Our Human Rights Due Diligence Programme is built on eight operational pillars, described below:
- Policy commitments
- Stakeholder engagement
- Risk assessment
- Impact assessment
- The Nestlé Human Rights Working Group
- Monitoring and reporting
Pillar 1: Policy commitments
We integrate human rights into new and existing policies and procedures.
In 2009, the Danish Institute for Human Rights performed a human rights gap analysis against all our relevant policies and procedures.
In 2010, we revised our 10 Corporate Business Principles, which form the basis of our Company’s culture, to include “Human rights in our business activities” as a principle. This is now considered as our Company-wide human rights policy. All our employees worldwide have received a copy of the updated Principles, and we have begun to roll out training sessions on them (see Pillar 3: Training).
Since 2010, we have adopted or revised 12 policies and procedures to address specific human rights topics. These include, for example, the Nestlé Supplier Code, our Policy on Conditions of Work and Employment, and the Nestlé Employee Relations Policy.
In 2012, following the approach described above, we launched two new policy commitments:
In addition, in 2012, we started to roll out a revised version of CARE, our independent audit programme that includes a new chapter on human rights and labour practices.
Pillar 2: Stakeholder engagement
We engage with our stakeholders on human rights issues at the international and local levels:
As part of our efforts to have our subsidiaries more engaged in UN Global Compact local networks, we hosted a workshop on business and human rights in Kenya (March 2012). As a Board member of the Global Compact network in Switzerland, we organised a dialogue with the promoters of the “Corporate Justice” Recht ohne Grenzen initiative, the Swiss UN Global Compact signatories, interested companies, civil society and other experts in the field (September 2012).
Nestlé and the International Union of Food, Workers (IUF) have agreed that it is in their mutual interest to establish a constructive and frequent dialogue (bi-annual meetings) on global labour issues. Two meetings already took place in February and December 2012.
We delivered on the commitments we’ve made in stakeholder consultations as part of our affiliation with the Fair Labour Association (FLA), and in particular in our Action Plans on Responsible Sourcing on:
- Hazelnuts: We participated in a round table stakeholder meeting on child labour in the hazelnuts supply chain organized by the Turkish Ministry of Labour in Turkey, Ankara, July 2012
- Cocoa: Together with the FLA, we organized a stakeholder convening in Côte d’Ivoire (Abidjan, November 2012) with all relevant local and national actors in the cocoa sector. The convening took place at our R&D Center and gathered more than 60 participants. The report of this convening is accessible on the FLA website
We continued our dialogue with Alliance Sud through formal annual high-level meetings and regular working level meetings and information exchange. Specific issues of concern, such as the corporate responsibility to respect human rights or trade union issues in Colombia and elsewhere, were discussed between Nestlé and Alliance Sud in a protected environment.
We participated in the Annual Conference of the Swiss Federal Department of Foreign Affairs (September 2012), as well as in the Annual Conference of Amnesty International Switzerland (April 2012).
In addition, we engaged with a range of national and regional stakeholders as part of the Human Rights Impact Assessments we carried out this year (see Pillar 5: Impact Assessment).
Pillar 3: Training
We train our employees and develop their capacities on human rights.
This year, we trained a further 18,103 employees as part of the roll-out of our online Human Rights Training Tool for our employees (see 'How we’ve performed' for more information). The on line training continues to focus on high risk countries as a priority.
Building on the online training, we also conducted three in-depth, face-to-face training sessions, reaching 166 employees from Corporate Human Resources.
On December 10, coinciding with the International Human Rights Day, we launched the first “Nestlé Human Rights Week”, including a lunch-time conference with Puvan Selvanathan, Chair of the United Nations Business & Human Rights Working Group.
We’ll continue and further strengthen our efforts on human rights awareness-raising and training throughout 2013, focusing on Corporate departments and countries where we carry Human Rights Impact Assessments (See Pillar 5: Impact Assessment). Combining these two initiatives – assessment and training – has proven very effective in helping our employees understand human rights and how they apply to their daily business activities.
Pillar 4: Risk assessment
We evaluate human rights risks across our business activities.
As in previous years, the members of the Human Rights Working Group (see Pillar 6 for more information) supported by representatives of the Danish Institute for Human Rights and the Fair Labor Association conducted their annual Human Rights Risk Assessment.
The objective of this process is to evaluate the likelihood and potential impact (high, medium, low) of human rights risks on our business. We evaluate these risks at five levels: Nestlé facilities, tier-1 suppliers, upstream suppliers, local communities and country operations. Every risk identified as ‘high’ has a specific action assigned to it in order to mitigate it, to be implemented by the relevant department or country operation. Progress on implementation is reviewed throughout the year by the Nestlé Human Rights Working Group.
For the first time, we included Maplecroft risk indices as part of the review process, in order to increase our understanding of human rights risks for business in specific countries. In addition, we added nine new risk indicators (increasing the number to 48, from 39 in 2011) to take new potential risks into account in the following areas: provision of accommodation and basic services, complicity, employees’ contracts, work-life balance, environmental impacts and community impacts.
This year, we identified 40 high risks at the five different levels under review: Nestlé facilities (12), tier-1 suppliers (14), upstream suppliers (10), local communities (1), and operating countries (3) (see 'How we’ve performed' for more information).
Pillar 5: Impact assessment
We assess human rights impacts where we operate.
This year, continuing our work with the Danish Institute for Human Rights (DIHR), we carried out three Human Rights Impact Assessments (HRIAs) in Russia, Uzbekistan and Kazakhstan. These add to the four HRIAs we’ve carried out previously in Colombia (2010), and Nigeria, Angola and Sri Lanka (2011).
Each of these assessments typically includes:
- In-depth interviews at the country head office with all the relevant managers: Human Resources, Legal, Marketing, Security, Safety & Health, Environment, and Procurement & Supply Chain
- Visit of factories and distribution centres, and interviews with management and employee groups (unionized and non-unionized, male and female, young and older)
- Visit of tier-1 suppliers and interviews with management and employee groups
- Visit of farmers or farmer associations if commodities are sourced locally
- Engagement with local representatives of:
- Trade unions
- Local communities
- International organisations (including UN Global Compact local networks, if any)
- A debriefing session with Nestlé country operation management, and
- An action plan drafted against DIHR’s recommendations.
Regarding investments, significant investment agreements as defined in the GRI Protocols Set for Human Rights are, in the Nestlé context, a little narrow in scope and would include only major transactions such as significant acquisitions of material and strategic importance to the Group. For 2012, this would include the acquisition of Pfizer Nutrition. However for all our acquisitions (even if not significant at Nestlé Group level as per the definition) Nestlé adopts a consistent approach and methodology which includes a detailed due diligence process supported by checklists and guidelines that should identify up front compliance and human rights issues before any firm and binding agreement is signed. In 2013 we will continue our work to fulfil our objective to ensure human rights concerns are properly identified and addressed as part of our M&A due diligence process.
Pillar 6: The Nestlé Human Rights Working Group
We coordinate our human rights activities across the business. Our Human Rights Working Group (HRWG) is made of eight departments: Human Resources, Public Affairs, Legal, Security, Compliance, Procurement, Safety, Health and Environment, and Risk Management. Its mandate is to strengthen the effectiveness and improve the coordination of human rights-related activities and initiatives across the company.
This year, our work concentrated on developing a document setting key priorities for 2012-2014. A work plan of specific actions to be carried out against these key priorities will be agreed each year by the HRWG.
Pillar 7: Partnerships
We partner with leading organisations to implement our activities. In 2012, we continued our close collaboration with the Danish Institute for Human Rights (DIHR) as part of the implementation of our Human Rights Due Diligence Programme. Our two-year partnership will be renewed in Q1 2013.
In February 2012, we became an official affiliate of the Fair Labor Association (FLA), which helps us address labour standards in our supply chain, starting with hazelnuts in Turkey and cocoa in the Cote d’Ivoire.
Our work with the DIHR and FLA, both expert organisations in human rights and labour, has been instrumental in helping us assess the positive and negative impacts across our entire value chain. These complementary partnerships are important drivers of our overall Human Rights Due Diligence Programme.
Pillar 8: Monitoring and reporting
We monitor our performance and report publicly on it every year. Our codes, policies, systems and practices are regularly audited. Together with our efforts on human rights risk and impact assessments (see Pillar 4: Risk Assessment, and Pillar 5: Impact Assessment), our monitoring mechanisms help us verify how far human rights have been integrated into our own operations and throughout our supply chain.
At Nestlé facilities level, the revised version of our CARE Audit programme includes a comprehensive, stand-alone Human Rights and Labour Practices section (see Managing compliance for more information). In addition, our Integrity Reporting System allows us to receive and resolve individual grievances from our employees, including when they relate to human rights issues (see 'How we’ve performed' for more information).
At tier-1 supplier level, our Responsible Sourcing Audit Programme verifies compliance against the Nestlé Supplier Code. Audits are performed by external auditors, using the Sedex Members Ethical Trade Audit (SMETA) 4-Pillar guidelines. Under these guidelines, audits are performed against a large number of human rights aspects, including forced labour, freedom of association, health & safety, child labour and young workers, living wage, working hours, discrimination, regular employment, sub-contracting, discipline, migrant and agency labour, and community benefits (see Managing Responsible Sourcing/'What we're doing' for more information about our Audit Programme).
At the upstream supplier level, our Responsible Sourcing Guidelines include human rights requirements that have been identified as material for each commodity. In addition, the verification and certification tools that we use as part of the Farmer Connect Programme and in our Cocoa and Nescafé Plans, such as 4C, UTZ, Fairtrade and Rainforest Alliance include specific human rights requirements.
Managing security risks
Security is an increasingly important human rights issue. We want our employees to work in an environment that is free from security concerns. The Nestlé Group Security (NGS) protects our employees, assets and reputation from threats of any kind. Externally, NGS cooperates with the relevant authorities to address security risks, and ensures we comply with applicable laws and regulations. Internally, it abides by our Corporate Business principles, Code of Business Conduct and commitment to Human Rights.
Compliance with these many different aspects of our regulatory environment must never be compromised, even when protecting our people and property against illegal activities by third parties.