MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2023
INTRODUCTION
At Beiersdorf UK Ltd (“Beiersdorf UK”) we want to play an active role in making positive contributions to society. Beiersdorf UK acknowledges that as being part of a global corporate organisation it has a responsibility to address and seek to eliminate the risk of slavery and human trafficking in its operations. This is as part of the respect that the company has for human rights, in line with the principles contained in the United Nations Universal Declaration of Human Rights and the UK Modern Slavery Act 2015.
In this statement, we set out Beiersdorf UK’s commitment to taking steps to identify and eradicate slavery and human trafficking from its business and from its supply chains. We do not tolerate slavery and human trafficking within the supply chain or within any part of our business.
As required by the UK Modern Slavery Act 2015, this statement reports on the steps Beiersdorf UK and the Beiersdorf group have taken in this regard during the financial year ended 31 December 2023.
STRUCTURE AND SUPPLY CHAINS
Beiersdorf UK, based in Birmingham, is a part of the Beiersdorf group, a global leader in the consumer goods industry. Beiersdorf UK’s principal activity is sales, marketing and distribution of products for the care and protection of skin marketed under major brands such as NIVEA, Eucerin and Elastoplast. An overview of where Beiersdorf UK fits within the global business, as well as details of the company’s core values and product brands appears in the online company profile. Information about the parent company Beiersdorf AG can be found on its homepage.
Beiersdorf UK is integrated into a supply chain whose processes take place predominantly within Europe. Only a handful of suppliers who directly supply Beiersdorf UK are located outside of Europe. More precisely, in 2023, Beiersdorf UK sourced 89% of the volumes of the finished goods from Beiersdorf owned factories and 11% from third-party manufacturers or third-party co-packers. 55% of these volumes were sourced from Germany, 21% from Spain, 16% from Poland, 3% from The Netherlands and the remaining 5% from the rest of the world.
Regarding goods and services not directly related to the production of products, 92% of spend was with suppliers located in the UK, 7% with those based in Europe and 1% with suppliers outside of Europe. 72% of spend (39% of suppliers) were covered by the Corporate Procurement (Global and Regional) function and 28% of spend (61% of suppliers) by the Local organisation.
POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
Policy for Employees
All Beiersdorf UK employees (200+) are provided with a Code of Conduct for Employees. The latest version of this Code of Conduct was officially introduced by the Board of Directors to all employees and managers in 2023. In addition, everyone is trained on this policy through e-learning.
The Code of Conduct is designed to help employees to understand the company’s principles and to act in accordance with them. Diversity and equal opportunities are an essential part of the Code of Conduct. The Code of Conduct also clearly states that Beiersdorf does not support or tolerate slave labour, child labour or human trafficking. Beiersdorf also stands for fair working conditions and promotes physical and mental health and safety at work.
Policy for Suppliers
Beiersdorf UK began roll out of an updated Code of Conduct for Business Partners at the end of 2022, with a compliance measurement beginning in 2023 to update suppliers to this new, more robust version which includes reference to regulations against the Modern Slavery Act. Among other things, the Code of Conduct prohibits the use of forced labour, inappropriate disciplinary measures, and child labour. Other minimum employee rights regarding working hours, remuneration and freedom of association are also covered. All suppliers are required to accept the standard set out in the Code of Conduct for Business Partners and inform their employees. Diversity and equal opportunities are an essential part of the new Code of Conduct. Suppliers agree to keep adequate records to demonstrate compliance and agree that Beiersdorf UK or its nominated representative may make announced or unannounced inspections to suppliers’ premises to verify compliance. Furthermore, an escalation process through the Global Sustainability team has been established to be applied in case a supplier refuses to accept the standards set out in Beiersdorf’s Code of Conduct for Business Partners.
As mentioned in the Non-financial Statement 2023, over 90% of Beiersdorf’s global goods and services in 2023 were procured with suppliers who accept its Code of Conduct for Business Partners. In 2023, 95% of Beiersdorf UK's spend was with suppliers who had signed up to Beiersdorf's Code of Conduct, which includes both the 2023 version and the previous one. Beiersdorf is currently in the process of transitioning all suppliers to its updated Code of Conduct. Further suppliers have confirmed compliance via individual commitments. Beiersdorf’s ambition is to increase acceptance by suppliers year on year of its Code of Conduct for Business Partners.
RISK ASSESSMENT, PREVENTION AND MITIGATION
Beiersdorf UK reviews annually the steps it has taken to address the risks of slavery and human trafficking in its business and in its supply chain, including the effectiveness of internal processes for reporting and escalation of issues.
Beiersdorf’s Corporate Sustainability team annually conducts a risk assessment of all approximately 21,000 direct suppliers of Beiersdorf affiliates including those who supply Beiersdorf UK. The process consists of appraising the country-related risk as well as the individual supplier’s significance to Beiersdorf in terms of procurement volume and procurement category. Country and industry specific risk factors are determined by a market leading third-party sustainability risk provider.
The screening differentiates between the risk levels low, medium and high. Direct suppliers rated medium or high risk are required to provide a comprehensive external assessment via the Ecovadis platform to enable an even more thorough risk assessment. The Corporate Sustainability team in Beiersdorf’s Headquarters in Hamburg then decides whether a subsequent audit is required. These audits are carried out by accredited external auditors commissioned by the supplier and follow the standardized “Sedex Members Ethical Trade Audit” (SMETA) 4-Pillar Audit Protocol. The audit results highlight specific challenges and any areas where action is required, for which our suppliers then work out corrective action plans with our support. In extreme cases, the audit results may lead to us excluding suppliers from our supply-chain network.
Additionally, Beiersdorf has an Implementation Process with regards to the Code of Conduct for Business Partners which entails risk profiling, risk assessments and audits. This is also described in the Non-financial Statement 2023. Lastly, incidents can be reported on Beiersdorf’s incident reporting platform. More information on this platform can be found on the global website and the platform itself.
DUE DILIGENCE
A substantial share of Beiersdorf’s suppliers have been analysed regarding certain criteria also relating to Modern Slavery. All suppliers considered higher risk committed to follow Beiersdorf’s Code of Conduct for Business Partners. Additionally, to drive ethical and sustainable improvements our top critical suppliers agreed to be part of Sedex.
Beiersdorf recognises that supply chains are highly complex and internationally intertwined and takes our responsibilities in these very seriously. Beiersdorf’s Code of Conduct aims to prevent misconduct and make clear what we expect from our suppliers in terms of environmental and social responsibility. At the end of 2022, the Code of Conduct was updated to follow Germany’s new Supply Chain Due Diligence Act where Beiersdorf’s headquarters are based, ready for implementation in 2023. This law requires large companies to take responsibility for upholding human rights in their supply chains and this altered our Code of Conduct for all suppliers of Beiersdorf worldwide, including those of Beiersdorf UK. The Code of Conduct is a binding contractual basis for compliance with human rights between Beiersdorf and its business partners along the entire value chain.
Elsewhere, a session on the Modern Slavery Act and Beiersdorf’s Modern Slavery Statement was hosted with all Beiersdorf UK staff during a company presentation in 2023. This presentation also covered updates made in our 2022 statement, how Beiersdorf is committed to opposing modern slavery and human trafficking as well as awareness of the Modern Slavery Act as a whole.
Furthermore, a detailed presentation was delivered separately to our UK Supply Chain function within an internal forum. This covered Beiersdorf’s Modern Slavery Statement and detail on our stronger Code of Conduct for Business Partners as well as a question-and-answer session to further deeper understanding.
Lastly, in 2023, Beiersdorf’s central sustainability and procurement teams held global Q&A sessions on the updated Code of Conduct for Business Partners as well as human rights trainings for new procurement staff attending our internal procurement academy.
Additionally, the Beiersdorf group commits to the approach of sustainable development through the Sustainable Development Goals (SDGs) which is part of our sustainable agenda available on the corporate website.
Beiersdorf also requires suppliers to engage the inclusion of modern slavery related questions in our standard tender process and part of supplier selection criteria. The supplier will then provide their modern slavery statements in support of Beiersdorf’s commitment to eliminate the risk of slavery and human trafficking with reference to the supply of products and / or services.
Finally, Beiersdorf leverages the synergies of the recognized Sedex, EcoVadis and AIM-Progress collaborative platforms on which further information can be found in the Non-Financial Statement 2023.
KEY PERFORMANCE INDICATORS TO MEASURE EFFECTIVENESS OF STEPS TAKEN
In 2023, 158 suppliers within our supply chains have been audited according to the “Sedex Members Ethical Trade Audit” (SMETA) 4-Pillar Audit Protocol by external auditors. Any non-compliances have been discussed with the suppliers and corrective action plans put in place alongside regular follow ups together with the supplier and auditor. In 2023 Beiersdorf did not have any cases of supplier relationship termination due to a major breach.
Beiersdorf’s current initiative is to ensure all suppliers with a yearly spend above €50,000 legally sign our updated, more robust Code of Conduct for Business Partners. This is being spearheaded by a central team within Beiersdorf’s headquarters, with local procurement teams support where required. In 2023 and continuing into 2024, it is a central focus of Beiersdorf’s procurement functions globally. Whilst suppliers may be currently covered by our previous Code of Conduct, it is our priority to update this to our latest 2023 version, resulting in a global Beiersdorf target of 60% of suppliers (that have a spend above €50,000) having signed this updated version by the end of 2024. As of May 2024, 66.3% of Beiersdorf UK’s suppliers have signed this updated version and this target will increase in 2025.
TRAINING
It is compulsory for every employee working in Procurement at Beiersdorf to attend an internal Procurement Academy. Training of the Code of Conduct for Business Partner and human rights processes forms part of this.
Since 2020, there has been a Modern Slavery SharePoint on our UK intranet that continues to be updated and promoted as a central source of key information for all Beiersdorf UK employees. It includes our Modern Slavery Statement, year on year improvement and training material.
Future training and education on processes related to the Modern Slavery Act is available to procurement colleagues from industry bodies and networks. We have planned for employees within our local procurement team in the UK to attend both in person and online events in 2024 to continually further their understanding on the topic.
CLOSING
This statement was approved by the Board of Beiersdorf UK on the 7th of June 2024. It is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Beiersdorf UK’s Modern Slavery and Human Trafficking Statement for the financial year ended 31 December 2023.
Signed
Jennifer Muller
Supply Chain Director Northern Europe
On behalf of the Board of Beiersdorf UK Ltd.