Deutscher Nachhaltigkeitskodex

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CSR-RUG

A globalised economy with increasingly complex supply chains and ever greater competitive pressure gives rise to the risk of human rights violations. Companies therefore increasingly have a responsibility to effectively defend these rights within their own business activities and all along the value chain. Human rights violations come to light more quickly these days thanks to the information society and are incorporated into companies’ risk assessments; they influence consumer behaviour and business relations. A company fulfilling its due diligence obligations can therefore not only boost customer and staff retention, but also improve supply relationships and thus contribute to the company’s long-term success.

What needs to be borne in mind?
The upholding of human rights is not just a topic for global enterprises. Human rights issues are relevant in Germany too, such as freedom of association (e.g. regarding the formation of trade unions), the principle of equal pay for equal work and protection from (occupational) diseases. Please give a precise account here of how your company fulfils its human rights due diligence obligations now and intends to do so in the future and demonstrate how you go above and beyond compliance with the laws as applicable. For guidance here, you may wish to refer to the publication “Respecting human rights: An introductory guide for business” developed by Global Compact Network Germany, twentyfifty and the German Institute for Human Rights.
There is a degree of overlap with criterion 14, Employee Rights. In addition to the upholding of your employees’ human rights, please therefore describe in particular how you handle the human rights of other stakeholders throughout the value chain, such as customers (e.g. product safety in relation to the right to physical integrity), residents (resettlement in relation to land rights), the especially vulnerable, etc.

Aspect 1:
Report on the goals and planned goal achievement time frames for the upholding of human rights by your company, any subsidiaries, and suppliers and service providers.

Aspect 2:
Report on the strategies and concrete measures for the upholding of human rights by your company, any subsidiaries and suppliers.

Aspect 3:
State whether previous goals were achieved and, if so, to what extent, and disclose any goals which were not achieved and why.

Aspect 4:
Report on the material risks arising from your business activities, your business relations and your products and/or services that are likely to have a negative impact on human rights.

Human rights apply to all people equally. They are universally valid and indivisible, and no one can be deprived of them. Governments and companies have a duty to protect these rights. This makes them directly responsible for the upholding of human rights. There are various globally recognised texts that lay down the various human rights, such as the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, the International Covenant on Civil and Political Rights, the Convention on the Elimination of All Forms of Discrimination Against Women, the Convention on the Rights of the Child and the ILO’s core labour standards.

Key Performance Indicator GRI SRS-412-3: Investment agreements subject to human rights screenings

a. Total number and percentage of significant investment agreements and contracts that include human rights clauses or that underwent human rights screening.
b. The definition used for ‘significant investment agreements’.

Key Performance Indicator GRI SRS-412-1: Operations subject to human rights reviews

a. Total number and percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country.

Key Performance Indicator GRI SRS-414-1: New suppliers subject to social screening

a. Percentage of new suppliers that were screened using social criteria.

Key Performance Indicator GRI SRS-414-2: Social impacts in the supply chain

a. Number of suppliers assessed for social impacts.
b. Number of suppliers identified as having significant actual and potential negative social impacts.
c. Significant actual and potential negative social impacts identified in the supply chain.
d. Percentage of suppliers identified as having significant actual and potential negative social impacts with which improvements were agreed upon as a result of assessment.
e. Percentage of suppliers identified as having significant actual and potential negative social impacts with which relationships were terminated as a result of assessment, and why.

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Key Performance Indicator EFFAS S07-02 II
Percentage of total facilities certificated according to SA 8000 standard. Link

Reporting on the National Action Plan for Business and Human Rights

If you wish to use your Code declaration of conformity to also report (element 4 of due diligence obligations) in accordance with the National Action Plan for Business and Human Rights (NAP), please additionally report on the basis of the following checklist. Questions set in italics are already covered in your responses to the corresponding Code aspects.

1. Human rights policy statement

State whether your company has its own corporate guidelines for upholding human rights and whether they also encompass the ILO’s core labour standards.
Has the company management approved the policy statement?
Describe your company’s internal and external communication on the topic of human rights.
At which level is responsibility for human rights concerns enshrined? (CSR-RUG checklist 1b)
Define the reach that your guidelines have (which sites, including subsidiaries etc.).

2. Procedures for the identification of actual or potential adverse impact on human rights

State whether and how your company analyses human rights risks (caused by your business activities, your business relations, your products and services, at its sites, due to political parameters) (criterion 17, checklist aspect 4).
Are especially vulnerable groups of people incorporated into the risk assessment?
What is your company’s assessment of the human rights risks and its ability to counter these itself?
How are human rights risks incorporated into your company’s risk management?

3. Measures to review effectiveness / Element: grievance mechanism

Is there training for employees in the area of human rights?
State whether and how the upholding of human rights is checked.
Describe any internal grievance mechanisms and clearly assigned responsibilities within the company or explain how access to external grievance mechanisms is ensured.
Do whistle-blowing mechanisms also apply to suppliers?

4. Human rights due diligence obligations in the value chain

Is there a suppliers’ code of conduct that comprises the four ILO core labour standards?
State whether and how a check is performed for human rights risks prior to entering into a business partnership.
Are suppliers given training on human rights?
What processes does your company use to guarantee that its suppliers uphold human rights?
Do you implement measures (jointly with suppliers) in the event of a conflict or do you work with other stakeholders? If so, which ones?
What redress policies are there? Report on incidents in the reporting period.

Reporting in line with the German CSR Directive Implementation Act
(German legislation implementing the Directive 2014/95/EU)

Upholding of human rights
If you also wish to use your Code declaration to comply with the reporting obligation in accordance with the CSR Directive Implementation Act (CSR-RUG), the checklist below will give you guidance regarding how the Code Office checks it for formal completeness. You can provide the relevant information concerning the upholding of human rights under this Code criterion. Questions set in italics are already covered in your responses to the corresponding Code aspects..

1. Report on the management policy pursued:
a. ls and planned goal achievement time frames (criterion 17, aspect 1).
b. How corporate governance is incorporated into the policy.
c. Strategies and concrete measures for achieving the goals (criterion 17, Aspect 2).
d. Internal processes for monitoring implementation of the measures.

2. Report on the results of the policy:
a. Whether and to what extent previous goals were achieved (criterion 17, aspect 3).
b. Whether and how it is determined that the policy needs modifying and what conclusions are then drawn.

3. Report on the risks:
a. How the risks were identified and the material risks were filtered out (due diligence processes).
b. Material risks arising from your business activities that are highly likely to have a negative impact on human rights (criterion 17, aspect 4).
c. Material risks arising from your business relations that are highly likely to have a negative impact on human rights (criterion 17, aspect 4).
d. Material risks arising from your products and services that are highly likely to have a negative impact on human rights (criterion 17, aspect 4).

cosnova GmbH

In the company: The respect and observance of human rights in our business activities are addressed by standards and measures at various stages of the supply chain. We consider our corporate values to provide the basis for all our actions. As an owner-managed family business that has been successfully developing cosmetic products for more than 15 years, we stand for our corporate values of passion, courage, trust, reliability, openness and responsibility. We also stand for loyalty – to our employees, to our business partners and to our locations. We assume responsibility and are committed to a high standard of ethics, fairness and transparency. In addition, compliance with human rights is ensured through our adherence to legal standards such as the German constitution (Grundgesetz) and labor law.

At the supplier: The cooperation with our suppliers is based on long-standing, close and trusting business relationships. We expect our partners to also act responsibly and work according to our standards. In order to build this basis for our business relationships on a common, defined foundation, a Code of Conduct for business partners was introduced in 2017. The Code of Conduct must be recognized and signed by all suppliers and partners and is based on the ILO Core Labor Standards and, of course, compliance with stipulated and local laws. Compliance with the Code of Conduct and our quality standards at our suppliers is checked by external audits. In addition, a new process is currently being developed for this purpose that specifically checks compliance with social standards. A further means of monitoring compliance with human rights in our supply chain is the sustainability assessment by EcoVadis, which also checks for fair working practices and fair business practices.

In our supply chain A major challenge of our business model is the extensive supply chain up to TIER 4/5. In order to follow the national action plan for human rights, we have carried out an analysis of our raw materials portfolio. Strategically important raw materials were identified, subjected to a supply chain assessment and a risk analysis was carried out.

The raw material mica has been identified as a high risk material for potential negative human rights impacts. As a first measure, a continuous Mica Supply Chain Mapping was introduced with the aim of achieving 100% transparency of the mica supply chain in our value chain in the long term. The willingness of our suppliers to participate in this Supply Chain Mapping was defined as a prerequisite for our business relationships, with the consequence that we voluntarily forgo suppliers who do not wish to disclose their mica supply chain. Currently, Supply Chain Mapping only applies to natural mica with India as the country of origin, as this is where the greatest risk of negative human rights impacts exists worldwide. In the long term, however, all other countries of origin of natural mica must also be included in the Supply Chain Mapping. In 2017, we joined the RMI (Responsible Mica Initiative) to find joint solutions to the problems in the mica supply chain and to implement our goals. The transparency of our mica supply chain is continuously measured and recorded as one of our key performance indicators. Our goal is to achieve full transparency of the mica supply chain by 2023.

Status 2017: 61 percent transparency
Status 2018: 62 percent transparency and/or 88 percent transparency if RMI members are classified as completely transparent.

Raw materials based on palm oil and palm kernel oil were identified as another human rights risk factor in our supply chain. In order to reduce the negative effects of palm oil cultivation on humans and nature and to stop them in the long term, sustainable cultivation is one of the most important "adjustment screws". For this reason, we became a member of the RSPO (Roundtable on Sustainable Palm Oil) in 2018. The higher the demand for sustainable palm oil is, the stronger are the incentives for producers to work in a sustainable manner. Every participant in the supply chain has the opportunity to promote and support sustainable palm oil. Some of our products contain palm oil and/or palm oil derivatives, although the proportion of palm oil in our product portfolio is relatively low compared to skin care products. According to our calculations, less than 15 percent of our raw materials contain palm oil, while the proportion of pure palm oil/palm kernel oil is less than 0.1 percent. Nevertheless, we are committed to meeting our responsibility as a player in the palm oil supply chain. As part of our sustainability strategy. we have therefore decided to purchase RSPO Credits from January 2018 to fully compensate the quantities of palm oil derivatives we use and thus promote the sustainable cultivation of palm oil. In addition, we compensate our quantities of pure palm oil and pure palm kernel oil by purchasing special RSPO credits that directly benefit small palm oil farmers. Quantities of credits purchased in 2018:

Total credits purchased:				440

Purchasing details 2018:
CSPO (Certified Sustainable Palm Oil)				364 Credits
CSPKO (Certified Sustainable Palm Kernel Oil)				73 Credits
IS-CSPO (Smallholder – Certified Sustainable Palm Oil)				1 Credit
IS-CSPKO (Smallholder – Certified Sustainable Palm Kernel Oil)				2 Credits

Future topics: In 2018, we joined the RBI (Responsible Beauty Initiative) to address further and future issues related to negative human rights impacts in the raw material supply chain. Here, too, we would like to work together with other industry representatives on solutions and goals for a transparent and sustainable supply chain.

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