Human Rights Policy Statement

Foreword

As a global enterprise, Probgen recognizes its social responsibility and is dedicated to upholding human rights and environmental stewardship throughout our entire value chain. We proactively identify and address risks related to human rights and environmental concerns, implementing responsible measures to mitigate any identified issues.

Our approach is informed by international standards that assist companies in defining and continually enhancing their commitment to human rights. Key frameworks guiding our efforts include:

  • United Nations Guiding Principles on Business and Human Rights (UN Guiding Principles): These principles provide a global standard for preventing and addressing human rights abuses linked to business activities.

  • Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises: These guidelines offer recommendations for responsible business conduct across various areas, including human rights and environmental impact.

  • OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: This guidance assists companies in respecting human rights and avoiding contributing to conflict through their mineral sourcing practices.

  • Local Legislation: We adhere to pertinent local laws, such as the UK Modern Slavery Act, which is supported by our UK affiliates.

These frameworks emphasize the importance of a due diligence process that enables us to proactively identify, assess, and mitigate violations of human rights or environmental obligations, thereby safeguarding the rights of affected individuals and communities.

Human Rights Strategy

At Probgen, we are committed to conducting all business activities in strict adherence to applicable laws and our Code of Conduct and Ethics.To enhance our commitment to human rights and environmental stewardship, we integrate the due diligence requirements outlined in the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz or LkSG) into our existing management systems, policies, and procedures. This integration encompasses areas such as occupational health and safety, environmental protection, supplier management, and site management.

The LkSG mandates that companies establish a risk management system to identify, prevent, or minimize human rights and environmental risks within their supply chains.

To facilitate compliance, we utilize our company-wide compliance and quality management system. This system provides protected channels for reporting concerns, manages the handling of incoming complaints, and supports comprehensive risk analysis in alignment with LkSG requirements. By embedding these due diligence obligations into our organizational framework, Probgen Biotech aims to uphold the highest standards of corporate responsibility and ethical conduct throughout our operations and supply chain.

Human rights in the supply chain

At Probgen Biotech India Private Limited, we uphold the highest standards of ethical conduct and corporate responsibility.To ensure these principles are maintained throughout our supply chain, we have established comprehensive guidelines that all our suppliers are expected to follow. These standards encompass:

  • Anti-Corruption Measures: Implementing robust policies to prevent corruption and promote transparency in all business dealings.

  • Ethical Research and Development: Conducting research and development activities with integrity, ensuring compliance with ethical standards and regulations.

  • Fair Trade and Competition: Engaging in fair business practices that promote healthy competition and prohibit anti-competitive behavior.

  • Environmental, Health, and Safety Standards: Committing to environmental protection and ensuring the health and safety of all employees and stakeholders.

  • Fair Labor Practices: Providing fair wages, benefits, and working hours in compliance with applicable labor laws and standards.

  • Freedom of Association: Respecting employees’ rights to freely associate and collectively bargain.

  • Non-Discrimination and Fair Treatment: Ensuring a workplace free from discrimination and harassment, where all individuals are treated with respect and dignity.

  • Responsible Sourcing of Materials: Procuring materials responsibly, including avoiding the use of conflict minerals and ensuring ethical sourcing practices.

These principles are integral to our contractual agreements with suppliers. We expect our suppliers to not only adhere to these standards but also to implement appropriate due diligence processes to identify, prevent, and mitigate human rights and environmental risks within their operations. Furthermore, we encourage our suppliers to extend these principles throughout their own supply chains, ensuring that ethical practices are upheld at every level.

By fostering a network of responsible and ethical partners, Probgen Biotech aims to contribute positively to society and the environment, while delivering high-quality products and services to our customers.

Risk management

At Probgen Biotech India Private Limited, we are committed to systematically addressing human rights and environmental risks throughout our value chain. Early identification of such risks is crucial for effective risk management. To oversee our human rights risk management, we have established a dedicated committee comprising key executives, including the Head of Corporate Procurement, Head of ESG Strategy & Impact Programs, and the Head of Global Legal Affairs and Compliance.

Our comprehensive risk management approach encompasses several critical components:

  • Regular Risk Assessments: We conduct ongoing evaluations of potential risks associated with both existing and new suppliers during their onboarding process.

  • Annual Workshops: Insights gathered from yearly environmental, health, and safety workshops inform our risk management strategies.

  • Expert Consultations: Engaging with external human rights experts enhances our understanding and approach to complex issues.

  • Stakeholder Dialogues: We actively participate in discussions with investors, non-governmental organizations, key opinion leaders, and other stakeholders to gain diverse perspectives.

These procedures complement our existing risk management systems tailored to specific areas affected by regulations such as the German Supply Chain Due Diligence Act (LkSG). By integrating these measures, we ensure that the perspectives and expectations of relevant rights holders are considered. Regular company-wide surveys and ongoing dialogues with employee representatives further enrich our understanding and response to potential risks.

This holistic approach underscores our dedication to upholding human rights and environmental standards, reinforcing our commitment to ethical practices and corporate responsibility

Risk analysis

Probgen Biotech India Private Limited adopts a risk-based approach to identify potential risks within our supply chain. Our risk analysis processes are in line with relevant legal requirements, such as the LkSG, and, in some cases, go beyond the prohibitions outlined in the law.

As part of our approach, the Human Rights Committee regularly evaluates (at least annually) whether human rights or environmental legal interests are being violated in our operations or whether there is a potential risk of such violations in our direct or indirect suppliers’ activities. This includes considering the origin and specifications of goods and materials.

If risks for potentially affected parties or the environment are identified, we evaluate and prioritize them based on factors such as business scope, root cause, capacity to address the risks, and materiality. The outcomes of this risk assessment are reported to our Executive Committee.

Furthermore, each new supplier is required to complete a detailed questionnaire that is thoroughly analyzed by our Procurement Department.

This risk analysis is also conducted on an ad hoc basis, especially if credible information surfaces suggesting violations of human rights or environmental obligations by indirect suppliers.

Prevention measures

As a general principle, our suppliers must adhere to our Supplier Code of Conduct, which includes embedded human rights and environmental principles. They are expected to implement these principles within their own supply chain. Direct suppliers are required to allow audits to monitor compliance with the Supplier Code of Conduct.

In case a risk is identified, members of Probgen Biotech India Private Limited’s procurement department must immediately establish appropriate preventive measures or purchasing practices and monitor them based on risk. These measures aim to prevent or minimize human rights and environmental risks and must be enforced across the business areas.

If risks are identified with direct suppliers, preventive measures are put in place and closely monitored. These include clear guidelines the supplier must follow.

If there are credible indications suggesting a potential violation by an indirect supplier, preventive actions will be taken to ensure compliance with human rights and environmental obligations. Suppliers are monitored according to risk analysis results and insights from whistleblower reports.

We provide web-based training on sustainability and human rights for our procurement staff.

The effectiveness of preventive measures is reviewed annually by the Human Rights Committee, with additional reviews as needed, such as during new product or business area launches.

Remedies

If we become aware of potential or actual violations of the prohibitions of the LkSG or our Supplier Code of Conduct, we will take immediate corrective actions to prevent, resolve, or reduce such violations. Any information we receive regarding potential violations by Probgen Biotech India Private Limited or its suppliers will be promptly forwarded to the relevant employees.

For our own operations, remedial measures will ensure that violations are prevented or terminated.

In cases of (imminent) violations in the business area of direct suppliers, we will create a corrective action plan and a timeline to end or minimize the violation, working with the affected suppliers to ensure its effective implementation, assuming the business relationship continues. For indirect suppliers, if there is credible evidence of a (threatened) violation, we will devise a strategy to prevent, end, or reduce human rights or environmental violations and ensure its implementation.

We reserve the right to end the business relationship in line with the LkSG requirements, particularly in exceptional cases. Such cases may include:

  • Serious legal violations

  • Failure to remedy the violation after the allotted time

  • No alternative, less severe actions available, and an inability to influence the situation effectively.

 
 

Complaints proceedings

Probgen Biotech India Private Limited provides all employees and external third parties with protected reporting channels to report violations of external and internal rules, including human rights or environmental risks, as well as violations arising from the actions of direct or indirect suppliers. All such reports are forwarded to and investigated by our compliance organization.

The Compliance Whistleblower System is a company-wide, transparent, public, and accessible complaints process. The system offers a secure reporting channel available 24/7 worldwide in over 20 languages via our digital platform or email, with the option for anonymous reporting.

Employees, managers, customers, suppliers, and other stakeholders can utilize the system, which is technically supervised by an independent operator. Data is stored on protected servers in Germany. The content of the reports is processed exclusively by Probgen, with strict confidentiality of the whistleblower’s identity, unless they choose to report anonymously. In cases of verifiable violations, appropriate disciplinary measures will be taken.

Probgen does not tolerate retaliation against complainants or whistleblowers. Violations of this policy will be treated as compliance violations.

Reporting obligations

​Probgen Biotech India Private Limited regularly reviews its procedures for implementing human rights and environmental due diligence  the German Supply Chain Due Diligence Act (LkSG). These reviews occur at least annually and whenever significant changes arise, such as the introduction of new products, projects, or business areas. This approach aligns with Section 5 of the LkSG, which mandates annual and ad-hoc risk analyses to address any substantial changes in risk exposure. 

The findings from handling information obtained through our reporting channels are incorporated into the evaluation of our procedures, ensuring that our due diligence processes remain effective and responsive to emerging risks. We anticipate publishing updated information on identified risks for the 2024 financial year, their prioritization, and the preventive measures we have defined. This update will be included in our policy statement, which we aim to release by the end of 2024.​

It’s important to note that while the reporting deadline for LkSG compliance has been extended to December 31, 2025, the requirement to conduct due diligence activities, including risk analyses and the implementation of preventive measures, remains unchanged.

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  • Address: P.N. 03 SECTOR 8   LAXMI IND PARK SAI, DERABASSI, MOHALI, 140507, PUNJAB 
  • Phone Number: +91 9896630863
  • Email Address: Info@probgenbiotech.com sanjeev@probgenbiotech.com
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