Human Rights
Elopak respects and supports internationally recognized human rights and labor standards, including those outlined in the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work (Core Labor Standards).
Elopak respects and supports internationally recognized human rights and labor standards, including those outlined in the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work (Core Labor Standards).
In 2022, Elopak had operating legal entities in more than 30 countries, production in 10 locations and sales to customers in 70 markets, hence we strive to positively impact our business partners and the communities where we operate. Elopak has its own operations as well as supply chains in countries associated with high political corruption and human rights risks.
Elopak actively works to ensure compliance with progressive human rights legislation, including the Norwegian Transparency Act (2022) and the UK Modern Slavery Act (2015). More countries have adopted similar laws for mandatory human rights and environmental due diligence in Europe, and the EU is following suit by adopting the proposal for the Directive on Corporate Sustainability Due Diligence in 2022. Elopak welcomes such initiatives, which are in line with our responsible way of doing business.
Freedom House is an independent organization dedicated to the expansion of freedom and democracy around the world. Freedom in the World is an annual global report on political rights and civil liberties. The end score for a country or territory is dependent on the aggregated political rights score and its aggregated civil liberties score, where the total of these two scores is equally weighted. The 2022 edition covers developments in 195 countries and 15 territories. Freedom House includes one of the indexes we use to evaluate risks of human rights violations on country level.
For more information about Global Freedom Status, please visit: www.freedomhouse.org
Approach
Our approach to supporting human rights in our work is based on the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidelines for Responsible Business Conduct. Human rights are included in Elopak’s risk management processes and embedded in our compliance program.
Governance
Complying with local laws and legislation is a line responsibility, and effective management of human rights issues requires cross-functional coordination. In Elopak, Group Legal & Compliance acts as support towards the Group to provide insights, guidance, and direction on compliance issues, encompassing human rights. The Ethics & Compliance Council has a responsibility to manage and coordinate human rights risks, along with other ethics and compliance risk areas, and facilitate an efficient implementation across the organization. The Council is made up of senior management from our Group functions: legal and compliance, human resources, procurement, sustainability, finance and IT, including members representing the business areas from operations and specific geographical regions. When deemed necessary, additional representatives participate in the Ethics & Compliance Council meetings. The Council is chaired by the Chief Legal & Compliance Officer. Ethics and compliance matters, including human rights, are regularly discussed with the executive management team and are reported to the Board Audit and Sustainability Committee twice a year by the Chief Legal & Compliance Officer.
Performance
In 2022, we carried out regular internal communication campaigns to build awareness within Elopak on the Code of Conduct and human rights. These communications included the publication of articles on our intranet to raise awareness on requirements within the Norwegian Transparency Act and Elopak’s main human rights risks. Elopak also conducted workshops with senior management on human rights issues in the company, and a celebration of the United Nations Human Rights Day.
During 2022, Elopak identified the following risks to human rights. An initial screening was done of India, which is continued in 2023, and as such not included in the below:
Managing human rights risks
Saudi Arabia
In 2022, Elopak acquired a production facility in Dammam in Saudi Arabia, as part of the same acquisition of the Morocco site. Approximately half of the total workforce of 40 employees are temporary workers and migrant workers.
Main risks include potential violation of the:
- Right to health and safety
- Decent working conditions
- Rights of vulnerable individuals and groups
Mitigating and managing the risks
During 2022, Group Health & Safety representatives visited the production plant in Morocco and raised awareness on health and safety issues. The Dammam plant was included in the Group Safety Network. Elopak will continue the safety training program and outline key objectives and safety measures for the plant. A safety audit will be carried out on site in 2023 to assess any further needs.
Elopak is working closely with the contracting company in Saudi Arabia to ensure workers are entitled to their rights. Through contractual clauses, the supplier shall ensure adequate accommodation, living conditions, and a decent wage, among other provisions. In 2022, as part of a dialogue with temporary workers, Elopak detected issues with wages that were not received on time and some instances of irregular wage deductions. These issues were immediately rectified. Similar meetings will be held going forward to ensure the issues have been addressed appropriately.
In 2022, Elopak improved the accommodation for our permanent employees which are non-Saudi residents. Read more below.
With the integration of the entity in Dammam, Elopak reviewed salaries against the local mid-market and updated employees’ wages and contracts to align with our Group principles.
Morocco
In 2022, Elopak acquired a production facility at Casablanca in Morocco. The majority of employees at the plant are local temporary workers.
Main risks include potential violation of the:
- Right to health and safety
- Decent working conditions
Mitigating and managing the risks
During 2022, there has been increased focus on health and safety at all our production sites, with a particular focus on identifying hazards and the risk they pose. In 2022, the Moroccan site was included in the Group Safety Network. Going forward, we will continue our safety training program (“Safe by Choice”) with specific program objectives for each site, including the plant in Morocco. A safety audit will be carried out on site in 2023 to assess any further needs.
Elopak’s approach to total remuneration is to benchmark against mid-market conditions. With the integration of Elopak Morocco, Elopak conducted a review of all wages against the local mid-market and updated wages to align with Group principles. All Elopak Morocco employees received updated contracts in line with local regulations and reflecting changes (e.g., to insurance policies) to ensure alignment with mid-market evaluations.
Ukraine
Elopak has an office in Kiev and a production facility in Fastiv, with a total of 151 employees in Ukraine. On 24 February 2022, the plant in Fastiv was temporarily closed in order to focus on the safety of employees and their families. In light of the extraordinary situation in Ukraine, a dedicated risk response team is working on managing and mitigating risks, continuously assessing the impact on Elopak’s people, business and assets, in line with the Elopak’s risk management principles. The plant was reopened in April 2022 to resume small-scale production to supply customers in Ukraine, in support of efforts to maintain supplies of essential goods in the country.
Main risks include potential violation of the:
- Right to health and safety
- Decent working conditions
Mitigating and managing the risks
Elopak conducted a comprehensive risk assessment that prioritized the personal safety and security of our employees in Ukraine before reopening the plant in April 2022. The company ensured compliance with security and safety requirements for employees, including providing a clear evacuation plan and suitable shelter in the event of an emergency. Elopak continues to evaluate the risks of operation on an ongoing basis.
Health & safety
Safety is our number one priority in Elopak, and we are committed to getting everyone home safe every day.
Main risks include potential violation of the:
- Right to health and safety
Mitigating and managing the risks
Risk assessments for machines and processes were conducted for our main activities. Based on inputs from risk assessments, the annual Safety Week was arranged across all Elopak sites with the theme “Mind the Risk”.
In 2022, Elopak entered into a joint venture agreement with GLS in India, forming a new company, GLS Elopak, with a 50/50 ownership structure. Going forward, Elopak will continue its safety training program with specific program objectives for the production plant, and a safety audit will be carried out physically in 2023 to assess further needs.
Safety best practices are shared across production sites. To meet specific challenges with heating in the converting plants, especially in the summer, breaks are planned at a frequency reflecting the temperature level and drinking water is made easily available. A trial for the use of cooling clothes has been started at one site. These mitigating measures reduce risks significantly. In 2022, we launched the “Golden Safety Rules” for our operational sites as part of Elopak’s safety culture and training program (“Safe by Choice”).
Supply chain
Elopak works with more than 5000 suppliers worldwide and sources parts and materials from various countries across the globe, including from high-risk countries.
Main risks include potential violation of the:
- Use of forced labor and child labor
- Decent working conditions
- Right to health and safety
Mitigating and managing the risks
We mainly focus on prioritized categories where more in-depth human rights risk assessments and supplier integrity due diligence processes are conducted to manage and mitigate potential violations of Human Rights. Read more about this here.
In 2022, no significant instances or indications of possible human rights violations were identified.
Improving housing conditions for workers in Saudi Arabia
In 2022, Elopak improved the accommodation for our permanent employees at the production plant in Dammam. This is a result of the integration of the entity in Saudi Arabia and the post-merger acquisition activities which includes a strong focus on human rights. Based on this work, we conducted, among different measures, a site visit to the housing facilities of our permanent employees which are non-Saudi nationals. Founded on the observations and conclusions from the site visit, local management relocated the employees to improved housing facilities. This example illustrates that we can make a positive impact on people where we operate.
Moving forward
In 2023, we aim to further improve our approach to human rights. We will roll out our Human Rights Policy for the organization and familiarize our employees with the human rights supporting framework.
Our key focus and priority for 2023 is to integrate new operating units located in high-risk countries (Morocco, Saudi Arabia, and India) into existing frameworks and processes. We are also increasing our efforts to map and assess potential human right violations in these operations (in particular in India which was not completed during 2022), their supply chains, and business relationships to mitigate and manage potential issues more effectively. Moreover, we are in the process of further improving our supplier qualification /due diligence framework by better integrating human rights considerations into the existing audit framework.
