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.
California Proposition 65 Reporting
The California "Safe Drinking Water and Toxic Enforcement Act", better known as California Proposition 65, is a California law from 1986 and affects all companies that market products in this US state. The list of substances and compounds to be declared is supplemented from time to time and currently comprises around 2000 chemical substances. Further background information can be found at:
LINNEMANN GmbH has written to all suppliers and compiled information in order to be able to provide companies that maintain business relations in the state of California with corresponding information. LINNEMANN GmbH is expected to add detailed information at this point until the 01.07.2023.
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.
China RoHS II
Linnemann GmbH hereby confirms that all its products comply with the directive GB/T 26572-2011 also known as China RoHS II. Linnemann does not supply products directly to the People's Republic of China. Likewise, Linnemann GmbH confirms conformity according to Directive SJ/T 11363-2014 on mandatory labeling of toxic and hazardous substances in electronic products
Regulated substances and limits:
- Lead (Pb) 0.1 %
- Cadmium (Cd) 0.01 %
- Mercury (Hg) 0.1 %
- Hexavalent chromium (Cr+6) 0.1 %
- Polybrominated biphenyls (PBB) 0.1 %
- Polybrominated diphenyl ethers (PBDE) 0.1 %
Linnemann GmbH confirms that all products comply with China RoHS II with the exception of the products listed below:
It should be noted that only electrical and electronic end products must be provided with the appropriate labeling. Linnemann Gmbh does not supply electrical and electronic products and therefore does not have to provide any labeling, but does provide its customers with the necessary information for final labeling.
Code of Conduct
The cross-sector Code of Conduct describes principles and standards of behavior relevant to the mechanical and plant engineering industry as well as the electrical and digital industries that responsible companies must observe in order to act responsibly.
A comprehensive description of the recommendations is provided by ZVEI (German Electrical and Digital Manufacturers' Association) and VDMA (German Engineering Federation) in the document.
» Download PDF – ZVEI-VDMA-Code-of-Conduct-2022-01-en.pdf
LINNEMANN GmbH applies the Code of Conduct as described in this document.
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
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.
EMRT - Extended Mineral Reporting Template
The Extended Minerals Reporting Template (EMRT) is a report built by the Responsible Minerals Initiative. It is used to fulfill the Sorfaltspflicht for cobalt and mica supply chain identification and information. The template for this was introduced on October 20, 2021.
Via the following link you can download our currently valid EMRT version 1.11.
» Download PDF – LINNEMANN-GmbH_RMI_EMRT_11_230328 Declaration.pdf
» Download PDF – LINNEMANN-GmbH_RMI_EMRT_11_230328_Smelter.pdf
EU POP Regulation
On July 15, 2019, Regulation (EU) 2019/1021 on persistent organic pollutants (POPs) entered into force. It is essentially an editorial revision of the previous Regulation (EC) No. 850/2004, which has undergone numerous amendments in the past. The new regulation introduced a concentration limit for the substance decabromodiphenyl ether (DecaBDE), which is used as a flame retardant, for the first time. A cumulative limit of 1,000 mg/kg now applies to it and the four other polybrominated diphenyl ethers (PBDEs) tetra-, penta-, hexa- and heptabromodiphenyl ether. The list of POPs that fall under the scope of the regulation is extended with substances at regular intervals.
LINNEMANN GmbH is expected to add detailed information at this point until the 01.07.2023.
Cultural management at LINNEMANN GmbH is characterized by a self-image that includes various principles such as values, attitudes, responsibility and environmental awareness.
The company philosophy also includes practiced connectivity. The team develops its strength from the totality. Functioning communication channels are an important prerequisite here. Digitization, networking and communication platforms such as feedback and team meetings are available and used at LINNEMANN GmbH.
Read about self-image and values in the LINNEMANN GmbH Mission Statement.
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:
|• 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:
Supply Chain Sourcing Obligations Law
The Supply Chain Due Diligence Act obliges companies with their head office, principal place of business, administrative headquarters, statutory seat or branch office in Germany to respect human rights by implementing defined due diligence requirements. The core elements of the due diligence obligations include the establishment of a risk management system to identify, prevent or minimize the risks of human rights violations and damage to the environment. The law outlines what prevention and remediation measures are necessary, obligates complaint procedures and regular reporting. ▪ The due diligence obligations apply to a company's own business operations, to the actions of a contractual partner, and to the actions of other (indirect) suppliers. This means that companies' responsibility no longer ends at their own factory gate, but exists along the entire supply chains. The law will initially apply to companies with at least 3,000 employees in Germany from 2023, and from 2024 also to companies with at least 1,000 employees. The Supply Chain Act contains an exhaustive catalog of eleven internationally recognized human rights conventions. From the legal rights protected in these conventions, behavioral requirements and prohibitions for corporate action are derived in order to prevent the violation of protected legal positions. These include, in particular, the prohibition of child labor, slavery and forced labor, the disregard of occupational health and safety, the withholding of an appropriate wage, the disregard of the right to form trade unions or employee representatives, the denial of access to food and water, and the unlawful deprivation of land and livelihoods.
LINNEMANN GmbH has taken advantage of the offer of the German government to integrate human rights due diligence processes via the „Helpdesk On Business & Human Rights“ and has both taken the necessary measures and instructed the LINNEMANN team and pointed out the due diligence obligations to business partners.
LINNEMANN GmbH applies the supply chain due diligence as described in the Code of Conduct.
TSCA Section 6(h)
Through the U.S. Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency (EPA) has taken accelerated action on five persistent, bioaccumulative, and toxic (PBT) chemicals and implemented a rule to regulate them on January 6, 2021. Specifically, the following chemical substances have been banned or significantly restricted from the manufacture, processing and distribution of these persistent, bioaccumulative and toxic chemicals.
- PIP (3:1) – phenol, isopropylated phosphate (3:1) (CAS 68937-41-7)
- DecaBDE – decabromodiphenyl ether (CAS 1163-19-5)
- HCBD – hexachlorobutadiene (CAS 87-68-3)
- PCTP – pentachlorothiophenol (CAS 133-49-3)
- TTBP – 2,4,6-tris(tert-butyl)phenol (CAS 732-26-3)
Further information can be found at:
LINNEMANN GmbH is expected to add detailed information at this point until the 01.07.2023.