GRI 205-1, GRI 308-1, GRI 308-2, GRI 414-1
50Hertz acknowledges its responsibility with respect to human rights and respects the rights of its employees, customers and consumers with regard to privacy, personal safety, freedom of expression and property rights. 50Hertz also assumes responsibility for ensuring that social standards are complied with along the supply chain. For this reason, 50Hertz is a signatory of the United Nations Global Compact and is also committed to the core labour standards of the International Labour Organization (ILO). Our Declaration of Principles on Human Rights Due Diligence underlines our commitment.
In order to ensure that our business partners also comply with internationally binding rules related to human rights - such as the prohibition of forced and child labour - sustainability and ethics are essential components of our evaluation of suppliers and service providers. Elia Group suppliers commit to a common and binding Supplier Code of Conduct (SCOC), which is a key part of all Elia Group supplier contracts. Suppliers must accept the SCOC when submitting a bid and are obliged to comply with it. Human rights are also included in the clauses of the General Purchasing Conditions. Further developments in this area are currently being discussed at Group level. For example, in future, suppliers will be asked about their approach to sustainability, including human rights due diligence, via an external service provider; their responses will be recorded on a balanced score card. The project is currently in its start-up phase and initial proposals are expected during the course of 2022. In addition, 50Hertz raises awareness about sustainable actions to take in regular discussions with stakeholders across the supply chain, furthering their understanding of compliance with ethical principles and guidelines related to sustainable development.
All procurement at 50Hertz is undertaken in accordance with specific guidelines. These state that all procurement activities above €100,000 are carried out centrally via the Purchasing Department. A multi-level strategy prevents any misuse and increases control. The ‘four eyes principle’ is guaranteed at all times. The procurement guidelines, purchasing manual and the General Purchasing Conditions form a framework which aims to prevent corruption across all of our locations.
Based on the human rights due diligence requirements anchored in the German National Action Plan (NAP), 50Hertz conducted an analysis of its direct and indirect supply chains. As a result, four human rights risks were identified as a priority:
• occupational health and safety;
• environmental protection and health;
• employment and working conditions;
• freedom of association and expression.
50Hertz examined these as part of an in-depth analysis of the submarine cable value chain, which is complex. Additionally, the construction of such cables requires high levels of investment. This analysis included interviews with 50Hertz’s direct suppliers in order to determine and track the risk potential of steps along the value chain and to develop suitable measures to address any issues that might be uncovered.
During the spring of 2021, an intensive stakeholder discussion about the enforcement of human rights along the submarine cable supply chain was held with key production and construction suppliers. Suppliers adopt a risk-based approach and process to mitigate the risk of human rights violations across their supply chains (these include adhering to a mandatory Code of Conduct, undertaking supplier assessments and audits, and the use of a whistleblower system). 50Hertz’s model approach for determining their own risks across the supply chain was outlined.
Sustainability-related changes will continue to be embedded into the supply chain management process over the coming years.