Henkel has a clear policy of doing business in an ethical and legal manner. This is inseparably linked with our commitment to respecting internationally acknowledged human rights. We follow ongoing human-rights-related developments very closely at both international and national level, including the National Action Plans for Business and Human Rights. We continue to develop our approach in line with the resulting expectations. In 2021, an internal cross-functional core team working across business units was established with overall responsibility to conduct a comprehensive review of our due diligence processes in consideration of the new legal requirements of German Act on Corporate Due Diligence in Supply Chains [Lieferkettensorgfaltspflichtengesetz], which came into force on January 1, 2023. In 2022, the engagement of the core team was strengthened, and its structure was formalized, in order to drive the implementation of targeted additions or adaptions. Since its establishment, the core team has updated and produced supplementary guidance to support the implementation of our commitments, and provided global training for internal and external stakeholders, such as suppliers.
Henkel conducts annual and ad hoc risk analyses to identify potential human rights and environmental risks. The risk analysis, which is subject to continuous improvements, serves as the basis for defining and prioritizing preventive measures.
We have identified two relevant human rights risks in our supply chain at present: raw materials based on palm oil and palm kernel oil, and raw materials from regions associated with military conflicts. We are closely monitoring these two areas with regard to their potential impact on human rights.
In order to reduce risks in the palm oil industry, we have made a commitment to procure our palm-oil-based raw materials in line with the principles and criteria of the Roundtable on Sustainable Palm Oil (RSPO). We also work closely with stakeholders along the value chain, from our suppliers to the RSPO, NGOs and smallholder farmers, to promote sustainable practices and respect for human rights.
To mitigate procurement risk from regions associated with military conflicts, including conflict minerals, we expect our suppliers to source conflict-free materials from responsible suppliers. We require our suppliers to perform due diligence on the origin and supply chain of these types of raw materials, and to provide evidence that they do not procure or process minerals from critical sources.
Henkel requests all affected suppliers to provide a completely filled and up-to-date Conflict Minerals Reporting Template (CMRT) disclosing all smelters in our common supply chain showing that all these smelters participated in the Responsible Minerals Assurance Process (RMAP) and are verified as conformant smelter by the RMI or any other OECD recognized business initiative.
All the CMRT’s are regularly reinvestigated and updated and published company wide. For more information, please see Conflict Minerals (henkel-northamerica.com) and our Responsible Sourcing Policy.