Human Rights

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

Our approach

At dormakaba, we want to lead by example and engage with our partners to drive more eco-friendly practices and support the protection of human rights. In today’s ever more interconnected and globalized world, there is increasing public focus on how companies are respecting human rights in their operations and across their business relationships within value chains. This means they have to demonstrate 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 that apply to all human beings, irrespective of nationality, place of residence, sex, national or ethnic origin, color, religion, language, or any other characteristic. Above all, human rights are interrelated, interdependent, and indivisible.

As a company with global 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 top priority and require our business partners to do the same.

Human Rights Due Diligence (HRDD)

Our aim is to conduct Human Rights Due Diligence (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 by and exercise their fundamental human rights.

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

Human Rights Due Diligence (HRDD) process

Policy commitment

Our human rights commitment established in the dormakaba Statement of Commitment on Human Rights extends to all individuals throughout the value chain. It was developed based on a gap assessment, stakeholder consultations, and approved by our then Chairman. Through this work, we also identified our most salient issues (see details in the following section). In prioritizing these salient issues, we recognize 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 therefore reassess salient issues and human rights risks annually based on internal and external stakeholder feedback and expert judgments.

In addition to our Statement of Commitment on Human Rights, our Responsible Labor Directive and the Zero Recruitment Fees Directive lay out our policy commitments on human rights-relevant topics of labor conditions for our workforce. These Directives give more concrete guidance and set minimum standards on topics such as freely chosen employment, working hours, workers’ accommodation, and responsible recruitment on a global level.

The commitment to human rights is further enforced by the human rights related sections in both the dormakaba Code of Conduct and the Supplier Code of Conduct, which establish the company’s expectations regarding human rights for employees and suppliers.

We are guided by international human rights frameworks, which include but are not limited to the “Protect, Respect, Remedy” framework of the UN Guiding Principles on Business and Human Rights (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.

Assessing actual and potential impacts to define salient issues

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 accordance with the UNGPs.

This included consultations with 20 key internal and external stakeholders, such as human rights experts, customers, and suppliers, which generated a focused list of salient human rights issues for dormakaba and formed the basis of the company's Statement of Commitment on Human Rights.

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 as 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, we commit to focusing on the salient human rights issues defined below (in alphabetical order):

Salient issue	Potential human rights impacts	Illustrative example in our value chain (not exhaustive)
Child labor	Rights on the protection of the child; Right to a family life; Right to an education	Child labor used for cobalt and mica mining.
Contributing to conflict	Right to the security of the person; Freedom from cruel, inhumane, and degrading treatment	Sourcing raw materials from conflict zones and therefore indirectly financing armed conflicts.
Customer safety	Right to health	Door not stopping during operation and injuring someone, or not opening in the event of fire and leading to a fatality.
Environmental issues impacting human rights	Right to safe and clean drinking water and sanitation; Right to health; Right to an adequate standard of living	Bauxite mine polluting water used by local communities for drinking, washing, and cooking.
Migrant workers (forced labor)	Right not to be subjected to slavery, servitude, or forced labor; Right to freedom of movement	Migrant workers in plants hired through recruitment agencies at risk of modern slavery/bonded labor.
Outsourced services	Right to health; Right to enjoy just and favorable conditions of work	Outsourced/subcontracted employees in plants facing health and safety risks (e.g., cleaning and security staff).
Occupational health & safety	Right to health; Right to enjoy just and favorable conditions of work; Right to social security, including social insurance	Staff installing products on behalf of dormakaba facing injury risks: lifting heavy equipment, unsafe construction sites, road accidents, etc.

Given the challenges of limited transparency in the value chain, our salient issues are regularly analyzed in more detail through human rights impact assessments or social audits in high-risk areas in order to develop appropriate measures. In doing so, we have developed a Human Rights Risk Management System and we have committed to conducting at least one social audit per financial year in our own operations.

Human Rights Risk Management System

In FY 22/23 we distributed a self-assessment questionnaire to local HR management for locations in scope of this Sustainability Report to assess their level of compliance with our Responsible Labor Directive and Zero Recruitment Fee Directive. We achieved a 100% participation rate, gaining valuable insights into the situation on the ground.

Each location received a social risk score depending on their compliance level, and this information was used to inform and develop a Human Rights Risk Management System. Additional internal and external social Key Performance Indicators (KPIs) were also used, ranging from country risk indexes provided by Verisk Maplecroft to working hours records, whistleblowing reports, and injury incident rates.

Each KPI was weighted based on the likelihood, scope, severity, and remediability of the associated human rights risks, and a final risk score was derived for each site. Sites were then classified according to a four-level risk scale between extreme, high, medium and low risk. This classification, in turn, serves as the basis for prioritizing sites for additional due diligence measures, such as on-site auditing cycles, mandatory training tailored to the risks identified, and one-to-one support. The risk scores and self-assessment questionnaire are now updated on an annual basis with a special focus on sites with medium, high, or extreme risk.

Integrate findings and take appropriate action

In FY 23/24, we conducted six audits to identify actual or potential human rights risks or abuses in those facilities identified through our Human Rights Risk Management System as having high or extreme risk. We engaged ELEVATE, an industry leader in Environmental, Social and Governance (ESG), and supply chain services to conduct the on-site audits. We conducted closure audits in our facilities in Singapore, Senai (Malaysia), Melaka (Malaysia), and Taishan (China) and initial audits in the Nogales (Mexico) and Chiayi (Taiwan) plants. These were conducted according to the ERSA 3.0 standard, which is in line with local law in addition to International Labour Organization (ILO) Conventions and industry protocols including RBA, ETI, BSCI, SEDEX SMETA, and IETP.

Of these, our Singapore and Nogales plants achieved good results (B level). The closure audit in Taishan showed an improvement versus previous findings but further corrective actions continue to be necessary. During the initial audit in Taiwan, it was discovered that migrant workers had paid recruitment fees, in violation of the company’s Employer Pays Principle. A reimbursement plan is being developed.

In Senai (Malaysia) all major findings from the initial audit had been resolved – however, a new Zero Tolerance finding was discovered related to forced labor risks faced by agency workers managed by an external security firm. Local management acted quickly to address the issue directly with the security company. The results from the closure audit in Melaka (Malaysia) were not yet available at the close of the financial year.

Each audit is followed by the development of a comprehensive corrective action plan that addresses the findings and builds the capacity of the different stakeholders to prevent the same human rights issues from reoccurring. To ensure complete objectivity and best practice in the development of the corrective actions, our external auditing partner guides the identification of root causes and the development of the corrective action plans for all social audits conducted in our own operations and those of our suppliers.

Furthermore, based on gaps in conformity with the Responsible Labor Directive and Zero Recruitment Fee Directive revealed as part of the global self-assessment questionnaire, 12 training modules to build the capacity of the local HR managers and plant managers were developed. These training modules are also a fundamental part of our Human Rights Good Practices Hub, which was also developed in FY 23/24. It serves as a “one-stop shop” for local managers, where they can find information about the Group human rights standards and applicable regulations, lessons learned from their peers, and readily available assets to communicate and fulfill the obligations.

Tracking and communicating performance

We are committed to transparently reporting on the progress of our efforts in our annual sustainability report and publicly accounting for how human rights issues are addressed.

We track the effectiveness of our actions and influence to ensure human rights are respected in the value chain. We do this through a management system with concrete targets and KPIs, monitoring the implementation of the human rights road map.

We also issue an annual Modern Slavery and Child Labor Statement that sets out what we are doing to ensure that slavery, human trafficking, and child labor are not taking place in our supply chains or any part of the business. The Statement lays out the strategy and actions that outline our compliance with the ILO Conventions 138 and 182, the ILO-IOE Child Labor Guidance Tool for Business, and the UN Guiding Principles on Business and Human Rights. In line with our adherence to these international standards – which are referenced in Annex 2 of the Swiss Ordinance on Due Diligence and Reporting Obligations in relation to Child Labor – dormakaba falls under the exemption rule of any further requirements stipulated in Article 9.

Remediating adverse impacts

When adverse human rights impacts caused by our business activities or linked to our operations are uncovered, we are committed to taking timely and transparent action to remediate them 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.

After having conducted the initial social audits in Malaysia and Singapore in previous financial years, we were confronted with the fact that an especially vulnerable group, migrant workers, frequently pays fees to agencies, i.e., for the recruitment itself, travel, passport, and visa processing. To remediate these impacts, we have developed improvement actions and the Zero Recruitment Fees Directive, which now regulates the minimum business standards regarding fees and costs associated with recruitment, including travel. Under this Directive, the company is commited to bearing the associated costs under the Employer Pays Principle.

As mentioned above, during the on-site audit at our plant in Taiwan in FY 23/24, it was found that migrant workers had paid recruitment fees to their labor agent. As a remediation measure, these migrant workers will be reimbursed for these fees retroactively.

Remediating child labor victims in the small-scale mining communities of the Democratic Republic of Congo

In a landmark project, we have joined forces with Save the Children Switzerland and The Centre for Child Rights and Business (The Centre) to address the pervasive issue of child labor in small-scale mining communities in the Democratic Republic of Congo (DRC).

dormakaba recognizes that any company sourcing electronic components cannot be sure that the cobalt in its products does not come from the DRC, where 70% of the cobalt mined worldwide originates and which is well-known for a high prevalence of child labor.

The project supports affected children and young people in mining centers in the DRC and provides long-term remediation. Children and young people working in cobalt mines are reintegrated into school or vocational training programs to afford them new opportunities. The project offers monthly living stipends, covers all educational and possible medical costs up to the age of 16, and provides each child with a case manager who supports the family and looks after the childʼs interests.

Each child is provided with a unique plan tailored to their specific needs, ensuring a holistic approach to their remediation. For some children, adequate remediation means reintegration into the schooling system, while for others it also requires extensive psychological support. This individualized care is critical in helping these children overcome the challenging circumstances they live in. By collaborating closely with local organizations and practitioners, our partners – Save the Children and The Centre – ensure that the interventions are culturally sensitive and more likely to succeed. This community approach leverages local knowledge and expertise while fostering the creation of a network of support that assists current victims, but also prevents future children from falling into the same circumstances. Over a period of ten years, dormakaba will invest around CHF 1 million in total to support the project’s objectives.

We are committed to furthering the impact of this initiative by encouraging other companies that utilize cobalt in their products to join us on the ground. Together, we aim to amplify the reach of the initiative, driving broader change and contributing to the fight against child labor in cobalt supply chains on a larger scale.

Access to grievance

We provide both internal and external stakeholders with the opportunity to communicate their grievances in an open manner. Our whistleblowing system ensures anonymity and data protection. The tool is available in nine languages.

Before it was launched, we collected feedback from various stakeholder groups and their representatives. For example, the German Works Council was consulted in the design phase and before implementing the whistleblowing tool. They agreed to its implementation, being satisfied that it provides effective feedback and ensures the protection of whistleblowers from retaliation. Furthermore, representatives from the Human Resources organization of various countries also gave their feedback on the design of the tool before it went live.

An external party has evaluated the dormakaba whistleblowing tool against the effectiveness criteria set out in the UN Guiding Principles on Business and Human Rights, which were mostly met, and the Global Compliance department reviewed the tool against the requirements of the newly adopted German Supply Chain Due Diligence Act during a recent update.

Global Compliance launched a communication campaign to familiarize our employees with the tool and its usage. The campaign included print media (poster campaign) for local implementation to reach production workers. Our Code of Conduct and the pre-departure phase training package for foreign migrant workers also include a detailed description of our reporting channels.

Lastly, we ask whistleblowers for their feedback on the design of the whistleblowing tool, e.g., accessibility and ease of use. All feedback is consolidated and considered in the regular system updates. The Global Compliance department tracks the implementation of the agreed remediation measures.

Further activities

During the current strategic cycle (2021–2027), we are also focusing our efforts regarding the protection of human rights on the following activities:

Ethical recruitment training
Due diligence on cobalt and conflict minerals
Respecting the right to water

Ethical recruitment training

Using the tools and training modules developed by the Responsible Labor Initiative, by 2027 we commit to providing ethical recruitment training for our labor agents in sending and receiving countries where we recruit foreign workers. This includes but is not limited to migration corridors between Nepal, Myanmar, and Malaysia, and between Taiwan and the Philippines.

In FY 23/24 we developed an eLearning module that lays out our requirements on ethical recruitment processes, which include freely chosen employment, zero recruitment fees, and mandatory pre-departure information. The aim of the training is to protect prospective migrant workers and reduce their risk of being trapped into situations of forced labor. The training will launch in early FY 24/25.

Due diligence on cobalt and conflict minerals

As a company procuring electronic components, we must take action to increase transparency in our supply chain regarding human rights violations during the mining of high-risk minerals. However, we are far away from the extraction of minerals in the value chain, and we do not directly import or purchase raw ore or unrefined minerals. However, they can be found in small quantities in some of our products’ components. Therefore, collaboration with actors in mineral extraction, processing, or transport is crucial to identify and manage the risk associated with potential links to conflict-affected or high-risk areas.

To increase our leverage, we collaborate with others through our membership of the Responsible Minerals Initiative (RMI), one of the most utilized and respected resources for companies from a range of industries addressing responsible mineral sourcing issues in their supply chains. By applying their tools and building our due diligence strategy accordingly, we are working toward our goal of ensuring supply chain traceability for minerals with a high risk of child labor by 2027.

An important step in achieving this goal was the publication of our Statement of Commitment on Responsible Minerals Sourcing, which helps our suppliers understand our expectations when it comes to tackling the human rights risks in our minerals supply chains. The Statement lays out the strategy and actions that we take in alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict and High-Risk Areas.

Furthermore, we have been consulting directly with suppliers since 2022 to gain greater visibility and a deeper understanding of the upstream parts of our cobalt supply chain. The goal of these dialogues is to assess the maturity of the supplier’s management system on conflict minerals and cobalt, assisting them in making improvements and finding ways to collaborate further.

Suppliers are selected on the basis of their responses to Conflict Minerals Reporting Templates provided by the RMI. Through these, we are able to identify high-risk smelters in our Tier 2+ supply chains, as well as the Tier 1 suppliers linked to them. Out of the suppliers evaluated in FY 23/24, ten have been prioritized for further action and five invited to engage in discussions. The dialogues are planned for FY 24/25. Ultimately, our aim is to galvanize support among our supply chain partners so we can increase the pressure at the “choke points” of the supply chain (e.g., metal smelters or refiners).

Respecting the right to water

We recognize that the human right to water entitles everyone to have physical and financial access to sufficient, safe, and acceptable water for personal and domestic use. As part of our obligation to respect this right, we assess the level of water scarcity in areas where we operate. The latest analysis revealed that approximately 40% of our sites have the potential for high to extreme water stress, defined as a “water demand to supply ratio of 40% or greater for the respective municipality”. The water stress analysis is based on the two databases Aqueduct Water Risk Atlas by the World Resources Institute and AQUASTAT by the Food and Agriculture Organization. Seven manufacturing sites have been found to have (1) high or extreme water stress, and (2) high water consumption relative to other sites.

Water stress level by sites*

*Based on all locations, including those beyond the regular scope of this report.

As part of our Sustainability Framework, we committed to establishing water stewardship programs in areas of high water scarcity, with no absolute increase in water consumption and reducing water intensity by 28% by 2027 (baseline 5,086 m³ absolute consumption and 25.5 L/hours worked in FY 19/20). We have reached this target ahead of schedule in a previous year and remained on track in FY 23/24. We will continue to monitor the status to ensure that the level remains within the target threshold until 2027.

Below are some examples from FY 23/24 of the water consumption reduction initiatives implemented to achieve this target:

At our production plant in Singapore, our colleagues increased the cycles of concentration for the cooling tower, which is a sustainable engineering solution to reduce water consumption in cooling towers operation. So far, a 5% improvement has been achieved in water intensity.
At our plant in Chiayi (Taiwan), we introduced the use of reclaimed water for our grass. Additionally, water meters have been installed to check for potential leaks. As a result, about 8,760 L per annum has been saved. In parallel, we launched activities to raise employees’ awareness of water preservation.
In Tocancipa (Colombia), we implemented operational controls during the nickel platting process in order to reduce wastewater generation.
Our manufacturing site in Chennai (India) introduced water saving measures by installing sensors for handwashing and lowering the water flow for the toilet facilities.

Outlook

During the upcoming financial year, we will continue to focus on our salient issues, evaluating the effectiveness of our projects and further refining our human rights due diligence processes. Our human rights risk management system will be updated to include new risk scores for our locations and new sites will undergo on-site audits. Corrective actions will continue to be implemented based on findings from the FY 23/24 auditing cycle.

Regarding our capacity building efforts, we will continue the rollout of our 12 training modules on our fair labor and human rights Directives for HR managers and site leads, and launch the ethical recruitment training for suppliers.

We will also continue working with our partners — Save the Children and The Center for Child Rights and Business — to contribute to the remediation of victims of child labor in small-scale mines in the Democratic Republic of Congo and to host dialogues with business partners in the cobalt supply chain.