In this context we are also committed to our obligations under the UK Modern Slavery Act. Below you will find the declaration of our company, SGL Carbon Fibers Ltd. It is made in accordance with section 54 of the Modern Slavery Act 2015 and describes the steps taken to prevent slavery and human trafficking in our own operations and in the supply chain.
The Global Purchasing department is responsible for implementing and applying the Supplier Code of Conduct, which was introduced in 2015 and is enshrined in SGL Carbon's General Purchasing Terms and Conditions. As part of the phased roll-out, the code was distributed to selected risk-relevant target groups based on their share of the annual purchasing volume. We also ask new suppliers that are entered into SGL Carbon's systems to sign the code and our purchasing guideline as part of the contract documents, or to show that they have equivalent compliance standards in place.
Global trade program
SGL Carbon has production sites in numerous countries and delivers products to customers around the world, which is why the avoidance of risks in connection with trade activities and customs regulations is of critical importance. These risks include potential supply problems, fines, criminal activity, and the evasion of taxes, customs duties, and other levies. Through our compliance processes, we aim to ensure that the exchange of goods and technology and the use of services occurs in accordance with the respective internal and external requirements. This principle is laid down in our group-wide global trade policy, as are our procedures for preparing, optimizing, and carrying out all trading activities, for control mechanisms, and for managing and monitoring risks and responsibilities.
Our export managers and export control delegates are responsible for export controls in our legal entities and units. Our compliance program for export control has been working with an SAP-based compliance module and supports the efficient monitoring of export transactions.
