Compliance
Digital whistleblower system
This whistleblower system is for use by employees and third parties to report suspicious cases within Thomann GmbH, its subsidiaries and affiliated companies (hereinafter “Thomann”) in accordance with §15 of the German Stock Corporation Act.
It enables the anonymous reporting of rule violations and suspected cases of non-compliance, and is for the purpose of prevention, clarification and resolution.
As a family business, taking responsibility is firmly anchored in our company philosophy.
In terms of compliant and law-abiding behavior, we place very high demands on ourselves that generally go beyond what is required by law.
Therefore, preventing damage (material and immaterial) caused by non-compliance with legal regulations and/or internal company rules is of the utmost importance.
We encourage all stakeholders (suppliers, service providers, purchasers, employees, applicants and others) to report compliance violations to us, as this is the only way to identify and remedy misconduct at an early stage.
This digital whistleblower system is available to all whistleblowers. It is a secure reporting channel that can be used anonymously and thus guarantees the legally required protection of whistleblowers and their sensitive data.
All reports submitted are checked, evaluated and processed by specially trained compliance management employees.
The system can be used to submit reports relating to the German Supply Chain Act (LkSG) as well as any other suspicious cases.
Link to whistleblower system: https://hintbox.thomann.de/
Human rights policy statement
Policy statement
Thomann Group
V 1.0
Last updated: 14 June 2023
Preamble
Thomann is committed to ecologically and socially responsible corporate governance. Our sustainability model includes adhering to ethical business practices, implementing environment-friendly processes and promoting social responsibility.
A) Basic approach
Thomann is aware of its responsibility to respect human rights and to prevent any kind of human rights violations both within our company and along our supply chains. We ensure relevant standards with regard to working conditions and respectful interaction with one another. The well-being of all people involved is of great importance to us.
Human rights standards refer to the rights set out in the United Nations (UN) Universal Declaration of Human Rights, the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, the European Convention on Human Rights (ECHR) and recognised regional and national systems for the promotion and protection of human rights.
The purpose of this policy statement is to reaffirm our ongoing commitment to respecting human rights in all our business activities, both in our own operations and in relation to our direct and indirect suppliers. In addition, it is intended to set out mechanisms to implement our strategy to prevent or minimise the human rights risks relevant to the company and thus ensure a high level of human rights protection.
This policy statement clarifies our approach to identifying all types of behaviour that could give rise to a human rights risk or environmental risk under the German Supply Chain Act, and to establishing monitoring, due diligence and training mechanisms as well as communication and complaints mechanisms to promote and protect human rights, covering all relevant areas of the company and its affiliated companies.
B) Scope of application and responsibility
As of 1 January 2024, this policy statement will apply to Thomann and all its subsidiaries and interests in which Thomann directly or indirectly holds >50% of the shares or otherwise exercises a decisive influence.
With this policy statement, our company management hereby clearly positions itself to particularly respect and support compliance with the following human rights and environmental obligations:
Our employees and society
- Prohibition of child labour and forced labour, slavery and human trafficking:
We reject all forms of forced labour or child labour without exception and are expressly committed to the prohibition of modern slavery and human trafficking. - Equal treatment of employees and zero tolerance of discrimination:
We ensure equal opportunities and do not tolerate discrimination on the basis of, for example, race, gender, religion, national origin, political opinion, sexual orientation, social background, age and physical or mental characteristics. - Freedom of association and collective agreements:
We respect the right of our employees to join a trade union. In addition, we support and initiate intensive dialogue with the respective employee representatives. - Health and safety:
Health and safety at work are our top priority. We comply with applicable health and safety laws worldwide, and also establish our own occupational health and safety standards at all our locations. - Fair working conditions and remuneration:
We ensure fair working conditions, fair pay and working hours in accordance with the national and international laws and guidelines applicable to our companies. - Ban on unlawful forced evictions
- Prohibition of violence by security forces
Our planet and its resources
We are committed to reducing the impact of our business activities on the environment, to conserving our natural resources and seeking solutions that help protect our environment. We also have the same expectations of our suppliers, which are also set out in our Code of Supplier Conduct. We place particular emphasis on the following aspects:
- Protecting the environment and preventing unlawful environmental impacts, including in the context of the Basel Convention (regarding the handling of hazardous substances and waste) and the Minamata Convention (minimising the release of mercury).
- Prohibiting causing harmful soil change, water pollution, air pollution, harmful noise emissions or excessive water consumption, as well as any violation of human rights through environmental damage.
Our supply chain
We also expect our business partners, including our direct and indirect suppliers, to be aware of their human rights, environmental and social responsibilities and to always follow certain basic ethical principles in their activities in accordance with this policy statement.
Our Code of Supplier Conduct, together with this policy statement, sets out the expectations of the Thomann Group towards its suppliers and the entire supply chain. We expect all business to be conducted in accordance with the Code of Supplier Conduct.
C) Implementing our human rights due diligence
Risk analysis and measures in own business area
To ensure adequate protection of human rights in its own business area, Thomann has established the necessary processes in corporate principles, guidelines and procedural instructions that apply and are implemented throughout the entire group of companies. All employees have unrestricted access to a person of trust, and employees and third parties have access to a fair, anonymous complaints procedure. Training is also provided on dealing with relevant human rights and environmental risks.
Risk analysis and measures in relation to business partners
We have integrated a comprehensive compliance programme, which we have developed with particular consideration of our individual risk profile, taking into account, for example, our industry, our product portfolio and our business activities in countries with an increased risk of corruption or human rights risks.
As part of the risk analysis, we have implemented strict monitoring and control activities to ensure that our compliance standards and requirements are met in day-to-day business. We simultaneously carry out regular risk analyses in order to continuously update and develop our evaluation mechanisms. An integral part of this risk assessment is, for example, a risk indicator for potential human rights violations that is based upon internationally used indices.
In cases where risks are identified, appropriate measures are initiated, whereby a well-founded decision on the business opportunity is required, particularly in the case of serious risks. Thomann is prepared to turn down a business opportunity even if it is legally permissible but poses an unacceptable risk to Thomann’s values.
Risk analysis and measures along the supply chain
Thomann has identified relevant direct suppliers and requested that they provide comprehensive self-disclosure. As a first step, suppliers with a high turnover and significance were considered. In addition, a regular media check is carried out with the aim of including all relevant existing suppliers in this continuous monitoring process.
The supplier selection and prequalification process has been adapted to ensure human rights screening from the very beginning of new business relationships.
The supplier evaluation is based upon a detailed survey with various themed questionnaires. The core topics are environmental protection, human and employment rights, occupational safety, anti-corruption and anti-bribery as well as responsibility along the supply chain. In addition, suppliers must submit relevant certificates and update these as required. This data forms the basis for the necessary monitoring and evaluation activities as well as a corresponding risk analysis.
The risk analyses carried out have shown that there could be potential risks along the supply chain with regard to working conditions, the environment and occupational health and safety. There are also increased risks for certain suppliers due to their location in very high-risk countries.
In order to minimise and mitigate risks, appropriate preventive measures and countermeasures have been defined and integrated into a multidisciplinary process that also provides for an escalation procedure. Thomann will also take appropriate measures if it obtains substantiated knowledge of a violation of a human rights-related or environmental obligation by a direct or indirect supplier.
D) Basic preventive and remedial measures and communication
Complaints mechanism
The Thomann complaints mechanism, consisting of a web-based whistleblower system, is a confidential point of contact that is available to all Thomann employees as well as external persons as an additional communication channel. It enables concerns or indications of possible violations of human rights and environmental due diligence obligations to be raised anonymously.
We follow up on all reports in accordance with binding internal regulations. Each investigation is carried out independently and objectively with the involvement of the compliance department. All reports and the respective investigations are regularly reported to the management in a standardised procedure. Thomann does not tolerate discrimination against persons who contact us via the complaints mechanism or other communication channels.
Link: https://hintbox.thomann.de
Training and sensitisation
We offer our employees training courses covering topics such as human rights, sustainability, the environment, health and safety, equal opportunities and much more. Our training programme also includes mandatory training on our Code of Conduct and various other compliance courses.
We are also continuously working on expanding our training programme. This includes, for example, offering training on human rights and environmental due diligence for selected target groups.
We also refer our suppliers to appropriate training programmes in addition to our employees.
Communication, documentation and reporting
We report on our activities, progress and ambitions in all areas of human rights in our annual report. In this report, we report transparently on material risks, our measures and the progress we have made in protecting human rights and the environment. To this end, a concept has been implemented to ensure the most complete documentation possible for traceability.
Remedial measures
If violations of human or environmental rights are identified that have been caused or contributed to by Thomann, we undertake to prioritise and address these incidents according to their impact and severity. This also includes endeavouring to provide appropriate redress to those directly affected.
Improvement and further development
We firmly believe that tackling human rights and environmental challenges in our global supply chains is an ongoing task that requires systemic change in addition to our individual company initiatives. Cooperation with our suppliers and business partners is of essential importance in this.
Therefore, Thomann will critically review its role and the implementation of its human rights due diligence obligations on a regular basis, and will continuously develop them further. This also applies to our various internal guidelines and processes relating to human rights.
E) Responsibilities
The overall responsibility for human rights and environmental due diligence lies with Thomann’s Managing Director. It includes the control and monitoring of measures relating to the German Supply Chain Act as a minimum. As part of the implementation of this policy statement, the Managing Director must obtain information about the work of the person or persons responsible regularly and at least once a year.
Every company in the Group is obliged to comply with this policy statement and to implement these principles. Responsibility for the implementation of human rights due diligence lies with the respective heads of department.
The Human Resources department is responsible for coordinating measures to ensure respect for human rights and fair working conditions. Processes to ensure due diligence within our supply chain are developed and defined by the Purchasing department. The Compliance department provides support and advice and is involved within the scope of its specialist responsibilities, particularly with regard to any corruption risks, but also functionally, for example in the investigation of reports of potential human rights or other relevant violations.
Mr. Markus Neser (COO) has been appointed Human Rights Officer and is supported by several departments. Our Human Rights Officer is responsible for monitoring the mechanisms described in the policy statement and will always be informed if a risk is identified. In high-risk cases, our Human Rights Officer will also take on an advisory role and participate in the final decision-making process.
Thomann will critically review this policy statement and its implementation on a regular basis and update it as required.
Last updated: 14 June 2023
UK Modern Slavery Act Statement
Thomann Group
Modern Slavery Statement
Financial year 2025
This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015. This report sets out how Thomann tackles the risk of modern slavery in our business and in our supply chains for the financial year 2025.
This statement has been approved by Johann Thomann, Managing Director of Thomann Group and is signed on behalf of the Board in accordance with section 54 of the UK Modern Slavery Act 2015.
1. Our Organisation and Supply Chains
The Thomann Group (“Thomann” hereafter) is a leading European retailer of musical instruments, professional audio equipment and related products. Thomann operates primarily through e-commerce channels and serves customers globally.
Thomann employs around 1,800 employees in six different countries. Its headquarter is located in Treppendorf, Bavaria, Germany, with subsidiaries in Germany, the United Kingdom of Great Britain and Ireland, Denmark, Sweden, France, Spain, and the United States of America.
Our supply chain includes (i) suppliers and distributors of established third-party brands such as Gibson, Sennheiser and Yamaha, and (ii) manufacturers producing Thomann own-brand products to our specifications. Across both segments, we source a broad range of musical instruments, electronic equipment, accessories, textiles and related products.
Certain parts of our global supply chain, especially raw material extraction, production, transportation and logistics, are generally more susceptible to modern slavery risks. For our business, this is relevant given our global sourcing footprint, with key regions including Europe, Hong Kong, China, Taiwan, India, Vietnam, South Korea and the United States of America.
2. Governance and Responsibility
Overarching responsibility for all forms of modern slavery, including forced labour, compulsory labour, child labour, servitude and human trafficking rests with the Managing Director of the Thomann Group, Johann Thomann.
Additionally, a Human Rights Officer has been formally appointed for oversight and is supported by cross-functional departments including Compliance, Human Resources and Purchasing which are responsible for conducting risk assessments and responding to (possible) identified risks concerning modern slavery. The Human Rights Officer is being regularly informed of identified risks and is involved in high-risk decision-making processes.
3. Our Policies on Modern Slavery
Thomann maintains a zero-tolerance approach to all forms of modern slavery, including forced labour, compulsory labour, child labour, servitude and human trafficking. Thomann respects and acknowledges the following international frameworks:
- the United Nations (UN) Universal Declaration of Human Rights,
- the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work,
- the European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR), and
- recognised regional and national systems for the promotion and protection of human rights.
Our commitment is embedded in our Policy Statement on Human Rights and our Supplier Code of Conduct, which apply to all Thomann entities and define minimum standards for our business partners.
These documents explicitly prohibit forced labour, child labour below applicable legal or ILO minimum age thresholds, human trafficking, the withholding of identity documents, recruitment fees charged to workers, and restrictions on workers’ freedom of movement or termination of employment.
Our internal policies are reviewed regularly and updated where necessary to reflect changes in our risk environment. Relevant employees are informed of policy updates and expectations through internal communication measures and targeted awareness initiatives.
4. Risk Assessment and Due Diligence Processes
At Thomann, we apply a structured, risk-based due diligence approach covering both our own operations and supply chain.
Own operations
Within our own operations, we have established processes to identify and address relevant human rights and labour-related risks. These processes are supported by internal policies, defined responsibilities, employee communication and reporting mechanisms.
In addition, we continue to strengthen our internal risk management processes. As part of this effort, we are progressively implementing comprehensive occupational risk assessments across our workplaces and activities, where appropriate. These assessments are intended to systematically identify and mitigate health and safety risks and support our broader approach to responsible business conduct within our own operations.
Our supply chain
Within our supply chain, our due diligence approach includes, in particular: supplier onboarding assessments, supplier self-assessments, country and sector risk screening based on internationally recognised indices, ongoing monitoring including media screening, and defined escalation procedures.
Our assessment shows that risks primarily occur in the procurement of goods and service, specifically logistic services. In tier-n we are mostly concerned with modern slavery in the stages of raw material extraction and the manufacturing of the goods we sell, specifically musical instruments.
Through the retail of musical equipment, Thomann also relies on the sourcing of certain minerals which may be associated with heightened human rights risks, including modern slavery through debt bondage and forced labour for children and migrants, in upstream stages such as extraction and early processing. We take such upstream risk indications into account where relevant when prioritising our due diligence activities.
Where significant risks are identified that conflict with our values and risk acceptance, we implement appropriate follow-up measures or, where necessary, terminate the business relationship, even if they are legally permissible.
To date, our annual risk assessments have not identified substantiated cases of modern slavery requiring immediate action but have indicated areas of elevated risk that warrant continued preventive measures.
5. Managing Risks in the Supply Chain
Suppliers are required to comply with our Supplier Code of Conduct and to cascade equivalent standards throughout their supply chains.
Concerning the use of conflict minerals, Thomann encourages its suppliers to obtain transparency on their sources and only procure minerals that are certifiable responsibly sourced.
Thomann reserves the right to conduct inspections or require recognised third-party certifications. In the event of substantiated non-compliance, corrective action plans are required. Thomann reserves the right to suspend or terminate business relationships in cases of serious or repeated violations.
In case a violation is brought to our attention, we will investigate the matter promptly, take appropriate remedial action, and work with the relevant parties to prevent recurrence.
6. Grievance Mechanisms
Thomann operates a confidential, web-based whistleblowing system accessible to employees and external stakeholders. Reports are submitted anonymously. All reports are investigated independently under defined internal procedures.
Additionally, Thomann maintains internal reporting and grievance mechanisms to enable employees to raise concerns related to human rights, modern slavery, unethical conduct or other compliance matters. Employees have access to designated internal confidential advisors. Reports are reviewed and investigated anonymously in accordance with defined internal procedures. Where a grievance report is being made, we aim to review it in a timely manner and address any substantiated issues appropriately.
Retaliatory measures against persons who report concerns in good faith either through the whistleblowing system or to internal confidential advisors are strictly prohibited. During the reporting period, no reports relating to modern slavery or human trafficking were received through either of these channels.The grievance mechanism forms an integral part of Thomann’s human rights due diligence framework and supports the early identification and mitigation of potential risks.
7. Training and Awareness
Thomann provides training to employees on compliance, human rights, sustainability, health and safety and related topics. Targeted due diligence training is provided to selected risk-facing roles, within Procurement, Compliance and Supply Chain Management functions.
For our own staff the following courses have been completed in the past financial year:
- First-Aid trainings
- Occupational safety trainings
- Fire Safety Trainings
We also engage in other training and capacity training activities:
- Leadership Trainings
- Leadership circle exchange forums
- Antitrust law trainings
Where necessary, we offer and conduct education and training programs jointly with our suppliers to strengthen the implementation of and compliance with the prohibition of modern slavery.
We provide our employees with information material on all topics relating to compliance, sustainability and human rights via our intranet and offer a direct link to the whistleblowing system.
8. Effectiveness and Continuous Improvement
Thomann recognises that addressing modern slavery risks requires continuous improvement. We regularly review our due diligence processes, risk indicators and internal policies and update them where necessary. Internal reporting mechanisms ensure that identified risks and mitigation measures are escalated to senior management.
Our modern slavery key performance indicators (KPI) focus on assessing the potential risks of our active suppliers:
| KPI | Target | 2025 |
| Percentage of active supplier that have received and formally acknowledged the receipt of the Supplier Code of Conduct. | 100 % | 95% |
| Percentage of active suppliers assessed against risks in the annual review. | 100 % | 95 % |
9. Next steps
At Thomann, we thrive to continuously revise our approach towards the mitigation of modern slavery risks and work on the standardisation of our associated processes:
- New suppliers will be assessed according to their relevance and impact (risk assessment), a corrective action plan will be drawn up if needed
- Until the end of Q2/2026, for all suppliers that are assigned the highest risk category corrective action plans have been prepared
- Preparation of a minimum human rights standard (“Thomann Standard”) for all tier-1-suppliers
- Annual workshops for capacity building with our strategically relevant suppliers
- Annual audits of our top 5 suppliers with the highest risk disposition to comply with our “Thomann Standard”
Date: 20.02.2026
You can download the Statement here.
Sustainability report
You can download the sustainability report for the last financial year here as soon as it is available.
Thomann Code of Conduct for Suppliers and Service Providers
Thomann is committed to ecologically and socially responsible corporate governance. Our sustainability model includes adherence to ethical business practices, implementation of environment-friendly processes and the promotion of social responsibility.
We expect the same from suppliers and service providers, as sustainable corporate development can only succeed if everyone involved not only recognises these values, but also implements them and lives by them.
You can download the SCoC (Supplier Code of Conduct) here.
