Berichte der Behörden und Ämter über Zuwendungen in Form von Sponsoring, Spenden und mäzenatischen Schenkungen. Sie beinhalten die von den Behörden und Ämtern sowie den direkten hamburgischen Mehrheitsbeteiligungen (öffentlichen Unternehmen) aus ihrem Zuständigkeitsbereich angenommenen privaten Zuwendungen in Form von Sponsoring, Spenden und mäzenatischen Schenkungen ab 5.000 Euro im Einzelwert und die von bestimmten hamburgischen Mehrheitsbeteiligungen aus ihrem Zuständigkeitsbereich geleisteten Spenden und spendenähnlichen Zuwendungen ab 2.500 Euro im Einzelwert.
Statement of Principles
I.
Foreword by the Management Board of the Bundesgesellschaft für
Endlagerung
Acting on behalf of the federal government, the Bundesgesellschaft für Endlagerung mbH
(BGE) is responsible for selecting the best possible location for the final disposal of high-
level radioactive waste materials and for the permanent storage of radioactive waste deep
underground.
With this Statement of Principles pursuant to section 6(2) sentence 2 of the Supply Chain
Act (LkSG), we, the Management Board of the BGE, stipulate the handling of human-rights
and environmental risks in our own area of responsibility and for the BGE’s supply chains
with respect to all of our sites.
At the same time, with this Statement of Principles, the BGE sets out the expectations of
employees, suppliers and business partners in terms of respect for human rights throughout
supply and value chains.
II.
Commitment of the BGE to respect for human rights
Against this background and as enshrined in its compliance programme, the BGE is
committed to respect for human rights and the prevention and remediation of violations in
these areas.
The BGE’s commitment to the upholding of human rights is based on the Guiding Principles
on Business and Human Rights of the United Nations (UN) and is also shaped by the
International Bill of Human Rights and the International Labour Organization’s Declaration on
Fundamental Principles and Rights at Work (ILO Core Labour Standards), with its four basic
principles regarding freedom of association and the right to collective bargaining, the
elimination of forced or compulsory labour, the abolition of child labour, and the prohibition of
discrimination in employment. To this end, the BGE obeys applicable national rules, such as
the Basic Law as well as labour and social laws and regulations.
The BGE expects its employees to follow the guidelines set out in this Statement of
Principles, as well as the BGE’s Mission Statement, when making business decisions. This
includes respectful and appreciative cooperation and fair collaboration with our business
partners.
The BGE also expects suppliers and business partners to commit to and abide by the
respect for human rights and internationally recognised labour and environmental standards
expressed in this Statement of Principles. At the same time, they are called upon to pass this
expectation on to their own suppliers and business partners.
III.
Approach of the BGE to implementing human rights due diligence
Implementation forms part of the BGE’s integrated management system approach. In
particular, the existing occupational safety and health and the risk- and compliance-
management system help to prevent or minimise harm to the reputation and credibility of the
BGE in terms of the avoidance of any violations of human and environmental rights. In this
way, the BGE builds trust and contributes to fair cooperation.
For the handling of risks within the supply chain and within its own area of responsibility, the
BGE has implemented a multistage process in which overall responsibility ultimately lies with
the Management Board. LkSG risk management is covered by the uniform corporate risk
management and is monitored by the Compliance/Anti-Corruption staff unit.
Negative impacts, whether they relate to human rights or the environment, are systematically
identified and remedied both at the BGE and at suppliers.
The process described in detail in chapters IV to VII forms the basis for the BGE’s holistic
and continuous LkSG approach.
The arranged activities are regularly reviewed in terms of their appropriateness and
effectiveness and undergo continual further development.
The processes and results are documented and stored accordingly and are incorporated into
the annual report to the Federal Office for Economic Affairs and Export Control (BAFA) in
accordance with section 10(2) of the LkSG.
IV.
Risk analysis in our own area of responsibility and in the supply chains
With this in mind, the BGE continually checks where particular risks of human-rights and
environmental violations exist within its own area of responsibility and its supply chains. This
check is based on an annual and also ad hoc risk analysis process that is carried out
both for our own business activities and for direct suppliers. This process, which is also
carried out for the BGE’s indirect suppliers where necessary, begins with an abstract
consideration of risks and serves, in particular, to identify industry-, raw material- and
country-specific risks for individual supplier groups with a view to the subsequent risk
analysis. In the second step, suppliers that are subject to an increased risk are
examined in relation to priority human-rights and environmental risks as part of a specific
risk analysis. This process incorporates the expertise and experience of the relevant
employees, who are in constant contact with the suppliers.
The following areas are identified as being particularly sensitive: child and forced labour,
income, working hours, discrimination, respect for freedom of association, and occupational
safety and health.
The results of the risk analyses are continually incorporated into business decision-making
processes in relation to internal business strategies as well as the BGE procurement
processes, which are regulated by procurement law. The risk analysis also provides a basis
for the identification of appropriate preventive and remedial measures.
V.
Preventive measures
At suitable points, the integrated management system approach involves using the
completed risk analyses as the basis for defining aims and measures. These are then
adapted and scrutinised in light of new results or findings. Corresponding measures are
implemented on different levels in order to minimise the priority risks:
•
•
•
VI.
Human-rights and environmental topics are enshrined within the BGE’s own area of
responsibility by means of guidelines, internal awareness-raising, and staff
education, as well as by continually reviewing measures with regard to their
suitability.
On entering into a contract, suppliers are obliged through supplementary
contractual terms to respect the values and expectations arising from this
Statement of Principles and to apply them when selecting their own suppliers.
Furthermore, the BGE reserves the right to implement different risk-appropriate
control mechanisms (e.g. spot checks and rights to information) in its
supplementary contractual terms.
Moreover, in formal procurement procedures exceeding the value limits set by the
BGE, suppliers are called upon to include information on violations of the LkSG that
are punishable by a fine in a self-declaration.
Complaint procedure
An appropriate and effective complaint procedure is available to employees, suppliers and
business partners, as well as potentially affected parties, allowing them to report violations or
negative impacts on humans and the environment in their own area of responsibility and in
the supply chain and then to prevent or counteract them accordingly.
Reporting individuals can contact the BGE’s Compliance and Anti-Corruption Officer with
their complaints/reports not only by phone but also via the internet
(https://www.bge.de/en/compliance/) and by post. This process is strictly confidential, and
the reporting individual can also submit their complaint anonymously. The complaint
procedure is impartial and respects the principle of the presumption of innocence.
All complaints and reports relating to human rights violations and relevant violations of
environmental obligations are processed in a transparent and predictable procedure. The
findings provide the basis for the identification, introduction and monitoring of effective
measures.
The sequence of complaint procedures is described in the procedural rules
(https://www.bge.de/en/compliance/).
Whistleblower system of the Bundesgesellschaft für Endlagerung
mbH (BGE)
Procedural rules pursuant to section 8(2) of the Supply Chain Act (LkSG)
Scope of application
The purpose of the reporting system of the Bundesgesellschaft für Endlagerung mbH (BGE)
is to uncover misconduct with regard to compliance with laws and internal rules of the BGE
and therefore to protect the BGE, its employees, and third parties from harm.
The BGE evaluates all evidence of compliance risks and compliance violations. In particular,
these include:
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•
•
•
violations of legal standards and regulations to which the BGE is subject
violations of the BGE’s Code of Conduct
violations of the BGE’s internal company rules
complaints relating to human-rights and environmental risks according to the
BGE’s Statement of Principles
Purpose of the reporting office
The BGE expressly encourages not only employees but also third parties to report violations,
anomalies and risks relating to infringements of the law and violations of the BGE’s rules.
The BGE’s Compliance and Anti-Corruption Officer is on hand to act as a reporting office.
The reporting office of the BGE meets the requirements for internal reporting offices in
accordance with the German Whistleblower Protection Act (HinSchG). The BGE ensures
that every report submitted in good faith is treated with confidentiality and respect.
Whistleblowers are protected against reprisals.
Report-handling procedure
Contact
The contact details of the Compliance and Anti-Corruption Officer are as follows:
Bundesgesellschaft für Endlagerung mbH
Compliance-/Antikorruptionsbeauftragter
Re “Report”
Eschenstraße 55
31224 Peine
Phone: +49 (0) 5171 43-1441
Email: hinweis@bge.de
Peine, 15 December 2023
The BGE is unreservedly committed to compliance with the law. Indeed, acting in accordance with the law is a matter of course for the BGE – not only as a federal company. The Management Board and all employees are required to act lawfully, ethically and in accordance with rules and contracts. The overarching commitment and obligation to comply with all legal requirements and internal guidelines is expressed by the BGE in its Code of Conduct, which defines the ethical basis and the framework for the BGE’s actions. The code is derived from the material legal risks identified and evaluated at the BGE, as well as from the BGE’s guidelines. For the BGE, however, compliance also entails a supportive culture with a view to ensuring conduct in accordance with the rules. The Code of Conduct is intended to help raise awareness of legal risks and avoid infringements of the law. It does so by specifying and explaining binding guidelines in an easily understandable form as general guidance in relation to all decisions and actions. The code applies to all employees of the BGE. However, the BGE also expects its contractors, suppliers and all third-party business partners to adhere to the applicable provisions of the code if they are working with the BGE. Code of Conduct (PDF, 1,64 MB) The BGE has set up a compliance management system, which it develops on an ongoing basis. The system is based on a compliance programme whose focus lies on proactive prevention. This includes key measures such as the creation of internal rule transparency, continual further development of the anti-corruption programme, and comprehensive training activities in all compliance-related risk areas. The programme, which is closely intertwined with risk management and the internal control system, is based on the legal risks identified, evaluated and documented at the BGE. The avoidance of future rule violations requires appropriate and effective measures to ensure that rule violations are detected and sanctioned. To this end, violations can be reported by both internal and external parties (via a “whistleblower system”). In addition to its own compliance audits, the BGE’s Internal Audit department assists the Compliance & Anti-Corruption staff unit in identifying the need for action and improvement as part of its risk-oriented audits. The BGE is unequivocally committed to respect for human rights and environmental due diligence. In terms of respect for human rights, the BGE is guided by the international human rights reference instruments and frameworks. The BGE’s comprehensive approach includes not only the BGE itself but also all suppliers and business partners within the existing supply chains. The BGE’s own commitment is set out in its Statement of Principles along with a description of the principal human rights, processes and measures addressed. This Statement of Principles also sets out the BGE’s expectations of its suppliers and business partners with regard to the protection of humans and the environment. Statement of Principles (PDF, 71 KB) (PDF, 0,07MB) The Compliance/Anti-Corruption Officer of the BGE is on hand to act as an internal reporting office. With regard to the acceptance and processing of reports, the officer is independent, not subject to instructions, and bound to secrecy. The reporting office established for this purpose meets the requirements for internal reporting offices in accordance with the German Whistleblower Protection Act (HinSchG). With this reporting office, the BGE safeguards the interests of whistleblowers and ensures that any reports received are handled confidentially and that whistleblowers are protected by every possible means – to the best of the company’s knowledge and belief – against any disadvantages resulting from a report. As far as legally permissible, anonymous reports are also accepted. However, it is helpful if the whistleblower gives their contact details when making a report in order to allow better investigation of serious misconduct and to increase the capacity for dialogue as part of the system. The BGE’s whistleblower system also serves as a complaints office in accordance with the Supply Chain Act (LkSG). Accordingly, it also allows the reporting of human-rights and environmental risks as well as violations of duties relating to human rights or the environment that arise due to the BGE’s economic activities in its own area or due to the actions of a direct or indirect supplier/service provider of the BGE. Procedural rules (PDF, 124 KB) (PDF, 0,07MB) The contact details of the BGE’s Compliance/Anti-Corruption Officer are as follows: Bundesgesellschaft für Endlagerung mbH Compliance-/Antikorruptionsbeauftragter Re “Report” Eschenstraße 55 31224 Peine Phone: +49 (0) 5171 43-1441 Email: hinweis(at)bge.de In addition, if anonymity is important to whistleblowers making a report by telephone, it is recommended that they withhold their number when making the call. A summary record is made of the report received by telephone. If the phone number for whistleblowers cannot be reached, a message can also be left on the answering machine connected to the phone number. Other than that, no audio recording or written record of calls is kept. As well as the possibility of the internal reporting office, the Whistleblower Protection Act provides for the possibility of an external reporting office. The option of contacting an external reporting office exists via the federal external reporting body at the Federal Office of Justice (BfJ). This external reporting body is objectively independent and organisationally separate from the rest of the BfJ’s area of responsibility. You can find additional, up-to-date information regarding reports to the Federal Office of Justice on the BfJ website (external link) Within the whistleblower system, data is processed according to the provisions of the General Data Protection Regulation (GDPR). Information for whistleblowers in accordance with sections 13 and 14 of the GDPR can be found in our data protection declaration .