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We are committed to clear and binding standards
As a global infrastructure company, operating under high social, environmental and ethical principles, HOCHTIEF is aware of its due diligence obligations and is committed to respecting and upholding all internationally recognized freedoms and human rights. The basis for this are:
- The Universal Declaration of Human Rights (UN, 1948)
- The International Covenant on Civil and Political Rights (UN, 1966)
- The International Covenant on Economic, Social and Cultural Rights (UN, 1966)
- The ILO Declaration on Fundamental Principles and Rights at Work and its follow-up Declaration (ILO Core Labor Standards, 1998)
- The Convention on the Rights of the Child (UN Convention of the Rights of the Child, 1998)
- The UN Global Compact (UN, 1999)
- The UK Modern Slavery Act (2015)
- The Australian Modern Slavery Act (2018)
- The Dutch Child Labour Due Dilligence Act (2019)
- The German Supply Chain Sourcing Obligations Act “Lieferkettensorgfaltspflichtengesetz” (2021).
We have expressed this clearly and bindingly in our internal principles. For example, the HOCHTIEF Code of Conduct, applicable to all our employees, and the HOCHTIEF Code of Conduct for Business Partners obliges them to comply with human rights. We have also reiterated our commitment to respecting human rights in our revised Position Paper. This is also reflected in our new guideline for business partners, "Human Rights - Our Requirements of You", which is also part of the supplier selection process in Europe.
Our commitment addresses our own operations and those of our value chain
Many people are—in a direct or indirect way—part of our projects. HOCHTIEF bears responsibility for all of them. We avoid any situation that could have a negative impact on their wellbeing. This applies in particular to respect human rights along our entire value chain, as well as their health and safety. This applies not only to our own employees, suppliers, subcontractors and their subcontractors, but also for example to those affected only indirectly by our projects, such as residents of nearby construction projects.
We have screened our potential subcontractors and suppliers with particular focus on those operating in countries with an increased risk of human rights violations. Through our HOCHTIEF Code of Conduct for Business Partners and the associated measures, we oblige our partners to enforce the same standards with regard to human rights, labour, social and environmental standards among their partners.
In addition, HOCHTIEF has expanded its supplier self-disclosure to include the topic of human rights—which we evaluate in a targeted manner—we aim to ensure that potential contractual partners meet our human rights compliance requirements in all of their actions.
HOCHTIEF continued to purchase materials and services for the most part in 2020 from subcontractors and suppliers with high human rights standards in accordance with the UN conventions. In the very few procurement countries where these conventions are not taken into account, we set our own requirements with our own standards.
Acting through our commitment / status quo
In order to prevent violations of human rights due diligence obligations, we first recorded potential human rights risks in our risk management system (Human Rights Corporate Management System).
This System includes the identification of those affected, the linking risks with (potential) human rights violations, the controls and areas of HOCHTIEF related to the protection of and respect for human rights as well as the way in which we report and update annually.
As first, we analyzed the countries in which HOCHTIEF has activities. This allows us to to identify the human rights that are most affected. In the second step, we considered the risk that may be associated with our individual activities.
To do so, we assigned the 30 articles of the United Nations Universal Declaration of Human Rights (UDHR) to the following 10 categories and then identified possible situations in which human rights could arise:
- Cultural Rights and intellectual property
- Data protection and privacy
- Decent employment and working conditions
- Freedom of expression
- Health and well-being
- Use of land and property rights
- Protection against discrimination and harassment
- Protection of physical integrity
- Avoidance of labor exploitation and modern slavery
- Transparency and anti-corruption
At the same time, we identified possible scenarios in which various social groups involved in the different phases of our projects could be exposed to human rights risks:
- HOCHTIEF Employees, including temporary andmigrant workers, students and any other type of worker.
- Value Chain Employees, including temporary andmigrant workers, students and any other type of worker.
- Business Partners and Customers: Public and private entities/companies that have commercial relations with HOCHTIEF, such as customers, suppliers, contractors, subcontractors, joint ventures, and further contractual parties (“partners”)
- Local Communities: include local residents living in the area surrounding our projects, users and civil society.
- Vulnerable Groups, including migrant workers, indigenous peoples and other minorities, youth, children, women and people with disabilities and/or reduced mobility.
We then discussed our preliminary findings with the subsidiaries and representatives of the individual departments and deepened the findings in interviews (due diligence process). We also identified the measures that have already been taken and implemented to reduce the potential risks For this purpose, we conducted an inventory of existing measures and processes in the most important functional areas (such as compliance, human resources, procurement, occupational health and safety and environmental protection) and assessed which of them can prevent or reduce the identified potential human rights risks. Among other things, we agree on contractual clauses with supppliers, subcontractors and joint venture partners in which human rights due diligence obligations are regulated within the scope of the cooperation. We also train employees and communicate reporting options transparently. Furthermore we have identified which risks or social groups still need to be covered by improvement meausres.
Once the risk analysis for the Division Europe has been completed, the risks in the Divisions Americas and Asia Pacific will be examined in order to subsequently implement a consistent human rights corporate management system.
Prevent, Respond and Mitigate
The existing options for making a report of violations of laws or internal regulations via HOCHTIEF´s digital Whistleblower system and the external whistleblowing hotline of our ombudsman can also be used as a complaints mechanism for reporting (possible) human rights violations. These grievance mechnasims are public and anonymous and accessible to all our stakeholders. This enables us to report (potential) human rights violations so that we can respond accordingly. The different reporting options are listed on our compliance website.
Sensitize our employees
Through the internal publication of our video on the treatment of human rights at HOCHTIEF, employees are made aware of this topic.In addition, the topic of human rights is subject of our WebTrainings as well as the start-up- and project-manager-training courses that take place regularly in the Division Europe. Moreover, the topic is part of the mandatory E-Learning of the HOCHTIEF Code of Conduct, to which we added a separate chapter with this subject.
In the interview with the employee magazine “ONE ROOF”, Board Member Nikolaus Graf von Matuschka emphasised the interface of the topic with other areas and the preventive responsibility for HOCHTIEF to ensure appropriate and necessary implementation of measures for the comprehensive protection of human rights.
Improving and monitoring the system
HOCHTIEF has been committed to respecting human rights through stakeholder initiatives for long times. One example is the Group´s commitment to the ILO core labour standards, which the compay signed together with several trade union federations in 2000.
The consideration and review of our risks will now take place annually in order to be able to regularly improve our measures and risk management. Of the individual measures, the Chief Human Rights Officer reports regualryl to the management. In addition, the Audit Committee of the supervisory board is informed once a year in a written report.