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GOVERNANCE 15

cases, they should directly contact the Compliance fulfills its financial, social, and environmental obliga-
Manager (CM) responsible for their location. Our tions in its relations with the outside world. We are
whistleblowing policy also makes it possible to anon- committed to supporting the positive development
ymously report serious misconduct to an internal or of local communities and showing respect for local
external body. Sanctions will be imposed in the case cultural characteristics, customs, and traditions. (
of violations of the business ethics guidelines. see 2.3).

[SDG 8; GRI 102-16, 207, 407, 408, 409, 410 ] Com- 2.1.4 Compliance
pliance with all laws that apply at the specific busi- [GRI 205, 207, 307, 410, 412, 419 ] RAFI operates
ness location is the foundation of our company’s a structured compliance management system that
ethical orientation. Because our company has its includes defined rules, measures, and control in-
headquarters in Germany, German legal standards stances for preventive and active compliance with
form the basis of our internal guidelines. In all corpo- applicable laws and regulations. In recent years,
rate activities, companies in the RAFI Group comply we have established a comprehensive role struc-
with all local and international legal standards. In our ture to better organize and monitor compliance
business relationships, we pay attention to the integ- tasks. All laws and regulations affecting any Ger-
rity, effective governance, and transparency of our man RAFI Group locations were consolidated in an
partners. We also communicate these values by bas- index of legal provisions so that appropriate roles
ing all external relationships on our comprehensive within the company could be assigned. We regu-
Code of Conduct. As an employer, we expressly re- larly update this index and consider whether it can
ject child labor, forced labor, physical and psychologi- be extended to other locations. Experts who regu-
cal disciplinary measures, and discrimination of any larly source information on legal changes and their
kind. We also take preventive measures to ensure consequences for our corporate group fill these
occupational safety, and we regularly review these roles. These colleagues receive further training in
measures to ensure that they continue to be up to their area of law at least every three years. All par-
date and effective. RAFI fully recognizes the princi- ties responsible for the compliance organization of
ples of the International Convention on Human the entire Group meet at least once a year to dis-
Rights, including the UN Declaration on Human cuss rights and obligations and to seek legal ad-
Rights, and respects the right of all employees to vice if required.
form or join trade unions, provided that such action is
within the framework of local laws and regulations. A Compliance Manager (CM) is responsible for en-
[GRI 413-1, 419 ] As a global company, RAFI also suring compliance with applicable laws and regula-