1. Introduction
We are committed to respecting all internationally recognised human rights and promoting them in our operations. We expect the same from our partners.
Companies must be aware of the impacts of their operations on human rights, both near and far. Our operations have an impact, in particular, on the human rights of customers, employees and the employees of the providers of products and services within the supply chain.
Our human rights principles describe our approach to human rights. They guide both our own operations and those of our partners. The principles describe how S Group identifies and assesses the impacts of its operations on human rights. They also indicate the practices we have to minimise and eliminate any adverse impacts.2. S group’s approach and the management of human rights issues
S Group is committed to respecting all internationally recognised human rights. We promote the fulfilment of human rights in everything we do, and we expect the same from our partners. We avoid causing or contributing to any adverse impacts on human rights by observing proper caution in accordance with the UN Guiding Principles on Business and Human Rights.
In its operations, S Group complies with valid international and national laws and regulations. S Group’s operations are also governed by international agreements and recommendations, such as the Universal Declaration of Human Rights, the UN Conventions on the Rights of the Child and Women, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.
Human rights management at S Group is part of sustainability management. SOK Responsibility is responsible for our human rights principles and their development and implementation guidance. Within S Group, SOK Responsibility is responsible for the assessment of human rights risks and the development of new operating models. It also steers and coordinates the continuous assessment of human rights risks in different functions. SOK Responsibility is also responsible for internal and external reporting related to human rights.
In accordance with the management model, SOK Responsibility regularly reports key risks related to human rights, key figures and the most significant selected projects to SOK’s Executive Board and senior management. SOK’s Executive Board approves principles and commitments related to human rights.
SOK’s units and subsidiaries evaluate key business area-specific risks and preventive measures. The units are also centrally responsible for the implementation of preventive and corrective measures related to human rights.
These human rights principles supplement S Group’s Code of Conduct and S Group’s responsibility principles and specify S Group’s approach to human rights.With regard to different functions, such as business areas and support units, S Group has assessed key impacts on human rights, the scope of these impacts and the available means to minimise any adverse impacts on human rights. The assessment begins with the identification of the groups whose human rights are affected by S Group either directly or indirectly. The assessment also takes into account particularly vulnerable persons and groups, such as children, women, migrant workers, indigenous peoples and persons with special needs.
In assessing our human rights impacts, we make use of reports and studies by various organisations and authorities, country-specific risk assessments, and dialogue with stakeholders such as non-governmental organisations and trade unions, as well as our own experience in monitoring working conditions at factories, for example. The assessment involves S Group’s specialists from different business areas and the Procurement, HR and Responsibility units. With regard to particularly vulnerable groups, the risk assessment involves stakeholders such as non-governmental organisations.
The assessment of human rights impacts is an ongoing process within S Group. For example, the fulfilment of human rights in the supply chain is continuously monitored in various ways.4. Key adverse impacts on human rights
S Group has both direct and indirect impacts on the human rights of various groups. The direct impacts are related to S Group’s employees and customers, while the indirect impacts are related to supply chain employees and communities through business relationships. Key direct and indirect human rights impacts are described below. This is not an exhaustive list, but a list of the key and most significant human rights impacts that S Group specifically aims to minimise. Other human rights are equally important, and we will continue our work to ensure that we do not hinder their fulfilment in any way.4.1. Direct impacts
S Group’s most significant direct human rights impacts are related to the safety of our customers and employees. Ensuring the safety of locations and products, self-monitoring and, for example, monitoring compliance with age limits for purchasing alcohol and tobacco products call for continuous work to ensure that no one’s safety is compromised at work or when visiting an S Group location. The materialisation of risks is possible.
Our possible direct human rights impacts also include non-discrimination and the equality of our customers and employees. Non-discrimination means the equal treatment of customers and employees and the accessibility of our locations, for example. We also respect our employees’ right to join trade unions, and do not tolerate any kind of discrimination or harassment. For example, we prepare non-discrimination and equality plans for our employees and train our employees to ensure an equal workplace community without any discrimination. The materialisation of this risk is unlikely.4.2. Indirect impacts
S Group may also have indirect impacts on the human rights of people working in the supply chains of products and services. Our most significant potential indirect human rights impacts are related to forced labour, discrimination, violations of freedom of association, child labour, human trafficking, insufficient salaries, excess working hours, compromised occupational health and safety, and a lack of freedom of association and collective bargaining.
Generally, S Group’s most significant human rights risks within the supply chain are related to countries where the laws and their implementation and monitoring are insufficient or that have not ratified international agreements on labour and human rights; to countries that have a large number of domestic or foreign migrant workers; to products and raw materials produced in high-risk countries that use low-skilled labour to a high degree; to goods suppliers who have not made a commitment to sustainability initiatives and have not developed operating methods to ensure responsible procurement; to non-certified high-risk raw materials; and to long supply chains. It must also be taken into account that non-risk countries may have areas with elevated levels of human rights risks. In particular, we carefully assess situations in which we purchase products and services from conflict-prone areas.5. Preventing and minimising adverse impacts on human rights
S Group’s work for the fulfilment of human rights is based on thorough risk assessments and the targeting of actions to areas where the risks are the highest. In accordance with the UN Guiding Principles on Business and Human Rights, actions are prioritised on the basis of the severity, irrevocability and probability of impact, and of whether impact is caused directly or indirectly, such as through business relationships.
We monitor the fulfilment of human rights in supply chains in many ways, including audits of suppliers in countries with a high risk classification and certifications of high-risk raw materials. We expect all of our suppliers of products and services to respect human rights, as well as to ensure that products can be traced back to the source of the raw materials. Alongside independent audits and certificates, we have developed a method to investigate the root causes of human rights risks in supply chains. Its goal is to identify current human rights issues related to products or production countries and their root causes, so that we can have an impact on them, together with our partners and stakeholders. Investigations are conducted by an independent third party, and we communicate their results openly.
We seek to have an impact on the development of working conditions in key countries from where we purchase products and services and on the development of laws that govern these through our partnership networks, whenever this development is in conflict with international human rights agreements and the ILO’s standards. Open interaction with stakeholders and our partnership networks is key in making an impact. We can also have an impact by issuing various statements to the authorities or companies, either separately or jointly with international networks.If any direct violations of human rights are discovered in S Group’s activities, we will immediately start an investigation process together with the business or other unit concerned and the stakeholders. Corrective measures are taken to prevent any broader impacts and, if possible, to repair any harm. We will also investigate our own operating methods to prevent similar violations from recurring.
If any defects related to human rights are discovered in S Group’s procurement of products and services, we will immediately start an investigation into the matter. Corrective measures will be agreed upon with the partner concerned, and their implementation will be monitored, for example, by means of audits. Cooperation with the partner concerned will not primarily be discontinued, as doing so would not help the workers’ situation at the factories and farms – cooperation is the best way to improve operations. Furthermore, boycotting a specific product or procurement area is never our primary solution, as this would often damage the position of workers who are already in the weakest position. In situations where a partner does not show any willingness or commitment to develop any repeatedly discovered defects, cooperation can be discontinued. Cooperation can also be discontinued if a partner does not consent to any audits conducted by an independent third party. The goal is to increase the capabilities of partners to improve the conditions of workers by providing training and by requesting suppliers to participate in training provided by amfori.
In supply chains in particular, S Group is not always able to have any direct impact on the correction of defects. In this case, it is important to grow influence by working with other companies, responsibility initiatives and other networks.7. Consultation of stakeholders
As part of its due diligence process, S Group engages in dialogue with relevant stakeholders and makes use of various reports, surveys and studies, for example. The risks we have identified, the due diligence process and its components are regularly reviewed with various organisations. Employees in the value chain are consulted through organisations representing them or through audits, whistleblowing channels and solutions enabled by digital tools, among other means.8. Whistleblowing channel
Any suspicions of misconduct and unethical activities can be reported through S Group’s whistleblowing channel to have these suspicions investigated. We will not, in any way, restrict the freedom of any stakeholder to report unethical activities. In addition, employees working in the supply chain have access to amfori’s whistleblowing channel, which can be used to report human rights violations in amfori members’ supply chains.9. Supporting a free civil society and defenders of human rights
The existence of a free civil society benefits companies. A well-functioning civil society forms the basis of a responsible and predictable government, which is also a precondition for sustainable and profitable business. A free civil society also produces valuable information about any violations of human rights. This information is an important part of the fulfilment of the due diligence principle related to human rights and helps to highlight any problems and process them together with our partners.
S Group has extensively and openly supported civil society in order to support human rights in supply chains. Defenders of human rights are individuals or groups who promote the fulfilment of human rights locally, nationally or internationally. Typically, non-governmental organisations, representatives of trade unions and employees who highlight defects in working conditions can also be considered defenders of human rights. We cooperate with non-governmental organisations, members of civil society and defenders of human rights. S Group openly provides information about its supply chains and the origin of products to civil society actors and the authorities within the framework of legislation.
We do not interfere with the work of defenders of human rights or the functioning of civil society, including campaigns related to S Group. We expect that our partners also respect the work of defenders of human rights and the functioning of civil society, and we do not accept any type of interference from our partners. In situations where there is clear evidence of one of our partners interfering with or preventing the work of defenders of human rights or the functioning of civil society, we aim to exert pressure within the scope of our influence on our partner to stop this interference.
If this situation is associated directly with S Group’s activities, legal and financial measures are also possible. Such situations will be investigated on a case-by-case basis. Improving legal protection at the national level is a key method in supporting the work of defenders of human rights, and their lawful activities should not be impeded by legal means.10. Communications
As part of our sustainability reporting, we provide information openly about S Group’s key procurement countries, audit results, the coverage of certificates and any activities carried out during the year regarding human rights. In addition, we also aim to communicate openly about development, challenges and key projects in our own communication channels. We operate openly and transparently in interaction with civil society.
Helsinki, 21th November 2024
SOK's Executive Board