E
EU TAXONOMY REGULATION
DNSH – Pollution prevention and control
In order to monitor compliance with mini- mum social safeguards, the Zumtobel Group uses an active whistleblower system that acts as a secure reporting and communi- cation system for all stakeholders to report suspected violations. The whistleblower sys- tem complies with the requirements of the EU Whistleblower Directive and the Whistle- blower Protection Act (Hinweisgeberschutz- gesetz, HinSchG). Critical concerns are reported directly to Corporate Audit and Compliance. Compliance with human rights and the ILO’s core labour standards in the supply chain is verified through spot checks. A Group-wide compliance management system (CMS) is in place to prevent corrup- tion and antitrust violations, underpinned by systematic risk analyses and compliance programmes, among other measures. Inter- nal audits and regular external reviews are also conducted to ensure tax compliance.
A number of policies have been rolled out in relation to pollution prevention and control. Statutory obligations regarding the monitoring and measurement of potential emissions of hazardous substances into the environment are met and regularly verified through internal and external audits. Through the Code of Conduct for Business Partners, requirements aimed at preventing pollution are extended to the supply chain as well.
DNSH – Protection and restoration of bio- diversity and ecosystems
Compliance with local environmental regu- lations is ensured through the integrated management system and internal policies. Particular attention has been paid to iden- tifying impacts on ecologically valuable or biodiversity-relevant areas at all production sites. Based on the analyses carried out, the relevant economic activities do not give rise to any material adverse impact on other en- vironmental objectives (DNSH).
Additional information
Note on the current status of the EU Taxonomy legislation: The Zumtobel Group understands that the definitions used in the EU Taxonomy Regulation and associated delegated acts are open to interpretation and no prevailing doctrine could be ascertained for the interpretation of certain economic activities at the time of reporting. In terms of ensuring consistent reporting across the board, a line of contact has been established and maintained with other stakeholders in the lighting industry to improve the scope and comparability of reporting; however, signifi- cant differences remain with regard to the interpretation of economic activities in terms of Taxonomy eligibility and alignment within the lighting industry. In our opinion, therefore, comparability remains limited with respect to the EU Taxonomy key performance indica- tors employed by various manufacturers of luminaires and lighting solutions.
MSS – Minimum social standards
The Zumtobel Group ensures minimum social safeguards are adhered to through the implementation of policies in the Code of Conduct and in the Code of Conduct for Business Partners. These policies set binding standards for conduct in business, legal and ethical matters. New employees complete mandatory online training on com- pliance issues and the Code of Conduct. The Code of Conduct for Business Partners ensures that due diligence principles are ap- plied and shared throughout the value chain. It forms an integral part of all contracts and is acknowledged and complied with by busi- ness partners and their employees.
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