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Human rights

TAG overview

As an international corporate group, we have a duty to respect human rights worldwide within our respective sphere of influence and we strive 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 and for adhering to legal requirements, for instance the German Supply Chain Due Diligence Act. 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

Our human rights due diligence process (Graphic)

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 such as 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 comply with human rights.

Our Human Rights Officer from the Group function Corporate Sustainability, Quality and Trade Compliance (SQ) is responsible for monitoring due diligence obligations concerning human rights and environmental matters. The Executive Board is informed at least once a year of the work of the Human Rights Officer and the implementation status of risk management and of the due diligence processes.

Those responsible for the issue in the Group functions, business sectors and local units are tasked with implementing our human rights due diligence processes in operations by integrating human rights due diligence into existing processes, for instance.

The cross-sectoral human rights working group exchanges information on activities and the latest developments in the areas of business and human rights. In 2023, 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 directive 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 instance, our

We expect our employees as well as our suppliers and all companies with which we have business ties to comply with this charter.

In 2023, our Executive Board approved our Group Policy Statement on Compliance with Human Rights and Environmental Due Diligence Obligations in accordance with the German Supply Chain Due Diligence Act. It applies to our own business operations, in other words to our entire workforces, as well as to our suppliers. The statement describes how we undertake to comply with our human rights and environmental due diligence obligations and provides information on the risks identified.

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 strive to 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

Risk analyses to determine human rights and environmental risks

We conduct special analyses to identify human rights and certain environmental risks. This enables us to identify potential risks, weight them appropriately and prioritize them. These risk analyses are carried out annually and on an ad hoc basis for our own business operations.

Our Social and Labor Standards Policy defines the corresponding commitments and principles as they relate to specific topics and 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.

We also assess human rights aspects at our sites through security audits and as part of the risk analysis. The audits are one control mechanism of our security governance framework. Through increased risk transparency and central follow-up of corrective and preventive actions (CAPA) we help ensure that our sites comply with safety-related 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

An online course trains our Managing Directors and senior management in how to meet the requirements of our Social and Labor Standards Policy in their area of responsibility.

We are constantly expanding our internal communication to better enshrine our commitment to human rights across the Group. In doing so, we are raising awareness of 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

In collaboration with Together for Sustainability (TfS), we offer our employees training modules from the TfS Academy. Through the platform, employees of TfS member companies and their suppliers can access a total of 181 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 and measures as well as the results of our human rights due diligence. We provide information on this annually in our Sustainability Report. Under laws in Australia, the United Kingdom and Norway, we are additionally required to publish information in these countries on our measures to combat forced labor and human trafficking. Apart from the UK Modern Slavery Statement and the Australia Modern Slavery Statement, we also published the Norway Transparency Statement for the first time in 2023.

Our complaint mechanisms

We have set up a Group-wide whistleblowing and complaints system that can be used to report potential violations of human rights, legal provisions and environmental issues, among other things. Our compliance hotline is a central element of this. 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 are committed to 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 addition, we published Rules of Procedure. These apply to tips or complaints that refer to human rights and certain environmental risks or violations at our company and along the supply chain in line with the German Supply Chain Due Diligence Act. In the reporting year, 184 violations of the Social and Labor Standards Policy were reported to us in our own business operations, 60 of which were confirmed. Furthermore, based on the complaint channels specified in the Rules of Procedure, there were no indications of child or forced labor or violations of the right to collective bargaining or freedom of association in our own business operations or in the supply chain in 2023.

Due diligence
Due diligence means a risk analysis exercised with particular care that is done in preparation for a business transaction, e.g. an acquisition.
The abbreviation for our Corporate Sustainability, Quality and Trade Compliance function.

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