Compliance Framework “ScandicEstate” LEGIER BETEILIGUNGS MBH

1. Introduction

  • Purpose: This Compliance Framework ensures that LEGIER BETEILIGUNGS MBH (hereinafter “LEGIER,” “we,” or “us”) and its affiliated brands SCANDIC ESTATE, SCANDIC PAY, SCANDIC TRUST, and SCANDIC TRADE (hereinafter “SCANDIC Brands”) comply with legal requirements, ethical standards, and best practices, particularly regarding human rights and environmental due diligence obligations. The goal is to avoid, identify, and minimize risks in our business activities and supply chains.
  • Legal Basis: The Framework is based on German laws, particularly the Supply Chain Due Diligence Act (LkSG), which mandates due diligence in supply chains to protect human rights and the environment.

2. Scope of Application

  • Covered Entities: Applies to LEGIER BETEILIGUNGS MBH and all SCANDIC Brands.
  • Supply Chain Coverage: Encompasses all direct suppliers and, where necessary, indirect suppliers involved in the production and delivery of goods and services for LEGIER and SCANDIC Brands.

3. Risk Management

  • Risk Assessment Process:
    • Annual risk analysis to identify potential human rights and environmental risks in our activities and supply chains.
    • Assessment of risks based on severity, likelihood of occurrence, and our ability to mitigate them.
  • Risk Mitigation Strategies:
    • Development and implementation of action plans for identified risks, including collaboration with suppliers, corrective actions, and, if necessary, termination of business relationships.
    • The Compliance Officer oversees the implementation of these strategies.

4. Policy Statement

  • Commitment: LEGIER is committed to respecting human rights and environmental standards in all business activities, including preventing forced labor, child labor, discrimination, and environmental destruction.
  • Expectations of Suppliers: Suppliers must adhere to the same standards and comply with our Supplier Code of Conduct.

5. Due Diligence Processes

  • Supplier Assessment and Selection:
    • New suppliers undergo a due diligence review.
    • Existing suppliers are regularly audited.
  • Monitoring and Audits:
    • Regular audits of high-risk suppliers, conducted internally or by third parties.
  • Corrective Actions:
    • In case of violations, suppliers must implement corrective actions within a specified timeframe, or face contract termination.

6. Complaint Mechanism

  • Channels for Submitting Complaints:
    • Establishment of a whistleblower system for anonymous reporting by employees, suppliers, and external stakeholders.
    • Available channels:
      • Online Portal: Secure, multilingual system.
      • Email: compliance@ScandicEstate.com
      • Phone: +49 (0) 232 57 44 78
      • External Compliance Officer: Attorney Axel Kapust.
  • Processing Procedure:
    • Complaints are investigated confidentially by the Compliance Officer and relevant departments.
  • Protection for Whistleblowers:
    • Confidentiality and protection from retaliation for whistleblowers acting in good faith.

7. Reporting

  • Internal Reporting:
    • The Compliance Officer reports quarterly to the management board on compliance activities and complaints.
  • External Reporting:
    • Annual compliance report on our due diligence efforts.

8. Training and Awareness

  • Employee Training:
    • Mandatory annual training for all employees on human rights, environmental standards, and the whistleblower system.
  • Communication:
    • The Framework is communicated via internal portals, supplier contracts, and public websites.

9. Monitoring and Review

  • Regular Reviews:
    • Annual review of the Framework for effectiveness and compliance with legal requirements.
  • Continuous Improvement:
    • Adjustments based on feedback and emerging risks.

Key Roles and Responsibilities

  • Management Board (Tetiana Starosud): Overall responsibility and approval of the Framework.
  • Compliance Officer (Attorney Axel Kapust): Oversight of the Framework, management of the whistleblower system, and reporting to the management board.
  • Department Heads: Ensuring compliance within their areas.
  • Employees: Adhering to the Framework and reporting concerns.

Contact Information

  • LEGIER BETEILIGUNGS MBH Kurfürstendamm 195, 10719 Berlin, Germany
    Phone: +49 (0) 30 99211 - 3 469
    Fax: +49 (0) 30 99211 - 3 225
    Email: Info@ScandicEstate.com
  • Compliance Officer Attorney Axel Kapust
    Jägerallee 29, 14469 Potsdam, Germany
    Phone: +49 (0) 232 57 44 78
    Email: Info@ScandicEstate.com

This Compliance Framework ensures that LEGIER and SCANDIC Brands operate ethically and in compliance with the law, with a focus on human rights and environmental standards.

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