14. the company shall disclose its policies for managing its material impacts on labor in the Value chain and the associated Material risks and opportunities.

(15) The objective of this disclosure requirement is to provide an understanding of the extent to which the entity has policies in place to address the identification, assessment, management and/or improvement of material impacts specific to labor in the value chain, as well as policies that address Material risks or opportunities associated with labor in the value chain.

16. the disclosures required by paragraph 14 shall include information on the policies the company applies to manage its Material Impacts, Risks and Opportunities related to labor in the Value chain in accordance with the ESRS 2 MDR-P Approaches to Managing Material Sustainability Aspects. In addition, the company indicates whether these policies cover specific groups or all workers in the value chain.

17 The company describes its commitments on human rights policies ( 112) relevant to workers in the value chain , including processes and mechanisms for monitoring compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises (113). In its disclosures, it focuses on the aspects relevant to, and the general approach to, the following:

18 The company shall indicate whether its policies on labor in the value chain explicitly address human trafficking (114), Forced labour and Child labour . The company also states whether it has a code of conduct for suppliers . (115)

(19) The company shall indicate whether and to what extent its policies on labour in the value chain are consistent with internationally recognized standards relevant to labour in the value chain, including the United Nations Guiding Principles on Business and Human Rights. (116) The company shall also indicate the extent to which cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises involving value chain workers have been reported in its upstream and downstream value chain and, where applicable, the nature of such cases. (117)

AR 10 If the Policies are limited to the company's labor force and do not extend to labor in upstream and downstream companies and Business relationships, they should be reported under ESRS S1 and not in relation to this requirement.

AR 11 If the disclosures made under ESRS S1 include information that is relevant to workers in the Value chain, it may be referenced here; information on the remaining elements shall then be provided in accordance with this disclosure requirement.

AR 12 The company may provide explanations of material changes to the policies adopted during the reporting year (e.g. new expectations for suppliers, new or additional approaches to due diligence and remediation).

AR 13 The policy may take the form of a stand-alone policy related to labor in the value chain or may be included in a broader document such as a code of ethics or a general sustainability policy that the company has already disclosed as part of another ESRS. In these cases, the company shall provide a specific cross-reference to indicate the aspects of the Policy that meet the requirements of this disclosure requirement.

AR 14 When disclosing the consistency of its policies with the United Nations Guiding Principles on Business and Human Rights, the company shall consider that the Guiding Principles refer to the International Bill of Human Rights, which consists of the Universal Declaration of Human Rights and its two implementing covenants, and the International Labor Organization's Declaration on Fundamental Rights and Principles at Work and its underlying core conventions, and may indicate consistency with these underlying standards.

AR 15 In disclosing how externally focused policies are incorporated, the company may consider, for example, internal policies on responsible sourcing and alignment with other policies relevant to workers in the Value chain, such as those related to Forced labour. With respect to the company's codes of conduct towards Suppliers, the summary shall indicate whether they contain provisions related to worker safety, precarious employment (e.g. workers on short-term or temporary contracts, workers employed through third parties, subcontracted to third parties or informal workers), human trafficking, Forced labour or Child labour, and whether these provisions are fully compliant with applicable ILO standards.

AR 16 The company can explain the ways in which it communicates its policies to the individuals, groups of individuals or companies to whom they are relevant, either because they are expected to implement them (e.g. company employees, contractors and suppliers) or because they have a direct interest in their implementation (e.g. Own workforce/own workers, investors). It may specify means and channels of communication (e.g. flyers, newsletters, dedicated websites, social media, face-to-face interactions, Workers' representatives) to ensure that the Policy is accessible and that the different audiences understand its Impacts. The company can also explain how it identifies and removes potential barriers to dissemination, e.g. through translation into relevant languages or the use of graphical representations.

With regard to the protection of workers along the Value chain, the company is fully committed to its corporate responsibility in the area of human rights, see Human Rights Strategy. The company's approach is in line with the UN General Principles on Business and Human Rights, which are based on the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises.

Our strategy on human rights

We are guided by the United Nations Guiding Principles on Business and Human Rights, which refer to the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises. We are committed to respecting and applying the relevant international treaties and declarations in the area of human rights. The protection of human rights and children's rights is considered a fundamental requirement worldwide.

We continuously improve our own processes and systems and implement specific actions to maintain our leading role in the industry with regard to human rights. Internal policies and procedures are used to prevent human rights violations. We strictly reject all forms of Child labour, Forced labour, modern slavery and human trafficking. This policy applies not only to our own operations, but also to the conduct of our business partners, as set out in the Code of Conduct, which is in line with the relevant international standards.

In 2023, we adapted our internal guidelines and processes to the new German Supply Chain Duty of Care Act (LkSG), which resulted in a number of relevant actions, particularly in the area of human rights protection and environmental protection. This was supported by tailored training and internal communication. Our employees were also informed of their obligation to report suspected violations of the law. In the coming years, we will introduce further actions in line with the identified Risks.