At Umicore, we consider respect for human rights a fundamental component of responsible corporate governance. We are committed to upholding internationally recognized human rights and labour rights in line with the following standards:
- Universal Declaration of Human Rights
- International Covenant on Civil and Political Rights
- International Covenant on Economic, Social and Cultural Rights
- International Labour Organization’s Declaration of Fundamental Principles and Rights at Work
- International Labour Organization’s core labour standards
We respect those rights in our operations throughout the world and we work to ensure that our business partners equally respect these fundamental human rights. Our approach is based on the UN Guiding Principles on Business and Human Rights and the UN Global Compact.
Where national law and international human rights standards differ, we will follow the higher standard; where they are in conflict, we will adhere to national law, while seeking ways to respect international human rights to the greatest extent possible.
Objective
This policy is the formalization of our human rights commitment: it sets clear expectations for responsible conduct, ensuring respect for human rights across our own operations, in our value chains and through partnerships. The policy establishes a framework for identifying, preventing and addressing human rights impact associated with business activities. It serves to build accountability, align with regulatory requirements and support the company’s commitment to human rights.
Scope
Umicore’s Human Rights policy covers our own workforce and the workers in the value chain.
Any reference in this policy to “Umicore employees” includes all subsidiaries and joint ventures where Umicore has operational control, as well as all subcontractors working on the sites of Umicore.
The expectations towards our business partners are set out in Umicore’s Global Sustainable Sourcing Policy (UGSSP), our business partner code of conduct.
General principles
We are committed to respecting human rights in line with the international human rights framework and the UNGPs. We aim to:
- Avoid causing or contributing to adverse human rights impacts
- Prevent or mitigate adverse human rights impacts linked to our operations, products or services through our business relationships
- Make a positive contribution to the advancement of human rights of all people, including vulnerable groups. In the event that we cause or contribute to an adverse impact on human rights, we provide for, or cooperate in, processes to enable a remedy.
1. Banning of child labour
At Umicore, we strictly oppose to any form of child labour. We undertake not to employ children in violation of ILO conventions 138 and 182. Umicore applies the age of 18 as the minimum age for employment, except in the framework of internship- or vocational training programs, organized in co-operation with schools and training institutes or approved by the competent authority. Special care will be taken that these young people, with a minimum age of 15, are fully protected and have received adequate safety training and instructions.
2. Preventing any forms of modern slavery including forced labour, slavery, servitude and human trafficking
In accordance with ILO conventions 29 and 105, at Umicore we are opposed to any forms of modern slavery including forced labour, slavery, servitude and human trafficking.
At Umicore, we do not tolerate recruitment, transportation, transfer, harboring, receipt or employment of any person by means of threat or use of force or other forms of coercion for the purpose of exploitation. All employees have the right to enter employment voluntarily and freely, without facing threats or penalties. This includes the right to choose their work without coercion. All employees should receive written contracts clearly stating terms and conditions of their work. No employees should pay recruitment fees and related costs as per ILO definition. Employers cannot use wage deductions to create debt bondage or job dependency. Practices such as confiscating or withholding worker identity documents without consent are prohibited. Employers must not use any means to restrict a worker’s ability to terminate employment.
3. Right to organize and collective bargaining
In accordance with ILO conventions 87 and 98, at Umicore we respect the freedom of employees to establish or to associate with any employee organization of their own choosing (including labour unions) without Umicore’s prior authorization. Founding, joining or being a member of a workers’ union recognized under applicable law shall not be used as a reason for a lack of equal treatment or retaliation.
We subscribe to the principles of ILO Convention 135 and Recommendation 143 and recognizes the right of its employees to be represented by workers’ unions and other employee organizations to collectively bargain on employment conditions and their right to strike.
We will not interfere with or finance labour organizations or take other actions with the intent of placing such organizations under our control. In the event of organization campaigns, the company and its executives shall remain neutral; the trade unions and the company will ensure that employees can make an independent decision.
We ensure that our employees can openly and regularly exchange views on working conditions with management in accordance with applicable law. If these principles are not in accordance with local law, Umicore will find local solutions that consider the relevant national legislation and our own guidelines.
Umicore and the respective employee organization will co-operate constructively in a spirit of good faith. It is our objective to involve and inform each individual employee as directly as possible. In doing so, a fair balance is sought between the economic interests of the company and the interests of our employees. Our conduct and tone towards employees are characterized by respect and fairness. Even in cases of dispute, the goal shall always be to maintain viable co-operation in the long term. This implicates, amongst others, the mutual respect of agreed commitments.
4. Equal opportunities and non-discrimination
In accordance with ILO convention 100 and 111, at Umicore, we make all efforts to foster an inclusive work culture. We appreciate and recognize that all people are unique and valuable and should be respected for their individual abilities.
We do not accept any form of harassment, discrimination, or unjustified unequal treatment, including on the basis of gender, religion, race, gender identity, national extraction or social origin, cultural background, social group, physical and/or mental disability, sexual orientation, marital status, age, political opinion, or other forms of discrimination covered by union regulation and national law. We promote an inclusive attitude when it comes to the diversity of our employees and actively work to identify and counter any barriers that may affect vulnerable groups within our workforce.
We provide equal employment opportunity and treat all employees fairly. Umicore employees and business units only use merit, qualifications and other professional criteria as a basis for employee-related decisions in Umicore, regarding for instance recruitment, training, compensation and promotion.
5. Health and safety at work
In line with ILO convention 155, we do not compromise on a safe and healthy working environment. Compliance with industrial health and safety regulations and high technical and operational safety standards are the basis for our work. Umicore strives to improve its health and safety performance continuously, with the aim to achieve a zero-harm workplace. To meet this objective, company representatives, employees, health and safety experts as well as employee representatives work together closely at all company locations. We cooperate with our employees to identify and address safety and health risks.
Following our Group Safety policies, standards and guidelines, we take a preventive approach to manage occupational and process risks in our own operations: to prevent work-related accidents and illnesses we apply principles of inherent safe design; we perform risk analyses to identify and assess risks and take the necessary actions to eliminate or reduce them. Training programs and medical surveillance programs are organized accordingly.
Moreover, we are continuously learning and integrating best practices in our existing operations, greenfield developments and future acquisitions.
6. Working time and paid holidays
At Umicore, we apply national regulations and international standards on working hours, including ILO conventions 1 and 14. Employees shall receive sufficient work breaks throughout the day to ensure healthy and safe working conditions. Working hours should not exceed legal limits or international standards, whichever is stricter. Employees should be guaranteed regular paid holidays.
7. Remuneration
In line with ILO convention 95, we work to ensure that employees are paid regularly and directly, in a legal manner. We do not tolerate unlawful wage deductions or deductions used as a means of disciplinary measures.
Remuneration and all the other benefits are based on the principle of fairness and comply with the individual minimum national legal standards or the standards of the national branches or company collective labour agreements, whichever is highest. This approach supports a remuneration that is sufficient to at least cover basic needs and provide a dignified livelihood.
8. Qualification
At Umicore, we promote measures aimed at the qualification of our employees to the extent that the broadening and consolidation of the professional and technical knowledge is relevant for a particular job. In this context, vocational training and employment training are of particular importance and can be seen as a shared responsibility on one hand for the employer to provide the necessary training, and on the other hand for each employee to take up the offered training.
9. Violence and harassment in the workplace
In line with ILO Convention 190, we do not tolerate violence, harassment, abuse or mobbing of any kind, independent of the worker’s contractual status. We create and maintain an environment free of violence or harassment and take measures, including awareness raising, education and training initiatives, to prevent and, in case of evidence, eliminate violence and harassment at work. This may include physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation.
Human rights due diligence
We recognize our responsibility to uphold human rights and are continuously improving our due diligence processes to identify and prevent any potential adverse human rights impacts from our business activities or relationships.
The main purpose of performing due diligence is to identify, prevent, and/or mitigate actual and potential adverse impacts. Umicore’s best-effort due diligence processes aim to be risk and compliance-based, proportionate, responsible, effective, dynamic and recurrent. We prioritise salient human rights risks based on their severity and likelihood. We analyze and manage identified risks through dedicated risk management processes, and make use of our contractual relationships and leverage, where possible. We aim to engage directly with business partners to prevent or mitigate any adverse human rights impacts.
In situations where Umicore has been found to be causing or contributing to a negative impact and where deemed required, Umicore shall offer or facilitate remediation to the individuals, workers and local communities, who have been harmed, through relevant judicial and non-judicial mechanisms. This includes:
- Remedy adverse human rights impacts on individuals, workers, and communities that Umicore has caused or to which it has contributed
- Leverage our suppliers and business partners to remedy adverse impacts that are linked to Umicore’s operations, products and services wherever possible.
Grievance mechanism
Umicore wishes to stimulate open and safe discussions about responsible conduct. According to Umicore’s Code of Conduct, all employees have the right and duty to address issues or concerns linked to the implementation of this policy. Our robust whistleblowing system aims to foster a culture of integrity by ensuring a safe and supportive environment for reporting concerns on practices and behaviours that are counter to our human rights commitments and values.
There are several grievance channels that Umicore’s employees and business partners can use to safely report suspected incidents without fear of retaliation. These reports can be made in the employee’s preferred language and will be handled on a confidential basis.
All employees are encouraged to address policy-related issues with their direct supervisor, their P&O contact, the Corporate Legal or Internal Audit Departments, or union representation.
Alternatively, any violation of the Human Rights policy, as well as any other concern can be reported through our Integrity Line, which is open to all employees, business partners and third parties. The Integrity Line is available on the Umicore webpage and allows to raise concerns using either an online contact form or a phone call. These complaints or expressions of concern can be made anonymously and are directed to Umicore’s Corporate Security department.
All complaints raised via either of these grievance channels are registered and followed up on by the company. At any point in time, if suspicions are confirmed, measures reasonable and appropriate to the situation will be imposed. If violations to human rights principles are caused by individual employees, there will be disciplinary measures in line with our internal corporate guidance and local employment law.
The Code of Conduct Committee at Umicore analyzes the content of the reported cases and evaluates the actions and responses given by local management and/or P&O. As such, the Committee acts as a controlling organ. The overall objective is to strive for equal response to similar cases and to report to the Executive Leadership Team.
Roles and responsibilities
Responsibility and stewardship
We emphasize collective responsibility for adherence to this policy, with every employee and value chain worker contributing to human rights commitments and continuous improvement. In all Umicore entities, employees at all levels are expected to comply with, accept and promote the commitments described in this policy.
Business group leaders are responsible for effective implementation of human rights due diligence in all entities belonging to their business group and may delegate responsibility for implementation of the policy to their local site responsible. Business group leaders ensure that all employees in their scope are properly informed and trained on the content and implementation of the policy. They foster accountability within their teams, make decisions and take swift actions based on the policy commitments and integrate those commitments into their business strategy.
To support this, Umicore’s Corporate ESG and P&O are responsible for developing communication and training materials. The corporate functions provide global guidance to business groups on the human rights due diligence process, including risk assessment.
This policy has been translated into internal controls and measures to monitor the respect for human rights. These are based on a risk assessment and are integrated into existing controls (e.g. MICR) and practices. The effectiveness of mitigating measures implemented locally based on the results of this risk assessment is tracked and monitored by the responsible business group using a combination of global and local KPI.
In the subsidiaries where Umicore has a significant presence, but does not exercise control, Umicore undertakes to use all the resources at its disposal to promote the principles stated in this policy.
Governance
The ESG department of Umicore is responsible for the overarching activities related to human rights. The responsible member of the Executive Leadership Team works with the business units on further developing human rights compliance, in line with agreed upon objectives, and receives regular information and reports on human rights activities from the corresponding specialist departments. Our business units also provide information on their respective human rights compliance measures to the members of the Executive Leadership Team who are directly responsible for the units in question.
The Executive Leadership Team of Umicore and the Sustainability Committee of Umicore’s Supervisory Board are briefed on a regular basis on Umicore’s human rights due diligence process.
This policy has been approved by Umicore’s Executive Leadership Team and will at all times be available on the Umicore webpage.