1. Publisher and purpose
This statement is made by:
SCANDIC ASSETS FZCO
Dubai Silicon Oasis DDP
Building A1/A2
342001 Dubai / UAE
Business License Number 050-3124863
This declaration is issued for:
Website: https://www.alexbodi.com
E-mail: [email protected]
Telephone: +971 56 929 86 – 90.
We want to respect human rights, avoid unlawful environmental damage and pursue appropriate preventative and remedial measures when risks are identified. This declaration is a framework for responsible action. It is not blanket proof that all suppliers and subcontractors have already been fully audited or that all conceivable risks have been excluded.
Status:
To the extent that legal obligations apply to this declaration, the respective prescribed procedures, content, documentation and reports are also actually fulfilled.
2. Applicable law and voluntary standards
The German Supply Chain Due Diligence Act (LkSG) does not automatically cover every foreign company with a website accessible in Germany. Its legal requirements, in particular a corresponding presence in Germany and the relevant employment thresholds, must be examined specifically. The commissioning of German service providers does not in itself justify direct applicability.
The European Directive on Corporate Sustainability Due Diligence, Directive (EU) 2024/1760, should be considered together with its amendments, in particular the Directives (EU) 2025/794 and (EU) 2026/470. It is not a general supply chain obligation that already applies equally to every company. National implementation, company and sales thresholds as well as the changed application dates must be taken into account.
In addition, product-related bans, sanctions, import regulations, occupational safety, environmental and other regulations may be relevant regardless of these thresholds. The Regulation (EU) 2024/3015 on products from forced labor is an independent set of regulations. A company cannot therefore conclude that every delivery is legal simply because it does not reach an LkSG or guideline threshold.
The internationally recognized human rights, the basic principles of the International Labor Organization, the UN Guiding Principles on Business and Human Rights and the OECD Guidelines serve as voluntary guidance. Legal obligations, contractual commitments and voluntary goals are expressly kept apart.
3. Human rights expectations
We reject forced labor, human trafficking, debt bondage, exploitative child labor, unlawful discrimination and violence or intimidation in the workplace. Personal documents must not be unlawfully retained in order to bind people to an employment relationship. Working and recruiting conditions should be understandable, comprehensible and legal.
Employees should be able to exercise their applicable rights to appropriate pay, occupational health and safety, legal working hours, freedom of association and collective bargaining. The specific legal structure depends on the relevant regulations; Different local rules do not justify conscious participation in serious human rights violations.
Particular attention will be paid to vulnerable groups and individuals who are exposed to increased risks due to language, migration, disability, economic dependency or a lack of effective advocacy. Their perspective should not be replaced by questionnaires aimed exclusively at a supplier's management.
4. Environmental expectations
We expect the lawful handling of hazardous substances and waste as well as appropriate measures to protect employees, residents and natural resources. Harmful soil, water or air changes, excessive water consumption and other impacts are particularly relevant when they affect protected rights and basic living conditions.
To the extent that the LkSG is applicable, its specific human rights and environmental bans must be observed. This also includes legal references to mercury, persistent organic pollutants and hazardous waste. These specific bans cannot be equated with a blanket legal guarantee of complete climate or environmental neutrality.
Voluntary environmental goals should be comprehensible, measurable and clearly defined in their scope of application. Terms such as “sustainable”, “environmentally friendly” or “climate neutral” must not be used as a comprehensive characteristic of all products or supply chains without a reliable basis.
5. Responsibility and organization
Management is responsible for the adoption and appropriate implementation of these principles. Clear responsibilities and escalation channels have been defined for procurement, personnel, business partner verification, product responsibility, technical security and complaints, all under the responsibility of SCANDIC ASSETS FZCO.
To the extent that responsibility for monitoring risk management is required by law, it is actually assigned and with sufficient authority. The naming of an external legal advisor or product expert in the legal notice does not replace this. A human rights officer is not automatically appointed by this declaration.
Relevant decisions should be documented. Business and purchasing decisions must take into account the identified risks; Care must not be limited to a purely formal signing of supplier terms and conditions. Responsible people need adequate information, time and opportunities to act.
6. Identification and assessment of risks
We take a risk-based approach to our own business area and the relevant supply relationships. The starting points are actual goods and services, production and performance locations, recruitment channels, key upstream suppliers, known sectoral risks and comprehensible external information. Not every business relationship needs to receive the same level of scrutiny, regardless of its risk.
When prioritizing, particular consideration must be given to the severity of a possible impairment, its extent, the probability and the possibilities of reparation or remedial action. Where the LkSG applies, its standards of appropriateness, ability to influence and one's own contribution to the cause are added. An economically low scope of delivery does not exclude a serious human rights risk.
Risk warnings should not automatically be treated as established violations. They must be properly checked and compared with available information. The assessment must be updated in the event of significant changes in business activities or reliable new information. If annual or event-related inspections are required by law, these must be carried out on time.
7. Actual priority risks
The priorities must emerge from a real risk analysis. A general industry list is not a substitute for the risks identified in your own company. For a policy statement that may be required under Section 6 Paragraph 2 LkSG, the company-specific findings and expectations required there must be specified accordingly.
Results of the actual risk analysis are published on 31. Published in December of a current year.
Prioritized measures:
For each identified risk, responsible functions, measures, deadlines and effectiveness criteria are supplemented by the SCANDIC ASSETS FZCO. Without appropriate data, it is neither claimed that there are no risks nor is full coverage of all supply chains guaranteed.
8. Prevention in your own business and with direct partners
Appropriate prevention measures can include risk-appropriate selection processes, understandable expectations, training, appropriate contractual regulations, controls and adapting your own purchasing practices. Measures are selected according to the respective risk; Obtaining a blanket form should not be the only response to a known serious problem.
Comprehensible expectations are communicated to direct suppliers. It must be clarified how relevant standards can be supported in their own business area and with risk-relevant subcontractors. Audit and information rights must be lawful, proportionate and practically appropriate.
Our own legal due diligence obligations are not passed on across the board to small suppliers. In particular, a supplier should not have to provide an unrestricted guarantee for all unknown precursors if such a guarantee is neither actually fulfillable nor legally appropriate. Effective risk-based collaboration and documented decisions are crucial.
9. Indirect suppliers and new information
If there are concrete indications of risks from indirect suppliers or other upstream actors, the appropriate and legally required steps are examined. If the LkSG is applicable, the corresponding event-related obligations are based in particular on its requirements for substantiated knowledge.
An indirect contractual relationship does not automatically release you from all responsibility, but it does not always lead to the same direct control options as in your own company. It must be determined what information and influence options actually exist and what measures are appropriate given the severity of the problem.
Information from employees, unions, affected communities, civil society organizations and authorities may be relevant. Your evaluation should be objective and without a blanket devaluation of critical sources. To protect affected people, the disclosure of identifying information must be limited.
10. Business partner integrity and CRIF
The contractually agreed cooperation with CRIF Germany, https://www.crif.de, concerns KYC, KYB and AML depending on the specific order. KYC (“Know Your Customer”) includes customer identity verification. KYB (“Know Your Business”) includes the examination of companies, their existence and relevant representation or ownership information. AML (“Anti-Money Laundering”) refers to measures against money laundering.
These procedures can help assess the identity and integrity of a business relationship. However, they do not replace a human rights risk analysis, an examination of working conditions or an environmental site assessment. A positive identity check does not prove that a supplier has no human rights or environmental risks.
The processing of personal data must be lawful, necessary and transparent. No comprehensive personal background checks of all employees will be authorized based solely on this policy statement. Misattributions, incorrect data and unsubstantiated suspicions require appropriate verification.
11. Product testing and technical safety
The contractually agreed product testing is carried out for the respective test items in collaboration with the Slow Medicine Research Institute, HP Prof. Dr. rer. nat. Dieter Lazik, Olympic Trail 7, 14471 Potsdam, carried out. The task, method and limits of information must be comprehensible for the specific result used.
A product test is neither a comprehensive supply chain test nor a certification of all working and environmental conditions at production sites. A test result may only be used for the properties actually examined. The legal obligations of a manufacturer, importer, dealer or other economic actor remain to be determined independently.
The technical monitoring of certain applications is carried out by Darktrace, https://www.darktrace.com, supports. This can help protect information and digital service relationships. However, technical security monitoring does not replace a human rights complaint procedure or a social or ecological assessment. There is no guarantee of completely secure supply chains.
12. Complaints and involvement of affected people
References to human rights or environmental risks can be made [email protected] with the subject “Supply Chain / Confidential Notice”. Access should not depend on the person providing the information being a direct contractual partner of the company. Notices should be as specific as possible without disclosing unnecessary personal information.
For particularly sensitive information, a suitable, secure transmission route must first be agreed upon. An ordinary email inbox is not an automatically anonymous reporting channel. If an independent, anonymous or specially protected procedure is set up, its actual functionality and accessibility will be published.
Good faith reports should be possible without retaliation. Processing should be carried out professionally, impartially and confidentially to the extent permitted by law. The interests and protection needs of affected persons must be taken into account. To the extent that the LkSG applies directly, a publicly accessible procedural code with the legally required features must be established; Simply providing an email address is not automatically sufficient.
Legal rights to report to authorities, to complain or to take legal action remain unaffected. This statement does not require any prior internal notice as a condition of such rights.
13. Remedy for identified injuries
If we discover a breach or if it is imminent, we will review necessary and appropriate steps to prevent, terminate or minimize it. To the extent that one's own activities contribute causally, the reaction must take this own role into account. Simply making a request to a supplier is not enough if our own procurement conditions are part of the cause of the problem.
Appropriate steps may include a concretely timed improvement plan, protection of affected individuals, changing work or procurement practices, redress within the framework of accountability and professional support. Goals, responsibilities and effectiveness must be clearly defined.
Termination of the business relationship is not presented as a universal standard solution. The severity, persistence, prospects of success of remedial action and possible negative consequences for those affected must be examined. Where legal requirements or a serious risk that cannot be controlled otherwise requires this, suspension or termination may be necessary.
14. Effectiveness testing and documentation
The effectiveness of the measures should be checked using comprehensible information. Pure activity figures such as questionnaires sent out or training hours completed are not sufficient if it remains unclear whether the actual situation has improved. Remedies achieved, recurring causes and remaining risks can be particularly informative.
Significant findings, decisions and measures must be appropriately documented. To the extent that the LkSG applies directly, the applicable documentation and storage obligations must be observed; § 10 Paragraph 1 provides for at least seven years of storage of the legally required documentation. Personal data will not be stored unchecked for longer than legally required.
Public reports must be prepared truthfully and in compliance with legitimate confidentiality and data protection interests, provided there is a corresponding obligation or reporting is voluntary. The existence of this website statement does not replace any legal documentation or required annual report.
15. Update and adoption
These principles are reviewed in the event of significant changes to business activities, risks or legal requirements. Findings from complaints, technical audits and business relationships should be incorporated into further development. Open implementation steps are not presented as measures that have already been completed.
Status: 01. October 2026.