Declaration of Principles on Respect for
Human Rights
Status August 2023
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1. Our commitment to respect human rights
We are aware of our corporate responsibility to respect human rights. We are therefore committed to respecting human rights in our own business activities and in our global supply and value chains, and to providing access to remedy for those affected by human rights violations.
In doing so, we align our business activities with the internationally recognized Guiding Principles on Business and Human Rights of the United Nations. We are thus guided by the requirements of the National Action Plan for Business and Human Rights applicable in Germany, as well as the laws on corporate due diligence in supply chains ("Supply Chain Due Diligence Act"). However, we would like to point out that there is currently no legal basis for this in Austria.
In addition, our understanding and human rights due diligence processes are based on the following international human rights reference instruments:
• United Nations Universal Declaration of Human Rights ((UDHR (A/RES/217, UN-Doc. 217/A-(III))
• The principles of the UN Global Compact
• The OECD Guidelines for Multinational Enterprises
• Gender dimension of the UN Guiding Principles on Business and Human Rights
• Sector-specific OECD guidelines
• The core labor standards of the International Labor Organization (ILO) with its five basic principles on freedom of association and the right to collective bargaining, the elimination of forced and child labour, the ban on discrimination in employment and occupation, and occupational health and safety
• European Convention for the Protection of Human Rights and Fundamental Freedoms
Ötscher has implemented the following human rights-related guidelines for itself and all suppliers, which are also the basis of our actions:
• Ötscher Code of Conduct
• amfori Business Social Compliance Initiative
Ötscher is also committed to the Sustainable Development Goals (SDGs) of the United Nations and has identified 4 of the SDGs as particularly important. All of our prioritized SDGs are related to human rights issues:
• SDG 5: Gender Equality
• SDG 8: Decent work and economic growth
• SDG 12: Responsible consumption and production
• SDG 13: Measures to protect the climate
We expect our business partners to also commit to respecting human rights, commit to establishing appropriate due diligence processes, and pass these expectations on to their own suppliers.
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2. Relevant human rights issues and potentially affected groups of people
We recognize that our business activities and our global supply and value chains can potentially cause adverse human rights impacts.
We are committed to respecting all internationally recognized human rights and focus our human rights due diligence processes in particular on the following human rights issues, which we have identified through a risk analysis as material for our business. These are the areas in which we see the greatest risks of negative impacts on people that are directly or indirectly related to our business activities at our sites and in our global supply and value chains:
• Forced and child labor, human trafficking
• Reasonable working hours
• Restrictions on freedom of assembly and association
• Discrimination in any form (e.g., gender, age, ethnic and social origin, nationality, religion or belief, physical or mental disability, sexual orientation)
• Threats to data protection and privacy
• Threats to health and safety at work (occupational health and safety; special protection of young workers)
• Precarious employment and working conditions
• Fair wages (at least according to state minimum wage laws or collective agreements)
• Corruption and bribery
• Restriction of access to education
• Environmental protection
In our efforts to respect human rights, we focus on the following groups of people, as their human rights are potentially at risk through business activities along our global supply and value chains:
• Our own employees at national and international locations, including trainees, temporary workers, interns and working students
• Employees of business partners
• Groups of people in our direct supply chain: employees of service providers and direct suppliers
• Groups of people in our downstream value chain: employees of customers, people in the vicinity of products and services (e.g., in the case of sponsoring)
• Groups of people irrespective of their location in the value chain: employees with contracts for work and services (within the meaning of Section 631 et seq. of the German Civil Code)
• Groups of persons with an indirect link to the value chain: members of local communities and residents in the vicinity of sites, family members, employees in public authorities.
Within these groups of people, we have identified individuals who are at higher risk of adverse human rights impacts. These are groups of people who have special needs, are socially excluded, or who find it difficult to have their concerns heard. These include:
• women
• elderly people
• sick people and people with disabilities
• groups in weak/unregulated environments
• ethnic/religious minorities
• lesbian, gay, bisexual, transgender, intersex, queer and non-binary people
• precariously or informally employed people
• people with little education or limited access to education
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3. Our approach and measures to implement human rights due diligence obligations
For us, respect for human rights is a continuous process and the implementation of human rights due diligence is subject to constant review and further development depending on changing conditions and our business activities:
To ensure respect for human rights, we have therefore embedded human rights due diligence processes as an integral part of our organization and in our relationships with our direct suppliers.
• We use an established process to identify and assess the relevant human rights issues and those potentially affected by our business activities and direct business relationships. This includes analyzing human rights risks and impacts through our services and products. To this end, we have added human rights issues to our company-wide risk and supplier management system.
• The analysis of human rights risks and impacts is updated at regular intervals and in the event of significant changes.
• The management fully supports the human rights officer (hereafter referred to as "MRB") and the complaints procedure office and supports them in their work and in initiating the necessary measures.
• In addition, we use the results as a basis for creating and, where necessary, adapting internal regulations, processes and training courses in order to take account of the changing requirements for our due diligence processes and obligations.
In order to meet our responsibility for respecting human rights, we rely on the interaction of different measures. We actively involve our employees in this. Basically, we live acceptance, inclusion and diversity.
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4. Effectiveness check
In the future, we will review our measures to prevent human rights violations at least once a year and as required. This will primarily be done through supplier evaluation and, if necessary, through supplementary supplier audits.
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5. Complaints Mechanism
We reject any form of human rights violations. For us, appropriate and effective complaints management is therefore an important part of our due diligence processes.
We have therefore set up a company complaints management system that is accessible both within (MRB) and outside of our company (complaints procedure office). It acts independently and is a neutral Conflict and Complaints Office. Employees as well as external parties have the possibility to send input to an external body via email (lueger@lucon.at) or via "anonymous contact form" (sustainability | oetscher.com), which will be mentioned publicly (e.g. on the homepage). This external body processes the submissions promptly and anonymously and determines how to proceed in consultation with the complainant. The identity of the complainant will be treated confidentially in any case. Complaints can be made in all matters, but in particular with regard to human rights violations, environmental damage and unethical business practices.
The processing of the matter raised is clarified internally without regard to the people and their hierarchical position in the company, the people involved are heard and a solution is found
brought about.
The complaints are evaluated periodically and communicated anonymously to the management every year via the management review.
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6. Workaround
We encourage all stakeholders to raise their concerns about our activities and suspected violations of our policies, including this statement. If there is a suspicion that our business activities cause or contribute to human rights abuses, we will investigate, address and respond to the concerns raised and take appropriate corrective action.
If we have concerns that our work is directly related to human rights abuses by a client, we raise our concerns with the relevant parties and seek to mitigate the impact.
If we have a reasonable suspicion or concrete indication of possible human rights violations in our company or along our upstream value chain, we investigate this carefully and consistently. We oblige our suppliers to support them in clarifying the facts and to cooperate fully within a reasonable time frame. Depending on the severity of the violation, we reserve the right to react appropriately in connection with our suppliers, from requesting immediate elimination of the violation to taking legal action and terminating the business relationship.
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7. Reporting
As an Austrian medium-sized company, Ötscher workwear is not subject to Germany's Supply Chain Due Diligence Act.
As an Austrian producer and retailer, we have made a name for ourselves since 1947 and, in addition to values such as "handshake quality", also those for top product quality, regionality, sustainability, human rights and the reduction of resources.
As a pioneer, we have therefore decided to orient ourselves to the requirements of the National Action Plan for Business and Human Rights applicable in Germany and to the law on corporate due diligence in supply chains ("Supply Chain Due Diligence Act"). However, we would like to point out that in Austria there is currently no legal basis for this, we are not subject to any reporting obligations and do not make information publicly available. These are only communicated to our business partners on request.
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8. Responsibilities for human rights due diligence in our company
We have defined clear responsibilities for exercising and complying with our human rights due diligence obligations.
The MRB is determined by the management. His/her tasks are recorded in the responsibility matrix. If necessary, the necessary steps are implemented with the responsible area of responsibility (e.g. personnel, purchasing, IT/data protection...). At least once a year, the management and the MRB agree on the tasks and activities.
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9. Training
We consider it an important part of our due diligence obligations to sensitize our employees to respect human rights and to provide them with the necessary specialist knowledge for the effective implementation of human rights due diligence processes. Appropriate measures are taken on specific occasions. This can also be training, for example.
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10. Commitment to the continuous development of our human rights due diligence processes
Respect for human rights and the implementation of human rights due diligence in our operational processes is an important contribution to improving the human rights situation. We accept this challenge and are committed to the continuous development of our human rights due diligence processes.
Ötscher workwear Götzl GmbH,
Ötscherplatz 1, A-3300 Amstetten
Phone: +43747264744-0, Fax: -48
E-mail:info@oetscher.com
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Ing.Mag. Thiemo Götzl
