The following table presents the policies and statements of commitments dormakaba has adopted to manage material sustainability matters. This disclosure fulfills the minimum disclosure requirements set out in ESRS 2, specifically the obligation to provide transparency on how we prevent, mitigate, and remediate actual or potential sustainability impacts, address related risks, and pursue associated opportunities. All listed policies were developed internally, taking into consideration the interests of stakeholders who may be impacted or who play a role in implementation. For each directive, we describe its key contents, including the general objectives and relevant material topics it addresses. We also specify the scope of the directive, the highest level of accountability within the organization, and any third-party standards we commit to. Where applicable, we indicate whether and how the document is made accessible to relevant stakeholders.
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Name |
Key content |
Relevance to material topics |
Scope and accountability |
Third-party standards/ initiatives |
Availability |
Link |
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Code of Conduct |
It describes our company culture and the shared values that we are committed to worldwide. It is supplemented by further rules and regulations. Content includes: compliance with laws and regulations, health & safety, human rights, conflict of interest, environment, the Supplier Code of Conduct, the values of trust, respect and tolerance, protection against corruption and bribery, fair competition and antitrust law, public relations and confidentiality, the responsibility of each employee and steps in case of misconduct and sanctions (whistleblowing system). |
- Human Rights - Energy & Emissions - Circular Economy & Materials - Fair Employment - Diversity, Equity & Inclusion - Occupational Health & Safety |
Scope: All dormakaba employees Accountability: Signed by the CEO, the Compliance Officer is the author and accountable for implementation. |
- UN Declaration of Human Rights - ILO Declaration on Fundamental Principles and Rights at Work |
Every employee is provided with the CoC. New employees receive it with their employment contract. It is published on the dormakaba Intranet. All employees are notified if major changes are made to the Code. It is available in 22 languages and also made available to the public and to anyone who requests it. |
dormakaba Code of Conduct |
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Statement of Commitment on Human Rights |
The Statement provides a common framework for the company’s human rights due diligence process within our entire value chain. It outlines the international human rights frameworks dormakaba adheres to, and identifies our salient human rights issues (child labor, contributing to conflict, customer safety, environmental issues impacting human rights, migrant workers, outsourced services, occupational health and safety). |
- Human Rights - Forced Labor - Customer Health & Safety - Occupational Health & Safety |
Scope: All fully consolidated operations of dormakaba Holding AG worldwide, including those of direct and indirect subsidiaries. It extends to all individuals throughout the values chain. Accountability: Signed by the Chairman, the VP of Corporate Sustainability is accountable for this Statement of Commitment. |
- Universal Declaration of Human Rights (UDHR) - International Covenant on Civil and Political Rights - International Covenant on Economic, Social and Cultural Rights - ILO Core Labour Conventions - United Nations Guiding Principles on Business and Human Rights (UNGPs) - OECD Guidelines for Multinational Enterprises - Ten Principles of the UN Global Compact (UNGC) - UNICEF’s Children’s Rights and Business Principles (CRBP) - Responsible Business Alliance Code of Conduct - OECD Due Diligence - Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas - ISO 45001 Occupational Health and Safety Management (OHS) - Standard Minimata Convention on Mercury - Stockholm Convention on Persistent Organic Pollutants - Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal |
The Statement of Commitment is published on the dormakaba Intranet and is also made available to the public and to anyone who requests it. |
dormakaba Statement of Commitment on Human Rights |
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Environment Directive |
It regulates minimum business standards on environmental management in manufacturing and product development practices. It includes requirements on resource efficiency, energy consumption, carbon emissions, air emissions, materials restrictions, water and waste management, product circularity and EcoDesign. |
- Energy & Emissions - Circular Economy & Materials - Human Rights |
Scope: All fully consolidated operations of dormakaba Holding AG worldwide, including those of direct and indirect subsidiaries. Accountability: VP of Corporate Sustainability |
- The Paris Agreement - Science Based Targets initiative - ISO 14001 Environmental Management System Standard - ISO 50001 Energy Management System Standard |
This directive is published on the dormakaba Intranet. |
Environment Directive |
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Material Compliance Directive |
The Directive ensures our products meet legal requirements on hazardous substances and responsible minerals sourcing. Currently in final approval stage, it defines roles, sets minimum standards, and will be rolled out across the organization in the next financial year. |
- Occupational Health & Safety - Human Rights - Circular Economy & Materials - Customer Health & Safety - Supplier Sustainable Development |
Scope: It refers to the entire value chain Accountability: VP of Corporate Sustainability |
- IEC 63000 - Minamata Convention - Stockholm Convention - REACH Regulation (EC 1907/2006) - UK REACH (UK SI 2019 No 758) - RoHS Directive (2011/65/EU) - UK RoHS (SI 2012/3032) - Toxic Substances Control Act (TSCA) - California Proposition 65 - Minnesota House File 2310 - Maine PFAS Reporting Law - New Mexico PFAS Reporting and Prohibition Law - EU Battery Regulation (EU 2023/1542) - WEEE Directive (2012/19/EU) - Waste Framework Directive (2008/98/EC) - PFAS Restrictions under REACH and POPs Regulation (EU 2019/1021) - Canadian Environmental Protection Act - Dodd-Frank Act - EU Conflict Minerals Regulation (EU 2017/821) - Hong Kong Ship Convention -German Supply Chain Due Diligence Act - EU Corporate Sustainability Due Diligence Directive |
This Directive will be published on the dormakaba Intranet. A mandatory training will accompany it, aimed at related functions in operations, product management, product development, procurement, and QHSE. |
Not publicly available |
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Employees |
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Responsible Labor Directive |
It regulates the minimum business standards during recruitment, hiring, and employment in terms of freely chosen employment, human treatment, security services, working hours, wages and benefits, the prevention of child labor, freedom of association, and workersʼ accommodation. |
- Fair Employment - Human Rights - Forced Labor |
Scope: All employees, including part-time and temporary workers as well as apprentices and student workers, contract workers, agency workers and casual workers (e.g., day labor workers). Labor Agents and Labor Contractors need to have executed contracts with service agreement requirements to ensure conformance with this Directive. Accountability: CHRO |
- SA 8000:2014 Social Accountability Standard - Universal Declaration of Human Rights (UDHR) International Covenant on Civil and Political Rights - International Covenant on Economic, Social and Cultural Rights - The International Labor Organization’s Declaration on Fundamental Principles and Rights at Work - UN Guiding Principles on Business and Human Rights - UNICEF’s Children’s Rights and Business Principles (CRBP) - The OECD Guidelines for Multinational Enterprises |
This directive is published on the dormakaba Intranet. Trainings have been provided for responsible employees. |
Not publicly available |
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Zero Recruitment Fees Directive |
This directive regulates the business standards regarding fees and costs associated with recruitment. |
- Human Rights - Forced Labor |
Scope: All employees Accountability: CHRO |
- Responsible Business Alliance Code of Conduct and Definition of Recruitment Fees - International Labor Organization’s General Principles and Operational Guidelines for Fair Recruitment and Definition of Recruitment Fee - UN Guiding Principles on Business and Human Rights |
This directive is published on the dormakaba Intranet. Trainings have been provided for responsible employees. |
Not publicly available |
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Total Rewards Directive |
The purpose of this directive is to set the overarching philosophy and principles applying to the rewards programs of dormakaba. It provides a common framework for rewards that is globally valid and used as the basis for any local programs. |
Fair Employment |
Scope: It is binding for all dormakaba Human Resources employees and line managers who are responsible for designing, communicating and implementing rewards programs. Accountability: CHRO |
not applicable |
This directive is published on the dormakaba Intranet. Trainings have been provided for responsible employees. |
Not publicly available |
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Talent Acquisition Directive |
The purpose of this directive is to provide a common understanding and key principles of attracting, recruiting, and onboarding talent across the organization. |
- Fair Employment - Diversity, Equity & Inclusion |
Scope: This Directive is binding for all those dormakaba employees involved in the hiring and onboarding process e.g., Human Resources, Talent Acquisition, Hiring Managers, and anyone in the panel involved in the selection process for both internal and external recruitments. Accountability: VP HR Employer Branding & Talent Acquisition |
not applicable |
This directive is published on the dormakaba Intranet. Trainings have been provided for responsible employees. |
Not publicly available |
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Anti-Harassment and Anti-Bullying Directive |
The directive provides guidance on preventing and managing any occurrence of workplace discrimination, specifically harassment and bullying. dormakaba will not tolerate any form of harassment or bullying and is committed to ensuring that employees are able to work confidently and without fear of harassment, bullying or victimization. |
- Fair Employment - Diversity, Equity & Inclusion |
Scope: All employees , furthermore contractors, interns, helpers and apprentices. Accountability: Global Employee Engagement & DE&I |
- UN Guiding Principles on Busines and Human Rights - ILO Conventions, including the ILO Violence and Harassment Convention |
This directive is published on the dormakaba Intranet in June 2025. Mandatory trainings will be provided to all employees in FY 25/26. |
Not publicly available |
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Occupational Health and Safety Directive |
The directive regulates the minimum business standards in regard to occupational health and safety management and processes at local levels, such as the safety of the working environments and the health of our employees, contractors, and visitors within our facilities. Furthermore, the Directive gives clear guidance on incident data management and on the effective control of facilities and equipment during high-risk activities. |
- Occupational Health & Safety - Human Rights |
Scope: All fully consolidated operations of dormakaba Holding AG worldwide, including those of direct and indirect subsidiaries. Accountability: VP of QHSE |
- ISO 45001 - ILO Guidelines on Occupational Safety and Health |
Thisdirective is published on the dormakaba Intranet. Trainings have been provided for responsible employees. |
Not publicly available |
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Supply Chain |
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Supplier Code of Conduct |
It outlines our requirements towards our suppliers and sub-contractors with regard to human rights, fair working conditions, child labor, health & safety, environmental responsibility, right to audit, business ethics, compliance with applicable rules and regulations, among others. |
- Supplier Sustainable Development - Human Rights - Energy & Emissions - Circular Economy & Materials |
Scope: Material suppliers, service providers and other business partners including their affiliates, officers, directors, agents, employees, representatives, subcontractors, and consultants (the “Supplier”) Accountability: SVP Global Procurement |
- ILO Core Conventions and 1919 (No. 1) - UN Global Compact - UN Guiding Principles on Business and Human Rights |
It is integrated into our online bidding system and is also part of our standard supplier contracts. It is published on the dormakaba Intranet and is also made available to the public and to anyone who requests it. |
dormakaba Supplier Code of Conduct |
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Sustainable Procurement Directive |
The Sustainable Procurement Directive aims to support and facilitate the purchase of products and materials that minimize the harmful effects to the environment from their production, transportation, use and disposition. A related purpose is to implement common supplier sustainability assessment criteria and processes to be used by all personnel that support ethical suppliers of environmentally sustainable products, services, and practices. |
- Supplier Sustainable Development - Human Rights - Energy & Emissions - Circular Economy & Materials |
Scope: All fully consolidated operations of dormakaba Holding AG worldwide, including those of direct and indirect subsidiaries. Accountability: SVP Global Procurement |
- ILO Core Conventions - ILO Declaration on Fundamental Principles and Rights at Work - Responsible Minerals Initiative - ISO 15686 – 5 - UN Guiding Principles on Business and Human Rights |
This directive is published on the dormakaba Intranet. Trainings have been provided for responsible employees. |
Not publicly available |
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Statement of Commitment on Responsible Minerals Sourcing |
The statement provides a common framework for the company’s due diligence process specifically related to the mineral supply chain which may potentially originate from conflict-affected or high-risk areas. It guides our efforts to address the risks associated with the supply chains of minerals identified as high-risk, including tin, tantalum, tungsten, gold, and cobalt. This commitment outlines our strategy to source minerals responsibly, in line with international standards and frameworks. |
- Supplier Sustainable Development - Human Rights - Forced Labor - Circular Economy & Materials |
Scope: The statement covers fully consolidated operations of dormakaba Holding AG worldwide, including those of direct and indirect subsidiaries and applies to all dormakaba employees and managers, including part-time and temporary workers as well as casual workers (e.g., day labor workers) Accountability: Signed by the CEO, the VP of Corporate Sustainability is accountable for this Statement of Commitment. |
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas |
The Statement of Commitment is published on the dormakaba Intranet and is also made available to the public and to anyone who requests it. |
Statement of Commitment on Responsible Minerals Sourcing |
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Terms and Conditions for Labor Agents and Labor Contractors |
These Terms of Conditions (ToC) are derived from our Responsible Labor and Zero Recruitment Fees Directives and extend the same requirements to labor providers, defining the working conditions that they manage on behalf of dormakaba. |
- Fair Employment - Human Rights - Forced Labor |
Scope: Labor providers Accountability: SVP Global Procurement |
- Universal Declaration of Human Rights (UDHR) - The International Labor Organization’s Declaration on Fundamental Principles and Rights at Work - UN Guiding Principles on Business and Human Rights - The OECD Guidelines for Multinational Enterprises - Responsible Business Alliance Code of Conduct and Definition of Recruitment Fees - International Labor Organization’s General Principles and Operational Guidelines for Fair Recruitment and Definition of Recruitment Fee |
It is sent to the labor agent/contractor by dormakaba. Signed copies are kept in the Human Rights Hub - Repository. |
Not publicly available |
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Other |
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Sustainability Communications Guidance |
This guidance defines the application of the sustainability communications activities, especially externally, in order to reduce the risks of greenwashing. The objective of this guidance is to provide an effective and professional approach by the responsible employees as regards to dos and don’ts, and the consistency of key messages and visuals. |
- Marketing & Labeling |
Scope: All dormakaba employees Accountability: VP of Corporate Sustainabilityn |
not applicable |
The Statement of Commitment is published on the dormakaba Intranet. |
Not publicly available |
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