MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2022
At Beiersdorf UK Ltd we want to play an active role in making positive contributions to society. Beiersdorf UK Ltd acknowledges that as a global corporate citizen it has a responsibility to address and seek to eliminate the risk of slavery and human trafficking in its operations. This is as part of the respect that the company has for human rights, in line with the principles contained in the United Nations Universal Declaration of Human Rights and the UK Modern Slavery Act 2015.
In this statement, we set out Beiersdorf UK Ltd’s commitment to taking steps to identify and eradicate slavery and human trafficking from its business and from its supply chains. We do not tolerate slavery and human trafficking within the supply chain or within any part of Beiersdorf UK Ltd’s business.
As required by the UK Modern Slavery Act 2015, this statement reports on the steps Beiersdorf UK Ltd and the Beiersdorf group have taken in this regard during the financial year ended 31 December 2022.
STRUCTURE AND SUPPLY CHAINS
Beiersdorf UK Ltd, based in Birmingham, is a part of the Beiersdorf group, a global leader in the consumer goods industry. Beiersdorf UK Ltd’s principal activity is sales, marketing and distribution of products for the care and protection of skin marketed under major brands such as NIVEA, Eucerin and Elastoplast. An overview of where Beiersdorf UK Ltd fits within the global business, as well as details of the company’s core values and product brands appears in the online company profile. Information about the parent company Beiersdorf AG can be found on its homepage.
Beiersdorf UK Ltd is integrated into a supply chain whose processes take place predominantly within Europe. Only a handful of suppliers who directly supply Beiersdorf UK Ltd are located outside of Europe. More precisely, in 2022, Beiersdorf UK Ltd sourced 91% of the volumes of the finished goods from Beiersdorf owned factories and 9% from third-party manufacturers or third-party co-packers. 61% of these volumes were sourced from Germany, 19% from Spain, 15% from Poland, 3% from The Netherlands and the remaining 2% from the rest of the world.
Regarding goods and services not directly related to the production of products, 93% of spend was with suppliers located in the UK, 6% with those based in Europe and 1% with suppliers outside of Europe. 64% of spend (35% of suppliers) were covered by the Corporate Procurement (Global and Regional) function and 36% of spend (65% of suppliers) by the Local organisation.
POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
Policy for Employees
All Beiersdorf UK Ltd employees (200+) are provided with a Code of Conduct for Employees. The latest version of this Code of Conduct was officially introduced by the Board of Directors to all employees and managers in 2023. In addition, everyone is trained on this policy through e-learning.
The Code of Conduct is designed to help employees to understand the company’s principles and to act in accordance with them. Diversity and equal opportunities are an essential part of the Code of Conduct. The Code also clearly states that Beiersdorf does not support or tolerate slave labour, child labour or human trafficking. Beiersdorf also stands for fair working conditions and promotes physical and mental health and safety at work.
Policy for Suppliers
Beiersdorf UK Ltd rolled out an updated Code of Conduct for Business Partners in 2023 which include reference to regulations against the Modern Slavery Act. Among other things, the Code of Conduct prohibits the use of forced labour, inappropriate disciplinary measures, and child labour. Other minimum employee rights regarding working hours, remuneration and freedom of association are also covered. All suppliers are required to accept the standard set out in Code of Conduct and inform their employees. Diversity and equal opportunities are an essential part of the new Code of Conduct. Suppliers agree to keep adequate records to demonstrate compliance and agree that Beiersdorf UK Ltd or its nominated representative may make announced or unannounced inspections to suppliers’ premises to verify compliance. Furthermore, an escalation process through the Global Sustainability team has been established to be applied in case a supplier refuses to accept the standards set out in Beiersdorf’s Code of Conduct. Suppliers are asked to sign the updated version of the Code of Conduct .
As mentioned in the Sustainability Highlight Report 2022 (Consumer Business Segment), over 90% of Beiersdorf’s global spend is with suppliers who accept its Code of Conduct for Business Partners for Suppliers. In 2022, 93% of Beiersdorf UK Ltd spend was with suppliers who were signed up to the Code of Conduct. Further suppliers have confirmed compliance via individual commitments. Beiersdorf’s ambition is to increase acceptance by suppliers year on year with regards to the Code of Conduct.
RISK ASSESSMENT, PREVENTION AND MITIGATION
Beiersdorf UK Ltd reviews annually the steps it has taken to address the risks of slavery and human trafficking in its business and in its supply chain, including the effectiveness of internal processes for reporting and escalation of issues.
Beiersdorf’s Corporate Sustainability team annually conducts a risk assessment of all approximately 21,000 direct suppliers of Beiersdorf affiliates including those who supply Beiersdorf UK Ltd. The process consists of appraising the country-related risk as well as the individual supplier’s significance to Beiersdorf in terms of procurement volume and procurement category. Country and industry specific risk factors are determined by a market leading third-party sustainability risk provider.
The screening differentiates between the risk levels low, medium and high. Direct suppliers rated medium or high risk are required to provide a comprehensive external assessment via the Ecovadis platform to enable an even more thorough risk assessment. The Corporate Sustainability team in Beiersdorf’s Headquarters in Hamburg then decides whether a subsequent audit is required. These audits are carried out by accredited external auditors commissioned by the supplier and follow the standardized “Sedex Members Ethical Trade Audit” (SMETA) 4-Pillar Audit Protocol. The audit results highlight specific challenges and any areas where action is required, for which our suppliers then work out corrective action plans with our support. In extreme cases, the audit results may lead to us excluding suppliers from our supply-chain network.
Additionally, Beiersdorf has a Business Partner Code of Conduct Implementation Process which entails risk profiling, risk assessments and audits. This is also described in the Non-Financial Statement 2022. Lastly, incidents can be reported on Beiersdorf’s incident reporting platform. More information on this platform can be found on the global website and the platform itself.
A substantial share of Beiersdorf’s suppliers has been analysed regarding certain criteria also relating to Modern Slavery. All suppliers considered higher risk committed to follow Beiersdorf’s Code of Conduct for Business Partners. Additionally, to drive ethical and sustainable improvements our top critical suppliers agreed to be part of Sedex.
Beiersdorf recognises that supply chains are highly complex and internationally intertwined and take our responsibilities in these very seriously. Beiersdorf’s Code of Conduct for Business Partners aims to prevent misconduct and make clear what we expect from our suppliers in terms of environmental and social responsibility. In 2023, the Code of Conduct was updated to follow Germany’s new Supply Chain Due Diligence Act where Beiersdorf’s headquarters are based. This law requires large companies to take responsibility for upholding human rights in their supply chains and this altered our Code of Conduct for all suppliers of Beiersdorf worldwide, including those of Beiersdorf UK Ltd. The Code of Conduct is a binding contractual basis for compliance with human rights between Beiersdorf and its business partners along the entire value chain. Consequently, suppliers are asked to sign the Code of Conduct.
All existing key suppliers that Beiersdorf affiliates (including Beiersdorf UK Ltd) have identified will also be asked to resign this updated Code, with this process being managed centrally via our Headquarters.
Additionally, the Beiersdorf group commits to the approach of sustainable development through the Sustainable Development Goals (SDGs) which is part of our sustainable agenda available on the corporate website.
Beiersdorf also requires suppliers to engage the inclusion of modern slavery related questions in our standard tender process and part of supplier selection criteria. The supplier will then provide their modern slavery statements in support of Beiersdorf’s commitment to eliminate the risk of slavery and human trafficking with reference to the supply of products and / or services.
Finally, Beiersdorf leverages the synergies of the recognized Sedex, EcoVadis and AIM-Progress collaborative platforms on which further information can be found in the Non-Financial Statement 2022.
KEY PERFORMANCE INDICATORS TO MEASURE EFFECTIVENESS OF STEPS TAKEN
In 2022, 138 suppliers within our supply chains have been audited according to the “Sedex Members Ethical Trade Audit” (SMETA) 4-Pillar Audit Protocol by external auditors. Any non-compliances have been discussed with the suppliers and corrective action plans put in place alongside regular follow ups together with the supplier and auditor. In 2022 Beiersdorf did not have any cases of supplier relationship termination due to a major breach.
It is compulsory for every employee working in Procurement at Beiersdorf to attend an internal Procurement Academy. Training of the Business Partner Code of Conduct forms part of this.
Following on from the tailored Modern Slavery Awareness training Beiersdorf UK Ltd implemented in 2020 for employees, the company has distributed reminders of this guidance through internal communications such as internal newsletters and will continue to do so in 2023 through presentations and internal company social channels. Finally, the Modern Slavery SharePoint that was established in 2020 continues to be updated and promoted as a central source of key information for all Beiersdorf employees. It includes our Modern Slavery Statement, year on year improvement and training material.
This statement was approved by the Board of Beiersdorf UK Ltd on 23rd June 2023. It is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Beiersdorf UK Ltd.’s Modern Slavery and Human Trafficking Statement for the financial year ended 31 December 2022.
Human Resources Director Northern Europe
On behalf of the Board of Beiersdorf UK Ltd