Actions Related to Workers in the Value Chain
United Internet has established procedures so as to incorporate, manage, and optimize matters affecting workers in the value chain. These procedures aim to ensure efficient, transparent, responsible interaction with all involved. In addition, the procedures help to obtain information on the working conditions of workers in the value chain.
The following combined actions enable United Internet to preventively combat risks and proactively support the well-being of workers in the value chain.
The strategies adopted to prevent and mitigate negative impacts depend on the relationship between United Internet and the entity causing the risk, the severity of the issue involved, and the ability to influence the suppliers concerned.
1 This does not apply to the Business Access Segment.
United Internet has established a complaints procedure to give workers in the value chain access to appropriate remedial action: The Group Guidelines on Dealing with Reports of Compliance Violations define responsibilities, binding rules, and clear processes on dealing with reports of potential human rights issues. These can be reported in confidence via the Integrity Line electronic whistleblower system. Reports and complaints received are used systematically to derive remedial actions for mitigating or ending such issues. Responsibilities and duties within the Company are clearly regulated and defined, so as to ensure systematical implementation of the due diligence obligations. The whistleblower system can be accessed with a single click via a separate menu item in the footer of the United Internet website and is publicly available.
In fiscal year 2024, the whistleblower system was extended to offer separate reporting channels for misconduct in own operations and misconduct in relation to the value chain.
The complaints procedure is an integral part of United Internet’s Code of Conduct for Business Partners and is also publicly available to workers in the indirect value chain as well as to United Internet employees and workers in its direct value chain. Business partners are obliged to inform their workers of how to use the whistleblower system. This can lead to an ad hoc risk assessment at indirect suppliers as well, if United Internet has actual indications to suggest a violation of a human rights or environmental obligation.
The whistleblower system is operated centrally for the entire Group by Corporate Compliance. The functions of Head of Corporate Compliance and of the Human Rights Officer at United Internet are performed by the same person. This allows the Company to ensure to efficacy of the procedure. The people entrusted with performing the procedure in the first instance are United Internet’s compliance managers. Compliance managers have been installed at all United Internet segments, including Corporate.
The binding internal process for dealing with reports is set in the Group Guidelines on Dealing with Reports of Compliance Violations and Conducting Internal Investigations and is described publicly in the Rules of Procedure for Reporting Misconduct in the Supply Chain. This document clearly sets out the following points:
Insights gained from dealing with reports relating to United Internet’s value chain or that the Company receives from whistleblowers who are workers in its value chain are included in modifications made to United Internet’s due diligence process. In this way, practical insights can be used to adapt of the goals that have been defined if necessary.
United Internet uses technical solutions supplied by EcoVadis to implement certain due diligence obligations relating to direct suppliers.
The Consumer Access Segment has already audited all connected call centers as part of due diligence outsourcing. In fiscal year 2024, a total of six outsourcing service providers were audited. No material indications of negative impacts were found in relation to the social matters of working practices, human rights, and compliance. In addition, regular on-site audits of service providers are performed by Legal Privacy together with the department concerned on the basis of an annually updated audit plan. Under this plan, full audits with two auditors alternate with focused checklist audits over a two-year cycle. Where possible, checklist audits are performed without advance notice, or with only a short notice period.
United Internet actively promotes inclusion, not just as an employer in relation to its own employees but also in its business relationships. For example, the Company has long-term partnerships with recycling specialists AfB and GDW. These two companies make valuable contributions to the employment opportunities for people with physical or mental disabilities. The work performed with the two companies to refurbish IT hardware is in keeping with United Internet’s interest in adding social value and positively impacting society.
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