Respect for Human Rights
The European legal framework in which Vonovia operates with its business model is strictly regulated and overseen in the markets in Germany, Austria and Sweden. This applies in particular to fundamentally enshrined human rights, to which Vonovia attaches great importance irrespective of the legal framework. Compliance with, and the fostering of, these rights is reflected in our ethos and mission statement. We regularly scrutinize our guidelines and adapt them to reflect changing underlying conditions. Due to the Supply Chain Due Diligence Act and the announced European regulation, the way in which supply chains are structured and the due diligence obligations associated with this are of increasing importance to the company.
In our Declaration of Respect for Human Rights, we communicate our clear conviction for a pluralistic democratic society and zero tolerance of human rights violations and our commitment to respect human rights in all aspects of our business. We adhere to the core labor standards of the International Labour Organization (ILO), the UN Guiding Principles on Business and Human Rights, and the principles of the UN Global Compact, which we committed to in 2020.
Vonovia’s business model includes the construction, maintenance and modernization of homes. From a human rights perspective, compliance with labor and social standards on construction sites in the course of these activities is of particular relevance. Some trade/construction activities in Germany are carried out by the company’s own technical service – and therefore by its own employees. This lessens both dependency on the services of external construction companies and – thanks to the measures established in the company’s own business area – the risk of noncompliance with labor and social standards.
Concrete cooperation with external partners and contractors is governed by Vonovia through its Business Partner Code, the general terms and conditions of purchasing, the general terms and conditions of Vonovia SE for building services, and individual contractual agreements within the scope of structured supplier management. The Business Partner Code must be signed prior to the conclusion of a contract. In this document, we set out, among other things, all material requirements necessary for compliance with human rights – from legal conformity and the fulfillment of legal standards for working conditions to an assurance of freedom of association and the exclusion of child labor, forced labor and discrimination. It is updated regularly – with the next update scheduled for 2023 – and applies to contractual relations in Germany and Austria. A corresponding separate Code is in place in Sweden.
As part of the regular evaluation of our major suppliers and contractors via our partner portal, we strive to ensure that the criteria stated in the Code are complied with. In the event of incidents and breaches, a structured management of measures is activated, which – once all other means have been exhausted – may result in blocks on orders and termination of contract. In Germany, contractual conclusion is preceded by an automatic check against EU sanctions lists, with the compliance department informed immediately in the event of a hit. In Austria, the procurement department reviews all new creditors and regularly reviews existing ones on a half-yearly basis as part of a compliance check that also includes an inspection of sanctions lists (via KSV1870). We also use long-term cooperation in the spirit of partnership to build a close relationship of trust with our contractual partners. This is largely the responsibility of the procurement department and allows any misconduct to be addressed. The procurement department has been assigned to the Chief Transformation Officer’s (CTO) Management Board function since January 1, 2022.
In the reporting year, we revised the Group procurement guidelines to further strengthen compliance with due diligence obligations and internal governance procedures, for example. The new guidelines apply throughout the Group and have been in effect since January 1, 2023. We also began the gradual integration of Deutsche Wohnen’s suppliers into Vonovia’s partner portal in the reporting year. The structures of Vonovia’s central procurement department were transferred to the Deutsche Wohnen subgroup.
Furthermore, in the reporting year we focused particularly on preparation for implementation of the requirements of the Supply Chain Due Diligence Act (LkSG), which has been applicable in Germany since January 1, 2023. This also includes reviewing existing guidelines, codes and processes as well as establishing responsibilities. In the course of this process, we updated our Declaration of Respect for Human Rights and republished it in the form of a Group guideline in January 2023.
The Compliance Officer was appointed Human Rights Officer as of January 1, 2023, and will report regularly to the Management Board in the future. The Compliance Officer will be supported by a committee that brings together due diligence coordinators from relevant departments. From 2023 onward, the committee will convene at least once per quarter and discuss the ongoing fulfillment of Vonovia’s human rights and environmental due diligence obligations. In the reporting year, we looked at how we can plan training sessions in order to further improve awareness of our human rights and environmental due diligence obligations among employees in relevant business areas in the future.
In the reporting year, we launched a comprehensive risk analysis for our supply chain and identified initial priority risk areas. We describe our approach and the risk areas identified in the course of the risk analysis in our Declaration. There were no indications of human rights violations within our own business area during the reporting year.
Vonovia has set up various procedures to allow potential abuses (such as human rights violations, environmental pollution, other unlawful actions) to be reported by both internal and external parties (see Combating Corruption and Bribery). We continued to develop our whistleblowing system in the reporting year and will integrate additional languages in 2023.