Social

 

Own workforce

NORMA reports information and data for areas of its own workforce in orientation to the ESRS. On the one hand, this is due to the limited availability of data, in particular the lack of granularity of the data as required by the ESRS. Secondly, there are systems in place that do not meet the reporting requirements of the ESRS, as their introduction in the past was not aimed at reporting. NORMA is working consistently to improve data quality and availability in the 2025 fiscal year so that it can be reported in accordance with the ESRS in the future. We do this not only to comply with legal requirements, but also in particular because it is important to us as a Group to provide our internal and external stakeholders with complete and accurate information. Nevertheless, NORMA is already in a position to report individual information and data, so the following available information is disclosed in accordance with the ESRS. The information is always given in the employee headcount. If there is a deviation from this definition or if the information is stated differently, this will be disclosed.

 

S1-8 Collective bargaining coverage and social dialog

 

[S1-8-60a] NORMA Group recognizes the important role of collective bargaining agreements in shaping the working and employment conditions of its employees. 43.0 % of temporary and permanent employees are covered by collective agreements, which corresponds to 3,284 employees worldwide. The collective agreements are negotiated locally and therefore vary according to country-specific requirements.

[S1-8-60b] Collective bargaining agreements have been negotiated for 713 employees in the European Economic Area, which corresponds to 9.0 %. As this information is only to be reported for countries in which NORMA Group has significant employment, defined as sites with at least 50 employees covering at least 10% of the total workforce, only the collective agreements for Germany can be reported in this context.

[S1-8-63a] With regard to social dialog, 9.0 % of NORMA Group employees worldwide are represented by workers’ representatives. This figure is given for the countries in the European Economic Area in which NORMA Group employs at least 50 employees who make up at least 10% of the total workforce.

[S1-8-63b] NORMA Group has an agreement with its employees regarding representation by a European Works Council, a Societas Europaea Works Council or a Societas Cooperativa Europaea Works Council.

 

S1-14 Health and safety metrics

[S1-14-88a + MDR-M 77] NORMA Group is committed to maintaining a robust health and safety management system to ensure the well-being of its workforce. At the end of the fiscal year, 87.3 % of employees were covered by the health and safety management system in accordance with ISO 45001, based on the total number of employees at that time.

In addition, 98.6 % of employees in the manufacturing plants are covered by the ISO 45001 management system.

[S1-14-88b] NORMA Group recorded zero fatalities as a result of work-related injuries last year.

This figure includes all reported fatalities at all NORMA sites worldwide. In addition to employees, external workers such as individual contractors or other persons working on the company premises under the supervision of the company are also included.

Within NORMA Group, cases are recorded using a standardized local data collection system. This survey makes it possible to record all fatalities across all locations and consolidate them at Group level. In addition, the Environment, Health and Safety department is obliged to report fatal accidents to the local authorities.

[S1-14-88c+d] In addition, a total of 77 recordable work-related accidents were registered in the last fiscal year, which corresponds to a rate of 4.97.

NORMA Group takes both injuries and illnesses into account when documenting recordable accidents, as incidents that lead to an injury or illness are defined as accidents. Reporting is carried out separately for the rates of reportable injuries and reportable illnesses.

The rate of recordable injuries in the last fiscal year is 4.97, while the rate of recordable work-related illness is 0.

This indicator includes all locations of the legal entities (subsidiaries) of NORMA Group. The number of reportable incidents refers to work-related injuries or illnesses that can lead to death, days lost, reduced ability to work, transfer to another job, medical treatment beyond first aid or unconsciousness. This includes significant injuries or illnesses that are diagnosed by a physician or other licensed health care professional, even if they do not result in the above consequences.

The rate of recordable injuries and illnesses is calculated by dividing the total number of recordable cases by the total working hours and then multiplying by one million.

[S1-14-88e] NORMA Group also reports on the number of days lost by its employees due to work-related injuries and work-related illnesses as well as the number of days lost due to fatalities as a result of such incidents. A total of 1,730 lost days were counted in the 2024 fiscal year.

The calculation of days lost is based on the first and last full day of absence and includes calendar days. This means that days on which the person concerned is not scheduled to work, as well as weekends and public holidays, also count as days lost. The local health and safety authority monitors and reports the days lost, taking into account the first and last full day of absence.

This indicator is monitored and recorded by the local health and social services, which document the days lost for each recordable accident. In exceptional cases, the exact number of days lost for certain incidents may not be immediately known. A preliminary estimate is made by the Health and Social Services Department.

S1-17 Human rights-related incidents, complaints and severe impacts

[S1-17-103a] During the reporting period, NORMA Group registered zero confirmed incidents of discrimination based on gender, race or ethnic origin, nationality, religion or belief, disability, age, sexual orientation or other grounds, including harassment, through its whistleblower system.

[S1-17-103b] In addition, NORMA Group received zero complaints related to human rights through internal complaints mechanisms that are independent of the incidents mentioned above. Complaints related to human rights refer to complaints regarding labor rights, freedom of association, forced labor, child labor, working conditions and occupational safety.

[S1-17-104a] NORMA Group identified zero confirmed cases of severe human rights violations in which the United Nations Guiding Principles, the International Labor Organization Declaration or the OECD Guidelines were violated.

[MDR-77] With regard to the number of incidents, all human rights violations reported by internal or external sources via NORMA Group’s whistleblower system and assessed by the Human Rights Committee as actual or severe human rights violations are taken into account. The Human Rights Committee categorizes and assesses the severity of the individual complaints on the basis of key questions. Since 2024, NORMA Group Integrity has also obtained a confirmation of completeness from relevant departments to ensure that all relevant complaints have been submitted to the whistleblower system. The information received is processed within NORMA Group and can be examined by external bodies on a case-specific basis beyond the legal requirements.

[MDR-77] NORMA Group’s legal counsels collect information from the CFOs of the regions who report on fines and convictions of each entity. This information is then consolidated by the legal department for the entire Group. Fines are allocated to the reporting year in which the decision became legally binding, although the possibility that reporting persons may conceal fines cannot be ruled out. The information received is processed exclusively within NORMA Group and is not validated by external bodies beyond the legal requirements.

[S1-17-103c] In connection with the reported cases of human rights violations and discrimination, the fines, sanctions and compensation for these incidents and complaints amounted to a total of zero euros.

[S1-17-104b] In connection with severe incidents relating to human rights violations, fines, penalties and compensation totaled zero euros.

 

S1-1 Policies related to the company's own workforce

[S1-1-19] NORMA Group has adopted policies and statements to effectively manage the material impacts associated with its own workforce. At the heart of these efforts are the Code of Conduct, the Human Rights Commitment Statement and the policies on Human Rights, Diversity and Inclusion. These policies are specifically tailored to the needs and rights of the employees and apply to all employees. NORMA Group has not identified any material risks and negative impacts in connection with its own workforce. Nevertheless, identifying, assessing and actively managing potential risks remains a key task in the area of human rights.

[MDR-P 65a-f] Human Rights Commitment Statement

NORMA Group is aware of the responsibility that arises from its global business activities and is committed to conducting its business in an ethical and socially responsible manner, as well as taking responsibility for its own workforce.

In the Human Rights Commitment Statement, NORMA Group points out that any form of violation of human rights is categorically rejected. NORMA Group is committed to the prevention of slavery and human trafficking within its own business activities and requires all business partners to refrain from violating human rights and to work towards this in their own value chain. If violations become known, NORMA Group gives its business partners the opportunity to remedy them as quickly as possible. The business relationship is then reassessed and termination of the contract is considered.

Responsibility for implementing the requirements set out in the statement lies with the relevant departments and all members of NORMA Group.

With this statement, NORMA Group commits to complying with the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, the Universal Declaration of Human Rights and the International Labor Organization's Declaration on Fundamental Principles and Rights at Work.

The publication of the statement is intended to ensure that NORMA Group transparently informs all potentially affected stakeholders and those involved in the implementation.

[MDR-P 65a-f] Human Rights

With a clear focus on employees, NORMA Group introduced a Human Rights Policy in the 2024 fiscal year to ensure that all employees and external partners respect and promote human rights in line with global standards and ethical practices. It is designed to ensure that potential human rights risks within the company’s operations are identified and mitigated, and to promote a positive working environment, leading to greater employee satisfaction, retention and fair treatment of all stakeholders.

The Management Board and local management bear overall responsibility for the topic of human rights and support the implementation of the policy and the measures derived from it.

The publication of the policy is intended to ensure that all potentially affected interest groups and those involved in its implementation are informed transparently.

[MDR-P 65a-f] Diversity & Inclusion

The Diversity & Inclusion policy underlines the belief that diverse teams bring different perspectives and ideas to the table, thus promoting creativity and innovation. NORMA Group strives for active inclusive environments to foster diverse viewpoints and make effective decisions.

The Management Board and local management bear overall responsibility for the topic of diversity and inclusion and support the implementation of the policy and the measures derived from it.

The publication of the policy is intended to ensure that all potentially affected interest groups and those involved in its implementation are informed transparently.

[MDR-P 65a-d] The Code of Conduct is described in detail in the chapter G1 GOVERNANCE.

[S1-1-20a-c] The Human Rights, Diversity & Inclusion policies introduced by NORMA Group in the fiscal year focus on the observance and protection of human rights, the promotion of equal opportunities, diversity and inclusion as well as the labor rights of all employees. The Code of Conduct, the Human Rights Commitment Statement and the policies on Human Rights and Diversity & Inclusion set out NORMA Group’s position on these issues, particularly with regard to its own employees.

NORMA Group underlines its commitment by firmly rejecting any form of human rights violations and does not tolerate any violations. The aim is to safeguard human rights and identify potential violations at an early stage in order to protect the rights of all employees, including their labor rights.

NORMA Group maintains a continuous dialog with its own employees through direct contact or the respective managers. This exchange is also promoted through employee surveys and close cooperation with employee representatives and trade unions. Its guidelines define clear measures and sanctions under labor law in order to exclude, minimize or completely eliminate potential human rights violations as far as possible.

[S1-1-21] NORMA Group’s values are in line with the ten principles of the UN Global Compact, the United Nations Guiding Principles on Business and Human Rights and the International Labor Organization's Declaration on Fundamental Principles and Rights at Work. This is reflected, among other things, in efforts to uphold fair working conditions, eliminate discrimination and combat corruption. NORMA Group strictly rejects human rights violations as described in the Universal Declaration of Human Rights and the Declaration of the International Labor Organization.

[S1-1-22] NORMA Group emphasizes in its policies that human trafficking, forced and compulsory labor and child labor are not tolerated under any circumstances within its own workforce.

[S1-1-24a-c] NORMA Group is currently developing a strategy to combat discrimination and harassment and to promote equal opportunities, diversity and inclusion. These efforts are firmly anchored in the Code of Conduct, the Human Rights Commitment Statement and the Human Rights and Diversity & Inclusion Guidelines. The content of this guideline addresses both aspects of discrimination, including harassment based on race, skin color and gender, and the promotion of equal opportunity and diversity. They are intended to make it possible to express any form of political opinion, national affiliation or social origin.

NORMA Group respects the respective national laws, but there are no specific Group-wide obligations regarding inclusion or positive measures for particularly vulnerable groups.

[S1-1-24d] By complying with the requirements set out in the Human Rights and Diversity & Inclusion policies and conducting voluntary training for employees, NORMA Group works to prevent and reduce discrimination and to act appropriately when incidents occur. In addition, the promotion of diversity and integration is to be actively supported in the future in order to establish an inclusive, respectful and equal working environment in the long term. For example, mandatory diversity and inclusion training for all employees and managers will be carried out in the 2025 fiscal year on the basis of the newly introduced guidelines in order to raise awareness throughout the organization.

 

S1-1 Policies related to health and safety

[S1-1-23 + MDR 65a+e] NORMA Group pursues a Group-wide approach to health and safety policy. All production sites are required to have a management system certified in accordance with ISO 45001:2018. NORMA Group has also implemented an occupational health and safety policy. This policy requires managers to create a safe working environment for all employees and other stakeholders.

[MDR-P 65c] The Chief Operations Officer of NORMA Group and the Vice President Quality and Environment, Health and Safety are responsible for implementing the policy.

[MDR-P 65b] The policy takes all employees into account.

[MDR-P 65f] By publishing the policy, NORMA Group wants to ensure that all potentially affected stakeholders and those involved in its implementation are informed transparently.

 

S1-2 Processes for engaging with own workers and workers’ representatives about impacts

[S1-2-27a+b] NORMA Group takes the perspectives of its employees into account by actively incorporating their insights and opinions into the decision-making process. Engagement is measured every two years as part of the global employee survey. Employee engagement reflects the involvement and enthusiasm of employees in their work and workplace. Some of the key metrics that are monitored are participation rate, overall average, engagement percentage and approval percentage. In addition to employee engagement, NORMA Group aims to understand employee needs, identify opportunities for improvement and translate feedback into feasible action plans at the global, regional and local levels.

Based on the results, improvement measures are required in the areas that are below average or below what is expected, which are determined by the managers at department and company level in a workshop. Workshops and training courses are conducted by providers and employees of the HR department.

The defined action points are monitored, analyzed and evaluated. From 2024, the employee survey will be conducted every two years; previously it took place every three years.

[S1-2-27c] The operational responsibility for ensuring that employees are involved in the survey and that the results are actively incorporated into NORMA Group’s approach lies with Human Resources.

The resources used for the global survey include EUR 90,000 in costs in the 2024 fiscal year and the manpower of one full-time employee. The measures resulting from the survey are defined, managed and reviewed at site level.

NORMA Group is also actively committed to occupational health and safety, including through safety committees in which local managers, non-executive employees and production employees working on an hourly basis participate. This exchange is intended to ensure that the knowledge gained is directly integrated into NORMA Group’s working methods. In addition, regular safety training and awareness campaigns are carried out during the fiscal year to further raise awareness of safety issues.

 

S1-3 Processes to remediate negative impacts and channels for own workers to raise concerns

[S1-3-32a] During the reporting period, NORMA Group has not identified any confirmed negative impacts related to working conditions, equal treatment and equal opportunities or other labor-related rights within its own workforce through its whistleblower system.

Nevertheless, NORMA Group focuses on minimizing potentially fatal incidents and high-risk incidents involving employees and external workers, among other things with regard to occupational health and safety. In the event of such incidents, detailed root cause analyses are carried out on site and immediate remedial measures are initiated and followed up in order to eliminate the underlying risk factors in the long term. Thanks to these safety precautions, the frequency of such incidents has already been reduced. Nevertheless, NORMA Group continues to focus increasingly on high-risk sites and uses the Safety Top Focus Program to further minimize potential negative impacts on the workforce.

[S1-3-32b] In addition, each NORMA Group production site has implemented a value-based monitoring program that actively involves workers in identifying and resolving potential safety issues that could lead to injury or illness. As soon as risks are identified, measures are immediately taken and implemented to minimize the identified safety risks for employees and external workers.

[S1-3-32b] NORMA Group has also implemented processes and procedures that enable employees to report their concerns, worries or needs. This also includes the possibility of addressing them directly or submitting complaints anonymously via the whistleblower system. Further information on the whistleblower system is provided in the chapter G1 GOVERNANCE. Another way of directly addressing issues is for employees to take part in the Employee Engagement Survey, which is usually conducted every two years.

[S1-3-32b] These channels are established by NORMA Group itself and through participation in third-party mechanisms.

[S1-3-32c+e+33] As part of its whistleblower system, NORMA Group has established a procedure to ensure that complaints related to employee matters are handled carefully and that issues raised are followed up and monitored. For NORMA, the use of channels and structures is an indicator that they are known and trusted. However, NORMA does not systematically survey relevant stakeholders on effectiveness and awareness. NORMA Group adheres to strict guidelines designed to prevent any form of retaliation against individuals, including employee representatives, who use the whistleblower system. Further detailed information on the procedures and monitoring can be found in the chapter G1 GOVERNANCE.

[S1-3-32d] Internal training and various communication measures such as the intranet, posters and additional information materials ensure that these channels are known and accessible in the workplace.

 

S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

[MDR-T 81] In the current fiscal year, no measurable results-oriented targets for working conditions, equal opportunities or occupational health and safety have yet been implemented. NORMA Group is currently in the process of establishing appropriate processes to develop and implement targets with regard to the impacts and opportunities related to its workforce.

 

S1-4 Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

[S1-4-38a+b] A wide range of measures are implemented in the area of occupational health and safety. As the materiality analysis did not identify any material negative impacts in terms of occupational health and safety, these measures are aimed at strengthening the positive effects and opportunities.

[S1-4-38c + 40 + 43] NORMA Group has implemented various measures to strengthen health and safety in the workplace. Safety committees, which consist of local managers, non-executive employees and production employees working on an hourly basis, regularly coordinate safety training, awareness campaigns and safety toolbox topics during the fiscal year. As part of job safety analyses carried out by the environment, health and safety managers at the respective local sites, risks are also identified, assessed and, if necessary, measures are implemented and monitored according to the risk level of the workplace. In addition, managers operate a value-based safety program that actively engages workers in identifying and reporting safety issues that could potentially lead to injury or illness. As soon as risks are identified, measures are immediately taken and implemented to minimize the identified safety risks for employees and external workers. These preventive measures make it possible to invest specifically in new safety technologies to avoid accidents at work. The scope of the measures described includes legal entities where there is a higher risk of occupational accidents.

[S1-4-38d] NORMA Group continuously conducts analyses and assessments to ensure the effectiveness of its measures to promote the safety and health of workers. This is achieved by continuously monitoring internal safety indicators, which include both leading and lagging indicators. Examples of lagging indicators include reportable accidents and near misses, while leading indicators include the results of VBS audits and safety training. A key component is obtaining and maintaining ongoing ISO 45001 certification and conducting internal and external ISO 45001 audits to ensure compliance with and the effectiveness of safety standards. After each reportable incident, NORMA Group reviews the corrective actions through analysis and applies the lessons learned. These processes enable NORMA Group to identify and implement targeted measures to promote positive impacts on the workforce.

[S1-4-39] [S1-4-41]

[MDR-A-62] In addition to the occupational health and safety measures mentioned above, NORMA Group has planned further measures that are managed and monitored at Group level. To promote the positive impacts, NORMA Group is in the process of establishing appropriate processes to further develop and implement sound measures. In the 2025 fiscal year, measures will be initiated to implement the adopted guidelines in the areas of “Human Rights” and “Diversity and Inclusion,” such as mandatory training and awareness programs for all employees and managers. In addition, the existing process for performance-related salary determination will be further developed. NORMA Group also aims to ensure that its own business processes do not have a negative impact on employees through measures aimed at complying with local laws and corresponding labor and occupational health and safety regulations and local provisions.

[S1-4/40] A Human Rights Committee was established in the 2024 fiscal year in the area of human rights and discrimination in relation to the company’s own workforce. Further information on this can be found in the chapter G1 GOVERNANCE.

 

Workers in the (upstream) value chain

 

S2-6 Share of preferred suppliers who have signed the Supplier Code of Conduct

[2-MDR-M-77a][2-MDR-M-77b][2-MDR-M-77c][2-MDR-M-77d] NORMA Group has defined a company-specific metric to address the potential impact related to workers in the upstream value chain. This shows the proportion of preferred suppliers who have signed the Supplier Code of Conduct. In the 2024 fiscal year, this share is 100 %.

To determine a preferred supplier, NORMA Group has developed a catalog of criteria that includes aspects such as competitiveness, transparent cost structures and delivery conditions. NORMA Group’s fundamental endeavor is to ensure that its suppliers understand the Supplier Code of Conduct and confirm compliance with the Supplier Code of Conduct by signing it in order to enter into long-term contractual relationships. The measurement of this key figure is not externally validated.

S2-9 Interests, views and rights of workers upstream in the value chain that could be materially affected by the company

 

S2-1 Policies related to value chain workers

[S2-1-16][S2-1-AR10][S2-1-AR11][MDR-P-65] NORMA Group wants to take responsibility along the entire value chain and is aware of the actual and potential negative impact on workers in the value chain. The material impacts identified in the materiality analysis relate exclusively to workers in the upstream value chain. NORMA Group has not identified any risks or opportunities. Nevertheless, it remains a key task to identify, assess and actively manage potential risks in relation to the workers in the value chain.

Further details on the materiality analysis process can be found in the chapter IRO-2 GENERAL REQUIREMENTS. NORMA Group has introduced the Supplier Code of Conduct to address negative impacts on workers in the upstream value chain and with regard to working conditions, equal treatment and equal opportunities as well as human rights. Suppliers who sign the Supplier Code of Conduct, i.e. in particular the preferred suppliers, undertake to respect and comply with human rights. This Code of Conduct is intended to ensure that both laws and ethical standards are complied with throughout NORMA Group’s supply chain. The globally applicable Supplier Code of Conduct sets out NORMA Group’s expectations for its suppliers regarding sustainable business practices in the areas of human rights, occupational safety, health, environment and business integrity. With regard to human rights, the Code is guided by the standards of the International Labor Organization, the Universal Declaration of Human Rights, the UN Global Compact and the SA8000 standard. The Supplier Code of Conduct was introduced in the 2014 fiscal year. It was last updated in the 2023 fiscal year to take into account the requirements contained in the Supply Chain Due Diligence Act. Furthermore, the Code of Conduct is applied as described in the chapter G1 GOVERNANCE. Compliance with the Human Rights Commitment Statements is also taken into account accordingly. Further information on this can be found in the chapter S1 OWN WORKFORCE. The aforementioned guidelines are reviewed and updated as required. As a rule, workers in the upstream value chain is also taken into account where applicable. [MDR-P-65a] Overall responsibility lies with the Management Board, while monitoring is carried out by the Human Resources, Corporate Responsibility, Integrity, Legal and Purchasing departments.

[S2-1-17a][S2-1-17b][S2-1-17c] Due to the size and complexity of the value chain, human rights violations cannot be completely ruled out. NORMA Group has only limited influence on compliance with the minimum standards beyond its direct business partners. If the company learns that business partners are committing or tolerating human rights violations, NORMA Group gives its business partners the opportunity to remedy this as quickly as possible. The business relationship is then reassessed and termination of the contract is considered. Indications of potential human rights violations are investigated. To this end, potential violations must be reported to NORMA Group Compliance as part of a defined reporting process. These are submitted to the Human Rights Committee for further analysis and evaluation. Further information on this process can be found in the chapter G1 GOVERNANCE. NORMA Group expects its suppliers to conduct their business in compliance with applicable laws, ethical principles, human rights and standards for occupational safety and environmental protection. The Purchasing department has therefore integrated social and environmental sustainability aspects into its processes and organization, including in the Purchasing Manual, which describes the key processes and procedures that serve as a framework for the global organization. The Supplier Code of Conduct reflects this self-conception and is guided by the standards of the International Labor Organization, the Universal Declaration of Human Rights, the UN Global Compact, and the SA8000 standard with regard to human rights. Approval of the Supplier Code of Conduct is a binding criterion in the catalog of requirements for the selection of new suppliers and is monitored by the Purchasing department. Further information on consent can be found in the chapter S2 WORKERS IN THE UPSTREAM VALUE CHAIN. [S2-1-18] The Supplier Code of Conduct, the Code of Conduct and the Human Rights Commitment Statement are commitments of NORMA Group that contain, among other things, declarations on human rights and clarify the company’s position in this regard. NORMA Group positions itself against human trafficking, forced labor and child labor in the value chain, among other things.

[S2-1-19][S2-1-AR14] NORMA Group’s commitments regarding workers in the value chain are in line with the ten principles of the UN Global Compact, the United Nations Guiding Principles on Business and Human Rights and the International Labor Organization's Declaration on Fundamental Principles and Rights at Work. In the 2024 fiscal year, zero incidents of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises concerning employees in the value chain were reported in the upstream value chain.

 

S2-2 Processes for engaging with value chain workers about impacts

[S2-2-22][S2-2-23] [S2-2-24]

In the 2024 fiscal year, NORMA Group has not implemented a comprehensive process to engage with workers in the value chain.

 

S2-3 Processes to remediate negative impacts and channels for value chain workers to raise concerns

[S2-3-27][S2-3-28][S2-3-29] NORMA Group is aware of its actual and potential negative impact on workers in the upstream value chain. Inadequate implementation of guidelines and controls in the supply chain may compromise the equal treatment of workers and human rights in the value chain. Suppliers who sign the Supplier Code of Conduct undertake to comply with the requirements set out in the Supplier Code of Conduct. NORMA Group has a whistleblower system that serves as a reporting mechanism and offers workers in the value chain the opportunity to report specific incidents and violations. For NORMA Group, the use of channels and structures is an indicator that they are known and trusted. However, NORMA does not systematically survey relevant stakeholders on effectiveness and awareness. These reports are followed up and appropriate measures are taken if necessary. Further information on the whistleblower system can be found in the chapter G1 GOVERNANCE.

 

S2-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

[S2-5-41][S2-5-42][MDR-T-72][MDR-T-81a][MDR-T-81b] In addition, NORMA Group has not yet defined any measurable, results-oriented targets with regard to workers in the value chain.

 

S2-4 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

[S2-4-32][S2-4-33][S2-4-34] [S2-4-35] [S2-4-36][S2-4-37][S2-4-38] [MDR-A-62]

Currently, NORMA Group has not implemented any specific measures related to workers in the value chain and no future measures are defined or planned. The reason for this is that NORMA Group proactively carried out an initial external risk analysis as part of the introduction of the German Supply Chain Due Diligence Act in 2023, which took into account both country and industry risks with regard to human rights. The result showed no increased risk for NORMA Group’s supplier base.

 

Affected communities

 

S3-1 Policies related to affected communities

For NORMA Group, respect for human rights forms the binding foundation for all corporate activities. As part of responsible corporate governance, NORMA Group is committed to protecting human rights along the entire value chain. NORMA Group therefore attaches great importance to protecting local communities that could be affected by the impact of business activities at various locations, especially in the vicinity of production sites.

[MDR-P][S3-1-16a][S3-1-AR9][S3-1-16b][S3-1-16c] NORMA Group categorically rejects the violation and restriction of human rights in any form. The company is committed to the Universal Declaration of Human Rights, as well as to the core labor standards of the International Labour Organization (ILO).

NORMA Group’s commitment to human rights is also reflected in its Code of Conduct. As part of the revision of the Code of Conduct in the 2020 fiscal year, a dedicated section on human rights was introduced to further emphasize NORMA Group’s position on this matter. Detailed information on the Code of Conduct can be found in the chapter G1 GOVERNANCE. The Code of Conduct encompasses the approach of respecting human rights throughout the entire supply chain. Among other things, NORMA Group exerts influence on local communities and people in the regions close to its sites and is aware of their material impact.

NORMA Group’s business activities have a positive impact on society, including economic contributions such as taxes, creating and securing jobs, making donations, sponsoring charitable organizations and projects, and complying with local regulations. NORMA Group thus contributes to the communities through various projects and investments. This includes NORMA Help Day, for example, which was introduced at the Maintal site in 2014 and has been offered at all international sites since 2015. Participation is voluntary, but more than 700 NORMA Group employees take part every year. Numerous NGOs benefit from the contributions made worldwide and projects that are organized regionally. In the 2024 fiscal year, there were numerous diverse projects across the sites. For example, employees in Brazil visited a facility for people with disabilities to give them a special day on site, while in Serbia a kindergarten was visited for a day. In the Czech Republic, support was provided in the renovation of the local swimming pool and in Malaysia, clean-up work was carried out on a public road.

NORMA Group is also involved in its social project NORMA Clean Water to find a solution to the challenges of water, sanitation and hygiene. Today, the NORMA Clean Water project can look back on a partnership of several years with children’s aid organization Plan International Deutschland, which implements projects in the respective countries. In the 2024 fiscal year, the health and nutrition of children and their families in the target regions was further improved. In addition, the water supply was further expanded and information on health and hygiene practices was provided in the communities. In this project phase, there was an even stronger focus on food security and combating malnutrition. The communities were therefore supported in planting vegetable gardens and informed about balanced nutrition in workshops.

NORMA Group is in selective dialog with affected stakeholders, such as representatives of municipalities and cities near the site. In addition, affected parties can report incidents at any time via NORMA Group’s whistleblower system, which will then be investigated. Detailed information on the whistleblower system can be found in the chapter G1 GOVERNANCE.

[S3-1-17] [S3-1-AR10] NORMA Group’s values are in line with the ten principles of the UN Global Compact (UNGC), as well as the United Nations Guiding Principles on Business and Human Rights (UNGP) and the Declaration on Fundamental Principles and Rights at Work of the International Labor Organization (ILO). If NORMA Group employees violate these values and this has a negative impact on affected communities, targeted training, changes in organizational processes, disciplinary measures or even termination of employment may follow after a case-by-case assessment. During the 2024 fiscal year, NORMA Group die not receive any reports of violations of the principles mentioned in this section.

 

S3-2 Processes for engaging with affected communities about impacts

[S3-2-24] In the 2024 fiscal year, NORMA Group did not introduce a comprehensive procedure for engaging with the affected communities. However, NORMA Group is in selective exchange with affected stakeholders, such as representatives of municipalities and cities in the vicinity of the site. The materiality analysis led to an indirect exchange with some mayors, such as the location in Serbia, on the material topics. In addition, the management at the Maintal site discusses overarching topics with the mayors at least once a year.

 

S3-3 Processes to remediate negative impacts and channels for affected communities to raise concerns

[S3-3-29] NORMA Group has a whistleblower system as a reporting mechanism to offer affected communities, among others, the opportunity to report specific incidents and violations. These reports are followed up and appropriate measures are implemented if necessary. For NORMA, the use of channels and structures is an indicator that they are known and trusted. However, NORMA does not systematically survey relevant stakeholders on effectiveness and awareness. Further information on the whistleblower system can be found in the section G1 - GOVERNANCE. There are currently no other channels, although personal contacts have been appointed at many NORMA locations in addition to the electronic systems.

 

S3-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

[MDR-T 81a] [MDR-T 81b] NORMA Group has not set any measurable result-oriented targets for the affected communities and does not plan to define such targets in the near future. This is because NORMA Group believes that the existing concepts are sufficient to manage the relevant sustainability-related impacts, risks and opportunities in this area.

 

S3-4 Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions

[MDR-A-62] NORMA Group has currently not implemented any concrete measures directly related to affected communities. No future measures are currently defined or planned in this regard. This is because NORMA Group is pursuing the reduction of GHG emissions at its production sites as part of the material topic addressed in the chapter E1 CLIMATE CHANGE, thereby simultaneously mitigating the negative impacts on affected communities.