As an international corporate group, we have a duty to respect human rights worldwide within our respective sphere of influence and to ensure that our business activities do not infringe upon these rights. By fulfilling our human rights due diligence obligations, we meet our responsibility to society. At the same time, this enables 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 prevent 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 integrate human rights due diligence into our business processes. Our approach to human rights due diligence encompasses six main components.
Our human rights due diligence process
We view our human rights due diligence as a continuous process, which we constantly adapt and improve. This also prompts us to continually review our approach. We closely monitor regulatory developments – for example, the planned EU directive on human rights due diligence.
Roles and responsibilities
Our Executive Board has ultimate responsibility for human rights within our sphere of influence. The Executive Board exercises this responsibility by requiring our Managing Directors to respect human rights.
Our Group Corporate Sustainability unit is responsible for coordinating all human rights due diligence activities across the Group. The persons responsible for these issues in the respective Group functions, business sectors and local units implement the specific measures, for instance by integrating human rights due diligence into existing processes.
The cross-sectoral human rights working group exchanges information on activities and the latest developments in the areas of business and human rights. In 2022, two meetings were held.
Within the UN Global Compact Network Germany, we are a member of the Business & Human Rights Peer Learning Group. In this context, we discuss challenges, current issues, experiences, and successful approaches in exercising human rights due diligence with other companies.
Our commitment: Guiding principles, charters and laws
Our Human Rights Charter aligns with the UN Guiding Principles for Business and Human Rights. It is our overarching human rights governance document and defines the relevant requirements for our company. These requirements cover a broad range of topics related to human rights, including, for instance, product safety, clinical studies, occupational health and safety, equal opportunity, fair pay, freedom of association and collective bargaining as well as the exclusion of child and forced labor. The charter interlinks and complements our existing rules and regulations pertaining to human rights. These include, for example,
- our Code of Conduct,
- our Social and Labor Standards Policy,
- our EHS Policy (Corporate Environment, Health and Safety Policy),
- our Supplier Code of Conduct (formerly Responsible Sourcing Principles),
- our Responsible Minerals Sourcing Charter, and
- our Charter on Access to Health in Developing Countries.
We expect our employees as well as our suppliers and all companies with which we have business ties to comply with this charter.
In 2022, we further developed our existing approach to human rights due diligence, prompted by the specific requirements of the new German Supply Chain Due Diligence Act. We strengthened the existing processes for risk identification in order to fulfill our due diligence obligations even better. Among other things, we appointed the Head of Corporate Sustainability, Quality and Trade Compliance as human rights officer to monitor compliance with human rights due diligence requirements and the implementation of processes throughout the Group in the future.
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. These risk assessments enable us to derive the corresponding strategies and measures. We track human rights risks through our strategic supplier risk process. More information on how we engage with suppliers can be found under Sustainable Supply Chain Management.
We also meet our human rights due diligence obligations when deploying new technologies. Our Code of Digital Ethics defines digital ethics principles and forms the basis for the work of the Digital Ethics Advisory Panel. More information can be found under Digital Ethics.
Measures to protect human rights
Auditing our sites and suppliers
Our Global Social and Labor Standards Policy stipulates the social and labor standards at our sites. We regularly check compliance with the requirements using a risk-based approach. Among other things, this takes into account risks that may arise if relevant laws and regulations change or if there are violations of internationally recognized labor rights by governments and companies, as assessed by the International Trade Union Confederation and documented in the annual ITUC Global Rights Index. If we identify a violation during the audit, we define remedial actions together with the responsible Managing Director and/or local HR staff.
In addition, we review human rights aspects at our sites through security audits. The audits are one control mechanism of our security governance framework. Increased risk transparency and centralized CAPA tracking allows us to ensure that our sites meet security-relevant human rights aspects.
Through the Together for Sustainability (TfS) initiative, we determine whether our strategically important suppliers comply with human rights standards.
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 also integrate human rights topics into our decision-making processes regarding mergers and acquisitions.
Creating awareness among our employees
To train our Managing Directors and senior management, we offer an e-learning course on implementing the requirements of our Social and Labor Standards Policy in their areas of responsibility. Our onboarding training for all new EHS managers continues to cover the topic of human rights, with a particular focus on the issue of modern slavery. In addition, the Supervisory Board received training on the requirements and implementation of the new German Supply Chain Due Diligence Act in 2022.
To embed respect for human rights even more strongly throughout the Group, we are continuously expanding our internal communication and awareness training on human rights and modern slavery. Through our global sustainability network, for example, we held a webinar on human rights in the corporate context in 2022. In addition, virtual information events on the implementation of the German Supply Chain Due Diligence Act were offered to selected target groups.
Training courses for our suppliers
Together with TfS, we rolled out the TfS Academy training platform in 2022. The platform offers employees of TfS member companies and their suppliers 165 courses in up to nine languages. The module on human rights due diligence, for instance, covers the topics of child labor, forced labor, human trafficking, discrimination, and harassment. We also participated in the #TfSTalks, an interactive webinar series.
Our reporting practices
We 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, legislation in Australia and the United Kingdom requires us to publish the steps we are taking to counter forced labor and human trafficking. Apart from the UK Modern Slavery Statement, we also published our Australia Modern Slavery Statement in 2022. Both have been signed by the Chair of the Executive Board and published on our website.
Our complaint mechanisms
Our compliance hotline is the most important channel for reporting complaints about potential human rights violations. Our employees as well as external stakeholders can report suspected cases via this Group-wide whistleblowing system 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. More information on the compliance hotline can be found under compliance management.
In 2022, there were no indications from our compliance hotline of child or forced labor or violations of the right to collective bargaining or freedom of association within our own global business operations. Regarding forced labor, we were informed that we offered rubber gloves for which a manufacturer is accused of labor abuses including forced labor in Malaysia. The matter is being investigated further. Our supplier has already terminated business relations with the manufacturer. Consequently, our company also no longer has any business ties to the manufacturer in the affected supply chain.