Annual Report 2021

Human rights

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, 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.

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 German Supply Chain Due Diligence Act and 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 Group Corporate Sustainability unit is responsible for coordinating all human rights due diligence activities. 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.

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 our employees as well as our suppliers and business partners to comply with this charter.

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.

Furthermore, we also track human rights risks through our strategic supplier risk process. More information on how we engage with suppliers can be found under Responsible supply chain.

We also meet our human rights due diligence obligations when deploying new technologies. In 2021, we adopted the Code of Digital Ethics. This 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.

In the reporting period, we analyzed our activities designed to implement human rights due diligence in order to identify potential for improvement. We took both stakeholder and regulatory requirements into consideration. The analysis showed that we need a uniform, Group-wide process in order to better evaluate the effectiveness of our human rights due diligence. Above and beyond this, we want to further strengthen the human rights working group, for instance by involving our business sectors more intensively.

Auditing our suppliers and sites

We use internal audits to check whether the workplace requirements of our Human Rights Charter are being observed at our sites. More information on internal audits can be found under Compliance management.

In addition, we review human rights aspects at our sites through site security risk assessments. In 2021, we formalized the assessments as security audits, which will be implemented at regular intervals in line with the audit plan in the future. The audits are one control mechanism of our security governance framework.

Increased risk transparency and centralized corrective and preventive actions tracking allows us to ensure that out 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.

Creating awareness among our employees

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, the onboarding course for all new EHS managers covers the topics of human rights and modern slavery. In addition, during the reporting period the regional Security Academy meetings elaborated on current developments in the areas of human rights and modern slavery. The Security Academy is a training platform for our local, national and regional Security functions. It addresses security-relevant topics and is coordinated by our Corporate Security Group function.

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 first Australia Modern Slavery Statement in 2021. Both have been signed by our Executive Board Chair.

Our complaint mechanism

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 in their respective national language, free of charge and anonymously to our Group-wide whistleblowing system, either by telephone or a web-based application through our compliance hotline. We thoroughly investigate all complaints that we receive and take countermeasures if necessary. In 2021, 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. More information on the compliance hotline can be found under Compliance management.

Human rights violations1










Number of reported violations of Social and Labor Standards Policy









Number of confirmed Violations of Social and Labor Standards Policy









thereof: number of incidents of discrimination










In 2020, we modified our reporting structure for human rights violations. Previously, we reported on such violations in the “Reported compliance violations” table. Since 2020, we report on violations of our Social and Labor Standards Policy, which was drafted and rolled out across the entire Group in 2019.


Due to our revised reporting practices, we have decided not to report the data from previous years.

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