United Internet does business in Europe and North America, in other words it is also active outside its home market of Germany. Consequently, responsibility in the value chain is a material topic for the Company, especially with respect to the protection of environmental, employee, and human rights. Human rights comprise not only fundamental rights such as the rights to life, freedom, and equality, but also a wide range of aspects from the world of work, such as the prohibition on discrimination and (“modern”) slavery, and the right to rest.
United Internet works together with a large number of companies in the value chain. Both United Internet’s own staff and the workers in its value chain – who are outside the direct sphere of influence of its business activities – can be exposed to hazards or grievances. This applies in particular to working conditions and human rights issues. As part of its double materiality assessment, United Internet applied the ESRS methodology to identify both positive and negative material impacts on workers in the value chain. These are described in the following.
IT hardware that United Internet sells or uses to provide internet and telecommunications services contains a number of different raw materials. Among the materials needed are oil (for plastics production), rare earths, lithium, silicon, and copper. These raw materials primarily come from China, Australia, the USA, Chile, and the Democratic Republic of the Congo. Extraction of these raw materials can be characterized by exploitative working conditions and human rights issues In particular the value chain for minerals can involve risks.
In addition to the danger of child labor in cobalt mines and hazardous working conditions for mine workers, employees at supplier operations, self-employed people, and workers at third-party undertakings can be exposed to risks. A lack of occupational safety measures can seriously impair workers’ health or in the worst case result in their death. What is more, workers in the value chain can be exposed to abuse, violence, and forced labor without enjoying adequate protection or legal certainty.
The IT hardware that United Internet needs is primarily manufactured abroad, e.g., in China, Vietnam, India, Taiwan, and Japan. Within IT hardware factories migrant workers, women, and contingent labor are particularly at risk. For example, they may suffer from low wages, long working times, a lack of occupational health and safety measures, discrimination, and insecure contracts, often without any or only a small chance of enforcing their rights. Workers can also be exposed to sexual harassment . Inadequate accommodation for migrant workers and foreign employees may further aggravate their exploitation. All these circumstances can potentially have a substantial impact on the physical and psychological health of those affected, and represent a disrespect for human rights.
Human rights issues can also occur in areas of United Internet’s downstream value chain: Hardware ordered by customers (e.g., cell phones or network devices) is delivered by shipping service providers. Cases of unfair pay or other working conditions that do not conform to statutory or social standards and that negatively impact the quality of life of the workers concerned may occur in this sector.
United Internet pays attention to diversity and inclusion both in its own operations and in the value chain. It promotes these values by specifically working together with inclusive business partners, especially when it comes to refurbishing IT hardware. This not only contributes to a more diverse and integrative working environment but also to more equal opportunities and social justice in society as a whole. At the same time, it strengthens independence, a feeling of self-worth, and the social integration of persons with disabilities.
United Internet is committed to complying with its due diligence obligations in the value chain.
United Internet’s supply chain risk management is centrally organized and embedded locally in the segments. The Company’s Management Board has commissioned the Head of Corporate Compliance to monitor the due and proper implementation of the relevant processes and actions by the segments. The individual segment concerned always remains responsible for establishing risk management and for ensuring that the due diligence obligations in relation to direct suppliers are complied with. United Internet makes financial and human resources available for meeting the due diligence obligations. In fiscal year 2024, a Senior Specialist Compliance and ESG was recruited to coordinate implementation of the due diligence obligations with respect to direct suppliers. A Supply Chain Compliance Manager was recruited at Corporate Compliance to support the Head of Corporate Compliance in his monitoring duties (Human Rights Officer).
United Internet has set out the principles and rules that apply when implementing its due diligence obligations in the value chain in its Policy Statement, the Code of Conduct for Business Partners, the Guidelines for Implementing Supply Chain Due Diligence ( SCDD) at United Internet, the Group Guidelines on Dealing with Reports of Compliance Violations and Conducting Internal Investigations, and its Purchasing Guidelines. These policies and guidelines address the positive and negative impacts that resulted from the double materiality assessment. They are described in more detail in the following.
United Internet has embedded the overarching principles for respecting human rights and environmental due diligence obligations under the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – LkSG) in its operating processes. They have been described and published in the Policy Statement.
The Policy Statement describes the human rights policy and the expectations to be met by employees and business partners. The following actions have been taken in order to implemented the strategy set out in the Policy Statement:
These measures cover all workers in the direct value chain plus those who could be directly affected in other ways by the Company’s economic activity. If risks are discernible, action is taken so as to effectively stop or mitigate potential impacts.
As part of its activities in relation to the L-CMS, United Internet performs regular risk analyses along the direct value chain so as to identify human rights and environmental risks. To do this, it uses a software solution to assess country and sector risks from a human rights and environmental perspective (gross risk). Where a gross risk is identified, the concrete human rights and environmental risks are determined, weighted, and prioritized on an individual basis in the specific context of the supplier concerned. When weighting the gross risks, United Internet hast followed the “Handout on the principle of appropriateness” and the “Guidance on conducting a risk analysis” published by the Federal Office for Economic Affairs and Export Control. In certain cases, e.g., for suppliers with an annual purchasing volume in excess of €100,000 – whom United Internet considers to be more relevant for the supply chain in principle – United Internet performs a specific, individual, comprehensive risk analysis. This is then used as the basis for deriving additional preventive measures if necessary. Human rights coordinators in the local purchasing units handle the implementation and communication of any such measures.
United Internet expects its suppliers and service providers to comply with the same principles as the Company does itself. These expectations are described in concrete terms in its Code of Conduct for Business Partners and form part of United Internet’s careful selection process for business partners. The code is intended to help guarantee corresponding working conditions in the value chain. At the same time, the goal is to avoid human rights issues in the upstream and downstream value chain and associated potential negative impacts resulting from United Internet’s business activities.
United Internet has explicitly committed itself to the prohibition of human trafficking, forced labor, and child labor. This commitment is embedded in the Code of Conduct for Business Partners and must be observed by suppliers and business partners.
The Guidelines for Implementing Supply Chain Due Diligence (SCDD) describe the structural implementation of the LkSG at United Internet and define core roles and responsibilities within the Group-wide LkS organization.
The Group Guidelines on Dealing with Reports of Compliance Violations and Conducting Internal Investigations define binding Group-wide rules for dealing with reports of violations of human rights and environmental due diligence obligations. They ensure the effective investigation of any such matters.
If Corporate Audit is commissioned in certain circumstances to perform an internal investigation under these guidelines, the audit findings are documented in the investigation report and communicated to the management responsible in the presentation of results, and the resulting recommendations are explained. Risk mitigation actions are then defined on the basis of the recommendations. The actions resolved by United Internet’s Management Board are documented in an action tracker tool, with Corporate Audit monitoring their implementation.
United Internet’s Source to Contract Guidelines are another policy. They contain guidelines and principles for operational and strategic purchasing, and set out the rules governing the tendering process plus demand management, product group management, supplier management, and contract management.
Links
Downloads
