Supply Chain Due Diligence Act (LkSG)

With the introduction of the Supply Chain Due Diligence Act (LkSG), the legislator has created a concrete framework for responsible and sustainable value creation in supply chains. As the holding company Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH (KVVH), we fulfil the requirements of the LkSG. Details on this can be found in the policy statement.

KVVH has set up a complaints procedure to ensure that the LkSG is complied with in our own business area and in our supply chains. Complaints and indications of human rights and environmental risks as well as violations of human rights or environmental obligations can be reported there. Further information on this can be found in the rules of procedure.

Declaration of principles
Rules ofProcedure
Declaration of principles

Declaration of principles of the KVVH

I. Our responsibility 
II. Implementation
III. Entry into force

I. Our responsibility

We, Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH, are aware of our responsibility to respect human rights and protect the environment. We respect human rights and environmental concerns both in our own business operations and in our value and supply chains and expect the same from our suppliers.

With this declaration of principles, we want to give our employees and business partners clear guidance for their actions, facilitate constructive dialogue and create trust.

II. Implementation

It is our corporate responsibility to identify risks of human rights violations and environmental damage in our supply chains and to derive effective preventive and countermeasures. In order to live up to our responsibility and fulfil our due diligence obligations in the long term, we carry out regular risk analyses with regard to our own company and our direct business partners.

1. risk analyses

As part of our risk analyses, we regularly check whether there are risks of human rights violations and environmental damage in our own business area or in our supply chains. Business partners, products and services are classified according to risk based on analyses of countries of origin and raw materials, among other things. We also liaise closely with our affiliated companies and other companies in our industry.

Based on the findings from the regular risk analyses, we develop specific measures to prevent or minimise any adverse effects of our business activities on human rights and the environment. We pay particular attention to the payment of appropriate wages, the observance of appropriate working hours, the avoidance of discrimination, the protection of freedom of association (the right of employees and employers to join together to protect and promote working and economic conditions) and occupational health and safety.

2. measures

We take the protection of our employees' human rights into account in our corporate principles and guidelines, collective labour agreements, works agreements, internal procedural instructions and in the design of our internal processes. We also prevent human rights violations by raising awareness and providing information in the form of training. Every employee has the opportunity to submit anonymous or personalised reports or complaints to our reporting office in accordance with the LkSG.

With our direct business partners, we are committed to working in partnership to improve any shortcomings. Any violations of which we become aware are rectified immediately, if possible before any damage occurs. Suitable measures are taken to prevent further offences in the future. The findings and the measures taken are integrated into our risk analyses on an ongoing basis.

We offer both internal and external whistleblowers the opportunity to report human rights violations or environmental damage anonymously or non-anonymously via the e-mail address as well as in writing or verbally. We guarantee confidential treatment and investigate every report conscientiously. Our complaints procedure is described in detail in our publicly accessible rules of procedure.

Transparent communication of human rights and environmental challenges is a core element of our corporate due diligence. We regularly report on material risks, preventive and countermeasures taken and progress made.

Our risk assessment, the measures taken and our complaints procedure are regularly reviewed and subjected to an effectiveness check at least once a year.

III. Entry into force

This policy statement comes into force on January, 1 st , 2023.

Rules ofProcedure

Rules of Procedure Complaints Procedure

1. Scope and purpose

These Rules of Procedure apply to Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH (hereinafter referred to as KVVH) as well as to the companies in the KVVH Group over which decisive influence is exercised within the meaning of the Supply Chain Due Diligence Act (hereinafter referred to as "LkSG") (hereinafter referred to as "affected Group companies").

The aim of the complaints procedure is to be made aware of grievances at an early stage in order to be able to avert them as far as possible before the damage occurs and to be able to take appropriate remedial measures.

Complaints can be filed in relation to all human rights and environmental risks or breaches of duty in accordance with § 2 (2) and (3) LkSG.

The Rules of Procedure are published in their present form on the homepage of the KVVH ( and can be made available on request.

2. Complaint channels

Complaints on the above topics can be made orally, electronically to the e-mail address lksgkvvhd or in writing to the postal address Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH, Meldestelle nach LkSG, Daxlander Str. 72, 76185 Karlsruhe. Every complaint is documented and taken seriously. All complaints and reports will be treated confidentially. Protection against discrimination and punishment based on a complaint based on good faith is guaranteed.

3. Procedure of the complaint procedure

The receipt of the complaint will be documented. Upon receipt of the complaint, an acknowledgement of receipt will be issued. Both anonymous and non-anonymous complaints are equally protected and dealt with. The competent office of KVVH or the affected group company will examine the complaint and contact the whistleblower, unless the complaint was made anonymously. The whistleblower is informed about the next steps and the expected time frame. If necessary, attention will be drawn to the possibility of other complaint procedures. Finally, feedback is provided on the outcome of the internal audit and/or on the corrective actions taken as a result.

If several complaints are received at the same time, more serious breaches of duty will be treated with priority.

4. Contact person

The responsible contact person for all information and complaints is the reporting office according to LkSG of the KVVH.

5. Efficacy control

The complaints procedure is continuously revised and subject to an effectiveness review at least annually.

In addition, findings from regular risk analysis are included.

6. Entry into force

These Rules of Procedure shall enter into force on January 1 st , 2023.


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