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 2020, we commissioned a human rights country assessment for the United Arab Emirates (UAE) by an external human rights expert. This country assessment provided an analysis of ongoing human rights issues and the resulting potential reputational and operational risks associated with our business 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) and human rights in the supply chain (such as the risk of child and forced labor). Depending on the level and type of future engagement in the country, these could potentially become concrete human rights risks. We are preparing an action plan based on our analysis and the findings in order to mitigate potential risks associated with our business engagement and ensure OMV’s compliance with its commitments to international human rights standards. In Malaysia, SapuraOMV has signed and published its Human Rights Policy Statement. Human rights aspects were also integrated into an 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 2020, 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.

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. For example, we conducted a Human Rights Self-Assessment at OMV Petrom in Romania in 2018. By 2020, all the recommendations from the assessment had been implemented, including the following key measures:

• 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.
• A lactation room to be used by employees that decide to return to work early and are still breastfeeding was set up at Petrom City headquarters.
• Our human rights expert cooperates closely with Procurement in order to ensure the full inclusion of human rights in the supplier auditing program.
• The Community Grievance Mechanism was externally assessed against the UN Effectiveness Criteria. (For more information, see Community Relations and Development.)

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.

OMV has engaged in dialogue with Corporate Human Rights Benchmark and participated in their assessment for 2020.