Framework for managing human rights

1. Embed responsible business conduct into policies and management systems

In 2022, Elopak adopted a new Human Rights Policy. The Policy is founded on Elopak’s existing commitment to respecting human rights, as outlined in our Code of Conduct, and aligned with international principles and requirements. The Policy is a starting point for our framework for managing human rights risks. As with other ethics and compliance topics, human rights are upheld in Elopak through governing documents. For human rights these include: Business Partner Procedure (Integrity Due Diligence process, including country risk assessment); Anti-Corruption Policy; safety procedures, HR procedures (including a Privacy Statement); Sourcing Policy including supplier qualification/due diligence requirements, Responsible Supply Chain Procedure; Global Supplier Code of Conduct ; and General Terms and Conditions of Purchase (GTCs).

2. Due diligence

a) Define scope
Human rights issues cover all our employees and business partners, including suppliers, contractors, customers, joint ventures, mergers and acquisitions, as well as our impact on local communities.

b) Identify and assess risks (risk assessment)
Our human rights risk assessment is part of the assessment of ethics and compliance in Elopak, which follows the company’s risk management process. With our risk-based approach to human rights, we prioritize our due diligence by focusing on size of the business and the context of operations for our own operations and joint ventures, i.e., using global human rights sources and indexes which evaluate risks of human rights violations on country level, and severity levels. We have established a process to identify and assess human rights risks by facilitating workshops in the organization with stakeholders representing our business areas and regions, including specific entities and support functions.

In 2022, we identified that our most significant risks for potentially violating human rights were related to safe working conditions for our production workers, as well as the risk to decent working conditions throughout our operations and supply chain, and the potential for forced labor in our supply chain.

Supply chain human rights risk assessment
Elopak has a risk-based approach to supply chain human rights due diligence. In 2021, we conducted a high-level review and risk assessment of our supply chain in order to identify key human rights risk topics and our human rights due diligence priorities. This is to allow us to better prioritize and channel our resources and efforts. Our main focus areas in terms of supply chain risk management are the prevention of forced and child labor; safeguarding the right to decent working conditions; and the right to health and safety.

To address issues more efficiently with our suppliers, we also focus on prioritized areas and categories. These have been identified considering Elopak’s influence, (e.g., spend and strategic importance) and activity/risk to people, (e.g., level of manual work, use of unskilled labor, hazardous work, etc.), as well as geography/country risk.

Using this approach, we prioritize the following categories for further due diligence activities:

  • Raw material categories (paperboard, aluminum, inks and solvents, polymers)
  • Logistics and transport
  • Filling machines
  • Catering and cleaning services
  • Maintenance

During 2022 we initiated more thorough human rights risk assessments. This started with raw material categories and suppliers; instituting mitigating actions and follow-up plans where there is a higher risk for adverse human rights impacts. Should we detect or be informed of human rights risks or adverse impacts in the non-prioritized areas of our supply chain, we will take appropriate action to mitigate risks there as well.

c) Prevent and mitigate human rights violations
Stakeholders engaged in the human rights risk assessment align on appropriate mitigating actions. A risk owner from the organization is identified for each significant risk that requires follow-up on agreed measures.

Integrity due diligence is conducted for new and existing customers, suppliers, and other business partners, such as joint venture partners or third-party representatives. Prior to major projects or expansion opportunities being initiated, we aim to conduct assessments to evaluate the risk of any potential negative impact on people. Third-party ethical audits are conducted where deemed necessary.

We work proactively with our suppliers to prevent and mitigate potential human rights violations. Mitigating measures include clarifying expectations and requirements through Supplier Code of Conduct engagement; inclusion of adequate contractual clauses on Responsible Business Conduct in supplier contracts; follow up meetings; internal and external supplier assessments and on-site audits. Read more about our approach here.

At Elopak, training, communication and awareness-raising programs are continuously ongoing as a further element in our preventive measures to mitigate human rights violations. The Code of Conduct mandatory training is our main initiative to build awareness about business integrity and prevent unethical behavior, including human rights breaches. Specific e-learning (nano-learning) courses on our responsibilities within business and human rights is offered to Elopak employees. In addition, further in-depth training is provided to relevant functions such as the Global Procurement Network.

3. Track and monitor

Group Legal & Compliance coordinates the internal follow-up of preventive and risk reducing measures with the designated risk owners to ensure progress and allow for evaluation of the effectiveness of the proposed measures. Third party ethical audits are conducted where deemed necessary.

4. Report and communicate

Grievance mechanisms

Grievance mechanisms are important to better understand the impact of our operations on the rights of individuals and groups. In Elopak, concerns or grievances can be reported in several ways. Our whistleblower helpline allows anyone involved in or affected by our activities to raise a concern, via phone, email, or an online form. The whistleblower helpline also includes concerns related to that of respecting human rights. The helpline is hosted by an independent external service provider and is confidential, anonymous, and available in multiple languages.

Internal and external reporting
Human rights, together with other ethics and compliance topics, are regularly discussed with the executive management team. Twice a year, the Chief Legal & Compliance Officer formally reports to the Board Audit and Sustainability Committee on compliance and business integrity matters, including human rights.

Pursuant to the UK Modern Slavery Act 2015, Elopak reports annually on steps that have been taken to ensure that there is no slavery or human trafficking in its supply chain. According to the Norwegian Transparency Act, Elopak reports annually (by 30 June) on the due diligence assessment conducted. The report is signed by the Board of Directors and CEO.