This code reflects Lemvigh-Müller A/S need to ensure that our suppliers and other business relations demonstrate responsible business conduct in relation to managing their potential and actual adverse impacts on internationally agreed principles for human rights (including labor rights), environment, and anti-corruption (hereinafter the principles are referred to as 'the Scope').
Managing adverse impacts is distinct from legal compliance. As a precondition, suppliers are expected to comply with national law.
Lemvigh-Müller A/S expects all suppliers to develop and implement a management system that is fully aligned with the globally agreed minimum standard (UNGP), thus to:
1. Adopt a Policy Statement:
- The Statement shall be approved by the most senior level of the supplier.
- Be informed by experts on the scope.
- Stipulate the supplier's expectations of employees and business relations on the scope.
- Be publicly available and communicated both internally and externally.
- Be reflected in other operational policies and procedures necessary to embed the policy statement throughout the supplier's operations.
2. Establish and maintain Due Diligence:
- Suppliers shall on a regular basis, identify potential and actual adverse impacts on the scope.
- Suppliers must act to prevent or mitigate the potential or actual adverse impacts identified and the track the effectiveness hereof
- Suppliers are expected to communicate their findings, actions, and tracking to relevant stakeholders, including Lemvigh-Müller A/S.
3. Provide for access to remedy:
- Where the supplier identifies that it causes or contributes to actual adverse impacts on the scope, the supplier must enable access to remedy for those affected and/or inform relevant authorities.
- The supplier shall provide access to remedy through legitimate processes (grievance mechanisms) to victims of actual adverse human rights impacts that the supplier causes or contributes to. If the supplier is merely linked to actual adverse impacts, the supplier must use or build its leverage to make the causing or contributing entity address the impacts.
Details on the scope for the required management system
The required management system shall at a minimum encompass adverse impacts on the human rights as stated in the UNGP, which includes:
- The core labor rights from the International Labor Organisation's Code of Conduct on Fundamental Principles and Rights at Work
- Significant potential and actual adverse impacts on the external environment in relation to the areas addressed by the principles in the Rio Declaration on Environment and Development
- Adverse impacts in relation to the scope outlined by the United Nations Convention against Corruption.
- As applicable, responsible Supply Chains regarding Minerals from Conflict-Affected and High-Risk Areas (Conflict mineral, also known as 3TG) as defined in H.R. 4173, the Wall Street Reform and Consumer Protection Act Dodd Frank Section 1502. For more information see: Lemvigh-Müller conflict minerals policy.
Implementation and Collaboration
This Code applies to Lemvigh-Müller A/S first-tier suppliers. Suppliers shall ensure that its first-tier suppliers have adequate processes in place to manage their adverse impacts on the scope. As part of this obligation, suppliers must make their first-tier suppliers aware of the scope and processes outlined in the Code and pose similar requirements to such suppliers.
Suppliers must maintain appropriate records to demonstrate compliance with the requirements of this Code. Appropriate records include, but are not limited to:
- Policy Commitment(s)
- Documentation of due diligence processes, including impact assessments
- Records from the tracking process on specific actions; and information on grievance mechanisms.
Should the supplier at the time of signage, not have implemented a management system as per requirement with this code, a implementation plan should be presented.
Lemvigh-Müller A/S expects all relationships, to at any time, be able to declare in writing their stage of implementation.
Suppliers shall cooperate in answering further questions, self-assessments, and if deemed necessary cooperate with Lemvigh-Müller A/S in addressing specific impacts. lf necessary, suppliers must accommodate visits from Lemvigh-Müller A/S to assert compliance, including providing for physical access to any representative from Lemvigh-Müller A/S or designated independent third parties.
lf Lemvigh-Müller A/S supplier causes, contributes or is linked to severe impacts the supplier shall notify Lemvigh-Müller A/S immediately, accounting for the supplier's actions to end, prevent or mitigate the re-occurrence of the severe impacts.
By non-compliance, suppliers must self-correct within a fixed period. Failure to notify about severe impacts, to self-correct or demonstrate willingness to address identified adverse impacts, Lemvigh-Müller A/S reserves the right to end the business relationship immediately.