Human Rights Assessment

dormakaba acknowledges the responsibility to respect human rights as outlined in the UN Guiding Principles on Business and Human Rights (UNGP).

Why it matters

In today’s ever more interconnected and globalized world, there is increasing public focus on how companies are respecting human rights in their operations as well as through their business relationships across value chains. That means demonstrating that they are not harming the fundamental dignity and welfare of people as they go about their legitimate work and generate the jobs, wealth and growth that benefit all communities. Human rights are rights inherent to all human beings, irrespective of nationality, place of residence, sex, national or ethnic origin, color, religion, language or any other status. Above all, human rights are interrelated, interdependent and indivisible.

As a global company with highly complex supply chains, dormakaba is exposed to increased risks of being directly or indirectly linked with human rights violations. We therefore treat the respect of human rights as a priority and require our business partners to do the same.

Key activities

In the financial year 2016/17, dormakaba committed to the development of a Human Rights Due Diligence (HRDD) process aligned to the United Nations Guiding Principles on Business and Human Rights (UNGP). Our aim is to conduct HRDD throughout our business to proactively assess, identify, prevent and mitigate actual and potential adverse human rights impacts on potentially affected rightsholders across the value chain. We also use HRDD to identify where we can better support and promote individuals’ ability to live and exercise their fundamental human rights.

In the financial year 2017/18, we conducted a Human Rights Due Diligence gap analysis. Based on the results, we worked with external human rights and business experts to outline the practical application of the UNGP within our business.

In the financial year 2018/19, we implemented a stepwise HRDD project plan, focusing on stakeholder consultations, policy development (dormakaba Statement of Commitment on Human Rights), human rights risk assessment including the identification of salient issues and roadmap development, with the overall goal of developing a human rights due diligence framework in line with international standards.

We have defined the following HRDD process and outlined it in the new Statement of Commitment on Human Rights to ensure dormakaba will be able to effectively implement our commitment to respect human rights:

Process of Human Rights Due Diligence (HRDD)

dormakaba focused on the following areas in the financial year 2018/19:

1. Developing our policy commitment
2. Assessing actual and potential impacts
3. Integrating findings and committing to appropriate action
4. Tracking and communicating performance
5. Supporting remediation of adverse impacts by providing access to grievance

Developing our policy commitment

Our human rights commitment was formalized in the financial year 2018/19, through the development of our new Statement of Commitment on Human Rights. It was elaborated based on the gap assessment mentioned above, stakeholder consultations and the salient issues identified (see details in the following section) and approved by our Chairman and CEO, Riet Cadonau.

In line with the “Protect, Respect, Remedy” Framework provided by the UN Guiding Principles on Business and Human Rights (UNGP) and as outlined in the company’s Statement of Commitment on Human Rights, dormakaba recognizes the important role the company has in respecting human rights. We are guided by international human rights frameworks, which include but are not limited to the UNGPs, the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, the Core Labor Conventions of the International Labor Organization (ILO) and the OECD Guidelines for Multinational Enterprises.

We are committed to fully respect the personal dignity, privacy and individual rights of our colleagues, customers, suppliers and other stakeholders. Our commitment to respect human rights extends to all individuals throughout the value chain, and we use the relationships with co-manufacturers, independent suppliers, and other business partners to encourage and promote the principles of the Statement of Commitment on Human Rights throughout our network. We believe that we can influence others through leading by example and therefore communicate proactively about our commitment.

Assessing actual and potential impacts

dormakaba does not attribute more importance to one human right over another. However, for the implementation of our human rights commitment, dormakaba prioritizes human rights issues that are most salient to the business – identified via a formal human rights saliency assessment conducted in the financial year 2018/19 in accordance with the UNGPs.

This included consultations with 20 key internal and external stakeholders including human rights experts, customers and suppliers, which generated a focused list of salient human rights issues for dormakaba and formed the basis for the company’s Statement of Commitment on Human Rights, which came into effect in August 2019.

The stakeholder consultations were focused on the potential gross risk of human rights impacts on rightsholders, as opposed to a standard risk assessment approach, which looks at the risk to the company. The company’s current management of human rights related topics were not evaluated. In other words, saliency was defined based on the inherent human rights risk, without reference to how well our company manages the topic already. Thirteen issues appeared as most relevant, and these were further analyzed in terms of the company’s leverage and the potential severity of impact. Severity here is defined by the scale, scope and remediability of the potential human rights impacts on people.

dormakaba Human Rights Saliency Matrix

Among the broader human rights issues identified, dormakaba commits to focus on the salient human rights issues (in alphabetical order) defined below:

Given the challenges of limited transparency in the value chain, our salient issues will be analyzed in more details through human rights impact assessments in high-risk areas in order to develop appropriate measures.

In prioritizing these issues, dormakaba recognizes that some groups may be at greater risk of negative human rights impacts due to their vulnerability or marginalization. We also recognize that the evaluation of the severity of potential impacts may change and that other issues may grow in importance over time. We will therefore regularly re-assess salient issues and human rights risks based on internal and external stakeholder feedback and expert judgments.

Integrate findings & take appropriate action

Based on the human rights-related risks and impacts identified, dormakaba will develop prevention and mitigation measures integrated into company operations, training programs, policies and management systems. This will be achieved through the implementation of a human rights roadmap which was established in the financial year 2018/19 and approved by the Executive Committee in the context of the HRDD process development.

dormakaba is committed to a continued dialogue with internal and external stakeholders to continuously improve its HRDD. Where our ability to influence potential human rights issues is limited, we strive to enhance leverage through (industry) collaboration and partnership with key stakeholders, including employees, suppliers, civil society organizations and businesses partners to prevent or mitigate negative human rights impacts.

Track & communicate performance

dormakaba will track the effectiveness of our actions and influence to ensure human rights are respected in the value chain through a system with concrete targets and key performance indicators monitoring the implementation of the human rights roadmap. Where possible, dormakaba will strive to measure the actual impacts of our actions on the human rights of potentially affected rightsholders.

Respect for human rights is an integral part of our global sustainability strategy and through the new Statement of Commitment on Human Rights, we commit to transparently report on the progress of our efforts in our annual sustainability report as well as through the annual Modern Slavery Statement to publicly account for how human rights issues are addressed.

Remediating adverse impacts

Access to grievance

dormakaba attaches great importance to an open corporate culture, where every employee is encouraged to speak up if they become aware of compliance risks, including as relates to human rights, through the reporting channels outlined in the Code of Conduct. In addition, the company ensures employees and external third parties, such as business partners or suppliers, access to an anonymous, confidential, and safe process for investigating grievances by means of a whistleblowing tool, which was launched in July 2019 and is operated by an independent third party.  We encourage our suppliers and business partners to use their own effective grievance mechanisms and inform their employees that the dormakaba whistleblowing tool is available for their use. dormakaba does not retaliate or permit retaliation against anyone who raises questions or concerns in good faith about corporate activities. We are committed to investigating these issues thoroughly and to providing appropriate responses and remedies.

Access to remedy

When adverse human rights impacts are uncovered due to our business activities or from linkages to our operations, we are committed to taking timely and transparent action to remediate in a fair and equitable manner in line with the UNGPs. Where we find impacts linked to our business relationships, we will use our influence to encourage suppliers and business partners to respect human rights.

Our performance

As regards our approach towards human rights, our biggest achievement in the last financial year was the development of our new Statement of Commitment on Human Rights and the identification of salient issues, which helps us to prioritize due diligence activities. However, the biggest challenge of limited leverage and limited transparency in the upstream and downstream value chain remains. This is especially true at the mineral extraction stage or in terms of improper use of our products by end-users. This is why we have planned to conduct a Human Rights Impact Assessment in line with international standards to collect more in-depth information on salient human rights issues in the financial year 2019/20.

Outlook

In the financial year 2019/20, we will focus on internal communication and awareness raising on our salient issues and the Statement of Commitment on Human Rights, as well as the roll-out of the above-mentioned Human Rights Impact Assessment. A key focus will be to further assess the topic of migrant workers and the business practices of recruitment agencies for which we currently have limited transparency. In addition, the recently approved human rights roadmap will be communicated, and the roll-out of first actions are also planned for the financial year 2019/20.

Gaining insight from business and human rights experts

Interview with Sibylle Baumgartner, Director & Co-Founder, focusright ltd.

As a business and human rights expert, you accompanied dormakaba through its development of a Human Rights Due Diligence (HRDD) process. What is your expectation towards companies in terms of HRDD?

Even though social topics are part of companies’ sustainability engagements, they often receive less attention than environmental topics because they are more difficult to quantify, and evidence is less clear. HRDD helps to make social issues more concrete and tangible for the business and to address them more systematically. It also helps companies to better understand the ways that environmental issues impact people and human rights. Appropriate HRDD in line with international standards requires Board-level commitment, the preparedness to look at the way the company operates from a different angle and acknowledging that the company’s operations might impact people across the entire value chain. Creativity is needed to find innovative approaches to tackle issues, especially when the company’s ability to influence is limited.

What were the key messages you learned through the stakeholder consultations?

Respecting human rights seems to be common sense and therefore the process was well-supported by the stakeholders consulted. It was clear that dormakaba cannot only ask others to comply with social and environmental standards, e.g. through the Supplier Code of Conduct, but that the company must also look at its own operations carefully. The following questions arose during the consultations: How can the company ensure that its commitment to respect human rights is implemented across the Group and throughout its value chain? What does HRDD really mean for the company? How can human rights issues be prioritized? Which measures are already in place and how must internal processes and management systems be adapted to reflect this commitment?

What do you see as the main challenges for dormakaba regarding human rights due diligence? 

The following three main challenges appeared while working on the HRDD process with dormakaba and the identification of salient issues for the company:

1. Adopting a human rights lens to risk management requires the company to consider the impacts it might potentially have on people, i.e. on “rightsholders” rather than on the company, through its operations and across value chains. When identifying salient issues gross risks must be considered: a human rights issue might therefore be identified as salient even if already managed well by the company, for example, as in occupational health and safety;

2. Limited value chain transparency: complex mineral supply chains and limited direct contact with end-users lead to a limited value chain transparency. It is therefore difficult for dormakaba to gather information on impacts that might occur both downstream and upstream the value chain;

3. Limited ability to influence: potential human rights issues were identified across the entire value chain leading to questions about the company’s ability to influence, especially where potential issues seem to be of systemic nature.