Thorsten Pinkepank

Thorsten Pinkepank 2Thorsten Pinkepank, Director, Corporate Sustainability Relations, BASF

UNGPs - Grievance Mechanisms - Communication channels - Community Advisory Panels -Hotlines 


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BASF is the world’s leading chemical company, with sales of around €72 billion in 2012 and more than 110,000 employees. Our portfolio ranges from chemicals, plastics, performance products and crop protection products to oil and gas.

For BASF, the responsibility to respect human rights is not a closed project. It is a journey that already started in the early days of the company and that will continue in the future. The journey started in 1875 when BASF sought to safeguard its workers by establishing a health insurance fund. Over the past 25 years, we committed ourselves to the Responsible Care Initiative, we joined the UN Global Compact as a founding member and added the Universal Declaration on Human Rights to our group-wide self-commitments. We also actively engaged in John Ruggie’s consultations.  Concerning the future of our human rights journey, we have identified human rights as one of the priority issues regarding sustainability. Human rights is therefore an integral part of our corporate strategy. Following that strategy, we are integrating sustainability, and human rights as part of it, even more strongly into our management systems.

We pursue an integrated approach to human rights due diligence. This means that the day-to-day responsibility lies with all relevant areas of our business, including strategic planning, human resources, occupational health & safety, security, compliance, procurement, or product stewardship. We have set up an internal network of experts from functional, operating and regional divisions to create awareness and build capacity. Our globally responsible Corporate Sustainability Board serves as the group-wide steering body and we have included our commitment to respect human rights into our Global Code of Conduct. Operational policies, such as our Group Guidelines on Responsible Care, as well as specified trainings, monitoring and reporting systems help to implement that commitment. The scope of human rights due diligence covers not only our own operations, but increasingly so our direct business relationships as well. Here we often face the challenge of improving leverage.

Let me now focus a little bit more on one particular aspect: grievance mechanisms. Grievance mechanisms are an important complement even for the best human rights due diligence process in place: firstly, because they help to identify potential or actual impacts on stakeholders at an early stage, and, secondly, because they address concerns by stakeholders before they turn into grievances, and so help to prevent grievances from escalating. Potential impacts may affect our own as well as our suppliers’ employees, our customers or the communities around our sites. They may relate to core labor standards and employment conditions, environmental impacts, safety and security, as well as situations of emergency. To give an example from the development of new sites: of course there will be positive impacts. These include the creation of local jobs and taxes as well as the implementation of state-of-the-art safety standards among our local business partners. However, there may be negative impacts as well: dirt and noise generated during construction and through traffic, or concerns from local communities about emergency preparedness and the impacts of emissions on health and agriculture.

Now, to establish communication channels which can serve as grievance mechanisms as well, we employ a range of instruments for each stakeholder group. The Guiding Principles describe the criteria for effective grievance mechanisms, and we strive to meet these criteria – which is not an easy task. It requires careful design. In that regard, we can still learn from other businesses and civil society as well.

Let me first talk about the communities around our sites and the communication channel we have established for them: Community Advisory Panels, or CAPs.  CAPs consist of community representatives, mostly between 10 and 30 people, who meet regularly, often on a quarterly basis, with the management of the site. It is the aim of CAPs to establish an open and honest dialogue that provides the neighbourhoods around our sites with the opportunity for direct involvement, while also allowing us to better address the expectations of the community. As of last year, we have set up 78 CAPs mostly at our larger production sites. What’s important: that community representatives truly represent the fabric of their community. In order to solve this challenge, we often engage with local organizations already during the process of selecting community representatives. To give an example: we launched one of our latest CAPs in Chongqing, China, in 2011. The CAP is supposed to bring citizens, specialists, authorities and NGOs together to consult on the implementation of our chemical production site. We selected the panel members from more than 200 applications. In doing so, we reached out to a local neighbourhood committee as well as local NGOs. Through their support we could ensure that the selected members represent a cross section of the local community.

Besides the communities around our sites, we provide a dedicated communication channel for our employees as well: our compliance hotlines. Hotline calls are taken by trained external lawyers. They can be used in an anonymous and confidential manner.  What’s important: a formal process including internal hotline coordinators, experts and our Chief Compliance Officer ensures that every call is dealt with and that each hotline caller receives a response in a timely manner. The hotlines are communicated to our employees through our mandatory compliance trainings and our intranet. We are reporting the yearly number of hotline calls and the number of verified grievances in our annual report.

We have learned one thing: that instruments like Community Advisory Panels or compliance hotlines require credibility in the eyes of our stakeholders to become trusted and effective tools. It is important to guarantee that employees need not fear any discrimination when using the hotlines. And with regard to the guidelines for our Community Advisory Panels: Community members must not receive any formal remuneration or any other kind of benefits, and they must not be selected based on close relations with site management. Overall, communication channels which can serve as grievance mechanisms are important complements to our human rights due diligence process.

Extract revised for written version from audio file recorded in July 2013