationally active company with extensive supply chains, we are aware that our activities are always associated with the risk that human rights could be endangered or even violated within the supply chain. Our aim is therefore to identify potential risks at an early stage and minimize them, prevent violations or respond to them appropriately.
2.3. Rules for working together
We expect our employees to behave in a lawful, respectful and tolerant manner towards our fellow human beings. Every employee is part of our corporate family and thus contributes to the external image of our company at all times. All of the information, guidelines and behavior specified in this policy statement and our Code of Conduct are binding for employees of the Mederer Group at all levels of the company. Employees are required to observe them and to approach their line manager or the management at any time if they have any questions or suggestions.
2.4. Cooperation with business partners
The Mederer Group works with qualified suppliers, sales partners and service providers ("business partners"), which it selects carefully and according to objective criteria. It places the same demands on its business partners as it does on itself and strives for long-term and economic business relationships. The principles and values contained in the Mederer Group's Code of Conduct (CoC) form the basis for cooperation with our business partners.
2.5. Risk management
2.5.1. Risk analysis
As part of the implementation of the LkSG, Trolli GmbH carries out an annual and ad hoc risk analysis for its own business area and for its direct suppliers. If a risk is identified in relation to one of the legal positions protected under the law, Trolli GmbH initiates appropriate and risk-related preventive and, if necessary, remedial measures. In doing so, it always acts according to the principle of "empowerment before retreat". When selecting risk-related measures, Trolli GmbH considers the results and experience gained from complaint management and internal effectiveness testing. In the event of substantiated knowledge at an indirect supplier, Trolli GmbH acts according to the same principle.
Due to the complexity and scope of the international supply chains, Trolli GmbH uses risk monitoring software to support the identification, validation, weighting and prioritization of risks in accordance with the LkSG.
2.5.2. Risk analysis procedure
A risk management tool is used to carry out risk analysis. The system offers an integrated software solution for the IT-supported implementation of the requirements of the LkSG and thus enables risk and supplier management based on the criteria of the LkSG.
The software provides a detailed overview of the company's own business area, its direct suppliers and - with the appropriate knowledge - its indirect suppliers and appropriately maps their specific human rights and environmental risks. All direct suppliers and the companies in the company's own business area are entered into the system. Using recognized indices and press releases, an abstract risk is determined for each company entered and each protected legal position.
Depending on the abstract risk disposition, the specific risks for individual business partners are determined in a second step. The specific risk is calculated based on a self-assessment by the business partner, proof of compliance with audit-based standards, experiences from the supplier relationship or information from the complaints procedure. Based on the specific risk, individual preventive measures can then be implemented if necessary.
2.5.3. Weighting and prioritization
The IT-supported risk management tool is used to prioritize risks based on the following criteria:
Violations of the ban on the worst forms of child labor and the ban on forced labor and slavery are considered particularly serious and irreversible violations. Corresponding risks are treated as a high priority.
Subsequently, risks that affect a large number of people, such as violations of occupational health and safety standards, wage discrimination and the creation of harmful soil, air and water pollution, are considered first and foremost. As part of the prioritization process, business partners from high-risk industries are given priority.
The ability to influence the direct perpetrator of the potential breach is assessed in particular based on the volume of trade with the business partner concerned.
An internal prioritization scale is also considered, which refers to the proximity of the purchased goods and services to the operational purpose of Trolli GmbH. The more closely a good or service is linked to the company's own products and the more important it is for the company's own production processes, the higher it is prioritized in accordance with the requirements of the LkSG.
The weighting and prioritization described above can ensure that prevention and remedial action is only initiated where necessary.
2.5.4. Identified risks
In the abstract risk analysis, occupational health and safety, inappropriate remuneration and harmful soil, water and air pollution were identified as potential risks for the company's own business division. However, the concrete risk analysis revealed that these risks can be classified as low due to existing preventive measures, such as comprehensive occupational safety precautions, collectively agreed remuneration and the establishment of an ethics management system.
The abstract risk analysis results in potentially sensitive sectors for the supply chain:
Due to the internal prioritization in accordance with the LkSG, the focus of the specific risk analysis is on:
2.5.5. Monitoring and effectiveness testing
The compliant and effective implementation of the LkSG is continuously monitored by the management of the companies concerned within the Mederer Group. The specialist department responsible reports to the management for this purpose at least once a year and on an ad hoc basis.
The Mederer Group is aware that the implementation of human rights and environmental due diligence in relation to the LkSG is an ongoing development process. It is currently in the middle of this process and is committed to continuous improvement.
In global supply chains, respect for human rights requires long-term commitment and a step-by-step approach. The Mederer Group therefore strives for continuous improvement in cooperation with its business partners within the supply chain. It is aware that not all goals can always be fully achieved.
As an international company with extensive supply chains, we are aware that our activities are always associated with the risk that human rights and environmental standards could be jeopardized or even violated within the supply chain. Our aim is therefore to identify potential risks at an early stage and minimize them, prevent violations or respond to them appropriately.
If violations occur despite numerous preventive measures, we can only take action if we become aware of them. To this end, we have introduced a complaints procedure for reporting human rights and environmental violations.
Link: Access to the online complaints portal
In addition to the digital channel, you also have the option of contacting our complaints office by post:
Trolli GmbH
For the attention of the complaints office
Oststraße 94
90763 Fürth
Germany
An explanation of the procedure can be found here.
As part of our social responsibility, we have developed a Code of Conduct for our employees, our suppliers and our business partners, which specifies our ethical business practices.
The current version of the “Code of Conduct of the Mederer Group” is available for download here.