Human rights due diligence

OMV has developed due diligence tools and techniques to assess the risk of human rights violations related to our business, even before we launch or acquire business in a new country. Human rights are one of the decision-making components determining OMV’s engagement in a given country and are presented to the respective Executive Board member before taking a decision to engage in a country. We use these assessments to derive concrete measures to reduce the risk of direct and indirect involvement in potential human rights violations. At all stages of the human rights due diligence process, we use the OMV Human Rights Matrix as a common standard, mapping reality on the ground against the concrete responsibilities as defined in the Matrix and identifying any gaps we need to focus on. This approach ensures that any potential human rights impact of our business activities is identified – whether this relates to non-discrimination and diversity, labor-related issues (e.g., minimum wage, adequate rest times), indigenous peoples’ rights, or human rights in the supply chain.

In 2019, we commissioned a Human Rights Country Entry Check for Indonesia by an external human rights expert. This check provided an analysis of ongoing human rights issues and the resulting potential legal, reputational, and operational risks associated with our planned engagement in the country. We identified general country concerns related to labor rights (such as union rights, migrant workers’ rights, health and safety at work), human rights in the supply chain (such as the risk of child and forced labor), land issues, and indigenous peoples’ rights. Depending on the level and type of future engagement in the country, these could potentially become concrete human rights risks. We elaborated and integrated potential risk mitigation measures into the further business development process in Indonesia.

In Malaysia, SapuraOMV developed a SapuraOMV Human Rights Policy Statement, which is planned to be signed by the SapuraOMV Executive Board and published on the subsidiary’s website. Human rights aspects will be integrated into a planned environmental and social impact assessment in 2020.

Our current operations are also subjected to regular assessments of their exposure to the risk of human rights violations. Due diligence starts with an Initial Risk Ranking at country level: Every country we operate in (or plan to operate in) is assessed based on comprehensive human-rights-related data and on consultation with internal and external experts. The countries are ranked by low, medium, and high risk, countries with highest manageable risk, and “no-go” countries with unmanageable risk. Based on this ranking, we develop our yearly work plan, defining further due diligence actions and human rights training. In 2019, country operations were informed about the outcome of the annual Country Risk Ranking, including information about the main human rights challenges as well as recommended mitigation measures and training options.

Employees being trained (photo)

The Human Rights Self-Assessment is one of the tools we use to assess the effectiveness of our human rights due diligence approach. Such assessments create internal awareness, capture our self-perception of our human rights performance, and facilitate the definition of gaps and further actions. In 2019, a Human Rights Self-Assessment was conducted in Yemen, where managers of departments dealing with human-rights-related topics – Human Resources, HSSE, Procurement, Community Relations, and others – were asked to fill out a questionnaire. It captured the self-perception of OMV Yemen with regard to compliance with the OMV Human Rights Policy Statement and Matrix in the country. An independent external expert assessed the plausibility of responses in light of available human rights country data. Based on the expert’s recommendations, OMV Yemen developed an action plan covering the areas of security, supply chain management, community development, and labor rights (maternity leave) in order to mitigate the risk of any negative impact on human rights and increase positive impact of our engagement in the challenging environment of Yemen. As one of the follow-up measures, OMV Yemen has revised their maternity leave regulation and expanded the duration of maternity leave to ILO (International Labour Organization) standards. This way OMV closed the gap between compliance with the applicable national law standards and international standards, which are more demanding in terms of labor rights protection. We are aware about a general rise in child labor and forced labor as well as the challenging security situation in Yemen and therefore pay particular attention to using all our professional contractor relations tools to identify any related problems. (For more information about contractor management, see Supply Chain.)

As a follow-up to the recommendations of the Human Rights Self-Assessment at OMV Petrom in Romania in 2018, the following key measures have been implemented:

  • OMV Petrom’s practice of wage deductions was analyzed in detail and full compliance with international standards was determined.
  • An internal awareness campaign against discrimination, sexual harassment, and violence was launched.
  • The Community Grievance Mechanism has been subjected to an external assessment. (For more information, see Community Relations and Development.)
  • Our human rights expert cooperates closely with Procurement in order to ensure the full inclusion of human rights in the supplier auditing program.

OMV strongly opposes forced labor, slavery, child labor, and human trafficking. We therefore fully support the aims of the UK Modern Slavery Act 2015 and are committed to operating our business and supply chain free from forced labor, slavery, and human trafficking. The OMV Statement against Modern Slavery and Human Trafficking explains in detail the measures taken against modern slavery and human trafficking in all parts of the business and supply chain. The statement is updated annually and signed by the Executive Board in accordance with the requirements of the UK Modern Slavery Act 2015 and is available on our website: www.omv.com/en/human-rights

OMV participated in a consultation round of the IPIECA Human Rights Working Group in 2019 and contributed to the consolidated IPIECA response to the UK Government, who was gathering views on several proposed amendments to the UK Modern Slavery Act. In addition, OMV has engaged in dialogue with Corporate Human Rights Benchmark and was included in their assessment for the first time in 2019.