Our responsibility

1. Introduction

GLOBAL CSR believes that the global market economy is crucial for achieving social, environmental and economic sustainability. We advise businesses in responsible business conduct; a prerequisite for realizing sustainability. We will not interfere with the free choice of our Business Relationships (BR) to determine where they strategically would wish to contribute to sustainable development.

However, we do expect our BR to demonstrate responsible business conduct by identifying and managing risks of actual and potential adverse impacts on sustainable development, the core elements of which are internationally agreed principles on human rights (including labour rights), the environment (including climate), and the economy (including anti-corruption, anti-trust, and tax).

This Code of Conduct for Business Relationships (CoCBR) serves the purpose of assisting implementation of our Policy Commitment, where we commit to require from our BR, including customers, suppliers and partners, that they demonstrate responsible business conduct as defined by the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises (OECDG). The UNGPs/OECDG is referred to as the ‘Standard’.

The management requirements set forth in this CoCBR for demonstrating responsible business conduct are aligned with the Standard and are distinct from legal compliance. BR are always expected to comply with national law. GLOBAL CSR reserves the right to levy additional specific requirements related to sustainable development, should specific circumstances require such focus.

1. Management Requirements

GLOBAL CSR expects its BR to implement and maintain a management system that is fully aligned with Standard. The required management system shall, at a minimum, address:

• Adverse impacts on the human rights stated in the International Bill of Human Rights, including the core labour rights from the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work;
• Significant adverse impacts on the external environment in relation to the areas addressed by the OECDG, including the Rio Declaration on Environment and Development, including the climate as reflected in the Paris Agreement; and
• Significant risks of adverse impacts on economic sustainability, as related to the scope outlined by the United Nations Convention against Corruption and the OECDG.

The areas mentioned above are hereinafter referred to as ‘the Scope’.

Implementation includes the following actions:

II.I. Adopt a Policy Statement

The Policy Statement shall:

• Be approved at the most senior level of the company;
• Be informed by experts in the UNGPs and OECDG;
• Stipulate BR expectations of its stakeholders, at minimum its employees and its business relationships;
• Be publicly available and communicated both internally and externally; and
• Be embedded in operational policies and procedures throughout the company.

II.II. Establish and Maintain a Sustainability Due Diligence Processes

In own operations:

• BR shall establish a risk management process that allows for regular assessments of actual and potential adverse impacts on the Scope. BR shall identify where ithey are at risk of causing or contributing toadverese impacts. BR shall act to prevent or mitigate the potential adverse impacts identified, and these actions shall be tracked to ensure effectiveness. BR are expected to engage impacted stakeholders in this process and to communicate identified risks, actions taken, and ongoing status on effectiveness to such stakeholders, as well as other relevant stakeholders, including GLOBAL CSR.

In business relationships:

• BR shall – as a minimum – require from their business relationships to also meet the Standard. Should BR find that they are linked to severe or significant actual adverse impacts on the Scope, BR shall, if necessary, use or build its leverage to make the business relationship that caused or contributed to such impact cease the impact and implement proper due diligence.

II.III. Provide Access to Remedy

Where the BR identify that they cause or contribute to actual adverse impacts on the Scope, the BR must provide access to remedy through effective grievance mechanisms for those affected. Notification of relevant authorities may also be necessary.

If the BR are merely linked to actual severe or significant adverse impacts, but do not cause or contribute to them, the BR shall not, but may, provide access to remedy.

• Collaboration

• GLOBAL CSR has implemented the requirements outlined in this CoCBR and is prepared to share any related information or documentation with its BR.

• To assist BR in meeting the Standard’s requirements for sustainability due diligence and documenting the work, GLOBAL CSR may provide access to the cloud-based platform, SEE impacts, that GLOBAL CSR uses to perform regular impact assessments against the Scope (sustainability due diligence) in own operations.

• Should our BR experience that GLOBAL CSR actions or omissions contribute to adverse impacts with them or cause adverse impacts on BR or their employees, BR shall notify GLOBAL CSR.
  
  
• BR must maintain appropriate records to demonstrate compliance with the requirements of this CoCBR. Appropriate records include:
  • a policy commitment;
  • documentation of due diligence processes, including operational-level impact assessments; transparent records on tracking specific actions;
  • documented grievance mechanisms, and
  • documentation for sending similar requirements to their business relationships.

• This CoCBR should form a foundation for collaboration between GLOBAL CSR and our BR to pursue continuous improvements in managing adverse impacts on the Scope. Should the BR not have implemented a management system in alignment with this CoCBR at the time of engagement, an implementation plan shall be developed and, if required, presented to GLOBAL CSR. GLOBAL CSR expects all BR at any time to be able to declare their stage of implementation in relation to the requirements contained in the Standard, i.e., this CoCBR.

• If GLOBAL CSR’s BR cause, contribute to, or are linked to actual severe impacts on the Scope, BR shall notify the public or GLOBAL CSR immediately. The notification shall include an account of the BR actions to end the severe impacts and to prevent or mitigate their re-occurrence. If BR neglect to notify the public or GLOBAL CSR of and cease severe impacts, or if they demonstrate a lack of willingness to meet the Standard, GLOBAL CSR reserves the right to end the business relationship immediately.