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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 among others:
- 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 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.
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. At HOCHTIEF we take responsibility for all of them by avoiding any situation that could adversely impact the well-being of the people involved along our entire value chain, as they are considered social actors whose human rights could be potentially affected by our activities and decisions.
We have identified the possible violations that could be generated in each of our activities. In our direct operations with our own employees and business partners, and indirectly, with subcontractors of our business partners and in communities of adjacent 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. In this way, we oblige our business partners to enforce the same standards with their contractual partners in regard of human rights, labor, social and environmental responsibility, through our HOCHTIEF Code of Conduct for Business Partners and the related monitoring measures.
In addition, HOCHTIEF has expanded its supplier self-disclosure to include the topic of human rights—which we evaluate in a targeted manner—, aiming to ensure that potential contractual partners meet our requirements for compliance with all internationally recognized human rights 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).
Our Human Rights Corporate Management System integrates the phases through which we have identified the rights holders, the risks related to human rights violations, the controls and areas of HOCHTIEF that are linked to the protection and respect for human rights as well as the way in which we report and update annually.
At first, we analyzed the countries in which HOCHTIEF has activities, to identify the human rights that present the greatest vulnerability in each country, secondly, we considered the risk that may be associated with our activities and the different potentially affected parties.
To do so, we took as reference the different internationally recognized human rights, linking them to the articles included in the United Nations Universal Declaration of Human Rights (UDHR), and then grouped the different human rights potentially affected by our activities in 10 different topics:
- Cultural rights and intellectual property
- Data protection and privacy
- Decent employment and working conditions
- Freedom of expression
- Health and well-being
- Use of lands 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 human rights risk could arise in relation to different right holders or social groups involved in the different stages of our projects:
- HOCHTIEF Employees, including temporary, migrant, students and any other type of employment.
- Value Chain Employees, including temporary, migrant, students and any other type of employment.
- 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.
- 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 used interviews to deepen the findings. The analysis was also focused on identifying the already taken and implemented measures to reduce the potential risks. For this purpose, we implemented a mapping exercise of the existing measures and processes in the most relevant functional areas (such as compliance, human resources, procurement, occupational health and safety and environmental protection) and assessed which of them were working to prevent and/or mitigate the potential human rights risks identified, and which risks and/or social actors where still to be covered by improvement measures.
Once the risk analysis for the HOCHTIEF Europe division has been completed, the risks in the HOCHTIEF Americas and HOCHTIEF Asia Pacific divisions will be examined to subsequently implement our Human Rights Corporate Management System.
Prevent, Respond and Mitigate
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 our compliance website.
Sensitize our employees
Through the internal publication of a multilingual explanatory video with basic information on human rights, the employees are made aware of the topic. In addition, the topic of human rights is subject of 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 emphasized 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.
Improve the system
From now on, we consider and review our risks on an annual basis so that we can regularly improve our measures and risk management. The Chief Human Rights Officer reports regularly to management on the individual measures. In addition, the responsible Committee of the Supervisory Board is informed once a year in a written report.