Management approach disclosures: Human Rights

The board views the upholding of human rights as an imperative. The board has, therefore, created a social, ethics and transformation committee which is required by South African law to deal with and monitor, among others, issues of human rights.

Barloworld respects human rights. These are central to the group’s legitimacy and covered in its Code of Ethics and Worldwide Code of Conduct. The group is a signatory to the UN Global Compact, of which Principles 1 and 2specifically address Human Rights. The group Chief Executive has expressed continuing support for the UNGC’s 10 Principles(see GRI 1.1, Barloworld Sustainable Development – Chief Executive’s Message and Barloworld’s 2015 COP). For details on the UN Global Compact, see: www.unglobalcompact.org. Internal focus is on work place related human rights which include: health and safety, development, prohibiting unfair discrimination, collective bargaining arrangements and prohibiting child labour. These are addressed through human resources initiatives across the group. The group also recognises and respects personal privacy.

The Barloworld Worldwide Code of Conduct articulates our values and our commitment to uphold human rights, protect the health and safety of others and contribute toward a global environment in which all people can work safely and live healthy, productive lives, now and in the future.

Relevant aspects of the Barloworld Worldwide Code of Conduct include:

  • We respect and contribute to the realisation of human rights
  • We provide employees with opportunities to develop
  • We treat people fairly and prohibit unfair discrimination
  • We protect the health and safety of others and ourselves
  • We recognise and respect personal privacy.
  • We build outstanding long-term relationships with our principals , suppliers and customers

Applicable aspects from our Code of Ethics are:

  • Obey the law
  • Respect others
  • Be Fair.

This commitment carried into our supply-chain through our Worldwide Conduct, the applicable aspects are:

  • Teamwork Value includes:
    • We build outstanding long-term relationships with our principals, suppliers and customers: …‘We expect our suppliers to comply with the sound business practices we embrace, following the law and conduct activities in a manner that respects human rights.’
  • Commitment Value includes:
    • We respect and contribute to the realisation of human rights: ‘Barloworld has a long-standing commitment to human rights and the dignity of all people. We create a work environment that recognises the rights of employees so that we can all enjoy a workplace that is respectful, puts safety first and values fairness, responsibility, transparency and diversity. We work with principals and suppliers who also demonstrate strong values and ethical principles and avoid those who violate the law or fail to comply with the sound business practices we promote.’

Third party service providers and suppliers (TPSP&S) in all business divisions have been subjected to a risk assessment and due-diligence process in relation to bribery and corruption. This due diligence process involves the integration a more rigorous screening of TPSP&S into the existing procurement processes and setting clearly defined minimum requirements. This process is now applied to new TPSP&S and is ongoing for existing TPSP&S, in accordance with the Barloworld due diligence policy. To date some 16 500 suppliers are being covered by such assessment. As part of this process, some 3 330 suppliers have signed the Barloworld Supplier Code of Conduct which includes, among other things, the following voluntary undertaking from suppliers:

“The supplier understands that it has responsibility for its own supply chain and for managing standards of conduct within its supply chain. It therefore agrees to encourage and promote high ethical standards and adherence to international best practices in human rights, health, safety and environmental standards when undertaking its contractual obligations towards Barloworld.”

The Supplier code of conduct also specifically prohibits the use of compulsory or child labour as well as unfair discrimination, and requires freedom of association and the right to collective bargaining.

An internal review has also been conducted on all our major principals and Original Equipment Manufacturers for risks relating to human rights or labour practices, and there were no adverse findings and all have a low risk rating. These suppliers account for the majority (some 70%) of our procurement spend in the group.

Investment and procurement practices

Human rights considerations form part of the group’s due diligence process for all investment opportunities.

The group’s modus operandi with regard to investments is one where it generally acquires a business in its entirety, or a controlling stake thereof. Workplace related human rights include health and safety, development, prohibiting unfair discrimination, collective bargaining arrangements and prohibiting child labour. These are covered in the human resources section of the due diligence process for all new investments opportunities. If the transaction proceeds, any gaps identified are then addressed in terms of the group’s values, code of conduct, compliance with applicable legislation, including those frameworks to which it is a signatory. All agreements specifically include clauses covering employees.

Our approach to Human rights compliance in our supply-chain is reflected in our Worldwide Code of Conduct as set out above.

Suppliers, service providers and contractors are expected to comply with applicable legislation; they are also expected to comply with their contractual obligations which set certain standards of conduct. The contracts of those not complying would be reviewed and appropriate action taken according to the circumstances.

The group sources the majority of its products from leading global OEMs with established and entrenched human rights policies and practices. Further, by representing leading global Original Equipment Manufacturers (OEMs) and brands, Barloworld participates in supply chains that conform to norms and regulations and that aspire to the highest standards. Where non-conforming suppliers are identified, appropriate action is taken according to the circumstances.

We are guided by the principles in the Barloworld Worldwide Code of Conduct, our values and ethics and we would apply these in order to take the appropriate action on human rights matters should the case arise, according to the circumstances.

Our Barloworld Worldwide Code of Conducts includes the following under the Value of ‘Commitment’:

We make responsible ownership and investment decisions – Barloworld investments must be compatible with social and economic priorities, local laws, customs and traditions of the countries where we do business. In all cases, our conduct should promote acceptance and respect for our company. We also expect that our host countries will recognise the need for stability, growth and business success and that they will honour their agreements, including those relating to rights and properties of citizens of other nations.

Non-discrimination

A workplace free from unfair discrimination is a fundamental value of the group and is entrenched in its Code of Ethics and Worldwide Code of Conduct. Group processes ensure that any instances of unfair discrimination can be reported and addressed.

Freedom of association and collective bargaining

Collective labour relations are constructively managed on the principle of freedom of association. Employees may associate or not with representative organisations and trade unions. Trade unions sufficiently representative of employees are recognised at appropriate operational levels, and operations covered by industry agreements participate in relevant industry forums.

There are no operations where the right to exercise freedom of association and collective bargaining is at significant risk.

As the group represents leading global principals and suppliers, it is not aware of any suppliers where freedom of association and collective bargaining are at risk.

The group requires that its supply chains conform to its values. Evidence of non-compliance would result in appropriate action being taken according to the circumstances.

Child labour

Barloworld does not have child labour. It is contrary to the group’s Worldwide Code of Conduct, our values and ethics.

As the group represents leading global principals and suppliers, it is not aware of any use of child labour in its supply chain nor has it identified any suppliers at risk.

Suppliers, service providers and contractors are expected to comply with applicable legislation; they are also expected to comply with their contractual obligations which set certain standards of conduct. Evidence of non-compliance would result in appropriate action being taken according to the circumstances.

Prevention of forced and compulsory labour

Barloworld does not have forced and compulsory labour. It is contrary to the group’s Worldwide Code of Conduct, our values and ethics.

As the group represents leading global principals and suppliers it is not aware of any use of forced and compulsory labour in its supply chains nor has it identified any suppliers at risk.

Suppliers, service providers and contractors are expected to comply with applicable legislation; they are also expected to comply with their contractual obligations which set certain standards of conduct. Evidence to the contrary, would result in appropriate action being taken according to the circumstances.

Security practices

Most business units and operations outsource their security arrangements. As with all other suppliers, they are expected to comply with the law.

Barloworld employees that are responsible for security are trained in relevant practices and procedures.

Indigenous rights

Barloworld respects the rights of indigenous people as considered in the GRI definition. As the group represents leading global principals and suppliers, it is not aware of any abuse of indigenous people’s rights in its supply chain. Suppliers, service providers and contractors are expected to comply with applicable legislation; they are also expected to comply with their contractual obligations which set certain standards of conduct. Evidence to the contrary would result in appropriate action being taken given the circumstances.

Assessment

Workplace related human rights include health and safety, development, prohibiting unfair discrimination, collective bargaining arrangements and prohibiting child labour.

These are covered in the human resources section of the due diligence process for all new investments opportunities. The group’s modus operandi with regard to investments is one where it generally acquires a business in its entirety, or a controlling stake thereof.

During the due diligence process, the targeted entity is assessed, including human resources matters and these include the above mentioned human rights issues. If the transaction proceeds, any gaps identified are then addressed in terms of the group’s values, code of conduct, compliance with applicable legislation, including those frameworks to which it is a signatory. All agreements specifically include clauses covering employees.

Suppliers and contractors are expected to comply with legislation and their contractual obligations which set certain required standards of conduct. The contracts of those that do not comply will be reviewed and appropriate action taken according to the circumstances. The group sources most of its products from leading global OEMs with established human rights policies and practices.

Third party service providers and suppliers (TPSP&S) in all business divisions have been subjected to a risk assessment and due-diligence process in relation to bribery and corruption. This due diligence process involves the integration a more rigorous screening of TPSP&S into the existing procurement processes and setting clearly defined minimum requirements. This process is now applied to new TPSP&S and is ongoing for existing TPSP&S, in accordance with the Barloworld due diligence policy. To date some 16 500 suppliers are being covered in such assessment. As part of this process, some 3 330 suppliers have signed the Barloworld Supplier Code of Conduct which includes, among other things, the following voluntary undertaking from suppliers:

“The supplier understands that it has responsibility for its own supply chain and for managing standards of conduct within its supply chain. It therefore agrees to encourage and promote high ethical standards and adherence to international best practices in human rights, health, safety and environmental standards when undertaking its contractual obligations towards Barloworld.”

The code also specifically states:

“The supplier may not directly or indirectly use any form of forced or compulsory labour or child labour. The supplier shall not employ children under the age of 15. (Note: Amend this age to conform to local labour law where applicable.) Where applicable, the supplier should ensure that all employees are permitted to participate in collective bargaining, without fear of intimidation or reprisal and be free to choose whether or not to do so. The supplier should promote diversity and may not discriminate in employment and occupation on such grounds as race, religion, disability, national origin, colour, gender, sexual orientation, age and/or physical or mental disability, or other unfair discrimination.”

An internal review has also been conducted on all our major principals and Original Equipment Manufacturers for risks relating to human rights, with no adverse findings and all have a low risk rating. These are significant suppliers and account for the majority (some 70%) of our procurement spend in the group.

Remediation

The group has not needed to make reparations for any human rights violations. Should such a case occur, we would comply with the law and act in accordance with any directive issued.

We would also be guided by the principles in the Barloworld Worldwide Code of Conduct, our values and ethics in order to take the appropriate action on human rights matters should the case arise, according to the circumstances.

Reporting of human rights violations and grievance mechanisms

The Barloworld Whistle-Blowing policy sets out procedures for reporting improprieties or improper conduct so that the rights of employees and other associated persons are protected where such disclosures are made in good faith.

Barloworld’s Worldwide Code of Conduct specifically covers process for reporting violations of the code. It includes an anonymous Barloworld Ethics Line, and provides assurance that the group does not tolerate any reprisals against an employee for raising a concern or making a report in good faith.

Coverage

Responses to the indicators cover the performance of Barloworld Limited in all the geographic regions in which the Barloworld group and its subsidiaries operate. The consolidated data incorporates the company and all entities controlled by Barloworld as if they are a single economic entity. There are no other entities over which the group has significant influence that it believes should be included in the report. Associates and joint ventures are equity accounted.