Sustainability Report 2023/24

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ENGEL Sustainability Report 2023/24 Sustainable Focus Areas / 07 / Governance attended the training related to the ENGEL Code of Compliance and core values. As a result, a culture of open communication (speak up culture) has been established, while maintaining a positive record regarding compliance-related incidents. For instance, in 2023, there were no reported cases of corruption, conflicts of interest, data protection breaches, or environmental incidents. The contents of the compliance training are based on the key areas covered in the Code of Compliance: • Data protection • Observance of the law • Bribery and corruption • Prevention of fraud • Conflicts of interest • Respect, integrity and fair working conditions • Product safety, sustainability and environmental responsibility • Foreign trade and export control • Compliance in the supply chain • Competition and anti-trust law • Responsible marketing • Privacy and confidentiality • Prevention of money laundering • Tax compliance ENGEL employees are also offered other training opportunities in the area of compliance, e.g. in relation to conflicts of interest, corruption and bribery, information security, and data protection. The training is complemented by group-wide operating procedures for the relevant compliance topics. How to report non-compliance and violations • An online whistleblower platform – the ENGEL Integrity Helpline – was installed in 2021 and expanded to four additional languages in spring 2023. The ENGEL Integrity Helpline is publicly accessible, thus open to all stakeholders. This whistleblower platform not only complies with the requirements of the relevant European Whistleblower Directive but exceeds them. ENGEL employees are familiarised with the platform at a training event. The platform collects the incoming reports and forwards them to the system address of the compliance department and allows for an anonymous bidirectional communication with the whistleblower. • The ENGEL Integrity Helpline also offers the additional option of contacting the compliance department over the phone via an anonymised, non-traceable telephone number. • Incidents may also be reported by email or at the occasion of a personal meeting. The compliance department decides on the follow-up of a report and, if necessary, leads the further investigation. In all cases, there is a direct reporting line from the compliance department to the management board. If necessary, other specialist departments are involved, whereby in particular the initiation of further investigation steps and any additional measures are coordinated. The compliance department is informed continuously about the ongoing investigative measures taken in each case, for as long as the case remains open. 66
Sustainable Focus Areas / 07 / Governance ENGEL Sustainability Report 2023/24 The insights gained from the incidents and measures taken in response assist in the implementation of sensibilisation measures after the case is closed. The monitoring of compliance breaches takes place directly on the whistleblower platform. ENGEL pays particular attention to data protection in general and the special requirements resulting from the General Data Protection Regulation (GDPR). By implementing the necessary technical and organisational measures – e.g. a central data protection organisation that is coordinated by IT and Legal –, the company has secured a consistently high level of data protection. As a result, ENGEL did not report a single data protection violation in the year 2023. To raise the awareness for the topic, ENGEL Austria employees also have to complete a training in “information security and data protection”, which covers the following points: • Usernames and passwords • Confidential documents • Use of email • ENGEL Company Data • Mobile data storage devices • Protection from unauthorized access • Social hacking • WiFi hotspots and internet access points • Reporting of information security incidents • Fundamentals of data protection In addition to data protection requirements under EU law, corresponding legislative initiatives in other legal domains are considered, e.g. the new data protection law in Switzerland, as well as the Personal Information Protection Law and Cyber Security Law in China, for which the necessary steps have been initiated for implementation. ENGEL understands compliance and sustainability with all their facets not as isolated topics, but is rather pursuing a holistic compliance approach that is embedded in all other processes and interfaces. The Compliance Department acts as coordinating port of call for all compliance issues and always interacts closely with other internal stakeholders. To meet the increasing requirements associated with the EU Taxonomy, the Corporate Social Reporting Directive, and the Corporate Sustainability Due Diligence Directive (CSDDD), the existing compliance management system is being redesigned and aligned with the criteria of ISO 37301. Additionally, the necessary independence of the compliance department and its global role are ensured through organisational elevation to a staff function reporting directly to the executive management at the holding level. Given the tense geopolitical situation, there continues to be a particular focus on trade compliance. Recent developments in the Middle East, the ongoing war in Ukraine, as well as targeted initiatives by individual countries such as the Uyghur Forced Labour Prevention Act in the USA, necessitate targeted actions in this regard. The future will also see a high priority assigned to the topic of supply chain compliance. Further information can be found in the above chapter “Human rights along the supply chain”. 67
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SUSTAINABILITY REPORT 2023/24
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Contents ENGEL Sustainability Repor
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01 / Message from the Management Bo
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02 / ENGEL at a glance ENGEL Sustai
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03 / The company ENGEL Sustainabili
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Page 71 and 72: 09 / Appendix / Further Key Figures
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Page 75 and 76: 09 / Appendix / Sustainable Develop
Page 77 and 78: 09 / Appendix / GRI Content Index E
Page 79 and 80: 09 / Appendix / GRI Content Index E
Page 81 and 82: 09 / Appendix / Notes ENGEL Sustain
Page 83 and 84: Editorial details Published by ENGE
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