Modern Slavery Act Transparency Statement

The following statement constitutes our company’s slavery and human trafficking statement with regards to the Modern Slavery Act 2015 for the financial year ending December 31st, 2020. The Modern Slavery Act seeks to address the role of businesses in preventing slavery and human trafficking from occurring in their business and supply chains.

Structure and Supply Chain

Sennheiser (UK) Limited is a wholly-owned subsidiary of Sennheiser electronic GmbH & Co. KG, which is a family owned company from Germany. Sennheiser now adds up to more than 2,450 employees all over the world. We have presence on all continents of the world Our plants are located in Germany, Ireland, USA and Romania. In addition, we closely work together with our Asian partner companies. Our supply chain extends through various tiers from strategic manufacturing partners, to componentry and materials suppliers, to raw material sources.

Policies on Modern Slavery

As a member of the Zentralverband Elektrotechnik- und Elektronikindustrie e.V. (the German Electrical and Electronics Industry – ZVEI), we have undertaken to comply with the “ZVEI Code of Conduct for Corporate Social Responsibility”. We hereby declare our support for the values and principles established by the Code. The Code of Conduct is founded on the cornerstones of internationally valid agreements. These include the United Nations “Universal Declaration of Human Rights”, the core labour standards of the International Labour Organisation (ILO) and the principles of the Rio Declaration on Environment and Development. Our actions follow the applicable laws and regulations of the countries in which we are active. The Code of Conduct acts as a guideline for the business behaviour of our employees in all corporate divisions and subsidiaries worldwide. We promote observance of the contents of the Code of Conduct on the part of our suppliers and their partners within the bounds of our respective abilities and spheres of action.

We respect and promote human rights as formulated in the United Nations “Universal Declaration of Human Rights”. We reject all forms of discrimination, forced labour and child labour.

In accordance with ILO core labour standards, we set great store by fair labour conditions, a safe working environment and appropriate remuneration for our employees. We likewise respect and support the right of our employees to freedom of assembly as well as collective bargaining.

We are committed to improving our practices to ensure that our preventive and remedial efforts continue to be relevant, timely and effective.

Due Diligence Process

All Sennheiser suppliers are required to read, review, and confirm in a written form their commitment to abide by Sennheiser’s (ZVEI) Global Supplier Code of Conduct, which includes relevant provisions prohibiting the use of involuntary or slave labor. The Sennheiser Code of Conduct further requires suppliers to certify their compliance with all such relevant laws. Per the terms of the Sennheiser Code of Conduct, Sennheiser regularly audits its suppliers itself or by certified independent auditing agency, including unannounced inspections of suppliers’ manufacturing facilities and employer-provided housing. In the event violations are found, the suppliers are required to take corrective action, and if the violations are not timely and satisfactorily remedied, Sennheiser terminates its relationships with such suppliers.

Suspected violations can be reported to local Human Resource functions or the Corporate Compliance Manager. If desired, suspected violations may also be reported to a central e-mail account which is owned by the responsible member of the Executive Management Board as well as the Head of Corporate Legal and the Corporate Compliance Manager.

Moreover, Sennheiser provides internal training to its supply chain management associates on issues regarding human trafficking and slavery to enable them to appropriately monitor Sennheiser suppliers’ compliance with the Sennheiser Code of Conduct.

Risk Assessment

The Sennheiser Group has implemented a risk management system which is designed to ensure the early identification, assessment and treatment of risks. Risks pursuant to social responsibility topics that relate to environmental, employee and social issues, as well as human rights, corruption and bribery are included. The Executive Management Board receives a report on the main risks of the company once a year.

This statement is made pursuant to s54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 31st, 2020.

This statement was approved
by the Managing Director of Sennheiser (UK) Limited