ANTI-DISCRIMINATION POLICY – THE WIENDELS GROUP (TWG)
Version 2026
1. General principle
The Wiendels Group (TWG) stands for equal opportunities in the labor market.
TWG offers job seekers and employees fair and equal treatment, regardless of:
- age
- sex or gender identity
- marital status
- sexual orientation
- religion, belief, or political opinion
- race, skin color, or ethnic origin
- nationality
- disability or chronic illness
- or any other ground protected under applicable laws and regulations
TWG does not tolerate any form of discrimination, direct or indirect. The only selection criterion TWG applies is: suitability for the position based on competencies, experience, and employability.
2. Purpose of this policy
The purpose of this policy is to clearly and transparently establish:
- What TWG understands by discrimination and discriminatory requests
- TWG’s position toward clients, employees, and third parties
- How employees should act in case of (potential) discrimination
- Where employees can go for consultation, reporting, or escalation
- The responsibilities TWG bears as an employer
This policy is part of TWG’s broader compliance and governance structure.
3. Definition of discrimination
Discrimination is defined as: Making a direct or indirect distinction between persons based on characteristics that are not relevant to the position, as specified in applicable equal treatment legislation.
This explicitly includes:
- Complying with discriminatory requests from clients
- Setting non-relevant selection criteria
- Excluding candidates without objective justification
- Indirect discrimination (e.g., seemingly neutral requirements that disadvantage certain groups) is also emphatically covered.
4. TWG’s position
TWG maintains a zero-tolerance policy regarding discrimination.
- Discriminatory requests from clients are always rejected
- Only objectively justified, job-related requirements are accepted
- TWG expects clients to act in accordance with applicable legislation
- If necessary, TWG will engage in dialogue with clients to correct improper requests and continue the partnership on the correct basis.
5. Actions by employees
All TWG employees have an active responsibility to:
- Recognize discrimination and discriminatory requests
- Refuse to cooperate with them
- Discuss and, where necessary, escalate the matter
In case of doubt
The employee consults with:
- Direct supervisor
- HR / Compliance
When identifying or reporting
The employee can contact:
- Direct supervisor
- Management
- Confidential counselor
Reports are taken seriously, handled confidentially, and followed up without any adverse consequences for the person reporting.
6. Responsibilities of TWG (employer)
TWG ensures:
Safe and respectful work environment
- Respectful interaction is central
- Undesirable behavior is actively prevented and addressed
Implementation and safeguarding of policy
- Active application and periodic testing in practice
- Integration into compliance, audits (SNA / SNF / WTTA), and internal controls
Communication and training
- Policy is provided upon employment
- Structural training and awareness for employees
- Practical instructions for recognizing and handling discrimination
Accessibility
- Publication via intranet and relevant company platforms
- Available to employees, clients, and stakeholders
7. Supervision and compliance
TWG actively monitors compliance with this policy through:
- Internal controls and audits
- HR and compliance monitoring
- Evaluations and incident registration
Violations of this policy may lead to disciplinary measures or termination of cooperation (in the case of clients).
8. Final provision
This policy is periodically evaluated and adjusted where necessary based on:
- changes in laws and regulations
- internal and external developments
- audit findings
Last update: March 2026