As a family-run company with its own full-scale production sites in Turkey and Egypt, Weberei Pahl is deeply rooted in textile supply chains. Sustainability is an integral part of our corporate strategy and our responsibility towards people and the environment.
1. Introduction and basic approach
- UN Guiding Principles on Business and Human Rights
- OECD Guidelines for Multinational Enterprises
- ILO Core Labour Standards
- National Action Plans and sectoral guidelines (e.g. Textile Alliance)
Our Code of Conduct forms the basis for our actions. It is publicly available and has been supplemented by guidelines on human rights, child labour, discrimination, health and environmental protection. The values and principles set out in the Code of Conduct are underpinned by concrete measures for dealing with human rights and environmental risks. An overview of prioritised risks and established due diligence processes can be found in the following chapters of this report.
2. Risks & due diligence processes
Our risk analysis is based on a structured survey along the supply chain (Tier 1 and Tier 2) and assesses the probability of occurrence and severity of impact. Prioritised risks relate to:
- Occupational health and safety
- Discrimination against vulnerable groups
- Environmental impacts of wet processes
- Access to living wages
Our measures include, among other things:
- Regular external audits (e.g. Sedex SMETA)
- On-site visits by our own auditors
- Certification requirements (e.g. Oeko-Tex Step, GOTS, GRS)
- Establishment of a complaints management system
- Deployment of sustainability coordinators in our own production facilities in Egypt and Turkey; additional measures are implemented with other Tier 1 suppliers (e.g. audits, questionnaires, individual consultations)
2.1 Overview of prioritised risks
Our risk analysis (as of July 2025) prioritises human rights and environmental risks on two levels:
(a) Sector-specific in accordance with OECD guidelines for the textile industry:
| Type of risk | Weighting |
|---|---|
| Discrimination, sexual harassment, gender inequality | medium |
| Working hours and overtime | medium |
| Occupational safety (e.g. machinery, ergonomics) | medium |
| Greenhouse gas emissions and climate impact | low |
(b) Country-specific in relation to our locations:
Based on our own assessment and external sources (including amfori and ITUC), the following country risks were classified as having increased relevance:
- Turkey: wage stability, women's and minority rights
- Egypt: inflation, living wages, freedom of expression
- India, Pakistan: social exclusion, discrimination, labour rights
These prioritised risks form the strategic starting point for further action planning. Specific measures are assigned to these risks as part of annual planning and in consultation with the sustainability coordination, complaint evaluation and audit report functions. We focus on the actual need for action at each location, with priority determined by the ratio of probability of occurrence and severity of damage. The risk assessment is updated annually and is firmly embedded in our sustainability management system. Feedback from direct suppliers is collected in a structured manner via questionnaires and personal interviews and incorporated into the risk analysis. Care is taken to ensure that responses are documented in such a way that they can be evaluated in the analysis and compared with internal assessments.
3. Dealing with stakeholders and vulnerable groups
We regularly identify particularly vulnerable groups along our supply chain. Currently documented:
| Country | Vulnerable group |
|---|---|
| Egypt | LGBTIQ+, women, children, people with disabilities |
| Turkey | LGBTIQ+, women, children, people with disabilities |
| Pakistan | LGBTIQ+, women, children, people with disabilities |
| India | LGBTIQ+, women, children, people with disabilities |
| Germany | LGBTIQ+, women |
Special protective mechanisms exist for these groups, e.g.:
- Local contact person
- Human rights policy & anti-discrimination guidelines
- Confidential & multilingual communication
- Awareness-raising among managers
4. Grievance mechanism & results
Our multi-level grievance system includes:
- Suggestion and complaint boxes on site
- Anonymous online forms (DE/EN/TR/AR)
- Confidential advisors and coordinators as points of contact
- Regular documentation and evaluation
Key topics of complaints 2022–2025 (location: Egypt):
All complaints were deemed to be justified, without direct causation by Weberei Pahl. All concerns were documented, processed and measures were taken (e.g. installation of fan heaters, lighting, care solutions).
| Subject area | Number |
|---|---|
| Health & hygiene | High |
| Water & heating | High |
| Lighting | Medium |
| Cleanliness | Medium |
| Childcare | Low |
| Noise & indoor climate | Low |
| Holidays & structure | Low |
Effectiveness is assessed based on the following criteria:
- Percentage of Tier 1 suppliers with preventive occupational health and safety measures
- Frequency and recurrence of issues
- Implementation rate of measures
- Processing time and feedback
Progress & effectiveness: In recent years, we have observed that complaints are being processed increasingly quickly and measures are being implemented promptly. Recurring concerns have decreased, indicating that the steps taken are having a lasting effect. Preventive measures, such as occupational safety training and improved safety standards, have helped to stabilise the number of complaints in the area of occupational safety. These observations confirm that both preventive and remedial measures are achieving noticeable progress.
5. Promotion of living wages
1. Summary
Securing and promoting living wages remains a key objective for Weberei Pahl. Based on the current risk analysis (2025), this issue has been confirmed as a priority human rights risk in both production countries – Turkey and Egypt. The analysis shows that wage stability and purchasing power depend significantly on inflation, exchange rates and regional living costs. Thanks to our close-knit, family-like structure, necessary adjustments can be implemented quickly and negative consequences for employees can be effectively mitigated.
2. Measures, progress, effectiveness, KPIs
Results of the risk analysis (2025)
The risk analysis shows:
- Turkey: Inflation-related fluctuations and differences between sectoral wages and regional living costs; ongoing monitoring of purchasing power is necessary.
- Egypt: Rising living costs and more volatile price developments increase the risk of a wage-cost gap.
- Overall: Informal employment relationships in upstream stages can make wage transparency and equal treatment difficult.
The analyses were compared with benchmarks from international sources (e.g. GLWC, Asia Floor Wage and local minimum wage information). These serve for classification purposes, not for direct wage determination.
Measures and progress
- Regular assessment of wage and cost of living developments in both plants by local coordinators.
- Coordination of price adjustments along the supply chain to ensure wage stability.
- Documentation of wage developments in our own plants as part of the annual risk analysis.
- Raising awareness among suppliers (Tier 1) about living wages and working conditions through questionnaires and individual discussions.
- Integration of the topic into supplier evaluation and future procurement criteria.
Effectiveness and progress measurement (qualitative)
Effectiveness is regularly assessed using the following qualitative indicators:
- Stability of wage developments despite regional price fluctuations,
- Feedback from complaint channels and audits with no indications of wage delays,
- Positive feedback from factory exchanges and staff discussions,
- Increasing involvement of suppliers in the issue of living wages.
Overall, the results show that the approach taken to date – combining informal and formal control instruments – is helping to effectively stabilise incomes at our locations.
3. Evaluation (economic efficiency, risk, feasibility)
| Assessment dimension | Assessment | Reason |
|---|---|---|
| Economic efficiency | medium | Price and wage adjustments require coordination, but are an integral part of stable supply chains. |
| Risk mitigation | high | Direct family coordination enables rapid responses to crises (e.g. inflation, exchange rates). |
| Feasibility | high | Short communication paths, local coordinators and existing management structures facilitate implementation. |
4. Recommendations and next steps (2026 onwards)
- Formalisation of wage assessment documentation (annual comparative report for each plant).
- Further expansion of supplier communication on living wages.
- Review of industry initiatives for joint data collection and exchange.
6. Responsibilities
- Strategic responsibility: Management of Weberei Pahl
- Operational implementation: Management in Egypt and Turkey
- Monitoring & documentation: Sustainability coordinators reporting to management in Egypt, Turkey and Weberei Pahl
- Communication: Sustainability management at Weberei Pahl (external & website reporting)
7. Supply chain transparency & origin
As a vertically integrated company with our own production facilities in Egypt and Turkey, we are able to fully record and regularly evaluate our direct business partners (Tier 1). Our facilities are 100% company-owned, giving us complete transparency over processes, working conditions and materials used at these stages.
For upstream stages (Tier 2 and Tier 3), we are increasingly recording places of origin, material sources and partners involved. In doing so, we are guided by the specifications of Green Button 2.0.1 and are gradually expanding the depth of data:
- Tier 1: Own factories in Turkey and Egypt, regularly audited and inspected.
- Tier 2: Yarn suppliers with Oeko-Tex, GOTS or GRS certification; origin data is documented.
- Tier 3: Initial origin information on cotton and recycled materials is available; systematic recording is in preparation.
Our goal is to be able to trace all key materials back to their countries of origin and sustainable practices in the medium term. Sensitive supplier relationships are subject to increased monitoring standards. Sustainability coordinators actively support this process for their own production sites and collect risk-based data points on origin. With other Tier 1 suppliers, origin data is increasingly being verified through audits, certificates and individual supplier discussions.
8. Clarity and accessibility of reporting
Our sustainability information is publicly available on our website:
- Central address: www.weberei-pahl.de/verantwortung
- Available content: Policy statement, Code of Conduct, sustainability reporting, certificates, audit evidence, complaints procedure
- Languages: German (complete), English (Code of Conduct, sustainability reporting)
- Publication frequency: continuously updated, reviewed at least once a year (see version history in documents)
The content has been designed to be understandable for different target groups (customers, business partners, auditors, the general public). The structure is based on the core elements of the Green Button and follows the principle of "do good and talk about it".
Clear language and transparency were emphasised in both the text and the tone. The content is not promotional, but descriptive and comprehensively documented. The key documents are clearly named, downloadable and versioned.
9. KPI-based progress measurement
We use quantitative and qualitative indicators to evaluate the progress of our due diligence processes. These enable us to track developments, measure success and identify areas for improvement. They are based on the prioritised issues defined in the risk analysis and the operational feedback from audits, complaints and coordinator reports.
Examples of key figures used:
- Proportion of audited suppliers with social or environmental certifications
- Feedback from the complaints mechanism (number, processing rate)
- Progress in documenting wage developments
- Proportion of risk management measures implemented
The KPIs are reviewed annually and documented internally. For greater transparency, the assessment is based on a traffic light system:
- green = fulfilled
- yellow = in progress / partially fulfilled
- red = not yet fulfilled, measures initiated
There is still room for improvement in certain areas, such as the traceability of wages at Tier 2 level. Initial measures have been launched in this regard and are being continuously monitored by our sustainability coordination.
This system allows for continuous progress monitoring in line with the PDCA cycle (Plan – Do – Check – Act).
10. Comparison with previous years & target system
We compare the development of key sustainability issues annually based on our risk analysis, KPIs and documented measures. The aim is to make progress transparent and identify areas for improvement at an early stage.
Developments observed (examples):
- Complaints: stable use of the system, consistent focus areas (e.g. health, indoor climate)
- Risks: prioritised risks such as discrimination and occupational safety remain relevant
- Implementation of measures: high proportion of short-term measures from 2024 already implemented
- Wage development: improvements documented at Tier 1 level; Tier 2 progress in preparation
Target systems result from:
- internal risk and action plans
- external standards such as GOTS, Oeko-Tex Step or SMETA
- strategic targets set by management
Target achievement is assessed on the basis of an internal traffic light system and reviewed at regular intervals with the sustainability coordinators at our own plants. For other Tier 1 suppliers, progress is assessed through project-related feedback, audit results and measure feedback. Particularly in areas with structural development needs (e.g. origin transparency Tier 2+), measures are pursued according to the principle of "continuous progress".
This systematic progress and target assessment is an integral part of our annual sustainability review.