Human Rights Due Diligence at Schaeffler
Respect for human rights is an integral part of the corporate responsibility of the Schaeffler Group. Due to its complex international supply chain, the Schaeffler Group is exposed to a certain level of risk of being confronted either directly or indirectly with violations of law or human rights.
The company’s acceptance of responsibility and the corresponding due diligence processes with regard to human rights issues are oriented toward the UN Guiding Principles on Business and Human Rights, the National Action Plan (NAP) for Business and Human Rights, the ten principles of the United Nations Global Compact (UNGC), and the Modern Slavery Act (MSA).
The MSA, which was passed in the U.K. in 2015, calls for companies to provide an account of their engagement in protecting human rights all along their value chain. Since the Schaeffler Group maintains business relations in the U.K., it is impacted by this disclosure requirement. The subsidiary companies The Barden Corporation (UK) Ltd and Schaeffler (UK) Ltd have published declarations to this effect on their websites. The Schaeffler Group fulfills these and other requirements with structured activities designed with long-term considerations in mind.
Structure and Development of the Human Rights Due Diligence Process
core elements are part of Schaeffler’s human rights due diligence process, which is being implemented.
In accordance with the PDCA (Plan-Do-Check-Act) management method, the process of human rights due diligence on the part of the Schaeffler Group is being iteratively and continuously further developed and improved. Preparation of the process is currently in the conceptualization phase. It consists of six key elements that recursively intermesh: (1) Declaration of principles of respecting human rights; (2) Complaint mechanism; (3) Human rights risk assessment and impact analysis; (4) Anchoring and integration; (5) Monitoring, communication, and reporting; (6) Awareness-raising, training, stakeholder commitment, and networking. Of the six core elements, some elements (phases 1, 2, 4, and 5) have already been implemented. For example, the Schaeffler Group has affirmed its respect for human rights in both its company and supplier codes of conduct, as well as through its declaration regarding the Modern Slavery Act as required in the U.K. A channel for complaints was established through a whistle-blower system in order to identify suspicious cases at an early stage. The whistle-blower system allows for the notification of violations of the Schaeffler Group’s Code of Conduct, including human rights violations, at any time. The system is available in several languages and enables confidential and specially encrypted, secure communication with the investigation team of the compliance department.
As a further element, the establishment of a human rights risk assessment and impact analysis to examine process-related potential risks pertaining to the respect for human rights is in progress. Up to now, there has been no human rights risk assessment and impact analysis. Both are currently being conceptualized. Thus far, reputational damage in the event of a breach of human rights has been included in the structured risk management of the Schaeffler Group as a qualitative issue. If necessary, human rights are reported to the Executive Board of Schaeffler AG within the framework of internal risk reporting.
In the future, the due diligence approach of the Schaeffler Group with regard to human rights will be further structured and detailed. The Business Partner Due Diligence process has not yet been comprehensively rolled out. It includes business partners who are susceptible to corruption. Conventional material suppliers are not yet covered. Objectives and measures for human rights due diligence have been anchored in the Sustainability Roadmap and are currently being implemented. For this, the conceptual development of a comprehensive human rights management policy is being advanced.
The information on respecting human rights is made available to the stakeholders of the Schaeffler Group in different report formats – for example, through the Sustainability Report. Schaeffler Group employees are made aware of human rights issues through internal training measures. This is done within the framework of compliance training, with reference to the Schaeffler Group’s Code of Conduct. Up to now, no separate training courses have been carried out on the subject of human rights. There were no confirmed cases of human rights violations in the period under review.
In July 2017, Schaeffler was invited to give insight into its approach to corporate due diligence at the CSR Management Forum 2017 of the Nuremberg Chamber of Commerce and Industry. Schaeffler participated together with representatives of other companies. Following the individual presentations, there was a discussion about best practices and industry-specific approaches for safeguarding adherence to human rights in the supply chain.
The modern slavery statements of the Schaeffler Group can be found at: