As an international corporate group, we have a duty to respect human rights worldwide within our sphere of influence and to ensure that they are not compromised by our business activities. Upholding human rights is indispensable and non-negotiable for us, which is why we also expect our business partners to guarantee that human rights are respected. By meeting our human rights due diligence obligations, we fulfill our social responsibility and secure our social license to operate. At the same time, this helps us to remain competitive over the long term.
Our approach to human rights due diligence
We are committed to upholding human rights, which is why we became a signatory to the UN Global Compact back in 2005. We endeavor to reduce the risk of human rights violations as far as possible, not only at our own sites but also along our entire supply chain. That is why we are continuously integrating human rights due diligence more firmly into our business processes.
Our approach to human rights due diligence encompasses six main components.
We view human rights due diligence as a continuous process, which we constantly adapt and improve. We closely monitor regulatory developments – for example, the National Action Plan (NAP) on Business and Human Rights of the German federal government on the implementation of the UN Guiding Principles and the planned EU directive on human rights due diligence. Regulations such as these prompt us to continually review our approach to human rights due diligence.
How we promote respect for human rights
To ensure that human rights are respected in our sphere of influence, we have defined clear responsibilities.
Our Executive Board has ultimate responsibility for human rights within our organization. The Executive Board exercises this responsibility by requiring our Managing Directors to comply with human rights.
Our Group Corporate Sustainability (CS) unit is responsible for coordinating all human rights due diligence activities and processes. Specific need for action, progress and measures are regularly discussed at CS Committee meetings. The persons responsible for these issues in the respective Group functions, business sectors and local units implement the measures decided.
The interdisciplinary Human Rights Working Group is developing cross-functional measures that we are using to meet our responsibility to respect human rights. This group meets three to four times per year. In 2020, it defined internal focus areas that build on our approach to human rights due diligence. Within these focus areas and based on the specific risk situation, we will implement further measures in order to better comply with human rights due diligence obligations.
Within the German Global Compact Network, we are a member of the Business & Human Rights Peer Learning Group, a working group in which we engage in dialogue with other companies to discuss challenges, current issues, experiences and successful approaches in exercising human rights due diligence.
Our commitment: guiding principles, charters and laws
Our Human Rights Charter aligns with the UN Guiding Principles on Business and Human Rights. It is our overarching human rights directive and defines the relevant requirements for our company. We expect all our employees as well as our suppliers and business partners to comply with this charter.
The charter interlinks and complements our existing rules and regulations pertaining to human rights, including, for example, our Code of Conduct, Social and Labor Standards Policy, EHS Policy (Group Environment, Health and Safety Policy), Responsible Sourcing Principles as well as the Charter on Access to Health in Developing Countries. Our standards cover a broad range of topics related to human rights. These include, for instance, product safety, occupational health and safety, equal opportunity, fair pay, freedom of association and collective bargaining as well as the exclusion of child labor.
In 2020, we also added human rights aspects to our Site Security Standard. In doing so, we want to ensure that these aspects are also included in the selection of security service providers, for instance.
In addition, we developed a Conflict Minerals Charter in 2020. This regulates responsible sourcing of minerals from conflict and high-risk regions.
Identifying actual and potential impacts on human rights
We perform risk assessments to understand the potential impacts our operations and business relationships could have on human rights. For instance, we investigate human rights risks at our sites as well as risks related to product and service sourcing. The following risk assessments enable us to derive the corresponding strategies and measures:
Within the scope our Group-wide Compliance Risk Reporting & Self-Monitoring process, we monitor and evaluate compliance risks. This has included human rights issues since 2019. In 2020, the consolidated results showed a low risk of human rights violations throughout the Group.
Furthermore, we also track human rights risks through our strategic supplier risk process. We plan to extend our risk assessment of the selection of new suppliers regarding modern slavery.
We are currently developing a new approach through which we aim to identify whether our external manpower is at risk. We are thus broadening the scope of the pilot project we conducted in 2019. Within the scope of this project, we conducted a Group-wide analysis of the work conditions of external manpower, especially in high-risk countries, such as China, Vietnam and the Philippines.
We take responsibility when deploying new technologies and comply with our human rights due diligence obligations. We are currently compiling an overview of the technologies we use in the company and are evaluating the human rights risks, if any, that are associated with them.
Measures to protect human rights
Auditing our suppliers and sites
In addition, we have been reviewing human rights aspects at our sites through site security risk assessments since 2019. Starting in 2021, these will be formalized as security audits and implemented at regular intervals in line with the audit plan. The audits are one control mechanism of our security governance framework and are thus a central element of it. We derive appropriate measures from the results. This allows us to ensure that our sites meet security-relevant human rights aspects.
Through the Together for Sustainability (TfS) initiative, we determine whether our strategic suppliers comply with human rights standards. For selected suppliers, we conduct our own sustainability audits. To prevent modern slavery and human trafficking, we will regularly review our supplier assessment and audit processes and are devising long-term measures together with our suppliers to this end.
Human rights and investment decisions
When projects exceed a certain cost threshold, our Investment Committee must approve the expenditure. In its decision, the committee considers various aspects related to the project, including environmental impact and health and safety. Furthermore, our Code of Conduct is binding where investment decisions are concerned. We are working to integrate human rights topics even more firmly into our decision-making process.
Creating awareness among our employees
To embed respect for human rights even more strongly throughout the company, we are expanding our internal communication and awareness training on human rights and modern slavery.
To train our Managing Directors and senior leaders reporting directly to the Executive Board, we offer an e-learning course on the requirements of our Human Rights Charter and our Social and Labor Standards Policy and the implementation thereof in their areas of responsibility. In addition, all new EHS managers took the “EHS StartUp!” onboarding course, which has been covering the topics of human rights and modern slavery since 2018. Our employees can find information about human rights on our intranet.
Training courses for our suppliers
In 2020, we introduced a TfS training course in Asia. We invited our Procurement employees to participate in various Ecovadis webinars. Part of the training program deals with TfS assessments and audits, which include compliance with human rights as an essential audit component.
In addition, we are in the process of developing a global training program for purchasers and suppliers together with TfS. This is to include training on human rights.
We use various formats to inform the public about our approaches, measures and results of human rights due diligence. We provide information on this annually in our Sustainability Report. Additionally, in the United Kingdom, the UK Modern Slavery Act requires us to publish the steps we are taking to counter forced labor and human trafficking. In 2020, we published our fourth UK Modern Slavery Statement. It has been endorsed by our Executive Board and is available on our website.
Our complaint mechanisms
Our SpeakUp Line is the most important channel for reporting complaints about potential human rights violations. Both our employees and all external stakeholders can report suspected cases in their respective national language, free of charge and anonymously, either by telephone or a web-based application. We thoroughly investigate all complaints that we receive and take countermeasures if necessary. In 2020, we noted no violations, either with respect to child or forced labor or with respect to the right to collective bargaining or freedom of association.