| A | B | C | D | E | F | G | H | I | J | K | L | M | N | O | P | Q | R | S | T | U | V | W | X | Y | Z | AA | AB | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
1 | Corporate Parent Company | Revenue (US$ Billion) | Report Period | Length of Report | A3.1. Relevant departments/business processes | B1.6. Risks in Own business area? | B1.7. Risks Direct Suppliers? | B1.8. Risks Indirect Suppliers? | C1.1 Violations own business area | C1.2 In which topics? | C1.3 How Many? | C1.4 Where? (May be in answer to "Describe the appropriate remedial aciton you have taken") | C1.5. Did the remedial measures result in cessation of the violation? | C1.6. Please explain. | C2.1.Violations identified at direct supplier? | C2.2 Human rights violated direct suppliers identified? | C2.3. How many? | C2.5. Did the remedial measures result in cessation of the violation? | C2.6 Please Explain | C3.1.Violations identified indirect suppliers? | C3.2 Human rights violated indirect suppliers identified? | C3.3 How many? | C3.5 Did the remedial measures result in cessation of the violation? | C3.6 Please Explain | D3.1. Were any complaints/tips/cases received during the reporting period via the grievance mechanism? | D3.2. Provide more detail on the number, content, duration, and outcome of the,procedures. | Number of Complaints/Number Sustantiated | D3.3. On which topics have complaints been received? |
2 | Mercedes Benz AG | 161 | 2023 | 52 | • Personell/HR • Occupational safety & occupational health management • Purchasing/Procurement • Supplier management • Legal/Compliance • Community/Stakeholder engagement • Auditing • Economic committee | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage • Prohibition and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibition and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Other prohibitions: Water scarcity | No | Yes | • Disregard for occupational health and safety and work-related health hazards | 1 | Yes | The implementation of the remedial measures was reviewed and ensured by Mercedes-Benz AG during the reporting period. | Yes | • Disregard for occupational health and safety and work-related health hazards | 1 | Yes (presumably) | "The issue was resolved by a corrective action during the audit" (described earlier on) | Yes | In the 2023 reporting year, the BPO and other departments examined 476 reports. If a breach of the rules is suspected, the BPO checks whether there are concere indications and commissions an investigation into the allegations. If there are no concrete indications, it is noted that no investigation will be carried out unless further information is received that supports the suspicion with concerete indications. Information relating to the LkSG is investigated in collaboration with the relevant departments, such as Human Resources and Purchasing. The decision on the outcome of the case is documented. The course of the complaints procedure and the time frame for the individual procedural steps are set out in the LkSG procedural rules. 26 of the cases are related to the LkSG. 15 of the cases concern the topic of "Prohibition of unequal treatment in employment" in the company's business area, which related to misconduct by employees to the detriment of other employees, such as "Violations of psychological/physical integrity", "Sexual harassment", or "Racism". The remaining 11 incidents relate to direct or indirect suppliers and concern the following protected interests: "Prohibition of forced labour and all forms of slavery", "Disregard for occupational health and safety and work-related health hazards", "Disregard for freedom of association", "Prohibition of withholding appropriate wages" and Prohibition of unequal treatment in employment". The proceedings were concluded in the reporting year. With the exception of the violations described in the report, no violations within the meaning of the LkSG were determined. In principle, the Mercedes-Benz Group decides on appropriate measures in the event of confirmed violations, taking into account the principles of propotionality and fairness. Personnel measures include warnings, reprimands and extraordinary dismissals. Measures against suppliers included on-side audits and supplier dialogues. The implementation of preventive and corrective measures at suppliers was reviewed. | 26/N | • Disregard for occupational health safety and and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage • Other prohibitions: Fair working conditions/renumeration | |||||
3 | Infineon Technologies AG | 16 | 2023 | 62 | • Personell/HR • Site development/management • Environmental management • Occupational safety & occupational health management • Communication/Corporate affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Mergers & acquisitions • Community/Stakeholder engagement • Auditing | • Disregard for occupational health and safety and work-related health hazards • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention | • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association and right to collective bargaining • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Prohibition of withholding appropiate wages • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | None | No | No | No | Yes | In the reporting period, five reports were received via the Infineon Integrity Line under the heading of human rights. As a first step, these reports were promptly checked for plausibility and categorised. However, based on the information received and the facts determinated, no violations of human rights and environmental obligations are identified. | 5/0 | • Prohibition of unequal treatment in employment | |||||||||||||
4 | Uniper SE | $88.63 B | 2023 | 41 | • Personell/HR • Site development/management • Environmental management • Occupational safety & occupational health management • Communication/Corporate affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Community/Stakeholder engagement | • Disregard for occupational health and safety & work-related health hazards | • Disregard for occupational health and safety & work-related health hazards • Destruction of the natural basis of life through environmental pollution | • Disregard for occupational health and safety & work-related health hazards • Destruction of the natural basis of life through environmental pollution • Unlawful violation of land rights | No | No | No | No | ||||||||||||||||
5 | E.ON | $88.29 B | 2023 | 39 | • Personell/HR • Environmental management • Occupational safety & occupational health management • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Auditing • Other: Risk management, ESG Reporting | • Disregard for occupational health safety and work-related health hazards | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | None | No | No | No | Yes | In 2023 the E.ON whistleblowing channels were used to report four potential human rights violations in connection with unequal treatment. The allegations were investigated locally by the responsible colleagues in cooperation with employees from local and central Compliance as well as from the Human Rights Center of Expertise. The findings of the 2023 investigations revealed that the allegations did not have any human rights violations. Whistleblowers receive a confirmation of receipt within seven days of receipt of their information and are informed of interim results when there are longer-lasting investigations or proceedings. There is no time limit for the investigations and proceedings. For E.ON the comprehensive examination is the focus and is not time limited. As no violation could be determined, no proceedings, including duration of proceedings, followed. | 4/0 | • Prohibition of unequal treatment in employment | |||||||||||||
6 | Siemens Aktiengesellschaft | $84.55 B | 2023 | 42 | • Personnel/HR • Site development/management • Environmental management • Occupational safety & occupational health manafement • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Mergers & acquisitions • Auditing • Economic committee | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibted production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibition import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | None | No | No | No | Yes | Since the LkSG came into force (1 January 2023), three complaints relating to the content of the LkSG were received by 30 September 2023 (end of the fiscal year) via the protected external reporting channels provided by Siemens (Tell Us and Ombudsperson), which are also referred to in the Complaints Procedure Rules. Two of the three complaints have already been processed in full and assessed as as unsubstantiated or unfounded. The processing of the third complaint (which includes several violations of human rights prohibitions) has not yet been completed for reasons for which Siemens is not responsible. | 3/1 | • Ban on child labour • Disregard for occupational health safety and and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | |||||||||||||
7 | BASF SE | $71.35 B | 2023 | 59 | • Personell/HR • Site development/management • Environmental management • Occupational safety & occupational health management • Communication / Corporate Affairs • Research & Development • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Quality management • Mergers & Acquisitions • Business Development • IT / Digital infrastructure • Community / Stakeholder Engagement • auditing • Economic Committee | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of containing waste POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of containing waste POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | •Disregard for occupational health safety and and work-related health hazards • Ban on child labour | None | Yes | • Disregard for occupational health safety and and work-related health hazards | 11 | Partially | In all cases, a corrective action plan was agreed with the respective supplier in order to bring about the necessary improvements within a defined schedule. For all of these cases, either our follow-up measures prove that the violations have been or the corrective action plan is still in the implementation phase. If no significant improvements are identified in the relevant follow-up audit, more stringent corrective actions or termination of the business relationship with the supplier in question will be considered.remedied We the right to business impose . sanctions in the event of serious violations of the standards defined in our Code of Conduct for Suppliers or of international principles.These can go as far as terminating the business relationship. We did this in one case in 2023. Also in cases We would terminating the business relationshipwhere necessary corrective measures have not yet been completed if there serious doubts about the supplier's pursuit of necessary improvements. | Yes | • Ban on child labour | 1 | Yes | The work was stopped immediately and the contract with one of the two farms was cancelled as it was not possible to deal with the incidents constructively. In order to ensure appropriate labour standards for future seasonal work, specific measures confirmed with the remaining business partner, such as the purchase of necessary protective equipment and other precautions to ensure were appropriate occupational health and safety. | Yes | A total of 643 complaints and enquiries were via the BASF Compliance Hotline in 2023 received . These related to all topics of the BASF Code of Conduct. These included 4 complaints relating to the content of the Supply Chain Due Diligence Act (Section 2 (4) LkSG). We examined these 4 complaints in detail. We concluded that they were not substantiated | 4/0 | • Disregard for occupational health safety and and work-related health hazards • Prohibition of withholding an appropriate wage • Destruction of the natural basis of life through environmental pollution • Unlawful violation of land rights | |||||
8 | Munich RE (Münich Rückversicherungs-Gesellschaft AG) | $70.82 B | 2023 | 10 | Not specified (shortened report) | None (shortened report) | None (shortened report) | None (shortened report) | None (shortened report) | None (shortened report) | None (shortened report) | Not specified (shortened report) | ||||||||||||||||
9 | Deutsche Börse Group | $7.53 B | 2023 | 18 | • Personnel/HR • Occupational safety & occupational health management • Communication / Corporate Affairs • Purchasing/Procurement • CSR/Sustainability • Legal/Compliance • Mergers & Acquisitions • Business Development • Auditing | None | • Disregard for occupational health safety and work-related health hazards | No | No | No | No | Yes | 8 tips were received. The complaints received were not included in the LkSG's scope of application. The content of each complaint concerned protected rights persuant to section 2 part 2 of the LkSG, however the complaints were not about the Deutsche Boerse AG supply chain (did not concern the Deutsche Boerse AG's own business area, or their direct or indirect suppliers). Deutsche Boerse AG recommended that the complainants address their complaints to BAFA. | 0/0 | • Disregard for occupational safety and work-related health hazards • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | |||||||||||||
10 | MVV Energie AG | $6.91 B | 2023 | 38 | • Personnel/HR • Site development/management • Environmental management • Occupational safety & occupational health manafement • Communication/Corporate affairs • Research & development • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Quality management • Mergers & acquisitions • Business development • IT/Digital Infrastructure • Community/Stakeholder engagement • Auditing | None | None | None | No | No | No | No | ||||||||||||||||
11 | Daimler Truck AG | $59.80 B | 2023 | 59 | • Personnel/HR • Environmental management • Occupational safety & occupational health management • Communication / Corporate Affairs • Purchasing/Procurement • CSR/Sustainability • Legal/Compliance • Mergers & Acquisitions • Community / Stakeholder Engagement • Auditing | • Disregard for occupational health and safety and work-related health hazards • Prohibition of unequal treatment in employment | • Prohibition of hiring or using private/public security forces that lack of instruction or control could lead to impairment • Disregard for occupational health and safety and work-related health hazards • Destruction of the natural basis of life through environmental pollution • due to Disregard for freedom of association - freedom of association & right to collective bargaining • • Prohibition of forced labour and all forms of slavery Prohibition of withholding an appropriate wage | • Disregard for occupational health and safety and work-related health hazards • • Prohibition of forced labour and all forms of slavery Prohibition of withholding an appropriate wage | Yes, in Germany and abroad | • Prohibition of unequal treatment in employment | 6 | Yes | Personnel measures were defined and implemented in all 6 relevant cases. In addition, every effort is being made in agreement with the parties involved or rather within the framework of the right of management under labour law to change the situation to such an extent that fair and respectful cooperation is possible again. | No | No | Yes | In the reporting year, we received a total of 11 cases relating to human rights violations in our own business area that were categorised by the SpeakUp team as high-risk reports. Of the 11 cases mentioned above, 6 were closed as "applicable" in the 2023 reporting year. These all fall into the category of "serious cases of sexual harassment, discrimination, racism". Of these, 5 cases related to sexual harassment in the workplace or rather unequal treatment on the basis of gender and one case of racist remarks. The time taken to process the cases varied, ranging from 4 to 9 weeks. The average processing time was 6.2 weeks per case. The company decides on appropriate measures on the basis of proportionality and fairness. In the 2023 reporting year, personnel measures included extraordinary dismissals, warnings, resignations, a transfer and the conclusion of a termination agreement. In addition, five suspected cases of human rights violations in our supply chain were received via SpeakUp's reporting channels. Two cases have already been finalised. These have proven to be unsubstantiated or rather unfounded. The first case was against an alleged supplier in Austria from the transport logistics sector, which was accused of disregarding basic labour and social standards of its employees. The case took 2 months to process. The allegations in particular to the inadequate provision of rest and break times and the payment of insufficient wages. The second case was concluded within a period of 6 months. The case was based on an anonymous tip-off directed at a supplier in Brazil, which was accused of unsuitable work organisation with regard to working hours and rest breaks. The investigations into the other three cases are still ongoing, which is why we do not yet have any results. These include two reports from Turkey. One case is directed against a direct supplier and accuses it of systematically combating and suppressing employee representation. The other case concerns a tip-off against a potential supplier in our supply chain, accusing it of negligent behaviour in the handling of acids. In a further case, which is directed against a direct supplier in Germany, the inadequate provision of personal protective equipment - in particular work safety shoes - is criticised. | 16/6 | • Disregard for occupational health and safety and work-related health hazards • • • Disregard for freedom of association - freedom of association & right to collective bargaining Prohibition of unequal treatment in employment Prohibition of withholding an appropriate wage | |||||||||
12 | Traton SE | $52.45 B | 2023 | 56 | • Personell/HR • Environmental management • Occupational safety & occupational health management • Purchasing/Procurement • Supplier management • Legal/Compliance • Community/Stakeholder engagement • Other: Corporate security | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Other prohibitions: Due to our global activities, we operate in countries with significant social, political or economic instability, conflict regions or high-risk areas, among others. Such an environment could, despite all efforts, make TRATON SE's commitment to compliance with international standards around the world more difficult • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs | • Disregard for occupational health safety and and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Prohibition of withholding appropriate wages | None | No | No | No | Yes | During the reporting period, 32 reports with a potential reference to the LkSG were registered. Five of these reports have already been concluded. The average processing time for the reports that have already been closed was 116 days. No violations of the LkSG were determined from the reports that had already been closed. The content of the registered cases was allocated to the following topics (in some cases, several topics per case): Prohibition of child labour (2), Prohibition of forced labour/slavery (16), Occupational health and safety (6), Freedom of association (3), Equal treatment in employment (2), Appropriate remuneration (4), Environmental human rights obligations (5), Respect for land rights (1), Minamata Convention (1), Stockholm Convention (1), General clause (1). | 32/0 | • Ban on child labour • Prohibition of forced labour and all forms of slavery • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding appropriate wages • Destruction of the natural basis of life through environmental pollution • Unlawful violation of land rights • Other human rights risks: At the time of reporting, one further complaint was still being clarified with regard to its relevance to the LkSG | |||||||||||||
13 | Bayer AG | $51.05 B | 2023 | 64 | • Personell/HR • Environmental Management • Occupational safety & occupational health management • Communication/Corporate affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • legal/Compliance • Mergers & acquisitions • Auditing • Other: Enterprise Risk Management, belonging to the specialist function 'Internal Audit & Risk Management' - IA&RM; Corporate Office | • Prohibition of hiring or using private/public security forces that due to lack of instruction or control could lead to impairment • Disregard for occupational health safety and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste-containing POPs • Prohibited import/export of hazardous waste within the meaning the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of containing waste POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention | • Prohibition of hiring or using private/public security forces that due to lack of instruction or control • Disregard for occupational health safety and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in empployment • Ban on child labour • Prohibition of withholding an appropriate wage | Yes, in Germany and abroad | Disregard for occupational safety and work-related health hazards | 64 | In Germany and abroad(?) | Yes | The corrective measures proposed by the sites are examined and approved by the lead auditor with regard to appropriateness and completeness. Where necessary, verfication documents for the implementation of measures are provided. A spot-check examination of whether agreed corrective measures were implemented sustainably takes place in the next audit. | Yes | • Ban on child labour • Disregard for occupational health safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | • Ban on child labour: 1 • Disregard for occupational health safety and work-related health hazards: 44 • Disregard for freedom of association - freedom of association & right to collective bargaining: 2 • Prohibition of unequal treatment in employment: 3 • Prohibition of withholding an appropriate wage: 11 | Partially | With their recognition through signing the audit reports which were carried out in accordance with industry initiatives, suppliers commit to ending all violations through the definition of corrective and preventive measures and corresponding deadlines. A renewed review of the cessation takes place in the follow-up audits. In Bayer's internal audits the cessation of violations by Bayer employees is tracked and reviewed. | No | Yes | A total of 1494 suspected compliance cases were recorded in the Compliance Management System in the reporting year, 90% of which were compliance-relevant as of 31.12.2023; subject to changes due to ongoing investigations. Compliance violations include all possible types of breaches against internal and external guideline and are systematically prosecuted. The measures to be taken depend on, among other things, the severity of the incident and the applicable law in each case. Each case is recorded group-wide in accordance with standardised crireria and handled in accordance with the guidelines of the Bayer Group regulations "Processing of Compliance Incidents". If a compliance incident is determined in the initiated investigation, a graded catalogue of measures is available. | N/N | • Disregard of occupational safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment | ||||
14 | Vonovia SE | $5.25 B | 2023 | 20 | • Personnel/HR • Site development/management • Environmental management • Occupational safety & occupational health management • Communication/Corporate affairs • Research & development • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Quality management • Mergers & acquisitions • Business development • IT/Digital Infrastructure • Community/Stakeholder engagement • Auditing | • Disregard for occupational health and safety and work-related health hazards •Prohibition of unequal treatment in employment • Other prohibitions: Discrimination against tenants or customers | • Disregard for occupational health and safety and work-related health hazards • Prohibition of forced labour and all forms of slavery • Ban on child labour • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs | None | No | No | No | Yes | In the 2023 reporting year, one report of a possible violation of human rights in the company's business area was received via the anonymous whistleblower portal BKMS. | 1/N | • Disregard for occupational health and safety and work-related health hazards | |||||||||||||
15 | Dürr Aktiengesellschaft | $5.21 B | 2023 | 43 | • Personell/HR • Environmental management • Occupational safety & occupational health management • Communication / Corporate Affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Mergers & Acquisitions • Auditing • Other: Risk management | • Disregard for occupational health safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Other prohibitions: With a global presence of 142 locations in 32 countries, we see potential risks in the area "Disregard for freedom of association - freedom of association & right to collective bargaining" in our own business area in certain countries due to national laws | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Other prohibitions: The determined human rights and environmental risks derive from the protected legal positions and are based on selected country-specific indices. The Duerr Group has a worldwide network with local suppliers. Because of this, no risk can be excluded with absolute certainty in the abstract risk assssment in the first step. The specific examination of risks takes place after the prioritisation and weighting of the respective issues. • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of containing waste POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | No | No | No | No | Yes | Complaints about potential human rights violations can be reported via the Duerr Group Integrity Line as well as the following alternative reporting offices - the superior person, the local compliance managers, the corporate compliance officer or the human rights officer. In 2023 and since the coming-into-force of the LkSG on 01.01.23, one complaint with content relating to the LkSG was received. This concerned the "prohibition of unequal treatment in employment". The complaint was evaluated for plausibility in accordance with our company directive on the whistleblower system and transferred to the department for processing. As a result we did not identify any human rights violations within the meaning of the LkSG. The assessment of the case led to the finding that no follow-up measures were needed. | 1/0 | • Prohibition of unequal treatment in employment | |||||||||||||
16 | MTU Aero Engines AG | $5.05 B | 2023 | 36 | • Personnel/HR • Site development/management • Environmental management • Occupational safety & occupational health manafement • Communication/Corporate affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Community/Stakeholder engagement | None | • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association and right to collective bargaining • Erohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding appropriate wages • Prohibited production, use and/or disposal of mercury (Minamata Convention) | None | Yes, only in Germany | • Other prohibitions: Prohibition of discrmination | 3 | Germany (presumably?) | Yes | Appropriate labour law measures have been taken (warning or rather cessation of employment relationship). | No | No | No | |||||||||||
17 | Fraport AG Frankfurt Airport Services Worldwide | $4.78 B | 2023 | 48 | • Personell/HR • Site development/management • Environmental management • Communication / Corporate Affairs • Purchasing/Procurement • CSR/Sustainability • Legal/Compliance • Mergers & Acquisitions • Auditing • Other: Risk management, Accounting, Group Works Council, Divisions with shareholdings | None | None | None | No | Yes | • Prohibition of withholding an appropriate wage | 1 | Yes | Termination of the business relationship has taken place | No | Yes | The tip concerned a service provider commissioned to a small extent by a fully consolidated Fraport holding abroad. The service provider is said to employ its employees at subsidiaries, thereby avoiding responsibility for the payment of benefits and transferring it to its subsidiaries, which fall under a regulation for micro and small enterprises. This scheme allows micro and small enterprises a reduced payment for holidays, bonuses and severance pay. The whistleblower also filed a complaint with the competent state supervisory authority. After a thorough investigation, it determined that the service provider - and not its subsidiary - was the whisteblower's true employer and imposed a fine on the company. The holding company discussed the matter with the whistleblower, reviewed the decision of the state supervisory authority, examined the commissioning and contract with the supplier and spoke with the service provider's HR manager. As a result, the holding company stopped working with the service provider and imposed a one-year ban on commissioning the service provider. Prior to any future commissioning, a comprehensive due diligence review must be carried out and it must be insured that the criticised practice has been discontinued. | 1/1 | • Prohibition of withholding an appropriate wage | |||||||||
18 | EnBW Energie | $39.93 B | 2023 | 44 | • Personell/HR • Environmental management • Purchasing/Procurement • CSR/Sustainability • Legal/Compliance • Auditing | • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Prohibition of unequal treatment in employment | • Disregard for occupational health and safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard of freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of withholding an appropriate wage | No | No | No | Yes | In the reporting period 17 complaints in relation to the LkSG were reported via the channels provided by the EnBW AG. The duration of the proceedings varied between a few days and several weeks depending on the substance of the complaint, the gravity of the risk posed or the breach of duty and the extent of the necessary awareness-raising measures. All cases were processed to completion. In five cases, unequal treatment in employment was identified. In these incidents individual misconduct was determined as the cause, without conclusions of systematic unequal treatment being drawn. For all of these cases, EnBW AG or rather the trusted personnell involved took appropriate measures to rectify the situation. The other complaints received related to the following topics: Disregard of occupational health and safety and work-related health hazards, withholding of an appropriate wage, unequal treatment in employment and the non-payment of social security contributions. These complaints were all classified as unfounded. | 17/5 | • Disregard for occupational safety and work-related health hazards • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage • Other aspects: Non-payment of social security contributions | ||||||||||||||
19 | SAP SE | $36.39 B | 2023 | 72 | • Personnel/HR • Environmental management • Occupational safety & occupational health management • Purchasing/Procurement • CSR/Sustainability • Legal/Compliance • Other: Risk management (Global Risk & Assurance Services), People Compliance, Corporate Security Investigations | • Disregard for occupational health and safety and work-related health hazards • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibition and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Disregard for occupational health and safety and work-related health hazards • Prohibition of withholding an appropriate wage | Yes, in Germany and abroad | • Prohibition of unequal treatment in employment | 39 | Not specified | Yes | SAP has implemented appropriate remedial measures to ensure that all behaviours that violate SAP's Global Anti-Discrimination Policy have been cessated. | No | Yes | • Disregard for occupational health and safety and work-related health hazards • Prohibition of withholding an appropriate wage | • Disregard for occupational health and safety and work-related health hazards: 1 • Prohibition of withholding an appropriate wage: 1 | N/A | Yes | In the reporting period of calendar year 2023, SAP received 142 reports worldwide that fall under the scope of the LkSG. This includes 78 reports of possible cases of discrimination and 64 reports in connection with allegations of sexual harassment. All of these reports were throughly investigated by the SAP People Compliance Team. In the course of investigations completed in 2023, SAP identified 8 violations of the company's anti-discrimination policy among the 78 reports of discrimination. As part of investigations completed in 2023, SAP identified 31 violations of the Anti-Discrimination Directive among the 64 reports of sexual harassment. The SAP People Compliance Team carries thorough and high-quality investigations as promptly as possible and for varying lengths of time. The duration depends, for example, on the availability of employees or the complexity of the incidents. If necessary, People Compliance takes interim measures to address potential ongoing behaviour while an investigation is ongoing. The information in this section relates to individual violations; systematic violations have not been identified and are prohibited by SAP's Anti-Discrimination Policy. | 142/39 | • Prohibition of unequal treatment in employment | |||||
20 | Volkswagen AG | $354.86 B | 2023 | 53 | • Personell/HR • Environmental management • Occupational safety & occupational health management • Purchasing/Procurement • Supplier management • Legal/Compliance • Community/Stakeholder engagement • Other: Group security | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibted production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs | • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention | • Disregard for occupational health and safety and work-related health hazards • Prohibition of forced labour and all forms of slavery • Prohibition of withholding appropriate wages | Yes, in Germany and abroad | • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs | 1 | Countries where violation could not be stopped: Germany, Slovakia, Poland, Belgium, Hungary, South Africa | Partially | With the disposal and replacement of the prohibited extinguishing agent with legally compliant extinguishing agents, the violation was stopped in many companies. The violation could only be partially stopped due to supply bottlenecks and the fact that legal approvals for the substitutions were not yet available. | No | Yes | • Prohibition of forced labour and all forms of slavery • Disregard for occupational health and safety and work-related health hazards • Prohibition of withholding appropriate wages | • Prohibition of forced labour and all forms of slavery: 1 • Disregard for occupational health and safety and work-related health hazards: 1 • Prohibition of withholding appropriate wages: 1 | Not specified | Yes | We received 104 reports that were assessed as relevant to the LkSG. 10% of these related to possible violations in the company's business area and 90% of the cases concerned possible violations in the supply chain. A total of 37 cases were completed. One violation was determined in the company's business area and one in the supply chain. The average processing time (receipt to completion of the complaint investigation) for the completed cases was 130 days. | 104/2 | • Ban on child labour • Prohibition of forced labour and all forms of slavery • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding appropriate wages • Destruction of the natural basis of life through environmental pollution • Unlawful violation of land rights • Prohibition of the hiring or use of private/public security forces that could lead to impairments due to a lack of instruction or control • Other human rights risks: Section 2(2) Nr. 12 LkSG (catch-all offence) - "Alleged starvation of employees of a supplier" • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handing of waste containing POPs | |||||
21 | Hochtief Aktiengesellschaft | $33.90 B | 2023 | 45 | • Personell/HR • Environmental management • Occupational safety & occupational health management • Communication/Corporate affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Auditing • Other: Operation | None | • Destruction of the natural basis of life through environmental pollution | • Disregard for occupational health and safety and work-related health hazards • None | Yes, only in Germany | • Prohibition of unequal treatment in employment | 2 | Germany (presumably?) | Yes | As this can only be assessed in retrospect in the following year, it is not possible to go into further detail at this time. | No | Yes | • Disregard for occupational health and safety and work-related health hazards | 1 | Not specified | Yes | In 2023, 251 reports were received via HOCHTIEF's whistleblowing systems. These related to various topics such as white-collar crime, personnel matters - labour law issues, conflicts of interest and human rights - including discrimination and harassment. Each case is investigated. Thereby 150 reports were related to the risk areas set out in the LkSG. The cases were generally resolved within a few weeks. If the investigation took longer, contact was always maintained with the whistleblowers and it was explained which measures required which amount of time. Interviews with the persons concerned were largely sufficient to clarify the incidents and improve the working atmosphere for the future. The outcome of each case depends on the nature of the complaint, the actual circumstances and the results of the investigation, as well as other relevant factors. The outcome may include a formal warning - or a final warning - training, an invitation to attend mediation, support for the participants concerned or a dismissal of the person concerned. The need for remedial action is assessed as part of the processing of all reports. If necessary, measures such as additional training, amended procedures and other - multiple - discussions or actions required for improvement will be initiated to address or mitigate identified labour law concerns without delay. | 150/N | • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | |||||
22 | RWE AG | $25.79 B | 2023 | 24 | Procurement, legal and sustainability departments, among others | • Commissioning of unqualified security staff • Restriction and/or disregard of the freedom to travel • Disregard for health and safety in the workplace • Disregard for freedom of association • Negative impacts on communities • Negative impacts on landscapes, ecosystems and biodiversity • Environmental pollution • Unequal treatment in employment • Withholding an appropriate living wage • Forced labour and all forms of slavery | • Commissioning of unqualified security staff • Restriction and/or disregard of the freedom to travel • Child labour • Disregard for health and safety in the workplace • Disregard for freedom of association • Negative impacts on communities • Unlawful expropriation of land, forest and water • Poor working conditions • Environmental pollutions • Unequal treatment in employment • Withholding an appropriate wage • Forced labour and all forms of slavery | None | No | No | No | "During the reporting period, no complaints were received via the channels established by RWE that would have substantiated a case." | 0/0 | |||||||||||||||
23 | TUI AG | $25.43 B | 1/1/2023-9/30/2023 | 77 | • HR • Environmental management • Workplace Safety, Health & Safety • Communications / Corporate and External Affairs • Procurement / Purchasing • Supplier Management • CSR / Sustainability • Legal / Compliance • Mergers & Acquisition • IT / Digital Infrastructure • Community / Stakeholder Engagement • Audit | • Disregard for occupational health and safety and work-related health hazards | • Prohibition of hiring or using private/public security personnel who may cause disruption due to lack of training or control • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association and the right to collective bargaining • Prohibition of forced labour and all forms of slavery • Prohibition of withholding an appropriate wage | None | Yes, only abroad | • Disregard for occupational health and safety and work-related health hazards | 1 | Yes | After contacting the responsible HR department to investigate the report, the accommodation was renovated, which ended the violation of the risk "Disregard for occupational health and safety and work- related health hazards". | Yes | • Prohibition of child labour | 1 | Yes | Various processes are in place to ensure that, apart from guests, no minors enter the hotel grounds. | No | Yes | During the reporting period, 49 reports relating to the GSCA were received. All cases were investigated and, if necessary, further measures were taken. All reports received related to human rights risks. The average time taken to conclude the complaints procedure, from receipt to closure of the case, was 74 days. | 49/N | • Prohibition of child labour • Disregard for occupational health and safety and work-related health hazards • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | |||||
24 | Adidas AG | $24.64 B | 2023 | 65 | • Personell/HR • Site development/management • Environmental management • Occupational safety & occupational health management • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Community / Stakeholder Engagement | • Disregard for occupational health safety and and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage | • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage | Yes, only abroad | • Disregard for occupational health and safety and work-related health hazards | 1 | Colombia | Yes | The implementation of the remedial measures had not yet been completed by the end of the reporting period. | Yes | • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of withholding an appropriate wage | Occupational Health and Safety 47 Freedom of Association 8 Witholding Wage 19 | Partially | Due to our continuous monitoring of suppliers' production facilities, including the evaluation of newly proposed suppliers, we are likely to continue to detect violations of our workplace standards. For individual suppliers, as part of the process described above, we track the application of corrective actions and their effectiveness in preventing recurrence of a violation. In cases where a direct supplier is unable to remedy a violation within a reasonable timeframe, we will follow the process described in our enforcement policy. | Yes | • Disregard for occupational health and safety and work-related health hazards • Prohibition of withholding an appropriate wage | Occupational Health and Saftey 95 Witholding Salary 36 | No response | No response | Yes | In 2023, most of these complaints were submitted by trade unions, labour rights and human rights groups. Such complaints were often also submitted directly to suppliers or through campaigns or other publications in the media. Further information and details on complaints received can be found at the following link: adidas-group.com/sustainability/social-impact/human-rights In 2023, we processed a total of 21 cases submitted adidas through the third-party grievance mechanism. Of these, 11 were new cases received in 2023 and 10 were cases received in previous reporting periods that not been closed by the reporting period ending 31 December 2022. A total of 14 cases were successfully concluded in 2023, 7 cases are open as furthermeasures or solutions are still pending. The majority of cases related to freedom of association and collective bargaining as well as remuneration and social benefits. There were no cases relating to forced or child labour. | 11/N | • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage |
25 | Ceconomy AG | $24.56 B | 2023 | 41 | • Personell/HR • Environmental Management • Occupational safety & occupational health management • Communication/Corporate affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • legal/Compliance • Mergers & acquisitions • Auditing | None | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of containing waste POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | None | No | Yes | • Disregard for occupational health safety and work-related health hazards • Other violations: Deficits in amfori BSCI defined performance area "Social Management System" | • Disregard for occupational health safety and work-related health hazards: 1 • Other violations: 1 | Partially | The violation could not be completely stopped by the direct supplier in a foreseeable time, so a plan for cessation was drawn up, which is currently in the implementation phase. | No | |||||||||||||
26 | Fresenius SE & Co. KGaA | $24.28 B | 2023 | 27 | • Personell/HR • Occupational safety & occupational health management • Environmental management • Purchasing/Procurement • CSR/Sustainability • Legal/Compliance | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of unequal treatment in employment • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs | • Disregard for occupational health and safety and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Ban on child labour • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs | • Disregard for occupational health and safety and work-related health hazards due to lack of instruction or control • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour | Yes, only abroad | • Disregard for occupational health and safety and work-related health hazards | 1 | China | Partially | The conversion of production processes is largely completed and will be finalised in 2024 | Yes | • Prohibition of withholding an appropriate wage | 1 | Yes | All temporary workers were properly renumerated. The outstanding salary payments and social benefits were settled. The service provider's billing system was adjusted. | Yes | • Prohibition of forced labour and all forms of slavery | 1 | Yes? (see comment) | "The offence has been stopped" (see comment) | Yes | In reporting period, Fresenius SE & Co KGgA and the divisions Fresenius Kabi, Fresenius Helios and Fresenius Vamed received a total of 47 human-rights related reports via our existing reporting channels. We inspect every complaint for human rights aspects as part of our case management processes. If the complaint is substantiated, we take appropriate remedial measures. In the reporting year, this concerned three reports, two of which concerned our supply chain. All reports were investigated. Where necessary, remedial measures were initiated or are being continued. On average, the procedures took several months. | 47/N | • Prohibition of forced labour and all forms of slavery • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association and right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage |
27 | Henkel AG & Co. KGaA | $22.51 B | 2023 | 85 | • Personell/HR • Site development/management • Environmental management • Occupational safety & occupational health management • Communication/Corporate affairs • Research & development • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Quality management • Mergers & acquisitions • IT/Digital infrastructure • Community/Stakeholder engagement • Auditing | None | • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association and right to collective bargaining • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour | • Disregard for occupational health and safety and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage | No | No | No | No | 0/0 | |||||||||||||||
28 | Heidelberg Materials AG | $21.78 B | 2023 | 71 | • Personell/HR • Site development/management • Environmental management • Occupational safety & occupational health management • Communication/Corporate affairs • Purchasing/Procurement • Supplier Management • CSR/Sustainability • Legal/Compliance • Mergers & Acquisitions • Business development • Community/Stakeholder engagement • Auditing • Other: Executive board & Supervisory board | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibition and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibition and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | None | No | No | No | Yes | A total of 50 incidents relating to the risk categories specified in the LkSG were reported as part of our complaints system, broken down as follows: Health and occupational safety - among the reported incidents, 22 cases were identified in the area of health and occupational safety. Of these, 11 cases were substantiated and one is still under investigation. Confirmed cases occurred in the area of logistics, in particular due to dangerous driving behaviour and occasionally due to missing safety equipment. Discrimination - a total of nine cases of discrimination were reported. One investigation has not yet been completed, while the other cases were not confirmed. Harassment - Four cases of harassment were reported and three complaints were substantiated. The investigation of the fourth case is not yet completed. Environmental aspects and land rights - a total of four cases were reported within the grievance mechanism, which concerned both environmental aspects and land rights. Two of these cases were confirmed as substantiated. The reported incidents included issues such as dust emissions, road pollution and the construction of a feeder railway line. Abuses at suppliers were also reported as part of our complaints system. Of the total of eleven complaints that were directly related to abuses at suppliers, two cases have been confirmed. The investigation of three further cases has not yet been completed. Nine of the eleven cases concerned possible unfair working conditions, uncluding inadequate pay, while the other two cases concerned workplace safety, sanitary facilities, a leak and missing safety precautions. No complaints were submitted regarding other risk categories of LkSG. Appropriate sanctions and/or corrective measures were taken for all confirmed incidents. The analysis of the confirmed incidents showed that they were neither systematic nor structural. The analysis also showed that the occurrence of these incidents is not to be traced back to a lack of effective preventive measures, but rather that they are isolated incidents. Beyond these isolated cases, the complaints did not lead to a finding of a lack of compliance in the risk areas of the LkSG . | 40/N | • Disregard for occupational health and safety and work related health hazards • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage • Destruction of the natural basis of life through environmental pollution • Unlawful violation of land rights | |||||||||||||
29 | Hapag-Lloyd AG | $19.53 B | 2023 | 44 | • Personell/HR • Occupational safety and occupational health management • Communication/Corporate affairs • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Auditing | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibition and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | Yes, in Germany and abroad | • Prohibition of unequal treatment in employment | 7 | Not specified | Yes | In the identified violation cases, disciplinary measures were taken which have led to the cessation of the violation. | Yes | • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | • Prohibition of unequal treatment in employment: 1 • Prohibition of withholding an appropriate wage: 1 | Yes | See above: In discussions with the suppliers it was determined in eah case that they had already taken remedial measures that had led to the cessation of the violation. Appropriate proof was requested and reviewed by Hapag-Lloyd. | No | Yes | The complaints procedure is open to reports of all kinds, including human rights and environmental reports. In the reporting period, Hapag-Lloyd received a total of 57 reports of violations, 41 of which via the Speak Up Line and 16 via compliance officers. Of the 57 reports, 16 were categorised as relevant to the LkSG. A violation was determined in seven reports. For the remaining nine reports, no violations could be determined, for example because anonymous reports did not contain succificient information and/or a discussion with the whistleblowers was not possible. All reports were processed within three months. | 16/7 | • Prohibition of unequal treatment in employment | ||||
30 | Schaeffler Technologies AG & Co. KG | 18 | 2023 | 86 | • Personnel/HR • Environmental management • Occupational safety & occupational health management • Communication/Corporate affairs • Purchasing/Procurement • CSR/Sustainability • Legal/Compliance • Mergers & acquisitions | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage | • Prohibition of hiring or using private/public security forces that could lead to impairment due to lack of instruction or control • Disregard for occupational health safety and and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention • Prohibited production, use and/or disposal of mercury (Minamata Convention) | • Destruction of the natural basis of life through environmental pollution • Prohibition of forced labour and all forms of slavery | Yes, in Germany and abroad | • Prohibition of unequal treatment in employment | 8 | Not specified | Yes | Refer to the above comments on the effectiveness test | Yes | • Prohibition of forced labour and all forms of slavery • Disregard for occupational health safety and and work-related health hazards • Prohibition of withholding an appropriate wage | • Prohibition of forced labour and all forms of slavery: 1 • Disregard for occupational health safety and and work-related health hazards: 5 • Prohibition of withholding an appropriate wage: 3 | Partially | A re-audit is planned after nine months from the date of preparation. This period was not yet completed in the reporting period. However, Schaeffler has no indication that the timelines for taking corrective action have not been or rather will not be met. | No | Yes | During the reporting period, the Schaeffler Group received a mid-double-digit number of reports of various kinds via the Schaeffler reporting channels, of which only a single-digit number has been confirmed to date. | N/N | • Prohibition of forced labour and all forms of slavery • Disregard for occupational health and safety and work-related health hazards • Disregard for freedom of association - freedom of association & right to collective bargaining • Prohibition of unequal treatment in employment • Prohibition of withholding an appropriate wage | ||||
31 | Salzgitter AG | 11 | 2023 | 53 | • Purchasing/Procurement • Supplier management • CSR/Sustainability • Legal/Compliance • Auditing | • Disregard for occupational health and safety and work-related health hazards • Destruction of the natural basis of life through environmental pollution | • Disregard for occupational health and safety and work-related health hazards • Destruction of the natural basis of life through environmental pollution • Disregard for freedom of association - freedom of association & right to collective bargaining • Unlawful violation of land rights • Prohibition of forced labour and all forms of slavery • Prohibition of unequal treatment in employment • Ban on child labour • Prohibition of withholding an appropriate wage • Prohibited production and/or use of substances within the scope of the Stockholm Convention (POPs) and non-environmentally sound handling of waste containing POPs • Prohibited import/export of hazardous waste within the meaning of the Basel Convention | None | No | No | No | Yes | None of the information received in the 2023 financial year related to human rights or environmental risks within the meaning of the German Supply Chain Due Diligence Act. | 0/0 | • Other prohibitions: None of the information received in the 2023 financial year related to human rights or environmental risks within the meaning of the German Supply Chain Due Diligence Act • Other human rights risks: None of the information received in the 2023 financial year related to human rights or environmental risks within the meaning of the German Supply Chain Due Diligence Act | |||||||||||||
32 | ||||||||||||||||||||||||||||
33 | ||||||||||||||||||||||||||||
34 | ||||||||||||||||||||||||||||
35 | ||||||||||||||||||||||||||||
36 | ||||||||||||||||||||||||||||
37 | ||||||||||||||||||||||||||||
38 | ||||||||||||||||||||||||||||
39 | ||||||||||||||||||||||||||||
40 | ||||||||||||||||||||||||||||
41 | ||||||||||||||||||||||||||||
42 | ||||||||||||||||||||||||||||
43 | ||||||||||||||||||||||||||||
44 | ||||||||||||||||||||||||||||
45 | ||||||||||||||||||||||||||||
46 | ||||||||||||||||||||||||||||
47 | ||||||||||||||||||||||||||||
48 | ||||||||||||||||||||||||||||
49 | ||||||||||||||||||||||||||||
50 | ||||||||||||||||||||||||||||
51 | ||||||||||||||||||||||||||||
52 | ||||||||||||||||||||||||||||
53 | ||||||||||||||||||||||||||||
54 | ||||||||||||||||||||||||||||
55 | ||||||||||||||||||||||||||||
56 | ||||||||||||||||||||||||||||
57 | ||||||||||||||||||||||||||||
58 | ||||||||||||||||||||||||||||
59 | ||||||||||||||||||||||||||||
60 | ||||||||||||||||||||||||||||
61 | ||||||||||||||||||||||||||||
62 | ||||||||||||||||||||||||||||
63 | ||||||||||||||||||||||||||||
64 | ||||||||||||||||||||||||||||
65 | ||||||||||||||||||||||||||||
66 | ||||||||||||||||||||||||||||
67 | ||||||||||||||||||||||||||||
68 | ||||||||||||||||||||||||||||
69 | ||||||||||||||||||||||||||||
70 | ||||||||||||||||||||||||||||
71 | ||||||||||||||||||||||||||||
72 | ||||||||||||||||||||||||||||
73 | ||||||||||||||||||||||||||||
74 | ||||||||||||||||||||||||||||
75 | ||||||||||||||||||||||||||||
76 | ||||||||||||||||||||||||||||
77 | ||||||||||||||||||||||||||||
78 | ||||||||||||||||||||||||||||
79 | ||||||||||||||||||||||||||||
80 | ||||||||||||||||||||||||||||
81 | ||||||||||||||||||||||||||||
82 | ||||||||||||||||||||||||||||
83 | ||||||||||||||||||||||||||||
84 | ||||||||||||||||||||||||||||
85 | ||||||||||||||||||||||||||||
86 | ||||||||||||||||||||||||||||
87 | ||||||||||||||||||||||||||||
88 | ||||||||||||||||||||||||||||
89 | ||||||||||||||||||||||||||||
90 | ||||||||||||||||||||||||||||
91 | ||||||||||||||||||||||||||||
92 | ||||||||||||||||||||||||||||
93 | ||||||||||||||||||||||||||||
94 | ||||||||||||||||||||||||||||
95 | ||||||||||||||||||||||||||||
96 | ||||||||||||||||||||||||||||
97 | ||||||||||||||||||||||||||||
98 | ||||||||||||||||||||||||||||
99 | ||||||||||||||||||||||||||||
100 |