Modern Slavery and Human Trafficking Statement 2018

Introduction

At Beiersdorf UK Ltd we want to play an active role in making positive contributions to society. Beiersdorf UK Ltd acknowledges that as a global corporate citizen it has a responsibility to address and seek to eliminate the risk of slavery and human trafficking in its operations, as part of the respect that the company has for human rights, in line with the principles contained in the United Nations Universal Declaration of Human Rights and the UK Modern Slavery Act 2015.

By this statement, we set out Beiersdorf UK Ltd’s commitment to taking steps to identify and eradicate slavery and human trafficking from its business and from its supply chains. We do not tolerate slavery and human trafficking either within the supply chain or within any part of Beiersdorf UK Ltd’s business.

As required by the UK Modern Slavery Act 2015, this statement reports on the steps Beiersdorf UK Ltd and the Beiersdorf group have taken in this regard during the financial year ended 31 December 2018.

Structure and supply chains

Beiersdorf UK Ltd, based in Birmingham, is a part of the Beiersdorf group, a global leader in the consumer goods industry. Beiersdorf UK Ltd’s principal activity is sales, marketing and distribution of products for the care and protection of skin marketed under major brands such as NIVEA, Eucerin and Elastoplast. An overview of where Beiersdorf UK Ltd fits within the global business, as well as details of the company’s core values and product brands appears in the online company profile. Information about the parent company Beiersdorf AG can be found on its homepage.

Beiersdorf UK Ltd is integrated into a supply chain whose processes take place predominantly within Europe. Only a very few suppliers who directly supply Beiersdorf UK Ltd are located outside of Europe. More precisely, in 2018, Beiersdorf UK Ltd sourced 81% of the volumes of finished goods from eight Beiersdorf owned factories, 19% from 21 third-party manufacturers or third-party co-packers. 62% of these volumes were sourced from Germany, 16% from Spain, 13% from Poland, 2% from France and the remaining 1% from the rest of the world.

Regarding goods and services not directly related to the production of products, almost 92% of the spend was with suppliers located in the UK, 7% with those based in Europe and less than 1% with suppliers outside of Europe. 49% of the spend (12% of suppliers) were covered by the corporate Procurement function based in the company’s headoffice in Germany and 51% of the spend (88% of suppliers) by the local organization.

Policies in relation to slavery and human trafficking

Policy for Employees

All Beiersdorf UK Ltd employees (>200) are provided with a Code of Conduct for Employees. An updated version has recently been rolled out by the Corporate headoffice in Germany. It will be communicated to all employees in the first half of 2019. It is designed to help employees and managers to understand the company’s principles and to act in accordance with them. The Code clearly states that Beiersdorf will not support or tolerate slave labour or human trafficking. Equally, Beiersdorf does not support or tolerate child labour. We also stand for fair working conditions and promote health and safety at work.

Policy for Suppliers

Beiersdorf UK Ltd also has a Code of Conduct for Suppliers which is currently under revision and planned to be communicated to all Beiersdorf businesses by end of 2019. Among other things, the current Code of Conduct already prohibits the use of forced labour and inappropriate disciplinary measures, and also prohibits child labour. Other minimum employee rights regarding working hours, remuneration and freedom of association are also covered. Suppliers are required to accept the standards required by the Code of Conduct and to inform their employees. They agree that they will keep adequate records to demonstrate compliance and agree that Beiersdorf UK Ltd or its nominated representatives may make announced or unannounced inspections to suppliers’ premises to verify compliance.

These requirements are also mentioned in the sustainability report. Furthermore, we commit to the approach ‘Supply Chain Sustainability through cooperation and transparency’ which is described in the responsible sourcing section of the corporate website. Finally, Beiersdorf leverages the synergies of the recognized Sedex and AIM-PROGRESS collaborative platforms on which further information can be found here.

In 2018, almost 90% of the suppliers used by Beiersdorf UK Ltd were signed up to the Code of Conduct for Suppliers before they started supplying to Beiersdorf UK Ltd. Further suppliers have confirmed compliance via individual commitments.

Due diligence and risk assessment, prevention and mitigation

Beiersdorf UK Ltd will review annually the steps it has taken to address the risks of slavery and human trafficking in its business and in its supply chain, including the effectiveness of internal processes for reporting and escalation of issues.

Beiersdorf’s Corporate Sustainability team annually conducts a risk assessment of all approximately 24,000 direct suppliers of Beiersdorf affiliates including those who supply Beiersdorf UK Ltd. The process consists of appraising the country-related risk as well as the individual supplier’s significance to Beiersdorf in terms of procurement volume and brand proximity. The country-related risk is determined by taking into account the country-risk assessments made by the international organizations Transparency International (TI), the Walk Free Foundation, the International Trade Union Confederation (ITUC) and the Yale Center for Environmental Law & Policy, Yale University.

The screening differentiates between the risk levels low, medium and high. Direct suppliers rated medium or high risk are required to provide a comprehensive self-assessment via the Sedex platform to enable an even more thorough risk assessment. The Corporate Sustainability team in Hamburg then decides whether a subsequent audit is required. These audits are carried out by accredited external auditors commissioned by the supplier and follow the standardized “Sedex Members Ethical Trade Audit” (SMETA) 4-Pillar Audit Protocol. The audit results highlight specific challenges and any areas where action is required, for which our suppliers then work out corrective action plans with our support. In extreme cases, the audit results may lead to us excluding suppliers from our supply-chain network.

Additionally, in 2018 Beiersdorf UK Ltd executed a supplier risk assessment evaluation. A substantial share of its suppliers has been analysed regarding certain criteria also relating to Modern Slavery statements. It is planned to execute this risk assessment in 2019 again while extending the scope to further suppliers as well as additional dimensions.

Beiersdorf also has a Supplier Code of Conduct Implementation Process which entails risk profiling, risk assessments and audits. This is also described in the sustainability report.

Lastly, incidents can be reported on Beiersdorf’s incident reporting platform. More information on this platform can be found on the global website and the platform itself.

Key performance indicators to measure effectiveness of steps taken

As mentioned in the sustainability report, in the initial risk screening in 2018, 15 suppliers were identified as high-risk suppliers. They have been audited by an external auditor based on the "Sedex Members Ethical Trade Audit" (SMETA) 4-PiIIar Audit Protocol. All non-compliances have been discussed with the suppliers and were dealt with by the end of 2018.

As also mentioned there, in 2018 we did not have any cases of supplier relationship termination due to a major breach.

Training

It is compulsory for every employee working in Procurement at Beiersdorf to attend an internal Procurement Academy. Training of the Code of Conduct for Suppliers forms part of this.

It is planned for 2019 to run a Modern Slavery and Human Trafficking training of local employees to whom this is relevant.

Closing

This statement was approved by the Board of Beiersdorf UK Ltd on 30 April 2019. It is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Beiersdorf UK Ltd’s modern slavery and human trafficking statement for the financial year ended 31 December 2018.

Signed

Thomas Riedner, Supply Chain Director Northern Europe
On behalf of the Board of Beiersdorf UK Ltd

UK modern slavery act compliance and anti-slavery statement central register