Environmental Protection
Metratec is committed to protecting the environment. As an SME and given our current way of operation luckily we have a fairly small environmental footprint. Thus, Metratec has so far not applied for or received certification according to ISO 14001 or similar environmental certification standards.
Environmental Pollution
Metratec develops, produces, and sells electronic products. Since the actual soldering processes are outsourced to EMS partners, the manufacturing is mainly limited to the setup and testing of PCBs and assembly into housings in some cases.
Material flows associated with these operating conditions are inbound streams of components and soldered PCBs and outbound streams of products. There is a small outbound stream of discarded electronics due to manufacturing errors. This stream is collected and disposed of separately by a specialized disposal company. Electronics disposal is less than 1 ton/year.
Other streams going into the company are packaging materials (mainly cardboard and plastics). Some of this material is reused if still suitable. The rest is collected separately and disposed of with the local trash collection services. Of course we also use packaging materials for our outbound products. For these we are registered and comply with the German Packaging Act.
There is also a small stream of residential type waste as our employees spend some of the working hours at the company and thus produce waste. Again, this is collected in five different categories (paper, organic, packaging, glass and refuse) and disposed of correctly by our (outsourced) cleaning service provider using the usual household trash collection facilities.
Metratec emits a small amount of fluid waste in the form of waste water due to employees using the kitchen and restrooms. This wastewater goes into the normal sewage system.
There are no regular gaseous emissions from the company.
A main stream into the company is electricity as the building is being heated via a heat pump. This is considered a relatively low emissions way of heating. Electricity is also being used for the heating of water for sanitation and cooking purposes as well as operating lights, electrical devices, computers and the like.
Employees are instructed to save energy e.g. by shutting down any devices not in use. These policies and instructions are part of yearly trainings. Electrical lighting is through fluorescent or highly efficient LED lighting and is being transitioned to purely LED lighting as fluorescent tubes reach their life expectancy. Public spaces use motion sensors to activate lights. Office lights are expected to be turned off manually before leaving. This is checked on a regular basis and employees are reminded in case they forget. The building does not have air conditioning.
Within the company, Frank Steyer, our head of operations, is responsible for questions regarding environmental impact. He is to be contacted directly with any issues regarding compliance with environmental laws or suggestions on lowering our environmental footprint.
Employees are encouraged to commute to work via bicycle by supplying sufficient bicycle racks. The company is also easily reachable via public transportation.
Power and water consumption are evaluated yearly by management with the intent of identifying savings potentials.
Metratec is not involved in activities that cause harmful soil contamination, water pollution, air pollution, harmful noise emissions, or excessive water consumption. Such activities would be highly regulated in Germany and the state enforces that these can not be done without permission. Should there be any questions regarding such concerns please contact Frank Steyer or use the whistleblower system to report such activities. No such cases have come to our knowledge and we have never been sued for environmental damages.
Substances of Concern
As Metratec is in the electronics business, our products and processes are strongly regulated with respect to their content of toxic chemicals. This is due to both the EU RoHS Guideline (Regulation 2002/95/EC last updated by Regulation 2015/863) and the EU REACH Guideline (Regulation 1907/2006 last updated by Regulation 2020/2096).
RoHS restricts the use of four toxic heavy metals (lead, mercury, cadmium and chrome-6) and some additives in plastics for use in electronics. Some exemptions apply but usually it can be said that our products are free of these substances. If exemptions apply these are such that there will be no meaningful release of these substances into the environment (lead encapsulated in glass). Beyond what is legally required, Metratec strives to eliminate components that are RoHS compliant only due to the use of exemptions in all cases in which replacements are available under reasonable conditions.
REACH on the other hand applies not only to the electronics industry but more generally in the EU. It regulates many chemical substances deemed to be hazardous to humans.
Metratec does not produce or import any significant amounts of chemicals that are in the ECHA candidate list for such Substances of Very High Concern (SVHCs). As such, we do not need to register our products with ECHA.
We do – however – have a reporting obligation to our customers with respect to any of our products that contain more than 0.1% by weight of any of the substances on the candidate list. This candidate list is appended twice per year by ECHA.
As we use a high number of components from a multitude of manufacturers for our products and since the list of substances on the candidate list always increases we can never be sure that the components we use will not be affected in the future. As an SME we are dependent on the manufacturers of the components we use to report compliance with the current SVHC candidate list – both in timing of the availability of these compliance documents and in the validity of their contents. Our own REACH compliance documentation will thus only reflect our understanding of SVHC content as of the publication dates.
In case we determine that a component we use does contain SHVC candidate list substances or in case a new substance is added to the candidate list that is included in a component we use above the required reporting threshold of 0.1% we will strive to identify an alternative component and replace the component affected. Metratec products will thus be free of SHVC candidate list substances whenever possible.
Due to both RoHS and REACH Regulations and due to the industry we operate in we can state that our products do not contain persistent organic pollutants (POPs) and that we do not use these in our manufacturing processes.
Waste
As described in the subchapter on Environmental Pollution, Metratec takes care to dispose of any waste properly and according to local laws and regulations using subcontractors of good standing. Given the business we are in, Metratec does not import or export waste in any form.
Human Rights & Labour
As a German company, Metratec is part of a closely regulated work environment that gives workers many rights and aids them in enforcing them.
Equal Rights & Discrimination
Treating all employees equally and assuring them of equal rights is an important value at Metratec. Management as a whole is committed to ensuring that this value is upheld. Ethnic origin, age, gender, disability status, religion, nationality, sexual orientation, social background, or political views are never a basis for discrimination.
Apart from the fact that it is illegal in Germany to discriminate against people based on these traits, Metratec has a history of being an inclusive environment in these respects. Most of these traits are none of our business as employers anyhow. Some of them are not even known to us.
As a matter of German employment law, we do not ask about many of these discrimination criteria as part of our recruitment efforts. When confronted with decisions that are influenced by these criteria Metratec tries to take the inclusive approach wherever economically feasible. Basically, if we can accommodate the special requirement within economic reason we will.
As an SME, we are challenged in our efforts to strive for equal representation in relation to the general population of these criteria as we usually do not have a sufficient number of candidates for new positions to be able to choose from.
However, looking at our existing pool of employees it would seem that limited diversity is not an issue. Management is focused on making this diversity possible. During the yearly management review, we check whether diversity according to the criteria we are legally allowed to know has declined or whether there are things we can do to allow employees affected by any discrimination criteria to feel more comfortable at Metratec. So far, there have not been any indications that employee training in this respect is necessary.
In general, as an SME the management team has a lot of direct contact with employees from all departments. In case an employee feels insecure or harassed due to any reason we encourage them to speak with management. In case the person feels uncomfortable about “outing” themself as having an issue there is also an anonymous whistleblower form the employee can use.
Forced Labour & Mistreatment
Metratec is proud of its good working conditions and healthy social environment. Management is absolutely committed to ensuring a work environment without physical, mental, sexual, or verbal abuse and will not tolerate threats or any other form of mistreatment of employees. Of course, most of these threats to a healthy work environment are already illegal in Germany and are easily enforced by contacting the authorities. But behavior that rises to the level of being legally sanctionable is way beyond what we would deem inappropriate behavior and sanction from the side of management.
Our employees are of course aware of this and are in turn encouraged to report any such misbehavior to their direct supervisor or any other person in the management team. Due to Metratec being an SME, there is frequent contact between all members of the company so that anyone has people they can confide in. In case someone feels uncomfortable about reporting such issues directly there is also the whistleblower form to report such issues anonymously. So far there has not been a need to do regular trainings on these issues though the policy is communicated at least yearly to all employees.
Being a company in Germany, we do not need to hire external security services to pressure our employees and any such action would be illegal. Labor relations in Germany are strictly regulated and the authorities will not tolerate any kind of abuse in labor disputes.
Also being a German company, Metratec is committed to rejecting any kind of forced labor and slavery. This is the completely unambiguous commitment by management. For obvious legal reasons, this is also something which is strongly enforced by local authorities.
Child Labour
The education of children is a cornerstone of sustainable and healthy societies. As a company, Metratec and its management are committed to ensuring that children receive a good education and we will of course not be employing children below the legal age limits set forth in German law or international standards.
As an SME, the management team gets to know any candidates for hire and will reject any that do not comply with age restrictions. German labor law also mandates this. As part of employing people, we are required to have their tax and insurance data on hand and both of these would raise immediate red flags if a candidate for employment were to be underage.
Amongst Metratec’s management, there is little doubt that any form of child exploitation is immoral. We will not tolerate any such crimes within our realm of influence.
Working Conditions & Wages
Metratec is a company that prides itself on its good working conditions. Part of these working conditions are the working hours. Employees are only productive and happy if they perceive themselves in a good balance between their work and private lives. Because of this, there is a wide range of latitude with respect to the amount individual employees want to work per week – of course within the legal limits in Germany.
As a European company, we record all working hours as is the law and we do not usually require any overtime. In rare cases where there is an urgent need for certain employees to do overtime that time is then later compensated by leaving work earlier.
Payment is generally based on what is usual in the local labor market and is necessarily above the legal minimum wage in Germany. As legally required, we supply the employer’s part of social security payments (medical insurance, retirement insurance, unemployment insurance, and long-term care insurance). Of course, payment is also not discriminatory along the categories discussed earlier but instead depends on qualification and productivity.
Freedom of Association & Collective Bargaining
As a German company, Metratec is part of the German labor law system which is well known for its protection of unions and the fundamental right of employees to bargain collectively. As an SME there currently does not seem to be a necessity for a works council as no such ambitions have been voiced by the employees. Within such a small organization, direct communication might make this less desirable. Management will not oppose the formation of a works council should such a desire arise on the side of our employees – nor can it due to German law.
Impact on Local Communities
Metratec has in the past acquired land to build an office and manufacturing building. This property was legally bought from the city of Magdeburg and is in an already developed area of the city. No livelihoods of people were negatively affected and no appreciable amount of natural resources (forests/waters) were negatively impacted. Nor could they have as this would be against German law which is strictly enforced in real estate matters.
Anti Bribery & Anti Corruption
Metratec GmbH is currently being managed by its three founders who still own a strong majority of the company. As such, the management team has a strong self-interest to avoid unnecessary or illegal payments in the form of bribes as these hurt the bottom line and the value of the company. All three founders are opposed to corruption and bribery and German society does not require bribery to get ahead in day-to-day operations. The vast majority of all monetary transactions are done electronically – we do not have cash at hand.
As a company, we sometimes receive gifts from suppliers (e.g. for Christmas). These gifts – even if they are addressed to an individual – are considered to be company property and to be shared between all employees. Below a threshold of 25€ (50€ in case of management), gifts can be graciously accepted by the employees but need to be shared as discussed previously. Any gift whose value goes beyond these thresholds can still be accepted and shared but needs to be reported by filling out an online form to allow transparency. Keeping gifts for oneself is considered theft of company property and employees are regularly informed of this and our other anti-bribery and corruption policies.
When interacting with other companies or entities, there is a tendency to be invited to meals or invite employees of other companies to meals.
Invitations by other companies can be accepted by our employees as long as it is within the realm of their usual interactions with these external companies and the assumed value of the meal does not exceed 25€ (50€ for management). Any invitations that exceed these thresholds need to be declined or paid for by Metratec or the employee itself.
When inviting employees from other companies to meals, management needs to approve of the measure and also of it being paid for. Guests need to be listed and a reason for the invitation also needs to be reported. This is also required by German law if such costs are to be considered operational costs.
The people responsible at Metratec for procurement and bill payment are both founders of the company and these two functions do not rest in the same hands. That way, an automatic four-eye principle is established to internally detect and interdict any form of bribery or corruption.
In case an employee feels that these anti-bribery and corruption policies are being violated they are encouraged to report this to their direct superior or any other member of the management team. In case the employee is uncertain or feels uneasy about this there is also an anonymous whistleblower form that can be used. So far, there have not been any such reports but should this change, the reports will be reviewed promptly. Any whistleblower will not be reprimanded or punished for what was reported in good conscience internally.
Metratec’s social responsibility statement (this document) is publicly available to our business partners. As part of our supplier due diligence procedure, we also inform them about our zero tolerance for bribery and corruption. In cases in which we are made aware of the misbehavior of our business partners in this way, we require them to stop, and in case this demand is not adhered to we terminate our business agreement.
Metratec has never been involved in any lawsuits that alleged bribery or corruption.
Health & Safety
Metratec GmbH values the health and safety of its employees both for the sake of their happiness as well as their productivity for the company. Management does everything reasonable to ensure safe and healthy working conditions. Within management, Frank Steyer is the first to contact when safety issues are to be reported and solved. He is also responsible for ensuring compliance with German occupational health and safety laws.
The company has issued a health and safety policy in accordance with its legal obligations and updates this policy as the situation requires. It contains all types of work being done from e.g. desk and office work to soldering and other assembly work. Management enforces adherence to this policy on a daily basis. New processes and devices are inspected for health and safety issues before being used and relevant measures are taken to mitigate any such issues.
This policy is trained yearly with all employees in their respective communication languages – mostly German but also in English if necessary for good understanding. Part of these trainings is to reflect previous incidents if any and to draw conclusions from them to avoid them recurring.
In case accidents occur, these are documented and the lessons that can be learned from them are systematically acted on to make sure that a risk that was previously not correctly identified gets addressed correctly in the aftermath. Also, management reviews accidents that happened in the previous year as part of the general management review and strives to get accident numbers down to zero.
Metratec generally does not have any workplaces that require the general use of protective equipment. There are some activities that do require wearing personal protective equipment but these activities are intermittent. The necessary protective equipment is supplied to any employees impacted by these requirements and use of the equipment is enforced. As part of the general safety instruction/training meetings the correct use of protective equipment is shown. Any new employees are subjected to such trainings prior to being allowed to start working in situations requiring the use of protective equipment.
A certain percentage of employees are always trained and certified in first aid so that in case an accident occurs there is someone knowledgeable to supply first aid.
Supply Chain Responsibility
Metratec is committed to working towards a sustainable and liveable future on this planet. As such, we invest in long-term relationships with our suppliers and expect them to align their business values with a similarly responsible approach.
To further this agenda, Metratec assesses its suppliers along several questions because we find that these play a major role in assessing risks associated with our social responsibilities.
Country: In many states e.g. in the EU and in the USA there exist strong legal protections against forced labor or environmental pollution which are also enforced regularly and reliably by the local authorities. In such states, it is easier to assume that these requirements are met.
Industry: Metratec is in the electronics industry and as such understands that industry better than most others. Suppliers that are also in this industry are thus easier to evaluate with respect to the risks associated with their products and assumed production processes. Also, there is an extensive set of legal requirements that any companies exporting to the EU must fulfill for the electronics industry (RoHS, REACH) which makes assessing environmental impact much easier.
Role in the supply chain: There is a strong difference between whether a supplier is simply a distributor/broker for parts of other manufacturers or a manufacturer themself with respect to the amount of scrutiny that is warranted. Many of our suppliers outside of the EU are only distributors or brokers for the parts we acquire and as such they themselves have small footprints in most of the aspects discussed here. In such cases, the manufacturers of the parts – even if they are not directly our suppliers – have to be and have been evaluated. Since these are usually large corporations, this has the advantage of usually having CSR statements available online. Unluckily, if they don’t, we do not have much influence on them as an SME.
Depending on the outcome of this first assessment, we delve deeper into the suppliers we see as more critical. In general, we ask our suppliers to fill out self-assessment forms that inquire into their human rights, occupational health and safety, environmental, and corruption policies.
As the questions within the questionnaire are asking for information of varying degrees of severity, we have an internal second version that has numbers attached to the optional answers so that we can get a quick numerical value for the assessment. Some questions deemed very important will – if answered incorrectly from our perspective – lead to either strong interventions from our side and changes at the supplier’s side or will lead us to terminate our contractual relationship.
Being an SME, we are currently not directly impacted by laws governing the supply chain. However, since we have a lot of corporate customers that are of much larger size and who are impacted by supply chain laws in their respective countries, we have been subjected especially to delivering Conflict Minerals Reports for some of our products. We are currently in the process of getting the according CMRT widened to cover all our products.
The person responsible for this type of question within Metratec is Frank Steyer (COO). Please get in contact with him in case questions with respect to CSR in the supply chain appear.
Conflicts of Interest
Metratec and its management take conflicts of interest very seriously as these affect decision-making outcomes negatively. In case there is such a conflict of interest, Klaas Dannen is our first point of contact in management.
In general, Metratec as an SME is small enough to have a good overview of the personal connections both within management and in the whole company. Decisions are based on economic criteria ideally taking into account the total costs of any decision. As procurement and sales are handled by different parts of the company in the realm of different managers, and payment is again separated, having conflicts of interest influence decisions is already strongly suppressed (four eyes principle).
Conflicts of interest are a part of our yearly employee trainings that also cover health and safety and other aspects.
As a matter of policy, personal connections are deemed to be off-limits as criteria when making business decisions. This is true for management and also for employees and communicated as such.
As an SME, we also have a good overview as to what employees’ close relatives are doing workwise and there are to the best of our knowledge no close relatives employed by customers. Neither are there any current customers that hold more than 3% in equity of the company. Equally, there are no close relations that have close business relationships with customers or direct business agreements between employees and customers. Overall, we are currently fairly sure that there are no conflicts of interest with any customers.