All nations are called upon to uphold and protect human rights and basic freedoms. As an international corporate group, we have a duty to respect human rights worldwide and to ensure that they are not compromised by our business activities. We are constantly working to integrate human rights due diligence into our processes in an effort to minimize the risk of human rights violations and to protect these rights within our sphere of influence. We will not tolerate any business activities or relationships leading to violations of human rights.
Our approach to human rights due diligence
We are committed to upholding and protecting human rights. To this end, we must first understand the potential human rights impact of our business activities and relationships, as well as identify the human rights due diligence measures already in place at our sites. This knowledge helps us adapt our Group-wide efforts to local circumstances and to the respective risk profiles. In this way, we can develop support programs, strategies and processes to overcome particular challenges.
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 with other companies to share lessons learned as well as successes in implementing human rights due diligence.
How we promote respect for human rights
Ultimate responsibility for upholding human rights within our organization lies with our Executive Board, which obliges our managing directors of our subsidiaries to meet this responsibility.
Our Group Corporate Responsibility unit is responsible for coordinating all human rights due diligence processes and activities. Progress and measures are regularly discussed at CR Committee meetings, while subject matter experts within our Group functions, business sectors and local units are in charge of initiating the necessary actions.
Moreover, we established an interdisciplinary Human Rights Working Group in 2019. Its objective is to develop and conduct joint, cross-functional actions that will enable us to meet our responsibility to respect human rights. The group meets three to four times a year. Four meetings were held in 2019.
Our commitment: Guiding principles, charters and laws
Our Human Rights Charter aligns with the UN Guiding Principles on Business and Human Rights. It underscores our commitment to respecting human rights while also defining the relevant requirements for our company. The charter interlinks and complements all existing rules and regulations pertaining to human rights, including, for example, our Code of Conduct, our Group Environment, Health and Safety Policy, and our Charter on Access to Health in Developing Countries. In 2019, we updated our Human Rights Charter, availing ourselves of expertise from external stakeholders such as trade unions, industry associations and representatives of potentially impacted groups. We also adopted a Group-wide Social and Labor Standards Policy, which reflects the labor standards of the International Labour Organization (ILO). Among other topics, the policy covers forced labor, modern slavery, human trafficking, child labor, freedom of association, and collective bargaining rights. In 2019 we also initiated the update of various aspects of our Group-wide Site Security Standard, including human rights.
At the end of 2016, the German federal government adopted a national action plan for implementing the UN Guiding Principles on Business and Human Rights. We welcome this plan and are steadily working to implement it across our organization.
In the United Kingdom, the UK Modern Slavery Act requires us to report on the steps we are taking to counter forced labor and human trafficking. In 2019, we issued our third UK Modern Slavery Statement, which has been endorsed by our Executive Board and is available on our website.
Continually improving our management processes
In order to mitigate human rights risks and prevent their negative impacts, we are working to integrate human rights due diligence even more firmly into our operational processes. With these risks in mind, we are focusing on external manpower, product and service sourcing, and collaboration with contract partners. We are currently creating a Group-wide overview of the use of external manpower, above all in high-risk countries such as China, Vietnam and the Philippines. Based on these findings, we intend to execute risk-based measures.
Our Compliance Risk Reporting & Self-Monitoring process also covers human rights topics. In 2019, we broadened our risk assessment of human rights and modern slavery. Initial results will be available in 2020.
In 2019, we also began reviewing human rights aspects within the scope of our Site Security Risk Assessments to determine whether site security has any connection to human rights risks, initiating the appropriate actions as necessary.
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 factors such as environment, health and safety. When it comes to investment projects, we are also bound by our Code of Conduct, which stipulates compliance with the principles of the UN Global Compact and therefore also with the core labor standards of the International Labour Organization (ILO), such as the prohibition of child and forced labor.
In 2019, we took further steps to raise awareness of certain human rights risks.
While revising our Human Rights Charter and introducing our Social and Labor Standards Policy in 2019, we launched an e-learning course targeted to all managing directors and senior leaders reporting to the Executive Board. The course requires them to implement both of these guidelines in their areas of responsibility.
As in the previous year, the EHS StartUp! onboarding course 2019 offered in Darmstadt (Germany) for all new EHS managers addressed the topics of human rights and modern slavery.
Additionally, we ran training activities (such as Procurement Training Academy) for new Procurement employees including sessions on sustainability and human rights in 2019 and conducted webinars for our Procurement staff. Lastly, we invited Chinese suppliers to attend a TfS training session in Shanghai (China).
Our employees can find information about human rights on our intranet.