Über uns

UK Modern Slavery Act 2015

INTRODUCTION

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Arvos Ljungström, a division of the ARVOS Group (“LJUNGSTRÖM”), is committed to combat slavery and human trafficking.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending on March 31, 2022 and was approved by the Executive Board of the ARVOS Group on September 24, 2021.

 

ORGANISATIONAL STRUCTURE

LJUNGSTRÖM is a global technology and innovation leader, specializing in full life-cycle services and solutions for thermal power plants and industrial facilities. With a history of heat recovery advances spanning 95 years, LJUNGSTRÖM is redefining clean thermal power technologies through its deep customer and technical knowledge, worldwide.

LJUNGSTRÖM serves the thermal power plant market with three key applications: air preheaters, gas-g​as heaters and AdvX™, based on our genuine Ljungström® technology platform.

LJUNGSTRÖM has under 700 employees in the USA, Germany, India, Japan, China and the Czech Republic, with approximately 30% in the USA.

 

OUR SUPPLY CHAINS

Our supply chains include procurement of steel, construction and erection services, manufacturing of machined and non-machined small and major metal parts to be integrated into our products and services. Steel purchases, primarily in the USA and Canada, account for a large portion of LJUNGSTRÖM’s total supply chain spends. Although we believe that there is limited incidence of modern slavery and human trafficking in the steel industry, especially in the United States and Canada, we remain extra vigilant in our developing countries where modern slavery and human trafficking are more prevalent.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free, we have established a number of provisions in our Group’s Code of Conduct and in our Group’s Sourcing Policy to wit, in pertinent part:

 

16. Human Rights, Employment and Work Safety

Human Rights: ARVOS respects and supports the protection of internationally proclaimed human rights in line with the United Nations Universal Declaration of Human Rights.

International Labor Organization (ILO): ARVOS supports the principles laid down in the ILO’s Declaration on Fundamental Principles and Rights at Work. It supports the work of the ILO in formulating and enforcing international labor and social standards and creating work in conditions of human dignity as a core requirement for combating poverty.

Freedom of Association: ARVOS acknowledges and promotes the freedom of association and the right of workers to collective bargaining within the bounds of prevailing laws and statutes. ARVOS ensures that union representatives are not discriminated against.

Forced Labor: ARVOS does not tolerate any form of forced or compulsory labor.

Human Trafficking: ARVOS does not tolerate or condone or engage in any form of human trafficking or slavery in any part of its global organization.

Child Labor: ARVOS supports the elimination of exploitative child labor. It employs only workers who are at least 15 years, or if a higher age limit applies in the country, then this age limit is complied with.

ARVOS accepts only a minimum age of 14 years by way of an exception, if a statutory minimum age of 14 years applies in the country in which the work is being performed. ARVOS commits to complying with the Convention concerning the minimum age for admission to employment (Convention No 138 of the International Labour Organization) as well as the Convention concerning the prohibition and immediate action for the elimination of the worst forms of child labor (Convention No 182 of the International Labour Organization). If a national regulation concerning child labor provides for stricter measures, these shall have precedence.

Equal Employment Opportunities: ARVOS observes all regulations in the relevant countries providing for equal employment opportunities and does not tolerate any illegal discriminatory treatment of its Employees, unless national law expressly provides for selection according to specific criteria. It hires, compensates and promotes Employees on the basis of their qualifications and performance.

 

1. LABOR

ARVOS‘ Suppliers and Contractors shall in particular comply with the following:

• Elimination of all forms of illegal, forced, or compulsory labor, including direct or indirect use of labor generated by humantrafficking
• Elimination of child labor: Suppliers and Contractors shall not employ persons not having reached the minimum age required for work and shall never support the use of child labor, except as part of an official government approved educational youth training scheme
• Elimination of discrimination of any kind in respect of employment and occupation
• Compliance with applicable laws and regulations related to maximum working hours and minimum days of rest
• Compliance with applicable laws and regulations related to the minimum level of wage
• Respect for freedom of association for their employees, in compliance with applicable laws
• Compliance with applicable laws and regulations related to

Those Sections demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

 

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk we have nominated the responsible heads of supply chain of the purchasing business units and the heads other purchasing functions, who report to the Group Management who in turn reports to the Group’s Risk Management Function.

As part of our initiative to identify and mitigate risk we have made accountable the responsible LJUNGSTRÖM heads of supply chain to report any issues pertaining to modern slavery and human trafficking to the ARVOS Group Management, who in turn report any issues to the Group’s Risk Management Function for immediate action and remediation.

LJUNGSTRÖM reserves the right to audit our business partners and our supply chains to help:

• Identify and assess potential risk areas in our supply chains.
• Identify inappropriate employment practices.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers, including a world class anonymous whistle blower procedure.

SUPPLIER ADHERENCE TO OUR VALUES

At LJUNGSTRÖM we have zero tolerance for slavery and human trafficking. To ensure that all those in our supply chain and contractors comply with our values, we operate in line with principles of responsible sourcing, including paying employees at the prevailing minimum wage applicable within their relevant county of operations. Also, we have in place a compliance programme, which is designed to require our suppliers and other business partners to confirm adherence to the principles set forth above or to, at least, demonstrate that they have equivalent principles and policies in place (self-certification).

SCHULUNGEN

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff as part of our overall Compliance Trainings. This includes all employees in a live session conducted at least every other year on adherence to our Code of Conduct.

GOING FORWARD

Going forward, we will continue to be vigilant in this area and intend to increase our training and enforcement efforts in the LUNGSTRÖM division in developing countries where modern slavery and human trafficking have had the highest incidence.

Arvos Ljungstrom, a division of the ARVOS Group

Chattanooga, Tennessee U.S.A.
September 27, 2021
David Breckinridge, President

 

 

 

DATA PROTECTION DECLARATION

 

1. INFORMATION REGARDING THE COLLECTION OF PERSONAL DATA

1.1 Below, we will provide you with information about the collection of personal data in the case of conclusion of an employment contract as a client, professional company, supplier, business partner, or other contractual partner (for example, as part of an application or employment relationship) or when using our website. Personal data pertains to all data traceable to you personally, such as name, address, email addresses, user behavior. Personal data pertains to all data traceable to you personally, such as name, address, email addresses, user behavior.

1.2. The responsible party as per Art. 4 (7) EU General Data Protection Regulation (GDPR) and other national data protection laws in the member states as well as other legal provisions related to data protection is:

Arvos Ljungstrom LLC
LJUNGSTRÖM
3020 Truax Road, PO Box 372
Wellsville, NY 14895, USA
Tel.: +1 585 593 2700
President: David Breckinridge
E-Mail: [email protected]

1.3. When you contact us via post, telephone, email or contact form, the information you provide (your email address, your name and your telephone number, if applicable) will be stored by us to answer your questions. We delete the data gathered in this context once its storage is no longer necessary or we restrict its processing should statutory retention obligations exist. Furthermore, we collect and use personal data of the data subjects and users of our website only – among others, to provide a functioning website – as far as this is necessary in the context of our contents and services or in the context of a contract fulfillment. The collection and use of personal data from the data subjects and users of our website can generally only take place once consent has been granted by the users. An exception applies in cases where prior consent cannot be given for practical reasons and/or the processing of the data is permitted by legal regulations.

1.4. Should we wish to make use of subcontracted service providers for individual features of our offer, or use your information for promotional purposes, we will subsequently inform you about the respective processes in detail. In doing so we will also indicate the fixed criteria for the storage period. In doing so we will also indicate the fixed criteria for the storage period.

 

2. YOUR RIGHTS – LEGAL GROUNDS

2.1. You have the following rights in relation to us with regards to your personal data:

• Right to access
• Right to rectification or erasure
• Right to restriction of processing
• Right to objection to processing
• Right to data transferability

2.2. You also have the right to complain about our processing of your personal data to a data protection monitoring body.

2.3. Where we obtain consent from the data subject for processing personal data, Art. 6 (1)(a) GDPR provides the legal grounds for the processing of personal data. When processing personal data required for the performance of a contract in which the data subject is a contracting party, Art. 6 (1)(b) GDPR provides the legal grounds. This also applies to processing procedures required for the implementation of pre-contractual measures. Where the processing of personal data is required for compliance with a legal obligation to which our company is subject, Art. 6 (1)(c) GDPR provides the legal grounds. In the case that the vital interests of the data subject or another natural person render the processing of personal data necessary, Art. 6 (1)(d) GDPR provides the legal grounds. If the processing is required to safeguard a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-named interests, Art. 6 (1)(f) GDPR provides the legal grounds for processing.

 

3. COLLECTION OF PERSONAL DATA WHEN VISITING OUR WEBSITE

3.1. In the event of purely informational use of the website, i.e., if you don’t register or otherwise provide us with information, we will only collect the personal data that your browser transfers to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to show you our website and to ensure stability and security (legal grounds Art. 6 (1) Clause 1 (f) GDPR):

• IP address
• Date and time of the request
• Time Zone Difference to Coordinated Universal Time (UTC)
• Content of the request (specific page)
• Access status/http status code
• Each transmitted quantity of data
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software.

3.2. In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive and assigned to the browser that you are using and allow the site that sets the cookie (here ours) to receive certain information. Cookies cannot run programs or transfer viruses to your computer. They serve to make the internet experience more user-friendly and effective overall.

3.3. Use of cookies:

3.3.1. This website uses the following types of cookies, the scope and operation of which are explained below:

• Transient Cookies (for this 3.3.2.)
• Persistent Cookies (for this 3.3.3.)

3.3.2. Transient cookies are automatically deleted when you close the browser. In particular, these include the session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This will allow your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

3.3.3. Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

3.3.4. You can configure your browser settings according to your wishes and, for example, reject the acceptance of third-party cookies or all cookies. Please be aware that you may not be able to use all features of this website.

3.4. All data is deleted as soon as it is no longer required to fulfill the purpose of its collection. If the data is collected for the provision of the website, this is the case when the respective session is completed.

3.5. If the data is stored in log files, this is the case after seven days at the latest. Further storage is possible. The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

 

4. OTHER FEATURES AND OFFERS OF OUR WEBSITE – EXTERNAL SERVICE PROVIDERS

4.1. In addition to the purely informative use of our website, we offer various services that you may be interested in using. To do this, you will generally need to provide other personal information that we use to provide the service and for which the aforementioned data processing principles apply.

4.2. In some instances, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are audited regularly.

4.3. Where our service providers or partners have their headquarters in a state outside of the European Economic Area (EEA), we will inform you about the circumstances.

 

5. OBJECTION TO OR REVOCATION OF THE PROCESSING OF YOUR DATA

5.1. Should you have granted consent for the processing of your data you may modify or completely revoke this at any time without providing reasons. You can send this revocation to us (see Clause 1.2. – Responsible Party) by post, email, fax, or in the form that was used when issuing the declaration of consent. No extra costs are incurred in such cases, other than postage costs or transmission costs in accordance with existing basic tariffs.

Such a revocation will impact the legitimacy of the processing of your personal data once you have sent it to us.

5.2. Where we support the processing of your personal data by referring to the balance of interests you can submit an objection to the processing. This is the case in particular if we do not require the processing to fulfill a contract with you. In the case of the following website uses, this will be additionally shown by us in the following description of the function. When exercising such an objection we ask that you provide the reasons for which we should not have processed your personal data as we have done. In the case that you provide an objection with reasons we will examine the situation and will either adjust or modify the data processing or indicate to you the mandatory reasons for continuing with the processing.

5.3. Of course, you may object to the processing of your personal data for marketing and data analysis purposes at any time. You may inform us about your objections to marketing by contacting us using the following contact information: [email protected]

 

6. USE OF GOOGLE ANALYTICS

6.1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, due to the activation of IP anonymisation on this website, your IP address will be shortened by Google beforehand within member states of the European Union or another contracting state of the Agreement on the European Economic Area (EEA). The full IP address will only be sent to a Google server in the US and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website usage and internet usage to the website operator.

6.2. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

6.3. You can prevent the storage of cookies with corresponding settings for your browser software; however, we point out that in this case you may not be able to use all features of this website in full. You may also prevent Google’s collection of data (including your IP address) generated by the cookie from your use of the website from Google and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

6.4. This website uses Google Analytics with the extension “_anonymizeIp()”. As a result, IP addresses are processed in a shortened form; a direct personal reference can be excluded. If a personal reference is contained in the data collected about you, it will be immediately excluded, and the personal data will be deleted immediately.

6.5. We use Google Analytics to analyze and regularly improve the use of our website. We can improve our offering with the statistics and make it more relevant for you as a user. For the exceptional cases in which personal data is transferred to the US, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 (1) Clause 1 (f) GDPR.

6.6. Information about third-party providers:

Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of service: https://www.google.com/analytics/terms/gb.html, Overview of data protection: https://www.google.com/intl/en/analytics/learn/privacy.html

7. GOOGLE MAPS INTEGRATION

7.1. We use Google Maps on our website. This allows us to show you interactive maps directly on the website and allows you to conveniently use the map feature.

7.2. By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. In addition, the data referred to in Clause 3 of this declaration will be transmitted. This is done regardless of whether Google provides an account that you are logged in to, or if there is no user account. If you’re logged in via Google, your data will be assigned directly to your account. If you do not wish this to be associated with your profile on Google, you must log out before activating the button. Google stores your data as usage profiles and uses them for purposes of advertising, market research and/or tailor-made website design. Such an evaluation is done in particular (even for non-logged in users) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have a right of objection to the formation of these user profiles, whereby you must contact Google to exercise them.

7.3. For more information on the purpose and scope of the data collection and its processing by the plug-in provider, please refer to the provider’s privacy policy. There, you will also find more information about your rights and settings options to protect your privacy: https://www.google.de/intl/en/policies/privacy. Google also processes personal information in the US and is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework

 

8. INTEGRATION OF YOUTUBE VIDEOS

8.1. We’ve included YouTube videos in our online offering, which are stored on https://www.youtube.com and are directly accessible from our website. User data is transferred when the videos are played. We have no influence on this data transfer.

8.2. By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data referred to in Clause 3 of this declaration will be transmitted. This is done regardless of whether YouTube provides an account that you are logged in to, or if there is no user account. If you’re logged in via Google, your data will be assigned directly to your account. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for purposes of advertising, market research and/or tailor-made website design. Such an evaluation is done in particular (even for non-logged in users) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have a right of objection to the formation of these user profiles, whereby they must be directed to YouTube for the exercise.

8.3. Please read the privacy policy for more information on the purpose and scope of your data collection and processing through YouTube. There you will also get further information about your rights and settings options to protect your privacy: https://www.google.de/intl/en/policies/privacy. Google also processes personal information in the US and is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

9. CONTACT FORM AND EMAIL CONTACT

9.1. There is a contact form on our web page which can be used to get in touch electronically. If you make use of this option, the data you provide will be transferred to and saved by us. This data includes:

 

Required fields:

• Name
• Email address

Optional:

• Company name
• Phone number
• Enquiry

 

At the time of sending the message the following data is also saved:

• IP address
• Date and time of sending the request

For the processing of the data, your consent will be obtained within the scope of the sending process and you will be referred to the data protection declaration. Alternatively, you can get in touch via the email address provided. In this case, the user’s personal data transmitted with the email will be saved. In this connection, there is no forwarding of the data to third parties. The data is solely used for processing the conversation.

9.2. The legal grounds for data processing, in the case that consent is granted by the user, are provided by Art. 6 (1)(a) GDPR. The legal grounds for data processing, transferred as part of an email, are provided by Art. 6 (1)(f) GDPR. If the purpose of the email/mail contact is the performance of a contract, Art. 6 (1)(b) GDPR provides additional legal grounds for processing.

9.3 The processing of personal data from the input screen solely serves us for contact purposes. In the case of contact being established by email, the required justified interests in the processing of the data are also included. Other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our IT systems.

9.4. The data is deleted as soon as it is no longer required to fulfill the purpose of its collection. This is the case for the personal data from the contact form input screen and that transferred by email if the respective conversation with the user has been brought to a close. The conversation has been brought to a close if circumstances indicate that the relevant subject matter has been conclusively clarified.

 

10. EXTERNAL LINKS

If you use external links that are offered within the scope of our Internet pages, this data protection declaration does not extend to these links. We accept no responsibility for external content provided for use via links and do not adopt their content as our own.

If we offer links, we assure that at the time the links were set, no violations of applicable law were discernible on the linked Internet pages. However, we have no influence on compliance with data protection and security regulations by other providers. Therefore, please also inform yourself about the data protection declarations provided on the websites of other providers.

 

 

 

WHISTLEBLOWING POLICY – Non-EU/Australia

Arvos Bidco S.à r.l. and their respective subsidiaries, (collectively, the “Company” or “ARVOS” or “LJUNGSTRÖM”) embrace and adopt this revised ARVOS/LJUNGSTRÖM Whistleblowing Policy (the “Policy”) for its employees who do not work in European countries or Australia, which provides the means for employees and business partners (e.g., vendors, suppliers, and customers) to come forward with credible and substantiated information about illegal conduct, violations of ARVOS/ LJUNGSTRÖM policies, or violations of ARVOS/LJUNGSTRÖM contracts, all for the purpose of creating transparency and a responsible corporate environment. In doing so, this Policy also provides that the Company will protect any individual from retaliation, if they have a reasonable basis and are reporting in good faith.

1. POLICY OBJECTIVE

The Company encourages ARVOS/LJUNGSTRÖM employees to report, as soon as possible, their concerns related to any illegal conduct they can reasonably substantiate or prove, serious violations of ARVOS/LJUNGSTRÖM policies (especially its compliance policies), or major violations of ARVOS/ LJUNGSTRÖM contracts harmful to ARVOS/ LJUNGSTRÖM or its customers. All reported concerns will be taken seriously, will be tracked individually, treated confidentially, investigated appropriately and conclusions will be shared with top management or the Board. The Company encourages as much substantiation, corroboration, evidence or supporting information as reasonably available to enable the Company to conduct a thorough investigation. In all instances, the anonymity of each reporting individual will be respected, and no unfair retaliation will be permitted.

2. BACKGROUND

This Policy is an essential element necessary to foster a work environment of openness, accountability, trust, and productivity. Protecting those who make reports under this Policy from unfair treatment, including retaliation, discrimination, or disadvantage, emboldens employees to report wrongdoing and increases the likelihood that wrongdoing is reported, uncovered, and brought to an end. For these reasons, persons in possession of such substantiated information are requested to report it.

The Company is committed to dealing responsibly and professionally with all genuine concerns. We expect all ARVOS/LJUNGSTRÖM employees to maintain high standards of behavior in accordance with the ARVOS/LJUNGSTRÖM values. Further, the Company abides by its Code of Conduct and all other Compliance Policies in its administration of this Policy and will not tolerate abuse of this Policy by reporting untrue or knowingly inaccurate which information.

3. WHAT IS ENCOURAGED BY THIS POLICY?

The Policy goals are met when an individual passes along information about a substantiated wrongdoing. For a matter to meet this goal, an individual who makes a disclosure must reasonably believe two things:

3.1 The first is that the reporting individual reasonably believes that the disclosure shows past, present, or likely future wrongdoing, which properly falls within one or more of the following categories:

• • Criminal offense
  • Failure to comply with the law
  • Endangering health and safety
  • Damage to the environment
  • Failure to comply with ARVOS/LJUNGSTRÖM code of conduct and corporate policies, including anti-corruption, anti-trust, anti-bribery, International Sanctions Policy, the use of data, and other policies identified by the Company
  • Covering up the wrongdoing in any of the above categories

  3.2 The second is that they are acting in public interest.

  Any other issues which are not covered by the categories above should be reported through the appropriate internal channel (e.g., HR, Compliance, Line Manager).

  4. WHEN TO REPORT A CONCERN

  Any person, including ARVOS/LJUNGSTRÖM employees, who have a reasonable belief of information that comprises such information described in the preceding paragraph, are requested to report that information. The Company encourages participation in the spirit of transparency and high standards of corporate conduct and ARVOS/ LJUNGSTRÖM values.

  However, the Policy is NOT designed to be a forum where disgruntled employees voice anonymously their criticism of management or their supervisor and such is unacceptable. Moreover, Whistleblowers should understand that false information or accusations submitted may result in decisions that affect other people’s lives and careers, and such malicious use of the Whistleblowing Policy is unacceptable. Therefore, honest whistleblowers should only submit information that they have a good reason to believe is true (see Section 3).

  Under no circumstances will there be any reprisal against anyone who reports information under the Policy in good faith. However, if after reporting the information the person reporting learns that the information provided is incorrect or has been innocently misinterpreted, please immediately report this in order to avoid an unnecessary waste of Company resources in investigating and more importantly to prevent damage to your colleague’s good reputation and career. Any malicious acts or attempts to cause damage to your colleague’s reputation and career could lead to civil and/or criminal liability in some jurisdictions. Note, acting maliciously or abusing the Policy never will be tolerated and could result in disciplinary measures up to and including dismissal in appropriate cases.

  5. HOW TO REPORT A CONCERN

  There are three ways that someone can report a good faith concern:

  • In person: You can speak with your line manager or another manager of trust about your concerns or with one of the following Compliance Officers who will not disclose your identity unless you agree:

  – Oliver Weingarth, Am Taubenfeld 21/1, 69123 Heidelberg, Germany,

  – Steve List, 2034 Hamilton Place Boulevard, Suite 220, Chattanooga, TN 37421, U.S.

  – Peter Bi, No 1515, Dazhong Mansion, West Zhongshan Road, Shanghai, China 200235

  – Katsuhiro Kurita, 7-1-18 Onoe-dori, Chuo-ku, Kobe City, Hyogo, Japan

  • Online: Visit the ARVOS Integrity Hotline at the below listed links and choose in which language you wish to complete the form:
  • for ARVOS on a server in a protected high security Access to this platform is granted to the information provider via the ARVOS website and the Compliance Section (icon “Reporting of Compliance Matters”):
    • • German
      • English
      • Chinese (SC)
      • Japanese
      • Czech
      • Polish

  You do not need to disclose your identity and can remain anonymous. In contrast to an e‐mail, it is not possible to trace your identity. You can create a mailbox, which is protected by a password created by you and to which only you have access. However, in order to facilitate a more fulsome investigation of the information reported, your identity would be appreciated. Note, the word “anonymous” is not equal to any of your reports using other person’s identity without having his/her prior authorization or even knowledge. If it has been found that you are pretending to be someone else or using another person’s identity, we reserve the right not to investigate your report. Furthermore, we will inform the actual person of your misuse of their identity and such behavior could lead to civil and/or criminal liability in some jurisdictions.

  If you wish to remain anonymous, the report will be received by an external contact person (“The Ombudsman”), who is the only other person who has access to the data on the Company’s account which is located on a highly secured server. Even the system administrator of ARVOS/LJUNGSTRÖM does not have access to the data. The ARVOS Ombudsman is the following German external Law Firm:

  Dr. Buchert & Partner Rechtsanwälte – Partnerschaftsgesellschaft mbB

  Bleidenstraße 1, 60311 Frankfurt am Main, Germany

  Phone: +49(0)69 710 33 33 0, Fax: +49 (0)69 710 34 44 4

  E‐Mail: kanzlei@dr‐buchert.de.

  Internet: www.dr‐buchert.de

  Dr. Buchert & Partner Rechtsanwälte has an extensive experience in dealing with compliance issues and operate independently without any ARVOS/LJUNGSTRÖM instructions on how to deal with a reported non‐compliance issue.

   

  The Ombudsman has the task to evaluate and, if necessary, to clarify the reported issue and to provide her assessment of the issue to the ARVOS/LJUNGSTRÖM Compliance Officers.

  • Call: Dial the above telephone number of The Ombudsman to report your concerns or call or write an E-Mail to one of the Compliance Officers:

  – Oliver Weingarth: E-Mail, [email protected]; Phone, +49 6221 753 2108

  – Steve List: E-Mail, [email protected]; Phone, +1 630 750 8000

  – Peter Bi: E-Mail, [email protected]; Phone: +86 139 1899 8885

  – Katsuhiro Kurita: E-Mail, [email protected]; Phone : +81 90 5129 6186

  6. INFORMATION NEEDED TO RAISE A CONCERN
     • When raising a concern under this procedure, you should provide at least the following information:
  • The nature of the concern and its key elements;
  • When it happened;
  • Who was involved and
  • The reason you believe it to be true (e., the substantiation/corroboration/evidence).
    • In addition to details of the concern, an employee should try to provide the following information:
  • The background behind the concern;
  • Whether the concern was already raised with anyone and the respective response;
  • Any other relevant dates; and
  • If applicable, any personal interests must be declared from the outset.
    • It is important that matters are not investigated by employees themselves. The employee should have a reasonable belief that wrongdoing, including breaches of the core values in the Company policies, laws or regulations, has occurred or is likely to occur.
  7. WHAT HAPPENS NEXT?
  • Within seven (7) days of the alert being made via our Integrity Hotline (either by disclosing identity and contact details or by having created an anonymous mailbox) a response will be sent to acknowledge the receipt of the concerns raised. Those raising a concern anonymously without creating a mailbox are encouraged to follow up by using the same way they have used when making the first contact.
  • The case will be reviewed internally and assigned for investigation. The person assigned the case will closely cooperate with one of the responsible Compliance Officers and the latter (or the Ombudsman) will maintain contact with the person making the report to help ensure clear communication about the progress of the case.
  • Once the investigation is concluded, the person who made the report will receive an explanation about how the concern has been addressed. If there are legal constraints, e.g., in a criminal investigation, the reporting person will receive sufficient information in order to see that the concern has been dealt with. If no further action is proposed, the Compliance Officer (or the Ombudsman) will inform the reporting person about reasons for this in writing.
  • If the investigation is not completed within 3 months or in the time originally estimated for the investigation, the Compliance Officer (or the Ombudsman) will provide regular updates to the reporting person.
  • Throughout any investigation, employees who make a report under the Policy are expected to continue their duties/role as usual, unless deemed inappropriate. An employee should not suffer any unfair or negative treatment as a result of raising a concern. Any such treatment should be raised and discussed with the responsible Compliance Officer.

  Effective February 1, 2022