Management of Impacts, Risks and Opportunities

Policies related to workers in the value chain

As a trading partner, we only have limited influence on the upstream and downstream supply chain; however, we work closely with selected direct suppliers (Tier 1) on the issue of sustainability. We have developed various policies to jointly promote the protection of human rights and the environment that are anchored in the sustainable procurement strategy, among other things.

Sustainable procurement strategy

The strategy adopted in the first half of 2025 is based on four pillars: transparency and accountability, respecting human rights and ethical labour practices, ensuring long-term resilience and reducing environmental impact – and contains specific actions with clear timeframes until 2030. It addresses the focus topics of sustainable supply chains, climate and energy, logistics, the circular economy and sustainable products from the Sustainability Strategy 2030. We use the Code of Conduct for Suppliers of Goods and Services as a frame of reference. The actions are backed by clear timetables and are reviewed annually by Corporate Sustainability Management. Implementation is carried out in close cooperation between Supplier Management, Legal & Compliance and Corporate Sustainability Management.

Supplier Code of Conduct

As an internationally operating group, Bechtle respects the principles of the International Bill of Human Rights, the ten UN Guiding Principles, the principles of the UN Global Compact, the Guidelines for Multinational Enterprises of the Organisation for Economic Cooperation and Development (OECD), the labour and social standards of the International Labour Organisation (ILO) and the principle of social partnership, which are explicitly mentioned in the Code of Conduct for Suppliers of Goods and Services (hereinafter referred to as the Supplier Code of Conduct). We strictly reject child and forced labour. With respect to human trafficking, the Supplier Code of Conduct makes implicit references and mentions, among other things, the ban on forced labour and modern slavery. Furthermore, the aforementioned international standards include protection against human trafficking.

We therefore expect our suppliers to comply with the legal provisions applicable to them and with the aforementioned standards, to respect internationally proclaimed human rights, and to comply with all conventions and standards drawn up by the ILO, particularly with regard to workers in the value chain. The Supplier Code of Conduct is therefore an integral part of the business relationship between us and our suppliers. It was first published in 2014 and comprehensively updated in 2022. To ensure transparency regarding working conditions and environmental impact, we have been using the EcoVadis supplier assessment tool since 2022, which enables us to track our suppliers’ compliance with social and environmental standards using a document-based audit. We also carry out an annual systematic risk analysis of all direct suppliers. Based on the results, we develop preventive and corrective actions. We are also establishing processes for supplier development and increasing transparency regarding conflict minerals.

In addition, we reserve the right to conduct compliance audits of our suppliers and utilise various control actions, including cooperation with the NGO Electronics Watch. No instances of non-compliance with standards in the value chain were received via our whistle-blowing system in the reporting period. The Human Rights Officer, who reports directly to the Management Board member responsible for sustainability, plays a key role in upholding and implementing human rights and environmental due diligence obligations.

With regard to our identified material impacts, we clarify our corporate responsibility in the Supplier Code of Conduct, which extends to the beginning of the value chain. As we trade in IT products that may require raw materials classified as conflict materials, we expect that raw materials are procured responsibly at the beginning of the supply chain and that they do not contribute to human rights violations, corruption, the financing of armed groups or similar negative effects in conflict regions. The same applies to IT production, which primarily takes place in China.

The Supplier Code of Conduct applies to all our suppliers and extends to our entire upstream value chain. During the reporting period, we further adapted our internal processes in purchasing so that the Code is systematically integrated into new and existing supplier relationships. Partners’ own guidelines that meet the requirements of our Code are reviewed and recognised accordingly as part of these processes.

The Supplier Code of Conduct was developed under the responsibility of the Legal & Compliance department on the basis of the requirements of the Supply Chain Due Diligence Act, which takes into account the interests of workers in the value chain per se. Supplier management is responsible for liaising with suppliers and obtaining their commitments. At the highest level of the organisation, the Chief Executive Officer is responsible for Legal & Compliance, while supplier management is the responsibility of the board member for Logistics & Service, Financial Services and Sustainability Management. The current version of the Supplier Code of Conduct was approved by the entire Executive Board. Supplier Management is responsible for implementation in collaboration with the Legal & Compliance and Corporate Sustainability Management departments.

Dealing with violations of the Supplier Code of Conduct

In addition to the aforementioned principles of the International Bill of Human Rights, the UN Global Compact, the OECD and the ILO, we require our suppliers to comply with all relevant laws and regulations in their countries as part of our Code of Conduct. The Supplier Code of Conduct is publicly available on our website.

The Supplier Code of Conduct also stipulates that a supplier must inform us as soon as it has knowledge, or reasonable grounds to believe, that it or a subcontractor or upstream supplier has violated the principles and standards. Furthermore, the supplier must inform us of the corrective actions it has taken to ensure compliance with the Supplier Code of Conduct. In addition, in the event of an (imminent) breach of the formulated principles and standards in its own business area, it is obliged to take appropriate remedial actions without delay, up to and including ending the breach.

If we are convinced that the supplier will not be able to remedy the breach in the foreseeable future, it shall, with our support, immediately draw up a plan to prevent, terminate or minimise the breach. In particular, the plan must contain specific actions, interim targets, a timetable and responsible persons in the supplier’s organisation. The supplier must implement the action plan without delay and support us in complying with our own existing legal requirements in this context.

If there are actual indications that an upstream supplier or contractor has violated the above-mentioned principles, in particular human rights or environmental obligations, we will support the supplier by taking appropriate actions to introduce suitable preventive and remedial actions. This may include checks, actions to prevent and minimise risks and participation in sector-specific or cross-sector initiatives.

During the implementation of these remedial actions, Bechtle shall be entitled to temporarily suspend the business relationship with the supplier concerned. If the actions taken do not lead to a sufficient improvement in the situation, we reserve the right to discontinue the business relationship and to terminate existing contracts with immediate effect.

The effectiveness of the corrective actions is regularly reviewed, for example through follow-up discussions or progress reports from suppliers, to ensure that risks are sustainably reduced and violations are effectively ended.

For more information, see the Supplier Code of Conduct

Processes for engaging with value chain workers about impacts

Our position within the value chain makes it difficult for us to communicate directly with the workers in the value chain, as we generally have no information about production sites, raw material extraction or contact details. We use research by NGOs to take the views of these people into account in our annual supplier and sustainability risk analyses, for example. These include reports by Electronics Watch, Human Rights Watch, Weed and the Business & Human Rights Resource Centre. The most recent detailed research was carried out as part of the materiality and supplier risk analysis. In addition to the annual risk analysis, an analysis can be carried out as required, for example if there are indications of increased risks in certain countries, sectors or supplier relationships.

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

There are special channels set up by Bechtle for whistle-blowers. Workers of Bechtle and external parties can contact the Compliance Board to report relevant compliance violations, including human rights violations, confidentially using a telephone hotline or alternatively via a separate e-mail account. These possibilities are also available to third parties. A description of the whistleblowing system and the contact details can be found on our company’s website.

Further information on the whistleblowing system can be found in the Governance information section. In the Supplier Code of Conduct, we express the expectation that our respective partner "ensures that the workers of the supplier, upstream suppliers and subcontractors, who come into contact with of Bechtle’s interests, are aware of the requirements of this Supplier Code of Conduct". The Supplier Code of Conduct describes the whistleblower hotline, including contact details, in a separate section. The whistleblower hotline was introduced as part of the implementation of the Supply Chain Due Diligence Act 2023. As there have not yet been any reports from workers in the value chain via this channel, we have no experience in this regard. No serious problems or incidents relating to human rights within the upstream and downstream value chain were reported through this channel in the reporting period. However, a process has been defined for handling reports in the supply chain that are received as part of the whistleblowing system in order to ensure that the reports are documented, evaluated and followed up in a structured manner and that the actions are checked for their effectiveness.

Taking actions

In the following, we report on the actions taken with regard to material impacts and approaches to managing material risks and exploiting material opportunities relating to workers in the value chain, as well as the effectiveness of these actions and approaches. The Supplier Code of Conduct is a key tool for preventing, minimising and eliminating negative impacts in our value chain. As the concept and actions are closely linked, the Code has already been described in detail above: see sections “Code of Conduct for Suppliers of Goods and Services” and “Dealing with violations of the Supplier Code of Conduct”. The current version is rolled out to new suppliers on an ongoing basis and presented to them for signature, as was also the case in the reporting period. The Code forms the basis for further preventive actions that extend beyond the direct suppliers into the upstream stages of the value chain.

In 2022, we established a process for systematically reviewing the environmental and social responsibility of our direct suppliers and manufacturers via the EcoVadis document-based audit. As of 22 January 2026, 255 companies were included in the measurement. Using the EcoVadis Score Cards, we can continuously check the effectiveness and track whether our suppliers are complying with the criteria of our Code. In addition, supplier risk analyses are carried out twice a year to evaluate the risks of direct suppliers and appropriate preventive actions are implemented on the basis of the results. From 2026, targeted supplier development discussions will also be held based on the results of the EcoVadis rating and the risk analysis in order to drive forward their sustainability activities in the environmental and social areas.

The goal for 2026 is to implement the actions defined in the sustainable procurement policy, among other things. We therefore pursue both general approaches (company-wide standards and processes) and specific approaches to avoid or minimise significant negative impacts on workers in the value chain.

We are also developing initiatives to promote additional positive impacts along the supply chain. This includes strengthening the dialogue with strategic partners to improve working conditions and integrating sustainability information into sales to enable customers to make responsible purchasing decisions.

The progress of the procurement strategy in the reporting period was as follows:

Through our mandatory Supplier Code of Conduct, we aim to avoid having, or contributing to, a material negative impact on the labour force in the value chain through our own practices. This involves obliging our suppliers, including their suppliers, to comply with the requirements described therein.

In order to implement the objectives and actions described here, the management level provides appropriate resources, for example for the costs of the supplier assessment using EcoVadis, the IQ Risk Tool from EcoVadis and the relevant unit in Purchasing. As of January 2025, the management of Corporate Sustainability Management was expanded from one to three equal managers (with an FTE of 2.5). One manager explicitly deals with the strategic organisation of the area of ethical management. Other specialist departments, such as the Legal department or Risk Management, are also involved in human rights issues in the value chain and are given the corresponding human and material resources.