The BMW Group recognises its responsibility as a company to respect human rights and environment-related standards. This applies not only to our own business activities, but also to our global supply chains. We help ensure these fundamental rights are observed by assigning clear responsibilities and through a wide range of different measures.
Respect for human rights and environment-related standards at the BMW Group.
Respect for human rights is not a one-time thing. We have to work at it all the time.
Chief Compliance Officer and Human Rights Officer, BMW AG
We have established appropriate due diligence processes to ensure compliance with social and environmental standards – both within our own company and sales network and in our relationships with suppliers and other business partners. We are guided by internationally recognised standards, including the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights and the Ten Principles of the UN Global Compact. The demands arising from these commitments for our company, our supply chain and our other business partners are anchored at the BMW Group through internal standards:
The human rights code outlines how we promote human rights and fair working conditions and implement the Core Labour Standards of the International Labour Organisation (ILO). The central themes of the Code are: no child or forced labour, equal treatment of all employees, the right to health and safety at work and freedom of association. The code provides guidance for BMW Group employees, suppliers and authorised sales partners and is actively communicated.
Since 2005, our Joint Declaration on Human Rights and Working Conditions (updated in 2010) has been our benchmark for value-oriented corporate governance. This commitment was developed with the participation of our employee representatives and the trade union, and is in line with globally recognised guidelines for environmental and social standards – such as the basic principles of the UN Global Compact.
The Code of Conduct provides a central set of rules, outlining what the BMW Group expects from its employees. It establishes guidelines for responsible and lawful conduct across the company for topics including corruption prevention, the principle of non-discrimination, mutual esteem and fair relationships with business partners, as well as environmental protection and animal welfare.
Our Supplier Code of Conduct summarises the BMW Group’s guiding principles for the global supplier network in accordance with internationally recognised sustainability standards and guidelines. We require our business partners to always comply with all legal requirements, protect the environment and respect human rights. We clarify these requirements, among other ways, in tender documents and purchasing terms and conditions for our supplier contracts. They therefore apply to all BMW Group suppliers. All suppliers are familiarised with the Supplier Code of Conduct, which also forms part of the appropriate contractual agreements.
Leveraging our impact together.
To fulfil our responsibility as a company, we rely on cooperation – with our employees, our business partners and our suppliers – because the only way to address the risks in our supply chain effectively is by working together. That is why our approach to compliance with human rights and environment-related standards applies to:
- our own business area,
- our suppliers
- and our other business partners.
Risk management and responsibilities.
We have been committed to respect human rights and environment-related standards throughout our global supply chain for many years. Across the company, we have defined clear responsibilities for effective implementation and monitoring due diligence requirements.
Within the BMW Group, responsibility resides with the respective business departments or with the management of affiliated companies; outside the company, it lies with the business partners and suppliers. Centralised units like Group Compliance (for the overall program design, for the BMW Group’s own business area and other business partners) and Purchasing and Supplier Network (for suppliers) support and monitor due diligence requirements.
In 2021, the Board of Management appointed the Chief Compliance Officer as Human Rights Officer. As an overarching control function, he assumes the monitoring task provided for the German Supply Chain Due Diligence Act with regard to the risk management for the implementation of due diligence requirements within the BMW Group. The Human Rights Officer works in close consultation with the responsible business departments and reports to the Board of Management at regular intervals and on an ad-hoc basis.
Within the BMW Group, the Group Compliance department is responsible for both overall concept development for compliance with human rights and environment-related standards, as well as for directing due diligence processes in its own area of business and at other business partners.
The department Purchasing and Supplier Network is responsible for implementing our due diligence processes in the supply chain. Creating transparency around highly complex, dynamic supply chains and making goods flows traceable is the most important requirement. To achieve this, we are constantly deepening our close cooperation with partners in the supply chain.
Implementing due diligence requires cooperation – company-wide, and with our suppliers and business partners. Within the BMW Group’s internal network, we share information between divisions on specific topics, such as occupational health and safety, environmental protection and compliance. Due diligence processes can thus be implemented jointly across the company. Outside of our own business activities, we actively work with suppliers, our sales organisation and business partners, as well as external experts and stakeholders, to refine our due diligence processes on an ongoing basis.
Risk assessment.
Being aware of our risks is fundamental to our risk-based approach. Our corporate due diligence activities are based on a comprehensive risk assessment that provides information on action areas and the degree of urgency. Annually, and on an ad-hoc basis – for example, in response to substantiated knowledge – we examine and assess the risk to human beings and the environment, as well as the impact of our business activities.
We consider potentially impacted groups, such as our own employees (including temporary staff and apprentices), employees of business partners and joint venture partners, employees in our supply chain and groups of people indirectly linked to the supply chain, such as members of local communities.
We rely on various data sources to identify potential risks for human beings and the environment arising from our business activities. External data from internationally recognised indices is systematically recorded and processed to identify country-specific and commodity-group risks for the purchasing and supplier network, as well as country- and business-purpose-specific risks in our own business area and at other business partners.
We are constantly working to improve our processes – also taking into account findings from our own measures and reports submitted through our complaints mechanisms as additional data points for our risk identification.
Subsequently is for the data to be evaluated and weighted. The relevance of the identified risks and the probability of their occurrence are important criteria in this respect. This results in an overall assessment of the risk situation in our own business area and at our suppliers and business partners that is referred to as abstract risk exposure. We then define risk-based control measures, such as questionnaires and audits, on this basis. The information obtained in this way about the actual situation on-site helps us clarify the risk assessment and identify any (imminent) human rights violations or non-compliance with environmental standards. In this case, we respond immediately with appropriate preventive and remedial measures.
Prioritising risk enables us to take targeted action, either in areas where we see particularly relevant risks (risk exposure) and/or where forecasts suggest we cannot preclude increased impact by our business activities (ability to exert influence and causal contribution). What we learn about human rights and environment-related risks and their impact in this way is channelled into our business decisions. This applies, for instance, to the selection and evaluation of suppliers and business partners, as well as to company transactions and market entry or exit decisions.
Knowing and countering risks.
As a manufacturing company with international locations and a large number of suppliers and other business partners, our activities are associated with inherent risks for human beings and the environment. We are aware of this and respond with risk-based preventive and remedial measures.
In the following, we describe the risks identified in the abstract risk analysis. We update this information on a regular basis and report any substantial changes in the risk situation.
Occupational health and safety.
Occupational health and safety.
Challenge: Comprehensive occupational health and safety requirements arise, in particular, from the manufacturing activities of our employees, suppliers and business partners.
Potentially impacted persons: BMW Group employees at all our plants, as well as employees of our business partners and suppliers.
Measures in our own business area, at our business partners and in our supply chain: We comply with all applicable occupational health and safety legislation worldwide and set our own requirements, based on globally recognised standards – including for the supply chain and business partners. Our catalogue of measures also includes certifications. Our own plants are certified to ISO 45001 or OHRIS. Beyond a certain size, we require a certified occupational health and safety management system (ISO 45001 or comparable) from our suppliers' locations. This is defined in our BMW Group Supplier Code of Conduct and is queried via a questionnaire.
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Environmental protection.
Environmental protection.
Challenge: Our activities as a manufacturing company and the activities of our suppliers and business partners entail comprehensive requirements for environmental protection and resource management.
Potentially impacted persons: Residents near sites operated by the BMW Group, our suppliers and business partners, local communities.
Measures in our own business area, at our business partners and in our supplier and sales network: An environmental management system certified to ISO 14001 is implemented at all BMW Group production locations. We agree on contractually binding requirements with our suppliers and business partners. From our suppliers' production sites, we require a certified environmental management system (ISO 14001 or comparable) above a certain size. This is defined in our BMW Group Supplier Code of Conduct and is queried via a questionnaire.
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Raw-material-specific risks.
Raw-material-specific risks.
Challenge: Some of the raw materials used in manufacturing our products are considered high-risk, since their procurement and processing entail increased risks for human beings and the environment.
Potentially impacted persons: Workers employed in extracting raw materials, groups in poorly/unregulated environments.
Measures in our indirect supply chain: Annual risk assessments for high-risk raw materials form the basis for developing prevention and remedial measures for specific raw materials. Further information on our key raw materials can be found here.
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Preventive, control and remedial measures.
The measures we take to prevent, monitor and remediate human rights and environment-related risks are always risk-based. We rely on a catalogue of measures that combines training, contractual agreements with suppliers and business partners, certification and reviews using questionnaires or audits.
Training courses.
Training is an important factor in raising awareness of social and environmental standards. We explain causalities and clarify our expectations. In addition to basic training for all non-production employees, the BMW Group also offers a wide range of training opportunities for in-house buyers and external suppliers. Through the Drive Sustainability initiative, we also provide suppliers with opportunities for industry-wide standardised training.
Contractual assurance.
Respect for human rights and environment-related standards is the foundation of any business relationship with the BMW Group. For both our dealers and our suppliers, we rely on contractual assurances of respect for human rights and minimum environmental standards. By signing a contract with a BMW Group entity, the supplier undertakes to implement necessary preventive or remedial measures no later than the start of production or by an agreed target date.
Questionnaires and audits.
Following a risk-based approach the BMW Group uses questionnaires to verify compliance with defined due diligence requirements in its own business areas and at suppliers. We also rely on risk-based on-site assessments. In high-risk or complex risk situations, or if violations have already occurred that require a structural solution, we conduct on-site human rights impact assessments.
Certifications.
We rely on reviews and certification performed by external service providers to monitor compliance with our specifications. We also commission independent third parties to conduct audits at our own locations, as well as for suppliers and business partners. Regular certifications for our own business area range from environmental management to occupational health and safety. Whenever possible, we also use external certifications for procurement of raw materials, such as the responsible mining standard established by the Initiative for Responsible Mining Assurance.
Verifying effectiveness.
At least once a year and on an ad-hoc basis – for example, in the case of substantiated reports – we verify the effectiveness of our activities with regard to the German Supply Chain Due Diligence Act. For this, we have integrated corresponding key figures into all steps of our corporate due diligence process – for example, processing time for complaints.
If we identify any missing functionalities, we make the necessary adjustments to improve processes – especially if preventive and remedial measures do not adequately address the risks, for example.
Complaints mechanisms.
Various complaints mechanisms give internal and external informants the opportunity to report possible violations of human rights and environment-related standards. This allows risks to be identified and addressed in the early stages and, if necessary, appropriate remedial action can be taken. The confidentiality and protection of informants are top priority. If preferred, concerns may also be reported anonymously. It is company policy that no attempt will be made to determine the identity of a person providing information, should they choose to make a report anonymously. In addition to having managers, local compliance departments and employee representatives as the usual first points of contact, various complaints channels are available to BMW Group employees and external informants. Since 2020, the BMW Group has been actively involved in a working group of the Automotive Industry Dialogue that is focused on developing a cross-company complaints mechanism in Mexico, in addition to its own options for submitting complaints.
Our complaints channels.
BMW Group employees and external informants can report cases of suspected non-compliance anonymously and confidentially using the BMW Group SpeakUP Line. Reports can be submitted both online and by telephone. The BMW Group SpeakUp Line can be reached 24 hours a day via local numbers (free of charge or at local rates) in almost 140 countries in a total of more than 70 languages.
The BMW Group has appointed an ombudsperson to advise on the system for reporting compliance concerns and ensure that reports from informants are forwarded to BMW Group Compliance. If preferred, this information can also be provided anonymously.
Our ombudsperson can be contacted as follows:
Dr Sibylle von Coelln
Telephone: +49 211 44 03 57 72
Fax: +49 211 44 03 57 77
Email: BMW-Ombudsperson@hvc-strafrecht.de
Postal address:
HEUKING · VON COELLN
Rechtsanwälte PartG mbB
Prinz-Georg-Str. 104
40479 Düsseldorf
Data privacy.
You provide your personal data voluntarily. You have the option to submit your report anonymously. If you voluntarily decide to provide your personal data and thus provide a non-anonymous report, we will process your information solely for the purpose of processing your report on the basis of Article 6 (1) LIT. C), F) of the GDPR. Further information on data protection and your rights can be found here.
Reporting.
We aim to be transparent about how we fulfil our due diligence obligations. We do so by addressing challenges and sharing experiences and best practices for dealing with human rights and environment-related risks and impacts. The input of right-holders and external stakeholders on whether our measures are effective and appropriate is also incorporated into the continuous improvement of our due diligence processes. Our aim is for our reporting to also contribute to the public debate around sustainable development.
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