Veonet GmbH and its subsidiaries the eyescan Group in the Netherlands, the Miranza Group in Spain, the Ober Scharrer Group in Germany, the SpaMedica Group in the UK, the Veonet Ireland Group and the Vista Group in Switzerland, (the “Company” or “we”) is committed to an ecologically and socially responsible corporate management. We strive to optimize our business activities and our services in terms of sustainability and ask our suppliers to contribute to this in terms of a holistic approach. In connection with the continuing cooperation, the Company and its suppliers (each a “Supplier”) agree on the validity of the following regulations for a joint code of conduct (the “Supplier Code of Conduct”). The Supplier Code of Conduct shall be the basis for all future deliveries. The Supplier undertakes to comply with the principles and requirements of the Supplier Code of Conduct. A breach of this Supplier Code of Conduct may be grounds and cause for the Company to terminate the business relationship, including all related supply contracts.
The Supplier Code of Conduct is based on the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – “LkSG”) and, in accordance with § 2 LkSG, on national laws and regulations as well as international conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children's Rights and Business Conduct, the United Nations Guiding Principles on Business and Human Rights, the international labor standards of the International Labor Organization, and the United Nations Global Compact. We expect our suppliers to be in compliance with the obligations laid down in the LkSG, especially to exercise due diligence with regard to human rights and the environment with the aim of preventing or minimizing human rights or environmental risks or ending violations of human rights or environmental obligations. Formal reporting obligations under the LkSG apply only to the extent they are in force and applicable under current law; the Supplier’s substantive due diligence duties—including risk identification, prevention and remediation measures, and adherence to the prohibitions listed below—remain unaffected.
Furthermore, following the entry into force of the Corporate Sustainability Reporting Directive (“CSRD”) in the EU on 5 January 2023, we expect our suppliers to be in compliance with the obligations set forth in the directive, insofar and as soon as the Supplier falls within its scope under applicable law and within the relevant implementation timelines. For the avoidance of doubt, the Supplier’s material human rights and environmental due diligence obligations pursuant to the LkSG continue to apply irrespective of any temporary suspension or deferral of formal reporting requirements under applicable law.
The obligations laid down in the LkSG with regard to human rights and the environment are especially the following ones:
Further Requirements for Suppliers: Subcontractors
Supplier complies with the previously articulated requirements and standards within its supply chain by engaging and evaluating its contractors in a consistent manner.
The Supplier complies with all applicable laws and regulations, especially regarding the management of its supply chains. This applies, among other things, to all social and environmental due diligence obligations as well as specific requirements, such as the LkSG and the CSRD. This includes establishing and maintaining risk‑based management systems that are appropriate and proportionate to the Supplier’s risk exposure and size, taking into account the applicability of relevant legal requirements.
The Supplier respects the prohibitions laid down in § 2 para. 2 no. 9–11 LkSG as well as the associated economic, social and ecological concerns of local residents in the area of its operations or production sites.
The Supplier does not tolerate any kind of corruption, bribery or extortion, nor does it participate in any form. This also includes any illegal offers of payment or similar benefits to public officials in order to influence their decision-making. Our employees will not be offered gifts or personal benefits that could be construed as a bribe. In no case will gifts or entertainment be offered to improperly influence a business relationship or in violation of applicable law or ethical standards.
The Supplier shall comply with all applicable anti-money laundering laws and implement the measures required by law to prevent money laundering. We only accept funds from legitimate sources.
The Supplier shall disclose all sustainability data that we reasonably require as part of our risk analysis and for preventive and remedial measures under applicable law, limited to what is necessary and proportionate for these purposes. The Supplier shall prepare and publish sustainability reports in accordance with the CSRD and other applicable legal requirements insofar, and as soon as the Supplier falls within their scope under applicable law and within the relevant implementation timelines; until then, the Supplier shall, upon reasonable request, provide the information necessary for our risk analysis and due diligence processes. Any assurance of sustainability reporting shall correspond to the level required by applicable law (e.g., limited assurance) or to prevailing market practice once applicable. Accordingly, the obligation to obtain a confirmation by a “certified third‑party CSRD rating service” shall be deemed satisfied by the legally required assurance or equivalent audit services. Reports and assurance statements shall be provided to the Company upon reasonable request.
Supplier shall encourage and provide a means for employees (which shall include confidential reporting options) to report concerns, complaints, or potentially unlawful activities in the workplace or business activities without threat of reprisal, intimidation, or harassment. The Supplier shall investigate such reports and take corrective action as necessary. To ensure that no occurrence goes unnoticed and that everyone involved is given the opportunity to report any misconduct, business concerns or potential violations of this Code of Conduct may be reported to the Company without any fear of retaliation through the form provided on the website. These reporting and investigation mechanisms operate irrespective of external reporting cycles and are designed to support effective due diligence at all times.
We expect our suppliers to implement management systems to meet the obligations stipulated herein, to identify risks within their supply chains and to take appropriate measures. In the event of suspected violations and to safeguard supply chains with increased risks, the Company may at any time require disclosure of the supply chains (including a complete representation of the supply chain (supply chain mapping) through to the source); such requests will be risk‑based and proportionate to the underlying concerns and applicable legal requirements. The Company reserves the right to take appropriate measures against suppliers who do not meet these requirements, which may ultimately lead to the suspension or termination of a supply relationship.
References in this Code of Conduct to specific laws or regulations (including the LkSG and the CSRD) shall be interpreted in line with their respective applicability and implementation timelines under current law. Where formal reporting obligations are temporarily suspended, deferred, or not yet applicable, the Supplier remains obligated to comply with the substantive due diligence duties and to provide, upon reasonable request, the information necessary for our risk analysis, prevention and remedial measures.
