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S2-4 - Actions taken and approaches adopted to manage Material risks and take advantage of Material opportunities in the Value chain

Updated over 5 months ago

ESRS Standard

The term"Policy" is synonymous with the term"Policy", which is used within the German version of the ESRS Standard.

30 The company shall disclose its actions with respect to managing material impacts on labor in the value chain, managing material risks and taking advantage of material opportunities related to labor in the value chain, and the effectiveness of those actions.

31 This disclosure requirement has two Targets: The first is to provide an understanding of any actions or initiatives the company is taking to

  • a) works to prevent, mitigate and improve significant negative impacts on workers in the Value chain, and/or

  • b) seeks to ensure material positive impacts on workers in the Value chain.

The second is to provide an understanding of how the company manages Material risks and takes advantage of Material opportunities related to labor in the Value chain. The company provides a summary description of the action plans and resources related to the management of its Material Impacts, Risks and Opportunities related to labor in the Value chain in accordance with ESRS 2 MDR-A Actions and resources related to material sustainability aspects.

32 With regard to material impacts, the company describes the following:

  • (a) what actions have been taken, are planned or are underway to prevent or mitigate significant negative impacts on labor in the Value chain,

  • b) whether and how it has taken actions to remedy or enable the remedy of an actual material impact,

  • (c) any additional actions or initiatives it is implementing primarily to achieve positive impacts on workers in the Value chain; and

  • (d) how it tracks and evaluates the effectiveness of these actions and initiatives in achieving the desired outcomes for workers in the Value chain.

33. in relation to paragraph 30, the company describes the following:

  • (a) the processes it uses to determine what actions are necessary and appropriate to respond to specific actual or potential negative impacts on workers in the Value chain,

  • (b) its approach to taking action in relation to specific material adverse impacts on value chain workers, including actions related to its own purchasing practices or other internal practices, as well as capacity building or other forms of collaboration with companies in the value chain or forms of collaboration with industry peers or other relevant parties; and

  • c) how it ensures that procedures to implement or enable remediation in the event of material adverse impacts are available and effective in terms of their implementation and outcomes.

34. with regard to Material risks and Opportunities, the company describes,

  • a) what actions are planned or have been taken to mitigate material risks to the company arising from its impacts and Dependencies related to labor in the Value chain and how it tracks effectiveness in practice; and

  • b) Actions planned or taken to address material opportunities for the company related to labor in the value chain.

35 The company discloses whether and how it takes actions to prevent its own practices from having or contributing to significant negative impacts on Own workforce/own workers in the value chain, including in relation to sourcing, sales and data use, where applicable. This may include an indication of the approach taken to address tensions between avoiding or mitigating material negative impacts and other business pressures.

(36) The company also discloses whether serious human rights issues and incidents have been reported within its upstream and downstream Value chain and, where applicable. (118)

(37) When providing the information required under paragraph 32(c), the company shall take into account ESRS 2 (see ESRS 2 MDR-T Tracking the effectiveness of policies and actions through targets) when assessing the effectiveness of an action by setting a target.

38. the organization specifies the resources allocated to the management of its Impact materiality, providing information that enables Users to understand how the Impact materiality is managed.


Application Requirements (AR)

AR 28. it may take some time to understand the adverse impacts and how the organization may be exposed to them through the workforce in its Value chain, and to identify and put into practice appropriate responses. In this regard, the company shall consider the following:

  • (a) its general and specific approaches to addressing significant negative Impacts,

  • b) its initiatives to contribute to additional material positive impacts,

  • c) how far it has progressed with its efforts during the reporting period and

  • d) its targets for continuous improvement.

AR 29 The appropriate actions may vary depending on whether the company causes or contributes to significant impacts or the significant impacts are directly linked to its activities, products or services through a business relationship.

AR 30. as material negative impacts on workers in the Value chain that occur during the reporting period may also be associated with companies or activities outside its direct control, the company may indicate whether and how it intends to use leverage in its Business relationships to address these impacts. This may include the use of business leverage (e.g. enforcing contractual requirements within business relationships or using incentives), other forms of leverage within the business relationship (e.g. offering training or capacity building on workers' rights to companies with which the company has a business relationship), or working with peer companies or other stakeholders (e.g. responsible hiring initiatives or ensuring Adequate wages).

AR 31 If the company discloses its participation in an industry or multi-stakeholder initiative as part of its actions to address material negative impacts, it may also disclose how the relevant material impacts will be addressed as part of the initiative and its own participation. Under ESRS S2-5, it may provide information on the relevant Targets of the initiative and progress towards achieving them.

AR 32 When disclosing whether and how the company considers the actual and potential impacts on workers in the Value chain when making decisions to terminate Business relationships and whether and how it seeks to mitigate any negative impacts of termination, the company may provide examples.

AR 33 If the company discloses how it tracks the effectiveness of its actions to address material impacts during the reporting period, it can provide any lessons learned from the previous and current reporting periods.

AR 34 The processes for tracking the effectiveness of Actions may include internal or external audits or reviews, legal proceedings and/or related court rulings, impact assessments, measurement systems, stakeholder feedback, Grievance mechanisms, external performance ratings and benchmarks.

AR 35 Reporting on effectiveness should enable an understanding of the linkages between the actions taken by the organization and the effective management of impacts. For example, to demonstrate the effectiveness of its actions to support its suppliers in improving their working conditions, the company may provide feedback from suppliers' workers indicating that working conditions have improved since it began working with these suppliers. Additional information that the company may provide includes data demonstrating a reduction in the number of Incidents identified, such as data collected as part of an independent audit.

AR 36. with respect to initiatives or procedures based on the needs of affected workers and progress in implementing such initiatives or procedures, the company may provide the following:

  • (a) Information on whether and how workers in the Value chain and Legitimate representatives or their Credible proxies are involved in decisions regarding the design and implementation of such programs or practices; and

  • (b) information on the intended or achieved positive outcomes of these initiatives or practices for workers in the Value chain.

AR 37. the company may indicate whether initiatives or practices whose primary objective is to achieve positive impacts on workers in the Value chain are also designed to support the achievement of one or more of the United Nations Sustainable Development Goals (SDGs). For example, a company committed to SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all could enable smallholder farmers in its supply chain to build capacity to generate income increases; or it could promote training to increase the proportion of women providing delivery services in its downstream Value chain.

AR 38 When disclosing the intended or achieved positive results of its actions for workers in the Value chain, distinguish between evidence that certain activities have taken place (e.g., that a certain number of workers have received financial literacy training ) and evidence of actual results for workers (e.g., that a certain number of workers report that they are better able to manage their household money so that they achieve their savings goals).

AR 39. in disclosing whether initiatives or practices also play a role in mitigating material negative impacts, the company may consider, for example, programs aimed at promoting the financial literacy of female workers that have resulted in more women being promoted and a reduction in sexual Harassment in the workplace.

AR 40. in disclosing the material risks and opportunities associated with the company's Impacts or Dependencies related to labor in the Value chain, the company may consider the following:

  • (a) Risks related to the company's impacts on workers in the value chain may include reputational or legal consequences if workers in the value chain are found to be subjected to Forced labour or Child labour,

  • b) Risks associated with the company's dependence on labor in the value chain may include business disruption if a pandemic shuts down significant parts of its supply chain or distribution network,

  • c) Opportunities related to the company's Impacts on labor in the Value chain may include market differentiation and greater customer attraction due to ensuring Adequate wages and conditions for Non-employees, and

  • d) Opportunities related to the company's dependencies on labor in the Value chain may include a sustainable supply of a Raw material in the future by ensuring that smallholder farmers earn enough to convince future generations to continue farming.

AR 41 When disclosing whether Dependencies become Risks, the company shall consider external developments.

AR 42 When disclosing policies, actions, means and targets related to the management of Material Risks and Opportunities, the company may provide cross-references to its disclosures on policies, actions, means and targets related to these impacts in cases where risks and opportunities arise from Material Impacts.

AR 43 The company shall consider whether and how its process(es) for managing material risks related to labor in the Value chain are integrated into its existing risk management process(es).

AR 44 When disclosing the resources allocated to managing material impacts, the company may indicate which internal functions are involved in managing impacts and the types of actions it takes to address negative impacts and drive positive impacts.


Examples from past practice

Examples serve only as an indication of how a disclosure requirement has been reported by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.

S2-4 - Actions to protect workers in the value chain

Sustainable supply chains and protection of human rights

We attach great importance to a sustainable approach to supply chain management, in particular the protection of risk groups that could potentially be affected by human rights violations. To ensure this, we rely on proven due diligence processes based on the continuous identification of Risks and the implementation of preventive and mitigating actions.

By introducing a human rights focus system, we can respond effectively to serious threats to human rights and the environment along the Supply chain. This system is based on internal analyses and enables us to target areas in the supply chain where the risk of negative impacts is particularly high.

Raw material supply chains

We take a particularly cautious approach to the procurement of Raw materials, especially if they could originate from conflict or high-risk areas. Our approach is based on the OECD Due Diligence Guidance. Important components of our approach include

  • the management and prevention of Risks,

  • monitoring the organizations involved in extraction and processing, and

  • clear communication and information mechanisms.

In this way, we ensure that our raw material supply chains are based on ethical and responsible principles. This helps to avoid conflicts and unethical practices and complies with international standards and requirements.

Assessment of health, safety and working conditions

Health and safety are essential components of the due diligence assessment of Suppliers. When selecting suppliers, we take into account factors such as the working conditions and safety measures that suppliers guarantee for their employees. On-site audits are used to check compliance with these standards. If suppliers do not comply with the required standards, we take appropriate actions.

Risk management and audits

To continuously improve our sustainability performance, we have established a quarterly risk management system for the Supply chain. Purchasing, supply chain and sustainability experts regularly assess internal and external Risks and Opportunities, particularly in relation to human rights. The aim is to raise awareness of sustainability-related risk management both within our company and among our suppliers.

In addition, we use targeted audit procedures to check our suppliers' compliance with human rights standards and other sustainability criteria. These audits include on-site assessments and the analysis of reports to identify potential Risks at an early stage. In 2023, this methodology enabled us to conduct several audits and gain valuable insights into the performance of our suppliers, which helps us to further improve our standards and processes.

Dealing with complaints and protection mechanisms in the Supply chain

Our approach to handling concerns and complaints in the Value chain is based on the principles of transparency, trust and effective remediation appropriate to the scale of the Incident. We are committed to continuously strengthening processes to provide or enable appropriate remediation to affected workers in cases where negative impacts have resulted from our actions or involvement.

Employees along the Supply chain also have unrestricted access to a confidential reporting platform that encourages them to anonymously report inappropriate or unlawful behavior. Further information on our Code of Conduct, the reporting platform and actions to protect whistleblowers from retaliation can be found in the relevant sections on corporate governance.

This article has been machine translated. In case of errors, please contact [email protected].

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