Page 1 / 5Modern Slavery Statement 2020/21

Classification: Publicdormakaba Modern Slavery Statement 2020/21
This statement is made pursuant to the Australian Modern Slavery Act 2018 and the UK ModernSlavery Act 2015 and sets out the steps dormakaba has taken to ensure that slavery and humantrafficking is not taking place in its supply chains or in any part of its businesses.
dormakaba is fully aware of the importance of the above Modern Slavery Acts and highly appreciates this valuableapproach to eradicate slavery and human trafficking from all areas of life. dormakaba also acknowledges its
responsibility to respect human rights as outlined in the United Nations Guiding Principles on Business andHuman Rights (UNGP). Further, the company is fully committed to uphold the principles of and adherence to its
Group policies covering human rights, forced, compulsory or child labor, environmental responsibility and businessethics.
About dormakaba
dormakaba makes access in life smart and secure. We are one of the leading companies in the global accesssolutions market. With our comprehensive portfolio and strong brands, we offer our customers products, solutions
and services for access to places, buildings and rooms from a single source. dormakaba has distribution channels
and production facilities in all of the industries’ key markets and will accelerate global expansion through astrengthened presence in Europe, the Americas and Asia Pacific. The company is present globally in over 130
countries by own activities and numerous partners. dormakaba has a strong Pool Shareholder Group that will ensure
its long-term-oriented strategy.

dormakaba has divided the areas of business in which the company is globally active into five segments. AccessSolutions (AS), which comprises four segments, is structured by region: AS AMER (North and South America), AS
APAC (Asia-Pacific), AS DACH (Germany, Austria, and Switzerland) and AS EMEA (Europe, Middle East, andAfrica). The other globally focused segment is Key & Wall Solutions with two Business Units, Key Systems andMovable Walls.
The four AS segments include all hardware- and software-based components, products, and solutions for accesssolutions as well as relevant services. The offering includes the global product clusters Door Hardware, Entrance
Systems, Electronic Access & Data, Interior Glass Systems, Lodging Systems, Mechanical Key Systems, Safe
Locks and Services, as well as local products. The portfolio ranges from door technology solutions, automatic door
dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakabagroup.com

Page 2 / 5Modern Slavery Statement 2020/21

systems, a wide variety of fittings, door closers and stoppers, and locking systems – from cylinders, keys, andlocks all the way up to fully networked and cloud-based electronic access solutions for companies, public facilities,
hotels, and many other applications. The range also includes physical access systems, high-security locks, glass
fittings, solutions for workforce management, as well as services for all these applications.
The segment Key & Wall Solutions features a high-performance range of key blanks and mechanical, electronicand (semi)-industrial key-cutting and origination machines. In addition, the portfolio also covers automotive
solutions such as vehicle keys, transponders as well as key programming devices and duplication equipment. The
segment also specializes in partitioning systems with its two product groups Acoustic Movable Partitions (bothvertical and horizontal) and Glass Horizontal Sliding Walls. Partitions are available from a manual application tofully automatic / electronic walls.
The most utilized raw material types include brass, zinc, aluminum, nickel silver, high-alloy special steels andglass. Indirect expenditures consist predominantly of capital goods and services. The global purchasing volume ofdormakaba corresponds to approximately 47% of total sales. The number of active suppliers for goods andservices is approximately 25,600 with spend focused in Europe (47%), North America (26%), and Asia (18%). In
the financial year 2020/21, dormakaba launched an initiative to consolidate and reduce the supplier base in orderto leverage synergies, build strong supplier relationships and support better due diligence processes.
Policies
I. dormakaba Code of Conduct
The company’s core values and principles are defined in the dormakaba Code of Conduct, which contains rules
and requirements specifically regarding human rights, forced, compulsory or child labor and compliance with allapplicable law and legal regulations in the following sections:••••Section C1: Compliance with the law and internal regulations
Section C2: Human Rights
Section C3: Trust, respect and tolerance
Section C12: Supplier code of conduct.

II. dormakaba Statement of Commitment on Human Rights
In line with the “Protect, Respect, Remedy” framework provided by the UN Guiding Principles on Business andHuman Rights (UNGPs) and as outlined in the company’s Statement of Commitment on Human Rights,
dormakaba recognizes the important role the company has in respecting human rights. The company is guided byinternational human rights frameworks, which include but are not limited to the UNGPs, the Universal Declarationof Human Rights (UDHR), the International Covenant on Civil and Political Rights, the International Covenant on
Economic, Social and Cultural Rights, the Core Labor Conventions of the International Labor Organization (ILO)
and the OECD Guidelines for Multinational Enterprises.
The dormakaba Statement of Commitment on Human Rights specifies the company’s commitment to support andrespect human rights for all people, as outlined in the dormakaba Code of Conduct. The objective of the Statementof Commitment is to provide a common framework for the company’s responsibility to respect human rights that is
globally valid and underlies all its business activities and partnerships. It introduces a more effective and proactive
management approach on human rights for the Group.
The Statement of Commitment clarifies:•
the relevant international human rights frameworks that the company subscribes to•the company’s salient human rights issues•
the company’s human rights due diligence framework describing the appropriate policies and processes
to implement its human rights commitment.
dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakabagroup.com

Page 3 / 5Modern Slavery Statement 2020/21

Among the broader human rights issues identified, dormakaba commits to focus on the following salient humanrights issues (in alphabetical order):
••
•
•
••
•

Child labor
Contributing to conflict
Customer safety
Environmental issues impacting human rights
Migrant workers (forced labor)
Outsourced services
Occupational health & safety

III. dormakaba Supplier Code of Conduct
dormakaba is committed to leverage its purchasing power to the benefit of those partners and suppliers whichalign most closely to its values and sustainability objectives. The company has already taken important steps in
embedding sustainability in its supply chain, namely by setting expectations to its suppliers. The dormakaba
Supplier Code of Conduct (SCoC) outlines minimal requirements with regards to human rights, fair working
conditions, environmental responsibility and business ethics. The SCoC includes three main sections of specificbearing to the topic of forced or compulsory labor, namely human rights, fair labor conditions and stipulations on
the suppliers’ own procurement practices. The latter relates to the expectation that suppliers guarantee that theirown suppliers adhere to the SCoC.
The dormakaba SCoC is integrated in the company’s online bidding system. It is further included as part of new
standard contracts. In addition, dormakaba has developed a user-friendly explanatory document of the SCoC
which is used to raise awareness.
General risk assessment as part of materiality process
As part of the company’s process for defining the material topics of its sustainability strategy, dormakaba focusedon the results of a study-based impact assessment of sustainability topics along its value chain. The aim was toconcentrate efforts where dormakaba can have the most impact on sustainable development. The analysis
included dormakaba data from procurement, sales, production and human resources. This was overlaid with over
50 risk indicators from social hotspot databases, the World Bank and the Organisation for Economic Co-operationand Development (OECD). The impact assessment showed that the potential impacts for the topic forced orcompulsory labor are evaluated as below medium with a balanced impact distribution along the value chain.
Geographically, the general risk is seen as high in China, India, Taiwan and Hong Kong. However, the industry
exposure along the value chain is lower than the average risk.
Human rights due diligence
In the course of the development of the Statement of Commitment on Human Rights, dormakaba notedthat migrant workers are known to be a particularly vulnerable group in today’s value chains. They are often facedwith unequal treatment, discrimination and abusive and fraudulent recruitment processes such as the deception
about the nature of the job, retention of passports, illegal wage deductions, or unethical business practices byrecruitment agencies, which sometimes charge high recruitment fees and related costs set up as loans they haveto pay back. Until the worker is able to pay his or her debt, he or she is trapped in debt bondage, a form of forcedlabor.

dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakabagroup.com

Page 4 / 5Modern Slavery Statement 2020/21

To gain a better understanding of migrant workers’ risks and vulnerability at dormakaba, the company carried out
a survey to examine where we employ migrant workers, what type of work they were doing, which countries theycame from and whether recruitment agencies were used in the recruitment process. Results were then compared
to a country-based migrant workers risk index provided by Verisk Maplecroft. Around 600 foreign workers wereemployed by dormakaba in 12 countries categorized as high or extreme risk for migrant workers by the index. In
nine of these countries, migrants were employed for low-skilled jobs in production. This worker profile isconsidered more vulnerable to exploitation than office workers. The countries of origin of the foreign workers werealso examined, excluding migration patterns from industrialized nations to emerging nations from the analysis. In
only three countries – Malaysia, Russia and Taiwan – were third-party recruitment agencies used, which wasanother indicator of potential risk.
Based on the analysis, the geographical scope for an on-site social audit based on standards from theResponsible Labor Initiative, of which dormakaba is a member, was set for Malaysia and Singapore. The audits
revealed, for example, that migrant workers under employment had paid recruitment fees. Various prevention andmitigation measures have been developed through a series of workshops with local stakeholders to raiseawareness, assess root causes and to develop solutions in a collaborative way. Besides priority findings related torecruitment fees, other findings related to due diligence processes for recruiters, and lack of communication on thedormakaba whistleblowing mechanism were discovered. Mitigation measures include, amongst others:• Development of service agreement templates for labor agents and labor contractors to better address
freely chosen employment and responsible recruitment practices• Requirements for pre-departure training for foreign migrant workers on recruitment fees and thedormakaba whistleblowing system• Development of a responsible recruitment self-assessment questionnaire for pre-contracting/prequalification phase with labor agents and labor contractors
To remediate adverse impacts, all foreign migrant workers were interviewed to collect information on recruitment
fees paid. We committed to fully reimburse recruitment fees dating back to those that had been paid even ten
years ago. We also developed a Responsible Labor Directive as a result of policy gaps discovered in the course ofsocial audits. The aim was to give more concrete guidance and minimal standards on topics such as freely chosen
employment and responsible recruitment on a global level. This was supplemented by a specific Zero Recruitment
Fees Directive as a further preventative measure.
Supplier assessment
The company applies a comprehensive self-assessment for all potential new suppliers as part of the supplierqualification process. This general self-assessment includes basic sustainability elements, such as managementpractice related to social benefits, formal employee suggestion programs, and environmental management
systems.
In addition, dormakaba has categorized its supply chain based on sustainability risk factors on a country-level,procurement spend, and material content of the goods purchased. Based on this categorization, suppliers areinvited to participate in an off-site assessment covering 21 sustainability criteria across four themes (environment,labor and human rights, ethics, sustainable procurement) conducted by a leading provider for monitoringsustainability in global supply chains called EcoVadis. In the financial year 2020/21, dormakaba invited around 450
suppliers to participate in the assessment. We saw substantial improvements in the participation rate, with 146
suppliers joining the assessment versus 86 in the previous reporting year. Of the 146 assessed suppliers, 37%
achieved a bronze, silver or gold rating by EcoVadis, considered as moderate or advanced performance.

dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakabagroup.com

Page 5 / 5Modern Slavery Statement 2020/21

However, the majority of assessed suppliers (55%) had only partial performance, with an additional 8% considered
to have insufficient performance. Improvement plans for 45 suppliers were requested.
To examine our suppliers’ situation on-site, dormakaba also developed a standard audit questionnaire that
contains topics related to quality system management. Among these, sustainability topics such as internal Code ofConducts, the dormakaba SCoC, and labor, health and safety and environmental standards are checked. Auditors
are asked to check documentation on-site related to:• Workers ages and identity records• Receipt of wages• Training and communication on internal Code of Conduct• Signature of the dormakaba SCoC
• Hazardous materials storage and worker training on safe handling• Injury rates• Development of water, energy and waste metrics over recent years.
In the financial year 2020/21, dormakaba conducted on-site audits for 26 suppliers in China. Regarding
sustainability criteria, there were no findings of non-conformance for social indicators.
dormakaba developed procedures and process flows for auditing rules and corrective action plans in terms ofsustainability performance of suppliers, which have been rolled out in the financial year 2020/21. At its core is theintegration of a sustainable development clause in contracts for new suppliers and for existing suppliers in thecourse of contract renewals. The sustainable development clause establishes and describes the suppliers’
obligation to participate in off-site assessments and/or on-site audits, and to commit to and implement animprovement plan if performance is below defined benchmarks.
Training
To raise more awareness sustainability and human rights issues in the supply chain, including forced labor, asustainability training for our procurement professionals specifically focused on the supplier sustainability
assessments (sustainability procurement targets, risk categorization of suppliers, EcoVadis assessment process,new escalation processes) was carried out. As at 30 June 2021, the training module had 320 participants.
dormakaba is committed to building on this approach in the coming years in view of its responsibilities as a good
corporate citizen.

Sabrina Soussan,
Chief Executive Officer, dormakaba Group
26 August 2021
The information in this Statement has been approved by the Board of Directors of dormakaba Group and relates to the 2020/21 financialyear. The scope included in this Statement covers fully-consolidated operations worldwide, including those of direct and indirect
subsidiaries.

dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakabagroup.com