First and foremost, all nations have a duty to establish a regulatory framework to protect human rights. As an international enterprise, we in turn also have a duty to uphold human rights, taking steps 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.
Our approach to human rights due diligence
We are committed to upholding and protecting human rights. To this end, we must better understand the potential impact of our business activities and relationships on human rights, as well as identify the practices already in place at our sites that fulfill the function of human rights due diligence. This knowledge helps us adapt our Group-wide human rights due diligence efforts to better meet local needs and adapt our processes in response to the respective risk profiles. In doing so, we can develop support programs, strategies and processes to overcome particular challenges. At the same time, we are working to identify the opportunities presented by the positive impacts of our operations.
Within the German Global Compact Network (DGCN), 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
Our Executive Board bears ultimate responsibility for upholding human rights within our organization. Our Group Corporate Responsibility unit handles the coordination of activities and processes relating to human rights due diligence. 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.
In 2018, we formed an internal, cross-functional human rights working group that has two overarching objectives. First, it helps us meet our obligation to respect human rights through joint, cross-functional actions. And secondly, it is intended to establish an ongoing dialogue on the subject. The group meets three to four times a year, with the first meeting having been held in November.
In 2018, we also added the topic of human rights to our manual for new managing directors in an effort to heighten awareness at the executive level. The manual is primarily intended to consolidate all the legal and compliance-related responsibilities of a managing director into one document.
Our commitment: Guiding principles, charters and laws
Our Human Rights Charter affirms our commitment to respecting human rights while also defining the relevant requirements for our company. This charter furthermore unites and complements existing policies and guidelines on human rights such as our Code of Conduct, our Corporate Environment, Health and Safety Policy, our Responsible Sourcing Principles, and our Charter on Access to Health in Developing Countries. In 2018, we started the process of updating our Human Rights Charter, partnering with external stakeholders such as trade unions, business federations and representatives of potentially impacted groups. Additionally, we are currently drafting a Group-wide Social and Labor Standards Policy. Aligning with the core labor standards of the International Labour Organization (ILO), this policy is scheduled for publication in 2019.
At the end of 2016, the German federal government adopted a national action plan for implementing the UN Guiding Principles for Business and Human Rights. We welcome this plan, which reflects the UN Guiding Principles and sets out the duty of states to protect human rights as well as the responsibility of companies to uphold them. It furthermore provides specific guidance on how the German federal government and German businesses can do so. Through our current efforts and initiatives, such as evaluating our existing grievance mechanisms, we are on the right track to fulfilling the requirements stipulated in the national action plan.
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 2018, our company once again issued our UK Modern Slavery Statement, which has been endorsed by our Executive Board and is available on our website.
Creating awareness
In 2018, we started to implement measures based on the findings from the Group-wide human rights self-assessment of our subsidiaries, which included initiating steps to raise awareness of certain human rights risks. In 2018, we hosted a workshop on modern slavery, which was attended by representatives from the Group functions Environment, Health, Safety, Security, Quality (EQ), Procurement, Human Resources, Compliance, and Corporate Responsibility. Human rights and modern slavery were also on the agenda of our annual Global Security Network Meeting in Darmstadt and our Environment, Health, Safety (EHS) forums in Tokyo and Shizuoka (both Japan) and Corsier-sur-Vevey (Switzerland). They were also part of “EHS StartUp!”, our EHS orientation program for all new EHS managers in Darmstadt.
Launched in 2017, our Group-wide online course on our Human Rights Charter was successfully completed by 194 people in 2018. This course was mandatory Group-wide for all managing directors as well as all leaders from the first managerial level below Executive Board. In addition to this, Procurement executives from the second and third managerial tiers were also required to take the course, which focuses on modern slavery and the increasing regulatory requirements for companies such as those set out in the national action plan and the UK Modern Slavery Act. By taking the course, participants confirm that they have read and understood our Human Rights Charter and are working to promote its values.
Continually improving our management processes
We are continuing our efforts to further integrate human rights into our operational processes, reviewing our approach to human rights risks and their impacts and working to improve them. We focus on external manpower, product and service sourcing, and collaboration with contract partners. We are currently working to obtain an overview of the use of external manpower Group-wide. Building on these findings, we intend to execute risk-based measures to increase awareness of modern slavery at the local level as well. To support these efforts, in 2018, we developed an interactive database for human rights risks and issues that also covers specific risks in individual countries.
Our annual compliance risk reporting covers human rights issues. In 2018, our Compliance Group function started updating their compliance risk reporting process with human rights and modern slavery now featuring more prominently in our risk reporting and our newly created self-monitoring process.
To reinforce human rights due diligence within our company, in 2018 we reviewed our existing grievance mechanisms, focusing particularly on their scope and effectiveness. Based on the results, in 2019 we decided to open up our SpeakUp Line, previously only accessible to employees, to external stakeholders as well. Grievances can now be reported via a link on our external website.
Human rights and investment decisions
When projects exceed a certain cost threshold, our Investment Committee must approve the expenditure. The committee’s decision 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.
Keeping employees informed
We use a variety of channels to educate our employees on human rights, including topical Intranet sites and other articles featuring employees explaining how their work intersects with human rights.