Compliance Management at LINNEMANN helps to avoid violations of rules. According to the ISO 37301 standard, LINNEMANN's compliance management system is based on the 5 recommended pillars.
At LINNEMANN, we recognized the requirements. Targets were set and responsibility was not left with a compliance officer to deal with, but every team member was informed and trained. Everyone actively cooperates.
By way of example and without priority, we describe below the topics listed in the Compliance Management System that accompany us in our daily work. This continuity ensures awareness, compliance, review and improvement. In this way, breaches of the rules can be efficiently avoided.
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CDA – Confidentiality agreement
Confidentiality agreements are not subject to legal regulation. LINNEMANN GmbH has formulated a description for business partners and customers on the observance of confidentiality, communicated it to the team and makes this internal description available for commitment in case of inquiries e.g. on a NDA - Non disclosure agreement. Care has been taken to ensure that the commitments to maintain confidentiality are tenable.
Code of Conduct
The interaction with each other, the interaction with partners and customers is regulated and described at LINNEMANN GmbH. Some of the principles and the agreed behavior are described in the mission statement. The Code of Conduct is interlinked in the Compliance Management System, e.g. with the Supply Chain Sourcing Act. The code stipulates that child labor is not permitted, and the analyses of the supply chains detect such violations.
Compliance Risk Management
Within the framework of the Compliance Risk Assessment, LINNEMANN carries out risk analyses as part of its risk management, identifies, assesses and communicates how any hazards can be countered.
Conflict Minerals - Section 1502 of the US Dodd-Frank Act.
The term "conflict minerals" under section 1502(e)(4) includes the four chemical elements tin, tantalum, tungsten, and gold, also called 3TGs, that originate in a particular part of the world where there is conflict affecting the mining and trade of these minerals.
LINNEMANN GmbH is aware of its social responsibility regarding environment, safety, health and human rights. Even though Linnemann GmbH is not subject to the reporting requirements of the Dodd-Frank Act, a survey of the entire supply chain is carried out once a year on a voluntary basis and a CMRT (Conflict Minerals Reporting Template) for the previous fiscal year is made available to our customers.
Current changes in the status of smelters cannot be considered, but will be reviewed and considered in subsequent CMRT reporting.
Via the following link you can download our currently valid CMRT version 6.22.
» Download PDF
Smelter list
» Download PDF
Crisis management
Crises do not announce themselves. Crises can have internal and external causes. In order to be able to continue to proceed in a structured manner in the event of a crisis, LINNEMANN GmbH has defined indicators and procedures for various scenarios.
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REACh - Regulation (EC) 1907/2006
On June 1, 2007, Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (in short: "REACh") came into force. As a downstream user and distributor of articles, the company Linnemann GmbH is not obliged to register chemicals.
According to Art. 33 of the REACh regulation, the company Linnemann is subject to the obligation to pass on information about substances in articles, if one of the delivered products contains a substance of very high concern (SVHC) in a mass concentration above 0.1%.
The list of SVHC substances is maintained by the European Chemicals Agency (ECHA) and can be viewed at the following link https://echa.europa.eu/de/candidate-list-table.
LINNEMANN GmbH would like to inform its customers that, with the exceptions listed below, none of the products contains a SVHC with a mass concentration above 0.1%.
None of the products contains any of the substances subject to authorization listed in Annex XIV.
The prohibitions on the use of substances in accordance with Annex XVII are also observed and complied with.
Products with SVHC:
RoHS - EU Directive 2011/65/EU with amendment 2015/863/EU
The EU Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment, known as RoHS for short, was transposed into German law in 2013 by the ElektroStoffV and comprises 6 substances. In 2015, the list of regulated substances was extended by another 4 substances through the delegated directive 2015/863/EU.
Substances regulated in Annex II of the RoHS Directive with concentration limits in homogeneous materials in percent by weight:
| • Lead | 0,1% |
| • Mercury | 0,1% |
| • Cadmium | 0,01% |
| • Hexavalent chromium | 0,1% |
| • Polybrominated biphenyls (PBB) | 0,1% |
| • Polybrominated diphenyl ethers (PBDE) | 0,1% |
| • Butyl benzyl phthalate (BBP) | 0,1% |
| • Dibutyl phthalate (DBP) | 0,1% |
| • Diisobutyl phthalate (DIBP) | 0,1% |
LINNEMANN GmbH confirms that all products comply with the requirements of the RoHS Directive. The following products use one or more exemptions according to Annex III:
