Declaration of Principles on the Human Rights Strategy of the SENNHEISER Group

Preface

This declaration of principles defines our commitment as the SENNHEISER Group to adhering to ethical, social, and environmental standards within our company and towards our business partners and customers. Taking into account the requirements of the law on corporate due diligence to prevent human rights violations in supply chains (Supply Chain Due Diligence Act - LkSG), it describes how we fulfill the legally mandated human rights and environmental due diligence obligations. Additionally, this declaration of principles provides information on the priority human rights and environmental risks identified based on a risk analysis.

 

SENNHEISER expects its suppliers throughout the entire supply chain to conduct their business with integrity and responsibility, adhering to all applicable laws regarding human rights and environmental concerns as per the LkSG. Accordingly, this declaration of principles articulates our human rights and environmental expectations for our suppliers and business partners in the supply chain.

 

Responsible and lawful conduct is an integral part of our corporate values. It is a fundamental requirement for the business activities of the SENNHEISER Group and encompasses compliance with all legal requirements, including cartel and competition law, corruption and money laundering prevention, export control law, and data protection law.

1. Our Commitment to Human Rights

We recognize the importance of responsible action and are firmly committed to implementing the principles of the Supply Chain Due Diligence Act in all our business activities. In this context, we adhere to the principles and guidelines of the following internationally recognized human rights and environmental frameworks and standards:

- The Universal Declaration of Human Rights of the United Nations

- Conventions and protocols of the International Labour Organization (ILO) on labor and social standards

- OECD Guidelines for Multinational Enterprises

- UN Guiding Principles on Business and Human Rights

- Principles of the UN Global Compact

We consider these international frameworks and standards as the basis for our commitment and the way we intend to conduct our business. We also expect our employees and suppliers in our supply chain to comply with these frameworks and standards.

2. Definition of Human Rights and Environmental Expectations

Our goal is particularly to fulfill the following human rights and environmental expectations:

Environmental Protection: For the SENNHEISER Group, responsibility for the environment means preserving the finite resources of nature. Therefore, careful and efficient use of resources is of utmost importance for the SENNHEISER Group. We advocate for sustainable practices, efficient resource use, and aim to minimize negative environmental impacts along the supply chain, especially harmful soil changes, water and air pollution, noise emissions, and excessive water consumption. Preserving biodiversity is emphasized through the protection of forests and the maritime ecosystem. Our processes, facilities, and equipment comply with legal requirements and environmental standards.

In this context, the SENNHEISER Group makes the following efforts to reduce its environmental impacts and risks and continually improve environmental protection:

- Use of green energy

- Use of recycled materials

The SENNHEISER Group is aware of the risks associated with the use of hazardous materials, chemicals, and substances. It takes responsibility to avoid risks to the environment and health by proper labeling of these substances and ensuring proper handling, transportation, and storage.

Human Rights and Social Responsibility: Respecting human rights and social responsibility towards our employees and third parties is extremely important for the SENNHEISER Group. We commit to respecting human rights in our supply chain and ensuring that we do not contribute to human rights violations in any form. Special emphasis is placed on combating child labor and forced labor, as well as modern forms of slavery such as servitude, human trafficking, work under threat of punishment, or economic exploitation.

The SENNHEISER Group maintains a non-discriminatory approach within the corporation, ensuring that unequal treatment of employees, for any reason, such as national or ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion, or worldview, is avoided. The principle of equal pay for equal work is particularly applicable.

Working Conditions: For the SENNHEISER Group, fair working conditions, occupational safety, and the promotion of employee health are of the highest priority within the framework of the company-wide health and safety strategy. We adhere to internationally recognized and nationally applicable labor standards and have established occupational health and safety management.

Compliance with legal working hours is of particular importance. The design of working hours within the company-wide occupational health and safety management is such that accidents due to physical and mental fatigue are avoided.

Harassment and any form of violence in the workplace are prohibited at the SENNHEISER Group and are strictly enforced.

Use of Raw Materials: The SENNHEISER Group strives to use only raw materials whose extraction, transport, trade, processing, and export do not directly or indirectly contribute to human rights violations, health and safety problems, environmental pollution, or compliance violations. We expect suppliers and stakeholders along the supply chain to have an adequate due diligence process. On an ad-hoc basis, we request information from our suppliers about their supply chain for these materials and, if applicable, other raw materials, including information about the origin of the material.

3. LkSG Risk Management

3.1 Risk Assessment and Management

Protection of the aforementioned human rights and environmental goods is covered by our comprehensive risk management embedded in our business processes. We strive to create transparency along our supply chain.

We conduct annual and ad-hoc risk analyses to identify potential hazards to human rights and the environment and to prevent risks or address any violations. Using a continuously updated risk analysis process, we identify and evaluate relevant human rights and environmental issues and potentially affected parties in our own business activities and those of our immediate business partners.

Within the risk analysis process, we initially identify, based on an abstract consideration of risks, industry-specific, product group-specific, and possibly country-specific risks in our own business area and supply chains. In the second step, those suppliers and companies with an increased risk disposition are examined through a specific risk analysis for priority human rights and environmental risks.

The identified risks are weighted, prioritized, and examined for their probability of occurrence. Our focus is on human rights issues identified as essential through risk analyses. The results of the risk analyses continuously influence the business decision-making process regarding supplier selection and management, as well as product selection.

For our risk management, the SENNHEISER management is responsible, and it delegates the corresponding tasks to the relevant business areas and functions. The responsibility for human rights and environmental due diligence lies with the Compliance Officer, who reports to the management in his function.

We annually review the effectiveness of our risk management process and conduct effectiveness checks as needed. Priority risks are particularly scrutinized. Based on these assessments, we develop appropriate measures to minimize risks and adjust our strategies accordingly.

3.2 Prevention Measures with Suppliers

We implement early measures to prevent and reduce adverse human rights and environmental impacts and risks that we have identified and prioritized. An important instrument for strengthening human rights, improving working conditions, and promoting fair trade is our SENNHEISER Code of Conduct for Suppliers, reflecting our expectations and providing the binding framework for our business partners and suppliers. The social and environmental standards of our suppliers are an essential part of our supplier selection. We also expect our suppliers and business partners to convey our human rights and environmental expectations to their suppliers and business partners, such as subcontractors in the supply chain.

Additionally, we collaborate with our suppliers to strengthen their capabilities in terms of social and environmental responsibility. We support them in implementing measures to improve their practices.

3.3 Prevention Measures in Our Own Business Area

SENNHEISER expects its employees to align their daily decisions with these guidelines and invests in raising awareness among employees to ensure that these values are actively lived in daily operations. We have implemented processes to detect violations of these principles, capture them through established procedures, and address them to derive appropriate measures for our business operations. This includes feedback from external sources.

3.4 Remedial Measures

We take all incidents and allegations seriously, whether raised by our employees, external auditors, business partners, the media, or other stakeholders. In case there is suspicion that our business activities cause or contribute to human rights or environmental violations, we will investigate, respond to, and take appropriate remedial measures to address the reported concerns. If there is a justified suspicion or specific indication of possible human rights or environmental violations along our supply chain, this will be carefully and consistently investigated. Depending on the severity of the violation, we retain appropriate response options with our business partners, ranging from requiring immediate rectification of the violation to legal action and termination of the business relationship.

3.5 Complaints Procedure

Through the SENNHEISER complaint procedure, we have established a cross-cutting reporting system for internal and external complaints with various contact channels to enable individuals to report human rights and environmental risks or violations in our own business area or in our supply chain. The complaint procedure is available in German and English. Reports can be submitted, optionally anonymously, via email to compliance@sennheiser.com or by postal mail. All reported indications and well-founded suspicions of possible human rights and environmental violations are processed transparently, fairly, and comprehensibly for all parties involved. Reports submitted through the complaint procedure are treated confidentially. It is designed to prevent any disadvantages for the whistleblowers based on their reports. Those responsible for handling reports and discussing the whistleblower's situation are obliged to act impartially. They carry out their tasks independently and without being bound by instructions. They are bound by confidentiality. We have established procedural rules for the complaint procedure and published them on the internet. Learn more about our whistleblower system and how it contributes to promoting a transparent and ethical corporate culture. Visit the following link for more information: Sennheiser Whistleblower System.

4. Documentation and Reporting

We will regularly review and adapt this declaration of principles to account for any changed circumstances and processes. We continuously document the fulfillment of our human rights and environmental due diligence obligations. The documentation will be retained for at least seven years. The report according to the requirements of the LkSG will be submitted for the first time for the year 2024 and will be transmitted to the Federal Office for Economic Affairs and Export Control in accordance with legal requirements, as well as published on our website.

5. Conclusion

This declaration of principles serves as the basis for our actions in accordance with the requirements of the Supply Chain Due Diligence Act. We acknowledge that implementing these principles is a shared responsibility that requires continuous commitment. By putting these values into practice, we aim to have a positive impact on people, society, and the environment.

We look forward to engaging with you and are available to address any emerging questions. Please do not hesitate to contact us – we are eager to engage.

 

The Management of SENNHEISER electronic SE & Co. KG