PDF Header: [Focus Topics – Respect for human rights]

Focus Topics – Respect for human rights

Respect for human rights  

Ensuring ethical governance

Management approach

Respect for human rights is reflected in our Code of Conduct, our Supplier Code of Conduct, our Human Rights Directive published in 2024 and our Whistleblowing Guideline.

Embracing an HRDD approach, Zehnder Group started recently developing a management system to conscientiously assess our human rights risks and impacts in a proactive manner. During this process, existing attributes will be reviewed based on a risk-based approach which includes a review of our compliance practices and a HRDD as well as a supplier sustainability risk assessment. We adhere to the principles of the ILO Conventions Nos 138 and 182, the ILO-IOE (International Labour Organization and International Organisation of Employers) Child Labour Guidance Tool for Business of 15 December 2015 with respect to fundamental labour rights and the UN Guiding Principles (UNGPs) on Business and Human Rights.

We put processes and policies in place for each of the six HRDD core elements: “Policy commitment”, “Risk & impact assessment”, “Risk-based measures”, “Embedding”, “Track & communicate” and “Grievance & remedy” and defined measures to improve in all six areas. The measures are regularly evaluated for their effectiveness. The human rights topics analysed are child labour, environmental issues impacting human rights, freedom of association and collective bargaining, living wage/income, modern slavery and forced labour, OHS, working conditions as well as workplace discrimination and harassment.

An external human rights consultancy supported us in building internal capacity and conducting a gap analysis. Based on interviews with 24 stakeholders, we analysed how internal policies and processes need to be adapted to comply with international standards on the core HRDD elements. The analysis showed that Zehnder already has individual HRDD elements in various directives, processes and systems. However, we did not yet have a holistic and systematic approach to implementing HRDD and certain elements needed to be further developed to comply with the UNGP and need to reach beyond tier 1 suppliers.

For each of the six HRDD core elements, Zehnder’s status was analysed and goals and respective measures were defined:

Next to the HRDD, Zehnder has several guidelines in place that already integrate human rights topics, such as the Anti-Harassment Directive and the Diversity and Equity and Inclusion Directive. Local OHS policies together with our management approach ensure a safe and healthy working environment for our employees. Regarding our value chain, the key guidelines are our Zehnder Group Code of Conduct, the Supplier Code of Conduct and our Modern Slavery Statement1. Another point worth mentioning is that the employees in most of our main sites are covered by collective bargaining agreements. However, we are not yet able to provide a company-wide figure on how many of our employees globally are covered by collective bargaining agreements, but we are confident that we will be able to report this figure next year.

In compliance with Swiss regulations regarding due diligence obligations and transparency concerning minerals and metals from conflict areas, as well as child labour, Zehnder addresses the topics of child labour and minerals from conflict areas within the broader context of its HRDD.

With respect to child labour, as explained above we are therefore following international standards and therefore comply with the equivalent provided by Swiss law2.

When sourced from a conflict-affected or high-risk context, all minerals and metals have the potential to cause or contribute to conflict financing and severe human rights abuses. Regarding minerals and metals from conflict areas, Zehnder Group has conducted an assessment of the minerals in scope in accordance with the Ordinance on Due Diligence Obligations and Transparency Regarding Minerals and Metals from Conflict Areas3. Assessing the import volumes from relevant business units in Europe4 showed that our total imports are below the threshold values in accordance with the Ordinance on Due Diligence Obligations and Transparency Regarding Minerals and Metals from Conflict Areas and Child Labour. Nevertheless, we aim to continue to reduce the use of conflict minerals in our products and, wherever possible, ensure that we do not use materials sourced from areas potentially affected by conflict.

Group Sustainability leads the HRDD at Zehnder and coordinates with the Group Executive Committee as well as relevant departments such as Legal, HR, Procurement, Logistics and the Competence Centres. Due diligence is applied through the six elements which form part of the HRDD approach set out above.

Limited to Zehnder Group UK
2 As defined in CO Art. 964j Para 4 and Ordinance on Due Diligence Obligations and Transparency Regarding Minerals and Metals from Conflict Areas and Child Labour Art. 9 Para 1
Tantalum, tin, tungsten, gold (3TG), as defined by regulation (EU) 2017/821
Lahr (DE), Bolesławiec (PL), Gränichen (CH), Vaux-Andigny (FR) and Manisa (TR)

Implementation and outlook

To implement the above management approach and policies, we defined an ambition that is underpinned by several targets and monitored via specific KPIs.

Ambition: Apply a Human Rights Due Diligence approach and respect the UN Guiding Principles on Human Rights

Set up Human Rights Due Diligence risk management process and implement a roadmap based on the UN Guiding Principles on Business and Human Rights

In 2023, we initiated the implementation of an HRDD process in accordance with international standards. Zehnder has developed a Human Rights Roadmap – a key tool when it comes to encapsulating all aspects of HRDD mentioned earlier. It will include quantitative as well as qualitative targets with clearly defined KPIs, measures, responsibilities, budget and resources, timelines and monitoring.
We continue to develop and implement the HRDD process and further develop the risk-based measures to tackle the salient human rights topics identified. This includes the development of relevant KPIs and setup of a systematic human rights risk management framework including a routine risk assessment.

Ambition: Minimise the use of rare earth and conflict minerals consumption in our products and production processes

Assess our main direct high risk material supply chains by country of origin

Many materials have been well researched and documented for the human rights risks that are related to their production. In addition to tantalum, tin, tungsten and gold, we acknowledge the potential adverse effects of other materials procured by our Group for goods production. These include iron for steel, bauxite for aluminium, copper and the mica group of minerals.
Primarily, our initial focus is on the steel industry. Our aim is to identify the sources of iron used in the manufacturing of our steel products. We have set ourselves the goal of discontinuing the sourcing of steel from conflict-affected and high-risk areas by 2025 in cases where such sourcing exists at present.

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