First and foremost, all nations have a duty to establish a regulatory framework to protect human rights. Particularly for international enterprises, it is important for this framework to be implemented across all countries to level the playing field for competition. As a company, 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 seek to better understand the potential impact of our business activities and relationships on human rights. Moreover, we examine our processes to 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 approaches 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 function Corporate Affairs 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 implementing measures.
Our commitment: Guidelines, 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. Our Human Rights Charter was developed in collaboration with human rights experts from various countries, including representatives from trade unions and business federations.
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 (NAP). We are committed to these principles, which codify the duty of states to protect human rights as well as the responsibility of companies to uphold them, providing a framework for how nations and businesses should do so. Through our current efforts and initiatives, 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. Our company issued its first UK Modern Slavery Statement in 2017. This statement has been endorsed by our Executive Board and is available on our website.
Constantly improving our risk management
Based on the findings from our 2012 Group-wide human rights risk assessment and our 2014 human rights impact assessment pilot in India, all our subsidiary heads conducted a human rights self-assessment at the end of 2016. Using an electronic survey we created, they provided detailed information on the main subject areas covered by our Human Rights Charter. This survey will help us better understand how our subsidiaries perceive human rights risks and manage them locally, while also raising human rights awareness and creating a foundation for systematic support.
In 2017, we evaluated the results of the survey and held discussions with subject matter experts in Group functions such as Procurement, Human Resources and Compliance. The conclusion was that our subsidiaries are thoroughly aware of human rights risks, guidelines and processes. This includes their employees' work conditions, potential product impacts, data protection, privacy protection, and access to health. Many of our subsidiaries also displayed sound knowledge of and great interest in human rights. At the same time, we identified some areas where we can improve. Regarding several issues, we need to increase risk awareness within our subsidiaries and must work to implement due diligence more stringently, embedding this approach more deeply at the operational level. We intend to use these findings to make our Group-wide approach to risk management more effective. In the course of enhancing our processes, we will implement risk-based measures to increase awareness of slavery (such as forced labor and human trafficking) within the Group. Furthermore, in an effort to constantly improve ourselves, we will be reviewing our mitigation actions with respect to external staff, product and service sourcing, and collaboration with local contract partners.
In September 2017, we launched an electronic confirmation course for our Human Rights Charter as one of the first follow-up actions from our human rights self-assessment. This course is mandatory Group-wide for all site directors as well as all managers directly below Executive Board level. Procurement executives from the second and third managerial tiers below the Executive Board are 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 implementing it within their area of responsibility.
In early December 2017, we informed all self-assessment participants of the aggregated results and called on them to take steps within their sphere of responsibility to implement the corrective actions identified. Furthermore, we've used the results to formulate numerous measures aimed at reinforcing human rights due diligence within our company. In 2018, for instance, we plan to review our company’s existing grievance mechanisms, focusing particularly on their scope and effectiveness.
Human rights and investment decisions
When projects exceed a certain cost threshold, our Investment Committee must approve the expenditure. The committee's decision takes into account factors such as environment, safety and health. 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 specific Intranet sites along with videos and other articles featuring employees explaining how their work intersects with human rights.