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BREMER’s Declaration of Principles under Section 6 (2) of the German Supply Chain Due Diligence Act (LkSG)

Respect for Human Rights and Environmental Protection

At BREMER SE (hereinafter also referred to as BREMER), respect for human rights and environmental protection are integral to our corporate responsibility. Our values, such as responsibility for people and nature, humanity, and community, underpin our approach. We are driven by a passion for construction, efficient resource management, and value creation, which shape our actions. Family values, solidarity, and reliability are deeply embedded in our corporate culture. Partnership and long-term connections are of utmost importance to us, and we treat others as we would like to be treated. These values drive us and form the foundation of our mission.

Our commitment to human rights and environmental protection is based on internationally recognised standards, including the UN Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, ILO Core Labour Standards, international environmental agreements like the Paris Climate Agreement, the Basel Convention, and other relevant international conventions. We acknowledge that our actions impact human rights and the environment, both within our company and throughout our global supply and value chains. Respect for human rights and environmental protection are principles that BREMER upholds, encompassing fair business practices that guarantee good living and working conditions. This commitment is mandatory for BREMER SE, as well as its subsidiaries, both domestic and international, with the board, management, and all employees committed to taking all necessary actions to prevent and address human rights violations and environmental harm. We also recognise our responsibility to prevent violations within our supply chain. This Declaration of Principles sets out our commitments, processes, and actions for respecting human rights and environmental protection in compliance with the requirements of the Supply Chain Due Diligence Act (LkSG).

Scope of Application

This Declaration of Principles applies to all business areas and subsidiaries of BREMER. It encompasses our entire global supply and value chains, including all direct and indirect suppliers, as well as other business partners involved in the production of our steel and prestressed concrete components and the construction of our buildings.

Commitment to Human Rights and Environmental Protection

a) Recognition of Human Rights and Environmental Protection
BREMER fully recognises the breadth of human rights and the need for environmental protection, committing to respect and safeguard them in all business activities and throughout our supply chain. This includes, in particular, the prevention of exploitation, discrimination, forced labour, and child labour, as well as ensuring safe and healthy working conditions. Scientific studies have identified the construction sector as an area where human rights violations can occur, particularly within the entire supply chain and concerning working conditions and safety. BREMER prioritises risk assessment in these areas for our employees, subcontractors, and raw material supply chain. Additionally, we are committed to protecting natural resources and ecosystems in the course of our business activities. Through the proper handling of (hazardous) substances, BREMER protects the environment, employees, subcontractors, and local residents.

b) Compliance with International Standards
We are committed to adhering to all relevant international human rights and environmental standards, including the UN Guiding Principles on Business and Human Rights, ILO Core Labour Standards, the Paris Climate Agreement, the Basel Convention, as well as regional and national regulations relating to human rights and environmental protection.

c) Responsibility of Management
The board and management at BREMER hold the highest responsibility for human rights and environmental protection within the company. They ensure that appropriate processes and measures are implemented, monitored, and regularly reviewed across all areas of the company. Managers are required to actively contribute to compliance with this Declaration of Principles and to ensure that their teams adhere to these principles as well.

Due Diligence and Risk Management

a) Risk Assessment and Analysis
In line with the LkSG requirements, we conduct continuous risk assessments to identify potential and actual human rights risks throughout our supply chain. These assessments are regularly updated to respond to changes in our business activities, supply chains, or regulatory environment. Depending on the nature and scope of business activities and relationships, both abstract and specific risk assessments are carried out, with a focus on industry-specific issues, such as the execution of construction services by subcontractors, which require attention not only to legal regulations but also to BREMER’s specific requirements as outlined in our Code of Conduct.

We place particular emphasis on environmental risks that may arise from our business activities or the actions of our suppliers. This includes risks associated with climate change, the use of natural resources, environmental pollution (e.g., water, soil, and air pollution), and biodiversity loss. Environmental monitoring considers the impact of our product and service manufacturing processes, including any work carried out by contracted companies or external suppliers, and the subsequent environmental impact. This includes energy, material, and CO2 reduction measures during the production process, as well as increased use of rail transport via our own railway connection as an environmentally friendly alternative to road transport. BREMER continually seeks innovative methods and procedures to further reduce resource and energy consumption and CO2 emissions through the development of new concrete formulations and manufacturing processes. Our buildings are designed to meet measurable and comparable criteria for environmental friendliness during construction and future operation, verified by sustainability certifications such as DGNB, LEED, etc. BREMER’s Sustainability Report documents each step and highlights the progress of implemented actions, following a process that is regularly reviewed and adapted.

b) Prioritisation and Action Planning
Based on the risk assessments, we prioritise identified risks by severity and likelihood. We develop and implement action plans to mitigate or eliminate these risks, which include training, supplier evaluations, audits, and collaboration with relevant stakeholders.

Environmental Protection Measures:
We implement specific actions to reduce our ecological footprint and promote sustainable practices throughout our supply chain. These initiatives include reducing greenhouse gas emissions, promoting sustainable resource use, encouraging circular economy practices, and minimising waste and pollutants.

c) Integration into Business Processes
Respect for human rights and environmental protection are integral to our business processes. This includes incorporating human rights and environmental criteria into our procurement and contracting processes, collaborating with suppliers to improve their human rights and environmental practices, and integrating human rights and environmental aspects into our strategic decision-making.

Prevention and Remedy

a) Preventive Measures
To avoid human rights violations and environmental harm, we implement a range of preventive measures that span all levels of our supply chain. These include training and awareness-raising for our employees and business partners, implementing our Code of Conduct for Business Partners, and conducting audits and regular reviews.

b) Remedial Actions
If human rights violations or environmental harm occur despite these precautions, we take immediate remedial actions. This includes working with affected parties to rectify the situation and, where necessary, introducing corrective measures and sanctions against involved suppliers or business partners.

c) Complaint Mechanisms
We ensure that all employees, business partners, and other affected individuals have access to an effective and easily accessible complaint mechanism for reporting potential or actual human rights violations or environmental issues. BREMER’s web-based whistleblower system is managed by an external provider and ensures low thresholds to facilitate easy reporting. All complaints are thoroughly investigated, and appropriate corrective measures are taken.

Transparency and Reporting

a) Disclosure and Communication
We are committed to transparency regarding our human rights and environmental due diligence obligations. This includes regularly publishing reports on our actions, progress, and challenges in the areas of human rights and environmental protection. These reports are available internally and externally to all interested parties.

b) Stakeholder Engagement
We actively engage in dialogue with our stakeholders, including customers, suppliers, employees, non-governmental organisations, and the public, to incorporate their perspectives into our human rights and environmental strategies and actions. This engagement helps us to learn continually and improve our practices.

Training and Awareness

a) Employee Training
We provide regular training for our employees to raise their awareness of human rights and environmental issues and strengthen their ability to address these topics. These trainings are tailored to the specific requirements of each department and role and include compliance with the LkSG.

b) Awareness for Business Partners
We work closely with our suppliers and other business partners to ensure they also respect human rights. This includes providing training materials, organising workshops, and promoting the exchange of best practices.

Monitoring and Further Development

a) Continuous Monitoring
The implementation of our human rights and environmental due diligence obligations is continuously monitored and evaluated. BREMER’s LkSG working group, comprising departments such as Legal and Compliance, Procurement, Sustainability Management, and Controlling, coordinates all risk monitoring and analysis measures and oversees compliance with human rights regulations within our organisation and across our supply chain. This working group evaluates the effectiveness of the measures taken and regularly reports to the board and management.

b) Improvement Processes
BREMER is committed to the continuous improvement of its human rights and environmental practices. This includes regularly updating our action plans, introducing new technologies and risk mitigation methods, and providing ongoing training for our employees and business partners.

Final Provisions

Management and department heads are responsible for adhering to and implementing the commitments outlined in the Code of Conduct, ensuring respect for human rights and environmental aspects in business operations. They must always encourage compliance with company values among those working within their areas of responsibility.

This Declaration of Principles is regularly reviewed by the BREMER board and updated as necessary to reflect changes in legal and societal frameworks. It becomes effective upon publication and is binding for all employees and business partners.

 

 

Paderborn, October 2024

The executive board

Torsten Schuff

Board member

Matthias Molter

Board member

Michael Dufhues

Board member