Due diligence obligations
With increasing regulatory requirements for responsible and sustainable corporate governance, particularly under the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, LkSG) and the Corporate Sustainability Reporting Directive (CSRD), Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH (KVVH) considers human rights, environmental, and ethical aspects not only within its own business operations but also throughout its supply and value chains.
KVVH’s corresponding principles and expectations are set out in its Policy Statement.
To enable the reporting of potential or actual violations of the human rights, environmental, and ethical requirements set out in the Code of Conduct, KVVH has established a complaints procedure. This procedure is available for matters relating both to KVVH’s own business operations and to its supply and value chains.
KVVH ensures the confidential handling of all reports received.
These Rules of Procedure describe the responsibilities, the complaints procedure process, and the principles governing the handling and documentation of reports and complaints.
Declaration of principles of the KVVH
I. Our responsibility
We, Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH (KVVH), acknowledge our responsibility to respect human rights and protect the environment. We respect human rights and environmental concerns within our own business operations as well as throughout our value and supply chains, and we expect the same from our suppliers.
In doing so, we rely on our Code of Conduct, which defines requirements for ethical and lawful behavior. We also commit to internationally recognized standards such as the UN Guiding Principles on Business and Human Rights, the core labour standards of the International Labour Organization (ILO) and the OECD Guidelines for Multinational Enterprises.
With this Statement of Principles, we aim to provide our employees and suppliers with clear guidance for their actions, enable constructive dialogue, and build trust.
II. Implementation
Identifying risks of human rights violations and environmental harm in our supply chains and deriving effective preventive and corrective measures are part of our corporate responsibility. To fulfil our due diligence obligations on an ongoing basis, we carry out regular risk analyses relating to our own operations and our direct suppliers.
1. Risk Analysis
As part of these risk analyses, we regularly assess whether potential risks of human rights violations or environmental harm exist within our own business operations or within our supply chains. We also maintain close dialogue with our affiliated companies and other organisations within our sector.
Based on the findings of these regular risk analyses, we develop measures to prevent or mitigate potential adverse impacts within the affected value and supply chains.
2. Measures
We uphold the protection of human rights of our
employees through our corporate principles and policies, our Code of Conduct,
collective agreements, works agreements, internal procedural instructions, and
the design of our internal processes. In addition, we prevent human rights
violations through awareness‑raising and training activities. Every employee
has the opportunity to submit anonymous or personalized
reports or complaints to our LkSG reporting
office. With regard to our direct suppliers, we pursue
a partnership‑based approach to address and
improve potential shortcomings. If violations become known, our business
partners are required to remedy them immediately—ideally before any harm occurs. For the future, appropriate measures are
requested or, where necessary, implemented by us to prevent further violations.
All findings and measures are continuously integrated into our risk analyses.
Both internal and external stakeholders may report human rights or environmental concerns anonymously via lksg@kvvh.de, or submit them in writing or verbally. We ensure confidential treatment of all reports and carefully investigate every concern. Our grievance procedure is described in detail in our publicly accessible procedural guideline.
Transparent communication regarding human rights and environmental challenges is a core element of our due diligence. We regularly report on key risks, the preventive and corrective measures taken, and the progress achieved.
Our risk assessment, the measures taken, and our grievance procedure are reviewed on a regular basis. The risk assessment (including the integration of measures already implemented) is updated at least annually.
III. Entry into force
This updated Policy Statement shall enter into force upon its publication on 11.08.2026. Upon its entry into force, the previous version dated 1 January 2023 shall be superseded and shall no longer apply.
Rules of Procedure
1. Scope and purpose
These procedural rules apply to Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH (hereinafter “KVVH”) as well as to those companies within the KVVH Group over which significant influence is exerted (hereinafter “affected Group companies”) within the meaning of the German Supply Chain Due Diligence Act (hereinafter “LkSG”).
The purpose of the complaints procedure is to ensure that grievances are identified at an early stage, allowing them to be addressed before any harm occurs and enabling the implementation of suitable corrective measures.
Complaints may be submitted in relation to all human rights and environmental risks or breaches of duty as defined under Section 2 (2) and (3) LkSG.
A detailed description of the environmental, social and ethical minimum requirements established by KVVH can be found in the Group’s Code of Conduct.
2. Complaint channels
Violations of the requirements set out in the Code of Conduct may be reported orally, electronically via the e‑mail address lksgkvvhd, or in writing to the following postal address:
Karlsruher Versorgungs-, Verkehrs- und Hafen GmbH
Meldestelle nach LkSG
Daxlander Str. 72
76185 Karlsruhe, Germany
Every complaint is documented and taken seriously. All complaints and reports are treated confidentially. Protection against discrimination or punishment as a result of a complaint made in good faith is guaranteed.
3. Procedure for Handling Complaints
Receipt of the complaint is documented. After receiving the complaint, an acknowledgement of receipt is issued. Both anonymous and non‑anonymous complaints are equally protected and processed.
The responsible unit within KVVH or the affected Group company reviews the complaint and contacts the reporting person, provided the complaint was not submitted anonymously. The reporting person is informed about the next steps and the expected timeline. If applicable, information on other available complaints procedures is provided. Finally, feedback on the results of the internal review and/or any corrective measures taken is given.
If multiple complaints are received at the same time, more severe violations are prioritized.
4. Contact Person
The KVVH Group has appointed a Human Rights Officer in accordance with the requirements of the LkSG, who can be contacted via the central reporting office (see Section 2: Complaint Channels). Reports concerning actual or potential violations of the requirements set out in the Code of Conduct are treated confidentially. All submissions are reviewed, appropriately processed, and, where necessary, corrective measures are initiated.
5. Effectiveness Review
If no violations of the requirements set out in the KVVH Code of Conduct or that of its subsidiaries have been reported, an annual risk analysis is carried out, forming the basis for reviewing and, where necessary, adjusting existing preventive measures.
If violations are reported, an additional effectiveness review is conducted to assess whether the measures taken effectively contribute to risk reduction and whether further adjustments are required. Furthermore, it is ensured that insights gained from reported violations are incorporated into the next risk analysis.
6. Entry into Force
This updated procedural description shall enter into force upon its publication on 11.08.2026. Upon its entry into force, the previous version dated 1 January 2023 shall cease to be valid.
Code of Conduct
The Code of Conduct sets out KVVH’s human rights, environmental, and ethical expectations regarding the daily conduct of its employees and its collaboration with suppliers.
It establishes a common understanding of responsible conduct and serves as guidance for cooperation within KVVH and with its suppliers.
Reports of potential or actual violations of the requirements set out in the Code of Conduct may be submitted through the complaints procedure.