Policy statement for the Phorms Group on respect for human rights

As a company in the education sector with a focus on bilingual teaching and learning, respect for human rights and the protection of the environment are for us a fundamental component of responsible corporate governance. Indeed, sustainability is in any case one of the core components of the Phorms concept. It is our ambition that human rights and environmental protection should be observed at all of our campuses and should be respected by our partners and suppliers as well. 

This policy statement on respect for human rights complements the Compliance Policy of the Phorms Group (hereinafter: “Phorms”). It is the basis and the benchmark for all guidelines and regulations that ensure that the company’s actions are responsible and ethically irreproachable. The Phorms Group comprises Phorms Education SE and all its associated enterprises pursuant to section 15 of the German Companies Act [Aktiengesetz, AktG].

1.    Our commitment

Respect for human rights and the protection of the environment are fundamental values at Phorms. 

Consistent with the United Nations Guiding Principles on Business and Human Rights, we support the principles expressed in the following internationally recognised frameworks and standards: 

•    the International Bill of Human Rights
•    the Declaration of the International Labour Organization (ILO) on Fundamental Principles and Rights at Work 
•    the United Nations Guiding Principles on Business and Human Rights
•    the United Nations Universal Declaration of Human Rights 
•    the United Nations International Covenant on Civil and Political Rights
•    the United Nations International Covenant on Economic, Social and Cultural Rights
•    the conventions and recommendations of the International Labour Organization (ILO) on working and social standards
•    the Declaration of the International Labour Organization (ILO) on Multinational Enterprises and Social Policy (MNE Declaration)
•    the guiding principles of the Organization for Economic Cooperation and Development (OECD) regarding multinational enterprises
•    the principles of the Global Compact of the United Nations (UNGC)
•    the Charter of Fundamental Rights of the European Union (CFR).

This policy statement will be communicated to employees, direct suppliers and the general public, particularly via the company’s website www.phorms.de.
It is our intention to continuously optimise our corporate actions and our services in respect of their sustainability. 

2.    Applicability

This policy statement applies to our employees in all areas of the company and at each of our campuses. With these standards we obligate all employees to conduct themselves towards colleagues, business partners and the community in a way that is both appropriate and lawful. We expect of our business partners that they will in turn pass on our commitment to a respect for human rights to their business partners and that they will act with integrity and in a way that is ethically irreproachable. 

3.    Risk analysis

Phorms is aware of its obligations pursuant to the German Supply Chain Due Diligence Act [Lieferkettensorgfaltspflichtengesetz – LkSG] and, accordingly, has established an appropriate and effective risk management system to ensure that it observes its duties of care as defined in the act. 

The aim of this risk analysis is to obtain information about the human rights and environment-related risks in our own field of operations as well as our supply chains, to prioritise these risks prior to further processing and, if necessary, to adopt appropriate measures. The risk analysis is conducted annually and, additionally, on a case-by-case basis.

4.    Complaints procedure and accountability

If it is established that there is a risk and that our business activities are having – directly or indirectly – negative impacts on human rights, we have a procedure in place to evaluate, modify, discontinue and/or correct this activity. We encourage our employees to report possible breaches of this policy statement on human rights. Such reports can be made to the local management team, the HR department or the central contact point for the reporting of breaches of this policy statement, which is to be found in the legal department of Phorms Education SE. Our employees, partners and third parties too can report potential breaches of this policy statement on human rights via compliance@phorms.de. It is also possible to report such breaches at any time to the responsible authorities. 

Several specialist departments participate in the operational implementation of the due diligence processes related to human rights and environmental protection. These departments make human resources available for ensuring compliance with the Supply Chain Due Diligence Act and report regularly as well as on a case-by-case basis on their findings. The risk management system ensures that our human rights strategy is firmly rooted in all relevant business processes.

5.    Preventative and remedial measures

In order to fulfil our responsibility to respect human rights, we rely on a combination of various preventative measures in our own area of business operations as well as with our direct suppliers. Our primary goal is to protect persons who are potentially affected and to identify, prevent or at least minimise negative impacts on human rights and environmental protection. To this end, we are developing standardised processes and procedures at Phorms. 

We will regularly communicate this policy statement as well as the human rights strategy on which it is based both internally (e.g. to employees) and externally (e.g. to suppliers). The values that underpin this policy statement will be a constituent part of all future contractual relationships of the Phorms Group. 

6.    Reporting

Our engagement with the topic of human rights and the conducting of a corresponding risk analysis is an ongoing process at Phorms. We will report on our progress in the implementation and development of our policy in our Supply Chain Due Diligence Act report, which will be published annually on our internet page www.phorms.de pursuant to section 10 of the Supply Chain Due Diligence Act. We will also report to the Federal Office for Economic Affairs and Export Control [Bundesamt für Wirtschaft und Ausfuhrkontrolle – BAFA]. 

7.    Next steps

Consistent with our culture of continuous improvement, we will conduct regular evaluations and checks to determine how we can best optimise and strengthen our approach to dealing with human rights in our sphere of influence. 

8.    Final Provisio

This policy statement for the Phorms Group on respect for human rights was passed by the managing directorate of Phorms Education SE on 1st December 2023.