Human Rights and Responsible Sourcing
Increasingly, multinational companies are expected and required to improve responsible sourcing practices not only across their own organisations, but also throughout their supply chains. Many of the most severe human rights problems occur at further upstream in supply chains and from the perspective of an OEM, with declining transparency up the supply chain, there is a corresponding increase in human rights risks and general sustainability issues.
Volkswagen fully commits to its corporate human rights responsibility. We primarily follow the UN Guiding Principles on Business and Human Rights which refer in particular to the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.*
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Many of the biggest human rights risks have been identified in the upstream supply chain. We minimise these risks by conducting responsible sourcing practices and implementing processes of human rights due diligence. To us, this means to actively engage beyond tier-1 and to improve sustainability throughout the whole supply chain. With our activities related to the S-Rating as well as with supplier trainings and workshops we contribute to reducting human rights risks in the supply chain. In this regard, a special focus lies on the responsible sourcing of raw materials.
* The Universal Declaration of Human Rights is codified in the International Covenant on Civil and Political Rights and in the International Covenant on Economic, Social and Cultural Rights. The UN Guidelines for Business and Human Rights are linked to the relevant OECD guiding principles for multinational companies. Of particular relevance are the OECD guiding principles on the fulfilment of due diligence to supporting responsible supply chains for minerals from conflict zones and high-risk areas.
Raw Materials Human Rights Due Diligence Management System
Over the last years the Volkswagen Group has been making progress on high-risk raw materials supply chains, working for more transparency and improving responsible sourcing practices of suppliers and sub-suppliers. In order to standardise and systemise our approach, engagements, tools and response mechanisms throughout the Group, we implemented a Raw Materials Human Rights Due Diligence Management System (RM HR DDMS).
This management system covers strategic and high-risk raw materials supply chains and supports the identification, assessment, and mitigation of human rights risks in these supply chain. Thereby, the DDMS ensures a standardised and systematic approach that should reduce potential and actual negative human rights impacts throughout our supply chains and ensure that sourcing practices in these supply chains conform to international good practice. The management system integrates and firmly anchors the OECD Due Diligence Guidance for Responsible Business Conduct into our responsible procurement strategy, and particularly considers the OECD-FAO Guidance for Responsible Agricultural Supply Chains , and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas .
The RM HR DDMS enables regular systematic risk management, that will necessarily entail more engagement with our suppliers and sub-suppliers. The Volkswagen Group recognises that reducing risk, addressing negative impacts and improving sustainability along supply chains can only be achieved together with committed business partners involved in those supply chains.
The DDMS is coordinated by a Group-wide working group (Raw Materials Human Rights Due Diligence Working Group) and implemented through activities performed at both the Volkswagen Group headquarter and brand levels.
Expectations towards Suppliers
As a Volkswagen Group (sub-)supplier, you are expected to abide by the good practice obligations set out in the Code of Conduct for Business Partners and further parts specific requirements for the use of responsibly sourced raw materials like in the case of battery cell production. Obligations are based on international good practice standards, industry standards, regulations and sustainability objectives set by the Volkswagen Group.
A summary of (sub-)supplier expectations is as follows:
- Acknowledge and understand Volkswagen Group’s expectations and objectives
- Respond with full transparency to enquiries from Volkswagen Group and its entities
- Act on issues identified in your facilities and/or supply chain
- Implement a human rights (based on the above mentioned OECD guidance) due diligence system appropriate to your own commercial activities
- Move consistently toward good practice actions, including publication of your own actions
Use of Conflict Minerals (3TG)
In addition to the expectations above, suppliers of material containing tin, tungsten, tantalum and/or gold (3TG) are required to:
- Provide their company-wide Conflict Minerals Reporting Template (CMRT) on an annual basis latest by the first of February for the previous reporting year. The CMRTs should be uploaded to Assent's platform and shared there with the Volkswagen Group. The invitation to the platform is sent via an e-mail from Assent.
- Confirm that the CMRT is correct and accurate for all 3TG containing products provided to VW Group
- Ensure that 3TG containing inputs are sourced solely from refiners found to be conformant with the Responsible Minerals Assurance Process (RMAP) as specified by the Responsible Minerals Initiative (RMI)
- Participate in industry-wide programs such as the Responsible Minerals Initiative
- Support non-certified 3TG refiners to undergo an OECD conformant certification process or to remove the refiner from the supply chain in case of non-cooperation
Information on how to fill in a CMRT can be found here:
As members of the Global Platform for Sustainable Natural Rubber, we are committed to legal compliance, community livelihoods, healthy, functioning ecosystems and respecting all human rights in natural rubber procurement and production. This is reflected in our High Level Commitment that falls in alignment with GPSNR’s policy framework.
1.0 / 22.04.2022
Please find further information on the topic of responsible raw materials sourcing here: