Preamble

d-fine GmbH (hereinafter referred to as d-fine) is a European consulting company focussing on analytically challenging topics, which are handled by employees with a scientific background and a high degree of responsibility for sustainable solutions and their sustainable technological implementation.

d-fine is committed to compliance with human rights and environmental standards. Respect for human rights (United Nations Universal Declaration of Human Rights) is a matter of course for the d-fine GmbH and its subsidiaries (d-fine Ltd, d-fine Austria GmbH, d-fine AG, d-fine AB, d-fine BV, d-fine s.r.l.). Furthermore, d-fine's business activities are in accordance with

• the German Basic Law Article 1
• the European Convention on Human Rights
• the fundamental principles of the International Labour Organization of the United Nations (ILO)
• the Guidelines for Multinational Enterprises of the Organisation for Economic Co-operation and Development (OECD)

The Sustainability Board is responsible for compliance with due diligence obligations. The management of d-fine is represented on this board by two managing directors. 

Complaints Procedure

If human rights or environmental violations occur within d-fine's supply chain, this can be reported anonymously on the d-fine website under d-fine anonymous. This applies to d-fine employees as well as employees of suppliers and interested third parties, such as members of affected communities or environmental and human rights organisations.

Risk Management and Risk Analysis for our Supply Chain

The Sustainability Board is responsible for risk management in the d-fine supply chain and organises the regular risk analysis once a year. As part of the risk analysis for our supply chain, individual risks for all relevant combinations of supplier sector and country are evaluated. This also includes our subsidiaries. In cases of increased risk, the relevant direct suppliers are assessed separately in terms of their respective risk. 

If potential violations of human and environmental rights in the supply chain or at d‑fine subsidiaries become known, this triggers an event-driven risk analysis. This applies in particular to indirect suppliers.

Priority Risks

The following priority risks for d-fine were identified as part of the risk analysis:

• Discrimination
• Poor working conditions
• Low wages
• Unpaid or forced overtime

In general, it can be said that labour-intensive services in sectors with structurally low wages are the main risk carriers among direct suppliers. In order to prevent the corresponding risks, d-fine ensures that its suppliers are paid appropriately for services rendered and products delivered and sensitises its suppliers to the human and environmental rights to be observed with the help of d-fine’s Supplier Code of Conduct.

Remedial Measures for Violations

In the event of violations, d-fine's primary objective is to bring the violation to an end in the interests of the affected parties or the environment. In doing so, d-fine shall support the supplier concerned as far as reasonably possible. If the supplier company is unwilling or unable to remedy a significant violation within a reasonable period of time, termination of the business relationship is available as a last resort.

d-fine documents all measures carried out as part of the due diligence obligations and reports these to BAFA once a year in accordance with the applicable requirements.

Expectations of our Employees and Suppliers

d-fine expects its employees and suppliers to comply with applicable law and to pay particular attention to respecting human and environmental rights in their own business and supply chain. In order to raise awareness of this and preventively reduce the risk of violations, d-fine has drawn up a supplier code of conduct, which will form part of future supply contracts. The code of conduct clearly formulates the requirements that d-fine places on its suppliers in terms of human and environmental rights.

Further Development of our Processes

d-fine works continually to improve its processes for compliance with due diligence obligations. This includes expanding the possible data sources for risk analysis when new relevant sources become known. The appropriateness and accessibility of the complaints procedure is also evaluated at least once a year.