The company discloses what measures it takes, strategies it pursues and targets it sets for itself and for the supply chain for ensuring that human rights are respected globally and that forced and child labour as well as all forms of exploitation are prevented. Information should also be provided on the results of the measures and on any relevant risks.
HOCHTIEF committed itself to the standards of the International Labor Organization (ILO) in 2000 and as a signatory to the UN Global Compact in 2008 to support and respect international human rights.
The Group's expectations are laid down in the HOCHTIEF vision, corporate principles and codes of conduct. In principle, the HOCHTIEF Code of Conduct and HOCHTIEF Code of Conduct lay down a binding obligation for business partners to comply with human rights - this is also a contribution to risk management within the Group.
HOCHTIEF sees key areas of responsibility for human rights compliance (anti-corruption), human resources, purchasing, corporate responsibility/CR and auditing. Responsibility always refers to our own employees and subcontractors.
In February 2019, the Executive Board and Supervisory Board published the annual Compliance Declaration pursuant to Section 161 of the German Stock Corporations Act (AktG). The declaration is fully reprinted in the HOCHTIEF Group Report 2018. We provide comprehensive information on our corporate governance practices online. At
www.hochtief.com/corporate-governance, you will find our Code of Conduct, all past compliance declarations as well as the current Declaration on Corporate Governance pursuant to Sections 289f and 315d of the German Commercial Code (HGB).
Aspects of particular relevance to HOCHTIEF include complaint mechanisms, forced labor, child labor, discrimination, freedom of association, health and safety at work. Against this background, the various departments deal with the issues, evaluate risks, define measures and exchange information closely with each other on an ongoing basis. A working group with representatives of the specialist departments coordinates the joint procedure. The aim is to rule out human rights violations in all project work processes over which HOCHTIEF has an influence.
Respect for human rights along our supply chain is of central importance to us - our purchasing volume and thus also the procurement of services provided by third parties for HOCHTIEF corresponds to approximately two thirds of Group work done. This means that numerous people are directly or indirectly involved in our project work. Subcontractors and suppliers from countries with an increased risk of human rights violations are particularly examined by us. By adding human rights to the subject of supplier self-assessment - which we specifically evaluate - we ensure that potential contractual partners meet our human rights compliance requirements in their actions. We work exclusively with subcontractors and suppliers to whom this applies.
We began working with rating agency EcoVadis during process at HOCHTIEF the reporting year and plan to continue the relationship in the future. Subcontractors and suppliers provide information about their businesses that EcoVadis analysts assess against sustainability criteria. The focus is on environment protection, employment rights and human rights, fair business practices, and the supply
chain. If risks are identified, we work with the subcontractor or supplier concerned to develop specific measures (referred to internally as “corrective action plans”). In this way, we aim to further enhance sustainability and transparency in our supply chain.
Our project activities directly and indirectly involve large numbers of people. In this connection, we place special emphases on respect for human rights at every link in our supply chain. We apply special focus in screening potential suppliers and subcontractors from countries with heightened risk of human rights violations. To ensure that potential trading partners from such countries meet our standards in their conduct with regard to safeguarding human rights, we require suppliers to provide self-disclosure information, which we assess on a targeted basis.
In addition to these checks, following delivery of goods or services, the HOCHTIEF project teams also conduct structured evaluations of our contract partners. This applies equally to both new and longstanding subcontractors and suppliers. In the HOCHTIEF Europe and Asia Pacific divisions, these in-project evaluations, which we perform both using established IT systems and manually, cover not only economic matters (such as the handling of change orders), but also environmental aspects
(such as the management of hazardous materials and waste and awareness of resource conservation)
as well as social issues (for instance, observing human rights, work safety directives, and fair pay).
We also set ourselves the goal of further improving transparency in our supply chain and of continuing to integrate sustainability aspects more strongly into our procurement processes. In the medium term, by 2030 at the latest, we wish to establish supplier and subcontractor CR performance as a quantifiable metric and a fixed selection criterion in prequalification.
In order to identify potential sensitive areas for human rights violations at an early stage, HOCHTIEF has been using a "Quick Check on Human Rights" since 2017 in internal auditing projects. The results are processed by the relevant departments.
At the present time, we see no significant risks likely to have a substantial negative impact on the sustainability aspect of human rights. Likewise, we currently anticipate no noteworthy risks arising from negative deviations from our major stakeholders’ expectations.
Further information can be found
here and under the corresponding key performance indicators.
Using the Sustainability Code Declaration of Conformity in the sense of the „NAP Business and Human Rights“
1. Human rights policy statement
a. ) State whether your company has its own corporate guidelines for upholding human rights and whether they also encompass the ILO’s core labour standards.
b. ) Has the company management approved the policy statement?
c. ) Describe your company’s internal and external communication on the topic of human rights.
d. ) At which level is responsibility for human rights concerns enshrined? (CSR-RUG checklist 1b)
e. ) Define the reach that your guidelines have (which sites, including subsidiaries etc.).
a.) HOCHTIEF committed itself to the standards of the International Labor Organization (ILO) in 2000 and as a signatory to the UN Global Compact in 2008 to support and respect international human rights.
The Group's expectations are laid down in the HOCHTIEF vision, corporate principles and codes of conduct. In principle, the HOCHTIEF Code of Conduct and HOCHTIEF Code of Conduct lay down a binding obligation for business partners to comply with human rights - this is also a contribution to risk management within the Group.
b.) In February 2019, the Executive Board and Supervisory Board published the annual Compliance Declaration pursuant to Section 161 of the German Stock Corporations Act (AktG). The declaration is fully reprinted in the HOCHTIEF Group Report 2018.
c.) We provide comprehensive information on our corporate governance practices online. At
Corporate Governance - HOCHTIEF, you will find our Code of Conduct, all past compliance declarations as well as the current Declaration on Corporate Governance pursuant to Sections 289f and 315d of the German Commercial Code (HGB).
d.) HOCHTIEF sees key areas of responsibility for human rights compliance (anti-corruption), human resources, purchasing, corporate responsibility/CR and auditing. Responsibility always refers to our own employees and subcontractors.
e.) HOCHTIEF established the HOCHTIEF Code of Conduct in 2002, subject to ongoing review. It is binding for employees of HOCHTIEF Aktiengesellschaft and the HOCHTIEF Europe division. Available in 13 languages, it incorporates our compliance requirements. The same standards have been integrated into the codes of conduct for the companies in the HOCHTIEF Americas and HOCHTIEF Asia Pacific divisions.
2. Procedures for the identification of actual or potential adverse impact on human rights
a. ) State whether and how your company analyses human rights risks (caused by your business activities, your business relations, your products and services, at its sites, due to political parameters) (criterion 17, checklist aspect 4).
b. ) Are especially vulnerable groups of people incorporated into the risk assessment?
c. ) What is your company’s assessment of the human rights risks and its ability to counter these itself?
d. ) How are human rights risks incorporated into your company’s risk management?
a.) Aspects of particular relevance to HOCHTIEF include complaint mechanisms, forced labor, child labor, discrimination, freedom of association, health and safety at work. Against this background, the various departments deal with the issues, evaluate risks, define measures and exchange information closely with each other on an ongoing basis. A working group with representatives of the specialist departments coordinates the joint procedure. The aim is to rule out human rights violations in all project work processes over which HOCHTIEF has an influence.
b.) We apply special focus in screening potential suppliers and subcontractors from countries with heightened risk of human rights violations. To ensure that potential trading partners from such countries meet our standards in their conduct with regard to safeguarding human rights, we require suppliers to provide self-disclosure information, which we assess on a targeted basis.
c.) At the present time, we see no significant risks likely to have a substantial negative impact on the sustainability aspect of human rights. Likewise, we currently anticipate no noteworthy risks arising from negative deviations from our major stakeholders’ expectations.
d.) In order to identify potential sensitive areas for human rights violations at an early stage, HOCHTIEF has been using a "Quick Check on Human Rights" since 2017 in internal auditing projects. The results are processed by the relevant departments.
3. Measures to review effectiveness / Element: grievance mechanism
a. ) Is there training for employees in the area of human rights?
b. ) State whether and how the upholding of human rights is checked.
c. ) Describe any internal grievance mechanisms and clearly assigned responsibilities within the company or explain how access to external grievance mechanisms is ensured.
d. ) Do whistle-blowing mechanisms also apply to suppliers?
a.) Based on the findings, suggestions for improvement were developed in consultation with the Executive Board and are now being implemented. Human rights will also be a special focus topic in future training courses to raise employees’ awareness for this issue.
b.) In order to identify potential sensitive areas for human rights violations at an early stage, HOCHTIEF has been using a "Quick Check on Human Rights" since 2017 in internal auditing projects. The results are processed by the relevant departments.
c.) As part of our grievance measures, HOCHTIEF’s whistleblower hotlines and official e-mail addresses can be used as a tool for reporting (possible) human rights violations. Due to its characteristics, these mechanisms are public and available to all our stakeholders, what allows us to prevent, mitigate and respond to possible human rights violations. The reporting options are presented on
Compliance - HOCHTIEF.
d.) Outside stakeholders such as business partners and subcontractors are also able to report issues. HOCHTIEF publishes all contact channels for this purpose on the Group website.
4. Human rights due diligence obligations in the value chain
a. ) Is there a suppliers’ code of conduct that comprises the four ILO core labour standards?
b. ) State whether and how a check is performed for human rights risks prior to entering into a business partnership.
c. ) Are suppliers given training on human rights?
d. ) What processes does your company use to guarantee that its suppliers uphold human rights?
e. ) Do you implement measures (jointly with suppliers) in the event of a conflict or do you work with other stakeholders? If so, which ones?
f. ) What redress policies are there? Report on incidents in the reporting period.
a.) and b.)
The Group's expectations are laid down in the HOCHTIEF vision, corporate principles and codes of conduct. In principle, the HOCHTIEF Code of Conduct and HOCHTIEF Code of Conduct lay down a binding obligation for business partners to comply with human rights - this is also a contribution to risk management within the Group.
c.) We began working with rating agency EcoVadis during process at HOCHTIEF the reporting year and plan to continue the relationship in the future. Subcontractors and suppliers provide information
about their businesses that EcoVadis analysts assess against sustainability criteria. The focus
is on environment protection, employment rights and human rights, fair business practices, and the supply chain. If risks are identified, we work with the subcontractor or supplier concerned to develop specific measures (referred to internally as “corrective action plans”). In this way, we aim to further enhance sustainability and transparency in our supply chain.
d.) We began working with rating agency EcoVadis during process at HOCHTIEF the reporting year and plan to continue the relationship in the future. Subcontractors and suppliers provide information about their businesses that EcoVadis analysts assess against sustainability criteria. The focus is on environment protection, employment rights and human rights, fair business practices, and the supply
chain. If risks are identified, we work with the subcontractor or supplier concerned to develop specific measures (referred to internally as “corrective action plans”). In this way, we aim to further enhance sustainability and transparency in our supply chain.
Our project activities directly and indirectly involve large numbers of people. In this connection, we place special emphases on respect for human rights at every link in our supply chain. We apply special focus in screening potential suppliers and subcontractors from countries with heightened risk of human rights violations. To ensure that potential trading partners from such countries meet our standards in their conduct with regard to safeguarding human rights, we require suppliers to provide self-disclosure information, which we assess on a targeted basis.
In addition to these checks, following delivery of goods or services, the HOCHTIEF project teams also conduct structured evaluations of our contract partners. This applies equally to both new and longstanding subcontractors and suppliers. In the HOCHTIEF Europe and Asia Pacific divisions, these in-project evaluations, which we perform both using established IT systems and manually, cover not only economic matters (such as the handling of change orders), but also environmental aspects
(such as the management of hazardous materials and waste and awareness of resource conservation)
as well as social issues (for instance, observing human rights, work safety directives, and fair pay).
We also set ourselves the goal of further improving transparency in our supply chain and of continuing to integrate sustainability aspects more strongly into our procurement processes. In the medium term, by 2030 at the latest, we wish to establish supplier and subcontractor CR performance as a quantifiable metric and a fixed selection criterion in prequalification.
e.) and f.)
If contractual partners fail to meet our requirements and are given a negative assessment by our project teams, they are either provided with targeted support as part of our supplier development process—such as under the collaboration with EcoVadis—or are flagged in our system and no longer considered for future contracts. In that case, they are phased out of future selection processes, i. e. the business relationship ends.