JUDO Wasseraufbereitung GmbH (hereinafter referred to as JUDO) is committed to respecting human and environmental rights in its own business operations. The same applies along our global supply chains. We therefore base our business activities on the following internationally recognised standards and guidelines:
Universal Declaration of Human Rights of the United Nations (UN)
Forced Labour Priority Principles of the Consumer Goods Forum (CGF)
International Covenant of 19 December 1966 on Civil and Political Rights
International Covenant of 19 December 1966 on Economic, Social and Cultural Rights
Conventions and recommendations of the International Labour Organization (ILO) on labour and social standards
United Nations Guiding Principles on Business and Human Rights (UNGP)
Guidelines of the Organisation for Economic Co-operation and Development (OECD) for multinational enterprises
Principles of the United Nations Global Compact (UNGC)
Minamata Convention on Mercury of 10 October 2013 (Minamata Convention)
UN Women's Empowerment Principles
UN Convention on the Rights of the Child
UN Convention on the Elimination of All Forms of Discrimination against Women
1. Scope of this Declaration of Principles
The standards and commitments formulated in this declaration of principles are binding for our employees throughout Germany and in all areas of the company. They oblige all employees to behave appropriately and lawfully towards colleagues, suppliers and partners.
Similarly, JUDO also obliges its suppliers to recognise the Supplier Code of Conduct published alongside this Declaration of Principles as binding and to comply with it. JUDO asks its suppliers to pass on this expectation to their own sub-suppliers and business partners. If necessary, JUDO also supports its suppliers and partners, for example by providing training, in recognising the need for action in accordance with this Code of Conduct and the Supplier Code and implementing appropriate measures.
2. Commitment to primary and fundamental human rights
Following an initial analysis of potential human rights and environmental risks in our own business area and in the business areas of our direct suppliers in 2023/2024, we are paying particular attention to the human rights described below:
2.1 Equal opportunities and equal treatment
JUDO rejects any form of unequal treatment, discrimination or harassment based on gender, ethnic origin, nationality, social background, religion, age, disability, sexual orientation and identity or other legally protected characteristics.
Instead, we promote and support all forms of diversity and inclusion in the working environment and are expressly committed to equal opportunities and equal treatment.
2.2 Forced labour and child labour
JUDO rejects any form of debt bondage or forced labour through indentured labour, slavery or prison labour and any form of human trafficking.
We also strictly reject any form of child labour. We therefore do not employ any persons who have not reached at least the legal minimum employment age. The minimum employment age determined by JUDO itself is in any case fifteen years. Persons who have not yet reached the age of eighteen also only carry out such activities under working conditions and working hours that take into account their training and education and are permissible according to the legal requirements.
2.3 Working conditions at JUDO
JUDO complies with all labour laws, in particular the regulations on rest periods, overtime, continued payment of wages in the event of illness and paid holidays. We observe the minimum wage legislation as well as the conditions and obligations of any applicable collective labour agreements. We enter into clear, comprehensible and documented employment agreements with our employees and pay remuneration on time.
We ensure that our employees are provided with a safe working environment in which the health of all employees is protected and the risk of occupational accidents and work-related illnesses is reduced. In particularly hazardous working environments (such as our production halls and warehouses), we provide protective equipment and organise regular occupational safety and accident prevention training.
2.4 Right to freedom of association and unionisation
JUDO respects the right of its employees to join or not join an employee representative body or trade union without disadvantage. We respect the right of our employees to conduct collective bargaining and to establish works councils. Employees who are active as employee representatives are neither disadvantaged nor favoured.
2.5 Privacy and data protection
JUDO respects the privacy of its employees and the confidentiality of their personal data.
3. Commitment to environmental obligations
In its business activities, JUDO assumes responsibility for the mitigation of global warming, for the avoidance and proper disposal of waste, for the reduction of air pollution and for the economical use of energy and water.
4. Risk analyses in JUDO's business area and along the supply chains
JUDO regularly conducts risk analyses on human rights and environmental risks in its own business area and along the supply chains. This is intended to identify and assess the potential and actual effects of our own business activities as well as the activities of our direct suppliers within the meaning of Section 2 (7) LkSG.
Based on an abstract risk assessment, we initially analyse industry-specific risks in our own business area and also country-specific risks in the business area of our direct suppliers. In a second step, we define priority human rights and environmental risks for those direct suppliers for which there is an increased risk disposition as part of a concrete risk analysis and analyse these in more detail. In doing so, we take into account the direct and indirect effects of our own business activities on our suppliers by analysing contractual conditions, sales volumes and opportunities to influence the actions of our suppliers. The content of these regular analyses includes all of the standards and guidelines listed at the beginning and all of the legal positions mentioned in sections 2 and 3.
The results of these risk analyses are continuously incorporated into our corporate decision-making processes and have an impact not only on our business strategies and purchasing decisions, but also on the selection of our suppliers.
5. Risk analyses as the basis for appropriate preventive and remedial measures
The risk analyses carried out form the basis for determining and developing appropriate preventive and corrective measures.
5.1 Preventive measures
By adopting internal behavioural guidelines, regularly training our own employees and continuously reviewing the suitability of our risk management objectives and measures, we enable our employees to identify and prevent risks in our own business area and in the companies of our direct suppliers and to minimise their probability of occurrence.
When selecting its direct suppliers, JUDO already takes into account the absence of human rights and environmental risks through the internal definition of purchasing practices. Through constant and open communication with direct suppliers, the formulation of requirements and expectations for direct suppliers in a supplier code of conduct and, if necessary, the performance of audits and on-site inspections by us or third parties commissioned by us, risks are recognised at an early stage and suitable preventive measures are defined in close coordination with the direct suppliers.
5.2 Remedial and restorative measures
If the risk analyses carried out show that JUDO's business activities lead to potential or actual human rights violations or give rise to such violations, JUDO will endeavour to develop appropriate remedial measures to end these violations or risks.
If human rights-related legal positions have been violated at a direct supplier, JUDO will define measures - with the establishment of a concrete timetable - to remedy these violations and prevent further violations. Future cooperation with JUDO may also be made dependent on the taking of appropriate remedial measures. In its Supplier Code of Conduct, JUDO reserves the right to contractually oblige its direct suppliers to assist in clarifying the facts of the case and to cooperate fully within a specified timeframe in order to remedy the infringements.
A continued refusal to co-operate may also result in the termination of the business relationship, as may a serious violation of protected legal positions.
6. Whistleblower centre regarding violations of the law and grievances (whistleblower portal)
JUDO attaches great importance to compliance with all applicable laws, regulations and the self-imposed compliance principles of conduct in its own behaviour and business decisions and actions at home and abroad. Our aim is to exclude any risks that could jeopardise our integrity and harm our company, our employees, business partners or third parties. In order to fulfil this responsibility, it is important that we become aware of any violations.
JUDO offers all employees and other third parties the opportunity and expressly encourages them to report any violations of the law and grievances to JUDO. If desired, they can also do so while maintaining their own identity. All reports received will be investigated immediately. Suspected cases are investigated and offences are followed up.
Information on violations of the law of any kind can be reported directly to our ombudsman. The SGP Lumen digital whistleblowing system is available for this purpose.
Within its sphere of influence, JUDO ensures that whistleblowers are not disadvantaged or penalised in connection with the information they provide.
7. Complaints procedure regarding human rights and environmental risks
Complaints regarding violations of JUDO's principles set out in this policy statement or the Supplier Code of Conduct, in particular human rights violations, illegal business practices or environmental risks, can be submitted via JUDO's complaints system. The complaints system also enables completely anonymous communication with the JUDO complaints office if desired.
Complaints, especially regarding the violation of human rights or environmental obligations within the meaning of the LkSG, can be submitted via the complaints procedure in this portal.
JUDO ensures within its own sphere of influence that complainants are not disadvantaged or sanctioned in connection with the complaint they have submitted.
If we determine that there is a risk in terms of human rights or the environment that has been caused or favoured by our business activities, we will adapt and change our business activities accordingly.
The management of JUDO Wasseraufbereitung GmbH
September 2023