T H E  S H I F T I N G  G E A R S  R E P O R T: 
An Assessment of 
Human Rights Risks & 
Due Diligence in the 
Automotive Industry
J U N E  2 0 2 0
Mary Beth Gallagher  
& Gina Falada
Research & 
Company Profiles
Written by: 
Sara E. Murphy
Edited by: 
Heidi Welsh

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TA B L E  O F  C O N T E N T S
Executive Summary................................................................................................................................................ 3
Introduction............................................................................................................................................................ 5
Company Assessment Results............................................................................................................................... 12
Key Points from Company Profiles........................................................................................................................ 16
Overview of Human Rights Risks in the Automotive Industry................................................................................ 20
Salient Human Rights Issues for the Automotive Sector......................................................................................... 24
Investor Call to Action.......................................................................................................................................... 30
Sector Specific Strategies to Support Effective Human Rights Due Diligence......................................................... 32
Recommendations for Automotive Sector Companies on Human Rights Due Diligence....................................... 36
A History of Human Rights Violations................................................................................................................... 38
Company Profiles................................................................................................................................................. 42
Axalta Coating Systems................................................................................................................................ 43
BASF............................................................................................................................................................ 46
BMW........................................................................................................................................................... 51
Bridgestone................................................................................................................................................. 57
Continental.................................................................................................................................................. 61
Denso.......................................................................................................................................................... 66
Fiat Chrysler Automobiles............................................................................................................................ 68
Ford Motor.................................................................................................................................................. 71
General Motors............................................................................................................................................ 76
Genuine Parts.............................................................................................................................................. 80
Goodyear.................................................................................................................................................... 82
Groupe PSA................................................................................................................................................. 85
Honda Motor.............................................................................................................................................. 88
Lear............................................................................................................................................................. 90
Nissan......................................................................................................................................................... 92
Nucor.......................................................................................................................................................... 94
PPG Industries............................................................................................................................................. 96
Renault........................................................................................................................................................ 98
Tesla.......................................................................................................................................................... 101
Toyota....................................................................................................................................................... 103
Volkswagen................................................................................................................................................ 105
Assessment Methodology................................................................................................................................... 108
Glossary of Terms & Resource List...................................................................................................................... 111
Index of Multi-Stakeholder Initiatives.................................................................................................................. 116
Investor Advocates for Social Justice Affiliates..................................................................................................... 119

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The automotive industry has a history of innova-
tion, revolutionizing transportation, and secur-
ing its role in daily lives. The complex logistics, 
supplier relationships, safety checks, and manu-
facturing operations that come together to bring 
consumers a shiny new vehicle significantly im-
pact the dignity and rights of employees, stake-
holders, and communities. As the industry stands 
at the brink of disruption – adaptation for climate 
change and electrification, the future of mobili-
ty, and dawn of autonomous vehicles – it is also 
contributing to exploitation of human rights. Ex-
tensive research documents human rights risks in 
the supply chains for commodities that go into a 
car, from leather to mica to rubber. Many work-
ers, including children, are vulnerable in the ex-
tensive global supply chain, in which automotive 
brands and their “Tier 1” suppliers hold signifi-
cant buying power. This system contributes to 
downward pressure throughout the supply chain 
to cut prices, often at the expense of wages and 
protections for workers. 
The shareholder advocacy initiative, Shifting 
Gears, led by Investor Advocates for Social Justice 
(IASJ), started with one simple question to com-
panies: How do you know your business is not 
contributing to forced labor or child labor? The 
companies IASJ engages have been unable to an-
swer this question in dialogue or their disclosures 
with certainty. This is a problem.  
The automotive industry has adapted its disclo-
sures to respond to the emergence of corporate 
social responsibility and increasing expectations 
from investors, customers, and regulators. How-
ever, the core business model, supplier relation-
ships, and the way things are done systemically 
have not shifted. As this report shows, evidence 
is absent across the automotive industry that 
corporations are effectively embedding commit-
ments to ensure respect for human rights. This is 
reinforced by the prevalence of vague language 
in company policies that fails to bind a compa-
ny and its suppliers to any specific actions or re-
quirements. Therefore, investors and stakeholders 
have legitimate uncertainty about the level of rig-
or and authenticity of companies’ efforts to ad-
dress human rights risks. More importantly, it is 
unclear whether any company in the sector has 
effective systems in place to meet their human 
rights responsibilities. 
After extensive sector analysis, investor engage-
ment, and the independent research commis-
E X E C U T I V E  S U M M A R Y
Key Findings of Research 
1.	 Governance and management sys-
tems for human rights is the weakest 
area for all companies. Only 3 com-
panies (BMW, Ford, VW) have at least 
limited disclosure of their human 
rights governance and management 
systems. 
2.	 The second-weakest scores overall 
occur in the area of embedding re-
spect for human rights across the 
business.
3.	 Traceability and supply chain trans-
parency is the third weakest area 
assessed and is lacking across all 
companies surveyed, with limited ex-
ceptions for conflict minerals. 
4.	 Even the stronger performing compa-
nies have only limited monitoring of 
human rights commitments among 
suppliers.
5.	 Access to grievance mechanisms is 
weak, constituting only hotlines, and 
disclosure on remedy is absent.

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sioned for this report, IASJ concludes that the 
automotive industry is failing to demonstrate re-
spect for human rights. Stronger governance from 
companies’ board and senior leadership is need-
ed to set the tone at the top and embed it through 
the lowest tier of the supply chain. Companies do 
not generally allocate sufficient resources, staff 
time, or incentives towards improving human 
rights due diligence, the systems outlined by the 
UN Guiding Principles on Business and Human 
Rights. Cost pressures, coupled with the absence 
of strong regulatory and legal frameworks for 
holding corporations accountable, contribute to 
lack of prioritization of human rights within the 
business. 
The most severe human rights risks are in the sup-
ply chain. Yet there is inadequate supply chain 
transparency or oversight to monitor even direct 
suppliers. Enforceable commitments that are 
cascaded from one supplier to the next through 
the supply chain either do not exist or are not 
monitored. Most companies do not conduct hu-
man rights risk assessments that would enable 
them to identify salient risks and prioritize efforts. 
They lack plans to develop mitigation strategies 
and evaluate the efficacy of their systems. Few 
companies have robust management systems that 
enable them to embed human rights criteria into 
business functions like assessing suppliers before 
entering contracts, incorporating human rights 
into purchasing decisions, and monitoring com-
pliance with human rights criteria in contracts.  
Still, certain areas of hope emerge - European 
companies in the sector generally have stron-
ger commitments, more resources allocated to 
human rights due diligence, and stronger per-
formance compared to American and Japanese 
companies. While this is likely due to more robust 
European regulatory requirements and investor 
expectations, these companies demonstrate what 
is possible. 
As society faces uncertainty from the coronavirus 
pandemic and the climate crisis, the automotive 
industry must center human rights in its response 
to crises and standard business activities. Many 
individuals impacted throughout the supply chain 
face vulnerabilities - both to their health and eco-
nomic resilience. It is important that companies 
identify and address these vulnerabilities.
Effective governance, oversight, strategic plan-
ning, and implementation of human rights respon-
sibilities is essential to prevent harm and protect 
the companies from risks. There are many human 
rights, legal, financial, business continuity, con-
sumer trust, and reputational risks that will persist 
in the face of weak human rights due diligence. 
Investors should engage companies, encourag-
ing them to strengthen governance and oversight 
of human rights, publish disclosure that will en-
able investors to more rigorously assess corporate 
practices, and evaluate the effectiveness of their 
corporate human rights due diligence. Investors 
should encourage regulators and policymakers to 
establish stronger legal requirements, including 
mandatory human rights due diligence. Efforts to 
strengthen company policies and practices can 
drive systemic change.  
Taking on these daunting issues will require in-
formed and committed leadership, and more 
sustainable and just business models. Investors, 
companies, and governments must address the 
root causes that contribute to poverty, forced la-
bor, and poor working conditions in the supply 
chain. To achieve these outcomes, investors must 
increase pressure on the industry as a whole and 
encourage individual companies to meet higher 
expectations for human rights outcomes.    
E X E C U T I V E  S U M M A R Y
Mary Beth Gallagher
Executive Director,  
Investor Advocates  
for Social Justice
June 2020

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About Investor 
Advocates for  
Social Justice (IASJ)
Investor Advocates for Social Justice (IASJ), a suc-
cessor to the Tri-State Coalition for Responsible 
Investment, is a 501(c)(3) non-profit organization 
representing investors with faith-based values 
who seek to leverage their investments to ad-
vance human rights, climate justice, racial equity, 
and the common good. On behalf of its inves-
tor Affiliates, IASJ engages companies to address 
strategic environmental, social, and governance 
issues and advocate for change. IASJ uses a vari-
ety of shareholder advocacy strategies, including 
dialogue with corporate investors, investor letters, 
filing of shareholder proposals, and proxy voting, 
to encourage corporations to adopt more ethical 
and sustainable business practices. IASJ believes 
in seeking out and building collaborative partner-
ships with those who share similar goals, in an 
effort to increase the effectiveness and impact of 
this work. Founded in 1975 as the Tri-State Coali-
tion for Responsible Investment, the organization 
formally transitioned to IASJ in October 2019. 
About Sustainable  
Investments Institute (Si2)
The Sustainable Investments Institute (Si2) is a 
non-profit organization based in Washington, 
D.C. that conducts impartial research and pub-
lishes reports on organized efforts to influence 
corporate behavior on social and environmen-
tal issues. Si2 closely follows shareholder reso-
lutions proposed by investor activists, analyzing 
changing reform campaigns and identifying key 
points of contention in reports that help investors 
to make informed, independent decisions about 
their votes and views on these proposals. Si2 also 
publishes related reports for the public on select-
ed topics.
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2
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The Shifting Gears Initiative
Shifting Gears is a collective shareholder advoca-
cy initiative led by Investor Advocates for Social 
Justice (IASJ) focused on engaging companies in 
the automotive industry. It was launched in Janu-
ary 2018 by sending investor letters to 23 compa-
nies in the automotive industry, including original 
equipment manufacturers (OEMs), Tier 1 suppli-
ers, and an automotive parts retailer. It aims to:
Encourage companies to act to meet their re-
sponsibility to respect human rights, including 
throughout their operations and global supply 
chains.
Encourage increased disclosure from these com-
panies on human rights due diligence to help in-
vestors make more informed decisions.
Increase investor awareness of human rights risks 
in the automotive sector and encourage investors 
to use their leverage to support more robust hu-
man rights due diligence in the automotive sector. 
There was a 91% response rate to the 
2018 investor letter, and investors have 
had a total of 40 dialogues with 15 of the 
23 focus companies since the initiative 
was launched.
The Shifting Gears initiative is grounded in the 
investor responsibility to respect human rights, 
based in the expectations of the UN Guiding Prin-
ciples on Business and Human Rights (UNGPs) 
and the OECD Guidelines for Multinational En-
terprises. This approach involves identifying, as-
sessing, and taking action to address human rights 
risks throughout investment portfolios. On behalf 
of its investor Affiliates, IASJ initiated dialogues 
with company management on the quality and 
effectiveness of each company’s human rights 
governance, policies, and due diligence process-
es. Consistent with UNGP 15, which details the 
practical steps companies can take to meet the 
corporate responsibility to respect human rights, 
these engagements include discussions on:
•	 Human rights policy commitments at the 
highest levels of the company;
•	 Efforts to embed this commitment through-
out the business and communicate the 
company’s human rights expectations 
throughout its business relationships;
•	 Governance systems and oversight mecha-
nisms for the company’s human rights risk 
management;
•	 Assessments to identify real and potential 
adverse human rights impacts in the com-
pany’s own operations and throughout its 
business relationships, including in its val-
ue chains; 
•	 Prioritization of the company’s salient hu-
man rights issues, which are defined by the 
severity of adverse impacts to stakeholders 
and likelihood of future occurrence;
•	 Taking action based on the company’s as-
sessment and prioritization processes;
•	 Tracking outcomes of the company’s ac-
tions on human rights; and
•	 Grievance mechanisms to enable access to 
remedy for victims of adverse impacts.
IASJ conducts in-depth research and analysis on 
each focus company, its human rights risks, and 
its approach to respecting human rights to fos-
ter in-depth and constructive engagements with 
companies. By engaging with a wide range of 
automakers and suppliers based in different re-
gions, investors are able to make peer compar-
isons, better understand the business model and 
OEM-supplier relationships, and observe sec-
tor-wide trends. There is a recognition that the 
capacity and resources for companies of different 
size and location in the supply chain may vary, 
and this may influence the level of sophistication 
of their human rights due diligence. Yet, regard-
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less of size or budget, every company should re-
spect human rights. Through dialogue, investors 
gain a better understanding of each company’s 
risks and their due diligence systems as well as 
raise potential areas for improvement. Through 
the course of engagement with companies in the 
automotive industry, it became evident that there 
is a wide range of policies in place, governance 
and oversight of human rights risks, rigor in im-
plementation and assessment, and outcomes for 
rights-holders.
For the 2020 proxy season, IASJ Affiliates filed 
shareholder proposals with 5 companies to re-
quest increased disclosure on issues or areas of 
concern where each company was not sufficient-
ly addressing its human rights responsibilities and 
the issue was not being adequately covered in di-
alogue. 
Three 
of 
these 
resolutions 
have 
shareholder votes in Spring 2020, 
including resolutions on Human Rights 
Policy Implementation at General Motors 
and Human Rights Disclosure at Tesla, 
Inc. A Human Rights Impact Assessment 
at Lear Corporation received support 
from 44.76% of shareholders.  
Throughout the initiative, IASJ consults with non-
governmental organizations, relevant industry 
groups, business and human rights experts, labor 
unions, worker organizations, multi-stakeholder 
initiatives, and others to seek to align investors’ 
engagements with the needs and priorities of 
impacted stakeholders and international human 
rights standards for responsible business conduct. 
Stakeholder engagement is central to IASJ’s ap-
proach to shareholder advocacy. 
About this Report by Si2
To better assess company performance and 
deepen the investor engagement, IASJ com-
missioned the Sustainable Investments Institute 
(Si2) to further develop an assessment model on 
human rights due diligence in the automotive 
sector. This methodology is explicated at the 
end of this report on page 108. Si2 conducted 
in-depth research on 21 companies identified in 
the Shifting Gears initiative using publicly avail-
able information, as of March 2020, and trans-
lated the assessment into a numerical rating 
presented below in the “Company Assessment 
Results” section on page 12. Si2 sent all com-
panies their profiles for verification and com-
ment. Only one company replied. The results 
of Si2’s research, the bulk of this report, appear 
in the “Company Profiles” section, beginning 
on page 42. Si2 also compiled an overview of 
violations linked to the focus companies. The 
violations are considered as separate from the 
company profile and did not factor into the 
score. The research approach used in this report 
to catalog and assess where companies stand 
provides one path to identifying the extent to 
which company policies are sufficient. It ad-
dresses corporate governance structures, sup-
pliers and transparency, how human rights may 
be embedded in company operations and the 
ways in which problems may be rectified. The 
company profiles also identify participation by 
companies in multi-stakeholder initiatives, a 
mechanism for developing best practices going 
forward.
This report includes key trends across compa-
ny assessments, highlights on each company, 
a scorecard that assesses each company across 
indicators, overview of the sector and salient 
human rights risks, the investor case for engage-
ment with the automotive industry, recommen-
dations for companies. A glossary of terms and a 
list of resources for further exploration appears 
after the company profiles on page 111. An in-
dex of relevant multi-stakeholder initiatives ref-
erenced in the report is provided on page 116.
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Key Trends Across Company Assessments
While many automotive companies have established human rights policies with varying degrees of rigor, 
the sector in general provides almost no evidence these policies are being implemented. Considering the 
various scandals that have undermined automotive companies’ reliability in recent years, investors may 
be less inclined to trust that policy implementation is as rigorous as companies’ aspirational disclosures 
suggest. 
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Si2
Governance and management systems for hu-
man rights is the weakest area for all com-
panies. Only 3 companies (BMW, Ford, and 
VW) have at least limited disclosure of their 
human rights governance and management 
systems.
There is a lack of board oversight of human 
rights. Only 2 companies have a board mem-
ber with human rights expertise (VW, Con-
tinental), while only Ford references human 
rights in a board committee charter (Sustain-
ability and Innovation Committee).
The second-weakest scores overall occur in 
the area of embedding respect for human 
rights across the business.
10 companies conduct some auditing with hu-
man rights criteria, the strongest being BMW, 
Ford, Groupe PSA, and VW. Only Groupe 
PSA discloses the percentage of supplier base 
that is audited, albeit a small percentage. 
Only 3 companies provide partial disclosure 
about percentage audited. BMW, Ford, and 
Groupe PSA provide information about reme-
dial action to address issues identified in the 
audit. All companies conduct announced au-
dits, rather than unannounced. 
Board level oversight of human 
rights is generally lacking, with  
no evidence. 
While a few companies in the research uni-
verse indicate they have a board member 
with human rights qualifications, they failed 
to substantiate this. The sustainability com-
mittees referenced did not describe how they 
address human rights. Companies generally 
pointed to enterprise risk management with-
out any specific mention of human rights.
Companies provide almost no 
evidence of implementation. 
While some companies have robust human 
rights policies in place, there is little evidence 
these are being implemented across the re-
search universe. For instance, few provide 
detailed disclosure on supplier audits and 
their results. Still fewer disclose clear, specific 
details of remedial action they have taken to 
remedy human rights problems uncovered in 
their supply chains. This report illustrates that 
automotive sector companies are highly likely 
to be exposed to such problems, and yet a de-
tailed and meaningful accounting of remedial 
action is hard to find among them. To demon-
strate genuine results, reporting will have to 
become more explicit and specific. 
- IASJ
- IASJ

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Si2
The highest-scoring human rights policies be-
long to European companies: BASF, BMW, 
Volkswagen, and Groupe PSA. As of the time 
of the writing, 4 companies had no compre-
hensive human rights policy, (PPG, Genuine 
Parts, Honda, and Tesla) while 1 company 
had a very weak “policy” (Goodyear). 2 com-
panies had statements, that do not amount to 
a full policy and do not meet all the criteria 
assessed (Lear and Denso). 
5 companies commit to respect international 
human rights standards (BASF, BMW, Groupe 
PSA, VW, and Renault), while 5 do not refer-
ence international standards at all (Goodyear, 
Tesla, PPG, Genuine Parts, Honda), and the 
remainder have a reference to international 
standards, but it appears non-binding (i.e. the 
companies will consider, are informed by, or 
strive to). 
In identifying human rights risks, Ford stands 
out as the only automotive company that has 
conducted a human rights saliency assess-
ment to identify its human rights priorities. 14 
of the companies include no information on 
their processes to identify human rights risks; 
while assessment and prioritization of human 
rights is even weaker, with 17 companies pro-
viding no information.
Companies continue to 
largely avoid binding or clear 
commitments about human rights 
in their value chains.  
As a general rule, the companies in the re-
search universe engage in verbal gymnastics 
when it comes to their human rights com-
mitments, particularly when referencing in-
ternational frameworks or conventions. The 
Corporate Human Rights Benchmark address-
es this problem in its discussion on the word-
ing of policy commitments, aptly noting that 
researchers should look for an explicit com-
mitment instead of vague or weak wording. 
Companies in this research universe tended 
toward the latter, and often used language that 
was internally inconsistent from one public 
disclosure to the next. In many cases, sifting 
through scores and even hundreds of pages 
of corporate jargon showed that a company’s 
approach boiled down to achieving the bare 
minimum of legal compliance. 
Company policies are almost 
entirely reactionary.  
There is very little evidence in the research 
universe of strategy development that begins 
with a risk assessment and analysis of salient 
and material human rights issues. Across the 
board, the companies evaluated in this report 
appear to have developed what policies they 
have in place in response to negative media 
reports that posed reputational risks. This rais-
es the possibility that human rights problems 
that have not yet attracted media attention 
may be going unaddressed.
- IASJ
- IASJ

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1 Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly traded companies to 
report annually on the presence of conflict minerals (such as tin, tungsten, tantalum and gold) originating in the Democratic 
Republic of the Condo or adjoining countries in the products the companies manufacture or contract to manufacture if the 
conflict minerals are necessary to the functionality or production of a product.
Existing reporting under these legal frame-
works provides a preliminary model for 
broader reporting. Some companies in the 
research universe have acknowledged this, 
and are beginning to apply their conflict min-
erals framework to other parts of their supply 
chains, particularly cobalt. Specifically, some 
companies are conducting detailed mapping 
of their cobalt supply chains, and some are 
disclosing their cobalt smelters. While every 
supply chain is different and presents unique 
challenges, this still provides a proof of con-
cept. It is possible to pursue greater supply 
chain visibility and to report publicly on it.
Noting the many tiers in the supply chain, 
cascading expectations is especially import-
ant to ensure implementation to the areas of 
greatest risk. However, only VW requires it, 
while 6 companies encourage it and 14 com-
panies have no requirement for cascading to 
sub-tier suppliers.
Legal requirements provide a 
glimpse of the possible.  
Required reporting by companies operating 
in the United States about conflict minerals 
exposure1, put in place by the Dodd-Frank 
Act, demonstrates what companies can do 
when pressed. Further examples appear in re-
porting requirements under the UK Modern 
Slavery Act and the California Transparency 
in Supply Chains Act. Furthermore, the Euro-
pean Union is slated to enact a conflict min-
erals rule in 2020. (The Glossary of Terms and 
Resource List, p. 111, provides details about 
these regulations.)
Supplier monitoring  
has missing teeth.   
Few companies appear to have a robust 
mechanism for dealing with human rights vi-
olations in their supply chain. Most “reserve 
the right” to terminate a supplier relationship, 
but no company in the research universe in-
dicates that it has actually ended supplier 
relationships over human rights violations; 
none report any significant penalties or strong 
remedial requirements. Thus, while there is 
ample evidence that the sector at large is ex-
posed to significant human rights violations, 
not a single company provides clear acknowl-
edgment that it has found and rooted out such 
problems within its own supply chain. 
- IASJ

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9 companies have a grievance hotline avail-
able, but there is only limited information 
about access to remedy at any of the compa-
nies. 6 companies (Tesla, PPG, Genuine Parts, 
Nissan, Honda, Denso) have no information 
about grievance mechanisms or remedy. 
Grievance mechanisms are limited.   
Most companies in the research universe 
have limited grievance mechanisms for hu-
man rights violations. While many appear to 
have no mechanism at all, Tesla highlights the 
deficits even more than those companies that 
disclose nothing. By instructing a nebulous 
“you” to write a letter to its corporate sec-
retary in the case of human rights concerns, 
the company lays bare the inadequacy of the 
broader sector’s reporting. Available evidence 
shows most firms have hotlines but not how 
grievances are addressed after calls come in. 
Notable exceptions are VW’s ombudspersons 
and Continental’s reporting of actual prob-
lems uncovered and subsequent remediation 
efforts. 
- IASJ

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1.8
1.9
1.9
2.2
2.2
2.2
2.2
2.3
2.3
2.3
2.4
2.5
2.5
2.6
2.6
2.6
2.6
2.7
2.7
2.8
2.9
Si2 compiled available evidence for each of the indicators set forth in the assessment method-
ology at the end of this report, then translated the qualitative findings into a numerical assess-
ment that ranged from 1 (strongest) to 3 (weakest) for each point. The results are summarized 
below, showing that three companies—BMW, Ford Motor and VW—stand out in their overall 
performance, with two companies—Denso and Honda—having the weakest showing. 
C O M PA N Y  A S S E S S M E N T  R E S U LT S

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Overall
Policy
Governance
Supplier 
Code
BMW
1.848
1.17
2.43
2.50
Ford
1.945
1.79
2.29
3.00
Volkswagen Group
1.999
1.36
2.43
1.00
BASF
2.205
1.33
3.00
2.50
Bridgestone
2.251
1.64
2.57
2.00
Groupe PSA 
2.269
1.36
2.86
1.50
Continental
2.293
1.88
2.57
2.00
General Motors
2.309
1.83
2.71
2.00
Goodyear 
2.382
2.40
3.00
2.00
Renault
2.390
1.52
2.86
2.50
Fiat Chrysler Automobile
2.430
1.86
3.00
3.00
Axalta Coating Systems
2.579
1.79
3.00
2.50
Toyota
2.579
1.93
2.86
2.50
Nucor
2.600
1.64
2.86
2.50
Tesla
2.603
2.57
3.00
2.50
PPG 
2.627
2.79
3.00
2.50
Lear Corporation
2.649
2.13
2.86
2.50
Genuine Parts Company
2.747
2.57
3.00
2.00
Nissan
2.748
1.98
3.00
2.50
Honda
2.783
2.51
3.00
3.00
Denso Corporation
2.906
2.12
3.00
3.00
1
2
3
C O M PA N Y  A S S E S S M E N T  R E S U LT S

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Traceability/ 
Supply chain 
Due Diligence
Remedies & 
Grievances
Multi- 
stakeholder 
Initiatives
BMW
2.00
1.96
2
1
Ford
1.75
1.96
2
1
Volkswagen Group
2.00
2.40
2
2
BASF
2.50
2.24
2
2
Bridgestone
2.25
2.60
2
2
Groupe PSA 
3.00
2.16
2
3
Continental
2.75
2.66
1
2
General Motors
2.25
2.68
2
2
Goodyear 
2.25
2.64
2
2
Renault
2.50
2.84
2
2
Fiat Chrysler Automobile
2.50
2.48
2
2
Axalta Coating Systems
3.00
3.00
2
2
Toyota
3.00
3.00
2
2
Nucor
2.75
3.00
2
3
Tesla
2.50
2.82
3
2
PPG 
2.75
2.66
3
2
Lear Corporation
2.75
3.00
2
3
Genuine Parts Company
2.75
2.80
3
3
Nissan
2.75
3.00
3
3
Honda
2.75
2.94
3
2
Denso Corporation
3.00
2.98
3
3
4
5
7
6
C O M PA N Y  A S S E S S M E N T  R E S U LT S

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C O M PA N Y  A S S E S S M E N T  R E S U LT S
OEMS vs.  
Suppliers
O E M S 
A V E R A G E  
O V E R A L L  
S C O R E
 2.35
S U P P L I E R S 
A V E R A G E  
O V E R A L L  
S C O R E
 2.50
Areas of Greatest Weakness
R E P O R T I N G
(indicator 5e)
H U M A N  R I G H T S 
C O M P E T E N C Y
(indicator 2f)
All companies assessed scored a 3 (lowest possible score) on the following elements:
Average Scores
3.00
2.50
2.00
1.50
1.00
Overall
1
2
3
4
5
6
7
1. Policy    2. Governance    3. Supplier Code    4. Traceability/Supply Chain   
5. Due Diligence    6. Remedies & Grievances    7. Multi-stakeholder Initiatives
Regional Average Scores on Relevant Themes & Indicators
Overall
A
B
C
D
E
A. HR Policy: Theme Score 1    B. Traceability: Theme Score 4    C. HRDD: Theme Score 5     
D. Traceability/Responsible Sourcing Commitment/Disclosure: Indicator 4a     
E. Human Rights Expectations Past 1st Tier: Indicator 5cvi
3.00
2.50
2.00
1.50
1.00
U.S.
Europe
Japan
1.91
2.82
2.36
2.56
2.66
2.24
2.19
2.44

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K E Y  P O I N T S  F R O M  C O M PA N Y  P R O F I L E S
Detailed company profiles are below on page 42. Some highlights for each company in the research uni-
verse are provided below. 
Axalta provides limited human rights 
disclosures and does not appear to 
have robust procedures in place to 
address human rights risks. The company does not 
have mandatory processes in place for suppliers 
and lacks significant monitoring and enforcement 
mechanisms for its suppliers. Its approach to hu-
man rights issues is generally tepid and indistinct.
BASF has a relatively robust human 
rights policy with strong alignment 
with international standards, al-
though its provisions for cascading are weak and 
ill-defined. The company does not require suppli-
ers to respond to questionnaire “requests,” and 
lacks teeth in its auditing language. BASF’s hu-
man rights requirements are generally vague and 
unenforceable. The company lacks any clear ef-
forts at the deep supply chain level.
Human rights is embedded in BMW’s 
company-wide compliance system 
and, to some extent, governance 
structures. The company conducted a detailed 
human rights risk assessment across its operations 
in 2017 and leads its peers in this regard. BMW 
provides broader disclosure than most of specif-
ic raw material risks, and it publishes its cobalt 
smelters and countries of origin. It also has rela-
tively strong requirements for cascading human 
rights down the value chain and is the only com-
pany in the research universe actively seeking to 
shorten one of its supply chains for the purposes 
of human rights compliance. Nevertheless, BMW 
still lacks detailed, systematic disclosure around 
human rights policy implementation.
Bridgestone is taking important ini-
tial steps toward more thorough 
management of human rights issues 
in its supply chain, but the company still has a 
long way to go. Bridgestone has recently pro-
mulgated a sustainable procurement policy and 
is starting to deal with human rights challenges 
in its natural rubber supply chain. The company 
has established some specific functions within 
its corporate structure that have explicit human 
rights responsibilities, which is a measure of gov-
ernance embedding that many of its peers have 
yet to undertake. Nevertheless, its communica-
tion is murky and internally inconsistent, and like 
so many of its peers, Bridgestone furnishes no 
evidence of implementation of any of its human 
rights policies.
Continental has a stronger approach 
than many of its peers to its natu-
ral rubber supply chain, but it does 
not translate this approach to other parts of its 
business. The company seems to have no audit 
structure in place, relying almost entirely on sup-
plier self-assessments. There is no evidence of 
high-level human rights risk assessment, mitiga-
tion and implementation. However, Continental 
provides more disclosure than most of its peers 
on the remedial action it has taken in response 
to grievances it receives through its established 
channels.
Si2

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Denso provides some of the most 
limited human rights disclosure in 
this research universe. Its so-called 
human rights policy is not actually about human 
rights. In general, the company offers only a se-
ries of statements of principle, with nothing sub-
stantive.
FCA’s policies that deal with human 
rights topics are weakly defined, and 
its expectations of suppliers are un-
clear. The company offers no explicit evidence of 
the implementation of its human rights policies.
Ford provides strong disclosure of 
supplier audit findings and remedi-
al action compared to others in the 
research universe, though the company still is 
not as detailed in its reporting as would be ideal. 
Noting that companies demonstrate through le-
gal compliance mechanisms (Dodd-Frank, MSA, 
etc.) that they are capable of more robust disclo-
sure and practices around human rights, Ford’s 
initial foray into including cobalt within its con-
flict minerals framework appears significant. Ford 
is unique in having a board committee specifi-
cally charged with managing human rights. The 
company also has stronger policies than most on 
ethical recruitment, although it lacks evidence of 
deep implementation. Ford also discloses more 
thorough policies and practices on high-risk in-
puts than most of the research universe, although 
evidence of implementation remains lacking.
While the companies in this research 
universe generally tend toward un-
clear wording and semantic gymnas-
tics, GM stands apart for its unnecessarily vague 
human rights policy. It appears almost intention-
ally constructed to avoid anything that might be 
construed as a commitment. The company’s child 
labor policy is also notably weak. Despite being 
exposed to a mica supply chain that uses child 
labor, the company does not directly address that 
supply chain in its public disclosures. Indeed, its 
reporting on child labor in general is thin. Like 
Ford, GM is expanding its conflict minerals prac-
tices to cobalt. This appears to be a step in the 
right direction, although evidence of implemen-
tation will be required to evaluate the efficacy of 
such efforts. GM has also taken fewer steps than 
other companies in this research universe that 
were similarly implicated in human rights viola-
tions in the cobalt supply chain.
GPC reports almost nothing pertain-
ing to human rights issues. Its sole 
relevant public disclosure is that 
it uses SA8000 audits, but the details are scant. 
GPC has a supplier code of conduct that prohib-
its child and forced labor and includes several 
additional provisions related to human rights, but 
the company does not publish this document. It 
is ostensibly available to anyone who completes 
a web form requesting it, but the process did not 
work when Si2 used it.
Goodyear makes a strong and specif-
ic traceability commitment, but the 
commitment is incomplete, omitting 
half of its raw material inputs. The company’s re-
cently introduced natural rubber sourcing poli-
cy is a significant step, but it lacks provisions for 
monitoring implementation, supplier transparen-
cy, penalties for non-compliance and details on 
labor rights protections.
Groupe PSA’s policies are more ro-
bust than most of the companies in 
this research universe, with in-line 
references to relevant International Labour Orga-
nization (ILO) conventions. PSA outperforms most 
of its peers on labor rights, having developed its 
human rights policy in partnership with interna-
tional trade unions. The company provides com-
paratively strong disclosure related to supplier 
audits and remedial action, though its reporting 
still lacks detail on specific issues. PSA is further 
along in engaging the full value chain than most 
of its peers, though not yet at an optimum. The 
company is weak on traceability, requiring sup-
pliers to “be transparent” without going further in 
its public disclosures. Furthermore, like the en-
tire sector, PSA provides limited evidence of the 
K E Y  P O I N T S  F R O M  C O M PA N Y  P R O F I L E S
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implementation of its human rights policies and 
procedures.
Honda’s human rights approach lags 
significantly behind its peers. The 
company discloses almost no poli-
cies or practices to address human rights issues, 
and what disclosure it does offer is presented only 
in the most general terms. Its entire human rights 
approach is aspirational, lacking any substance. 
Importantly, Honda does not actually prohibit its 
suppliers from using child labor, requiring only 
that they comply with applicable laws.
Lear discloses very little activi-
ty around human rights issues and 
makes vague statements that are al-
most entirely aspirational. The company has no 
child labor prohibition beyond legal compliance. 
It offers a more detailed smelter disclosure in its 
conflict minerals reporting than most, although 
that disclosure only covers data, not remedies. 
Lear publishes its purchase order terms and con-
ditions, where many of its peers do not. The com-
pany claims supply chain management among 
its core strengths in its business proposition, 
yet it highlights supply chain complexity in its 
non-committal language around conflict miner-
als.
Nissan’s human rights disclosure 
is sparse and entirely aspirational. 
The company provides no evidence 
whatsoever of implementation. Further, it re-
quires suppliers to self-report human rights vio-
lations, with no apparent penalty for failure to do 
so. Nissan collaborates with Renault on sustain-
able purchasing but provides no evidence of im-
plementation.
Nucor has a useful, targeted policy 
and disclosure around Brazilian pig 
iron. The company recently pub-
lished a human rights policy that covers a num-
ber of key issues. Evidence of implementation 
remains non-existent. 
PPG has no human rights policy. Its 
Supplier Code of Conduct covers 
most top-line issues, but the com-
pany provides no evidence of implementation. 
Apart from a few “assessments” and “evalua-
tions” of key suppliers, PPG requires suppliers to 
self-report violations. PPG discloses some efforts 
to deal with human rights challenges in its mica 
supply chain, although the company is behind 
on its own commitments. While there are indi-
cations of some movement to improve policies 
and practices around forced labor, disclosures 
are largely aspirational.
Renault conducted a full cobalt sup-
ply chain mapping and published EV 
battery suppliers and cobalt coun-
tries of origin, which is more than many of its 
peers have done. This indicates a strengthening 
approach to cobalt and 3TGs, although the com-
pany still provides limited evidence of implemen-
tation. Renault discloses very little in the way of 
broader human rights due diligence.
Tesla discloses little information re-
lated to human rights. The compa-
ny makes no baseline human rights 
commitment, its policies are largely focused on 
compliance and thinly articulated, and it provides 
almost no evidence of implementation. Tesla has 
some notable initiatives around cobalt, both in 
reducing its dependence thereon and in auditing 
well down the supply chain, though details re-
main in short supply. The company’s “grievance 
mechanism” for human rights concerns is espe-
cially anemic.
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Toyota provides rather perfuncto-
ry reporting on conflict minerals, 
especially given its size. Its overall 
human rights reporting appears entirely geared 
toward Dodd-Frank compliance and is presented 
in vague and general terms with zero evidence 
of implementation. The company fails to report 
at all on other areas of risk, such as lithium and 
graphite, even though it has recently been public-
ly implicated in human rights violations in those 
supply chains.
VW has one of the most robust sup-
plier codes of conduct in this research 
universe. It goes into significant de-
tail and includes relatively strong cascading re-
quirements. The company discloses relatively 
solid overall due diligence and risk management 
systems for sustainability issues, although it still 
offers limited detail as to how those play out spe-
cifically in the realm of human rights. Important-
ly, it offers limited evidence of implementation. 
For a company that recently weathered a major 
scandal over widespread false reporting of vehi-
cle emissions, a higher evidentiary standard at-
taches. 
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The Automotive Industry Business Model Exacerbates to Human Rights Risks 
There are significant human rights risks in the automotive industry throughout its operations and value 
chain. Workers in manufacturing facilities may experience threats to their rights to a healthy and safe work-
ing environment, freedom of association and collective bargaining, freedom from harassment, discrimina-
tion, and retaliation. Workers in the supply chain who extract, harvest, and process the commodities used 
to manufacture vehicles are at risk of being subjected to forced labor, child labor, and hazardous working 
conditions, while also experiencing many of the same labor rights abuses that occur in manufacturing. 
Human rights standards include the International Bill of Human Rights (Universal Declaration of Human 
Rights, International Covenant on Economic, Social and Cultural Rights, and International Covenant on 
Civil and Political Rights) the ILO’s Declaration on Fundamental Principles and Rights at Work, and the 
UN Guiding Principles on Business and Human Rights. Human rights encompass universal and inalien-
able rights which are inherent to all people, without discrimination.
O V E R V I E W  O F  H U M A N  R I G H T S  R I S K S  
I N  T H E  A U T O M O T I V E  I N D U S T R Y
Conflict Minerals: Up to 50% of car parts contain tin, tantalum, tungsten, and/or gold (3TG),  
which may finance and fuel conflict if sourced from certain regions of the DRC.
Sources: https://iasj.org/shifting-gears-infographic-sources
Auto Industry Has High Impact & Leverage on Human Rights 
Rubber, which may be produced with 
forced and child labor in Southeast Asia 
and Liberia, is used to produce tires.
Cobalt, used in lithium-ion batteries, may 
be sourced from mines in the DRC where 
child labor is prevalent.
Cattle raising is associated with risks of 
forced and child labor, and leather tan-
ning also relies on child labor.
Electronics manufacturing is linked to 
forced labor in China and Malaysia and 
child labor in China. 
From metallic paints to brakes, car parts 
may contain mica mined by children in 
India and Madagascar.
Charcoal and iron ore, components of pig 
iron used to make steel, are associated 
with risks of forced and child labor.

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M I C A  M I N E S
I N T E R M E D I A R I E S
P I G M E N T  
S U P P L I E R S
PA I N T S  &  
C O AT I N G S  
S U P P L I E R S
A U T O 
M A K E R S
The business model of the industry includes ex-
pansive, global supply chains, which make it 
more challenging to effectively identify and ad-
dress these risks. Automotive companies source 
metals, minerals, and other inputs from suppliers 
from all over the world in order to produce the 
estimated 30,000 parts that make up an aver-
age vehicle. These supply chains are very exten-
sive, with some companies indicating they have 
12,000 – 18,000 global suppliers, while others 
disclose 1,200 Tier 1 suppliers alone. This makes 
close oversight of the supply chain burdensome, 
or for some, nearly impossible. Each commodity 
has a distinct supply chain with different num-
bers of steps from raw material through refining 
and production, different purchasing structures or 
choke points, and varied on the ground contexts. 
This makes a one-size-fits all approach impossi-
ble. Several high-value and critical raw materials 
can be sourced only from very limited geograph-
ical regions. These may include resource-rich 
countries that face corruption, conflict, and weak 
rule of law, including inadequate enforcement of 
labor laws. 
Many of the automotive industry’s most salient 
risks, defined by severity, likelihood of future oc-
currence, and negative impacts to people, arise 
at the raw material and commodity level. When a 
company is determining its prioritization of risks, 
even if the human rights impact is linked to only 
a small portion of the company’s business or pro-
curement spend, the severity of the harm should 
determine the company’s approach to mitigating 
the potential impact rather than the relevance to 
the business. 
Through purchasing agreements and contractual 
relationships, Original Equipment Manufacturers 
(OEMs), which are at the top of the supply chain, 
may limit their liability or create intermediaries. 
All of these business practices compromise the 
ability to achieve transparency, traceability, and 
accountability. Oftentimes, automakers have di-
rect contractual relationships with Tier 1 suppliers 
that supply automobile parts such as steel or tires. 
Tier 1 suppliers have contracts with Tier 2 suppli-
ers supply components of those parts to the Tier 
1s. There are not direct purchasing relationships 
between OEMs and deeper tiers of the automo-
tive supply chain, and automakers have limited 
operational control of suppliers beyond Tier 1 
and Tier 2. Moving down the supply chain, Tier 3 
to Tier “n” suppliers, which may go any number 
of further layers, source, refine, process, and sell 
raw materials. At each stage, ideally, a supplier 
would convey their expectations (e.g. on quality, 
price, and human rights) through their contract, 
to their sub-supplier, and establish a mechanism 
to oversee these expectations. In practice, it is not 
clear how this is carried out or whether it is done 
consistently and effectively. This makes it diffi-
cult to effectively influence or monitor suppliers’ 
compliance with international human rights stan-
dards, local labor laws, disclosure requirements 
O V E R V I E W  O F  H U M A N  R I G H T S  R I S K S
Mica Supply Chain

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under Section 1502 of the U.S. Dodd-Frank Act, 
and companies’ own human rights policies and 
supplier codes of conduct. Meanwhile, an OEM 
is linked to each of these entities through the 
business relationship, and therefore has a respon-
sibility to conduct appropriate human rights due 
diligence at different tiers based on whether the 
company directly caused, contributed to, or is 
otherwise linked to an adverse human rights im-
pact in the supply chain. Due to the difference in 
size suppliers may have less capacity and more 
informal processes, but the responsibility to re-
spect human rights applies to OEMs and suppli-
ers, regardless of size, sector, or structure. 
An OEM and its suppliers should prevent caus-
ing or contributing to adverse human rights im-
pacts and contribute to mitigation when adverse 
impacts occur. When human rights harms occur 
deeper in the supply chain and multiple com-
panies may be contributing to or directly linked 
through sourcing relationships, according to the 
UNGPs, companies are still considered to be di-
rectly linked to these impacts. In such cases, the 
level of a company’s contribution or linkage to the 
harm may depend on several factors: (1) the ex-
tent to which the company enabled, encouraged 
or motivated the harm; (2) the extent to which it 
could or should have known about the harm and 
(3) the quality of its steps to mitigate the harm. 
Companies should seek to prevent or mitigate the 
harm, and are expected to use leverage, whether 
alone or with others, to mitigate the harm, and in 
some cases, provide remedy. 
The structure of the value chain in the automo-
tive industry business model exacerbates these 
risks. Supply chain and sourcing relationships 
are not transparent, in part due to intense com-
petition for suppliers and business relationships, 
and some companies indicate they do not know 
their full supply chain. This is a significant risk 
not only related to human rights impacts, but also 
for maintaining business continuity and quality 
control. The value chain relies on complex glob-
al sourcing networks to procure the wide range 
of materials required for automobile produc-
tion, and the scale and scope of the supply chain 
makes comprehensive supplier monitoring nearly 
impossible, and serious violations may fall under 
the radar and continue to occur. Automakers take 
quality and consumer safety seriously and are re-
quired to have systems to ensure vehicle safety 
compliance. Yet these same assurance practices 
are not deployed to assess and address human 
rights and labor practices.
In the absence of meaningful financial incentives 
to reward companies for responsible business 
practices, the majority of companies in the auto-
motive sector have deprioritized efforts to create 
the necessary business environment to identify, 
monitor, and address human rights risks in their 
raw materials supply chains. Coupled with the 
regulatory and legal challenges to holding com-
panies accountable for human rights violations, 
there appears to be a lack of control and effective 
mitigation for human rights impacts associated 
with business activities in the sector. 
O V E R V I E W  O F  H U M A N  R I G H T S  R I S K S
“Automotive supply chains are highly 
complex and reliant on a range of materials 
that may be produced with forced labor. 
Workers in lower tiers of automotive 
supply chains are particularly at risk. 
The COVID-19 crisis magnifies these 
risks: It has significant negative impact 
for workers in global supply chains, such 
as lack of sick leave, reduced hours and 
wages, or job loss, thus exacerbating 
vulnerability to exploitation.” 
Felicitas Weber, KnowTheChain Project Lead, 
Business & Human Rights Resource Centre, 
2020

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No 
companies 
disclosed 
linkage 
between incentives or compensation to 
human rights performance. BMW links 
incentives to sustainability, but it lacks 
specificity on the proportion of this that 
is related to human rights. 
Materiality of Human-Rights Related 
Risks in the Automotive Sector
While saliency looks at the most severe impacts 
to rightsholders, investors must also analyze 
those risks that pose the greatest financial risks to 
companies. There is often convergence between 
the human rights risks in the sector and the risks 
to the business. 
The Sustainability Accounting Standards Board 
(SASB) is a nonprofit organization that sets fi-
nancial reporting standards to help companies 
“identify, manage and communicate financial-
ly-material sustainability information to their 
investors.” In November 2018 SASB published 
77 industry-specific standards which provide 
a “minimum set of industry-specific disclosure 
topics reasonably likely to constitute material 
information”, including “how management or 
mismanagement of each topic may affect value 
creation.” To measure a company’s performance 
for each topic, SASB provides a “set of quantita-
tive and/or qualitative accounting metrics.” SASB 
is supported by an Investor Advisory Group with 
membership from global asset owners and asset 
managers. 
SASB identifies “labor practices” and “materials 
sourcing”, among other factors including “prod-
uct quality and safety” as financially material for 
automotive OEMs and “materials sourcing” as a 
financially material for auto parts manufacturers. 
Labor practices encompasses a company’s ability 
to uphold fundamental labor rights by complying 
with labor laws and international standards, in-
cluding the prohibition of child labor and forced 
labor, compliance with wage and hour laws, and 
the company’s relationship with organized labor, 
among other issues. SASB points out that due to 
the global nature of the automotive supply chain, 
companies may operate in countries with weak 
labor protections, and that if companies fail to 
effectively manage labor rights risks, including 
issues related to worker pay and health and safe-
ty, labor strikes may result, which can disrupt 
operations and have negative financial impacts. 
Adopting measures to strengthen protections for 
workers is an investment in a company’s long-
term financial sustainability by enhancing worker 
productivity. Materials sourcing poses financially 
material risks for automakers as rare earth metals 
and minerals are required for automobile produc-
tion, and these materials are often sourced from 
limited geographies, often from countries “sub-
ject to geopolitical uncertainty.” Companies can 
reduce their exposure to materials sourcing-relat-
ed risks by innovating ways to limit the use of 
these materials or use alternatives and develop-
ing more direct sourcing relationships.
O V E R V I E W  O F  H U M A N  R I G H T S  R I S K S

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Each company should be able to identify where 
it is sourcing its raw materials and whether they 
are sourced, produced, or manufactured under 
conditions that violate human rights. There are 
several salient human rights impacts in the sec-
tor, which occur in both the supply chain and in 
operations. 
Child Labor
Several commodities used in the production of 
automotive parts have well-documented cases of 
being mined, harvested, extracted, or processed 
by children. In many instances, children are car-
rying out hazardous work that puts their health 
and safety at risk, amounting to the worst forms 
of child labor as defined by the ILO. According to 
the ILO, 152 million children worldwide are vic-
tims of child labor, 73 million of these children 
work in hazardous conditions, and 19 million 
of the children working in hazardous conditions 
are under age 12. Hazardous work carried out by 
children in the raw material supply chains for the 
automotive industry includes work underground 
or in confined spaces, work with dangerous 
equipment and tools, handling of heavy loads, 
S A L I E N T  H U M A N  R I G H T S  I S S U E S  
F O R  T H E  A U T O M O T I V E  S E C T O R
Sources: https://iasj.org/shifting-gears-infographic-sources
Mapping Child Labor Risks in the Global Automotive Industry
Cattle ranching in Brazil, Chad, Costa 
Rica, Ethiopia, Lesotho, Mauritania, 
Namibia, South Sudan, Uganda, 
and Zambia, and leather tanning in 
Bangladesh, Pakistan and Vietnam
Mica mining in 
India and  
Madagascar  
(used in paints, 
coatings, brakes, 
and other parts)
Electronics 
manufacturing  
in China
Cobalt mined in the Democratic 
Republic of Congo (used in lithium-
ion batteries for electric vehicles)
Mining of conflict 
minerals (tin, 
tantalum, tungsten, 
and gold) in 
the Democratic 
Republic of Congo, 
and tin in Bolivia 
(minerals used in 
up to 50% of auto 
parts)
   Rubber tapping in 
Burma, Cambodia, 
Indonesia, Liberia, 
the Philippines  
and Vietnam  
(used in tires)
Charcoal 
production in Brazil  
and Uganda  
(input of pig iron)

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exposure to hazardous substances, and work for 
long hours. Child labor often occurs when adult 
workers are unable to meet their quotas or earn 
enough income to cover the household’s basic 
needs. While minimum working age varies across 
countries, child labor is recognized as an illegal 
practice under international human rights law. 
However, in countries with weak rule of law, cor-
ruption, or other factors preventing the enforce-
ment of labor laws, child labor persists. Until 
adult workers are paid a living wage to address 
the root cause of child labor, systemic poverty, 
children will continue to be denied an education 
and a healthy and safe childhood.
Roughly 60% of cobalt, a mineral used in electric 
vehicle batteries, is sourced from the Democratic 
Republic of Congo (DRC), where child labor is 
widespread in the mines. UNICEF estimates that 
there are 40,000 children working in the DRC’s 
cobalt mines. Children work in hand-dug tunnels 
at risk of collapse without any safety equipment to 
extract the cobalt, leading to life altering injuries 
and even death. The projected growth of electric 
vehicle adoption is a source for disruption in the 
automotive industry. Environmental benefits of 
electrification are clear. However, in addition to 
concerns about adequate supply, there are seri-
ous negative social impacts linked to the inputs 
for EV battery materials, such as child labor in 
cobalt mining in the DRC. Tesla is among five 
companies facing a class action lawsuit filed on 
behalf of 14 children and parents from the DRC, 
which includes allegations of “aiding and abet-
ting in the death and serious injury of children 
who claim they were working in cobalt mines in 
their supply chain.” 
Mica used in up to 15,000 different automo-
tive parts, including paints and coatings, brakes, 
and other components, may be produced under 
conditions of child labor if sourced from India 
or Madagascar. Children as young as five begin 
working in the mines sorting sharp mica chips 
outside the mines and move onto more danger-
ous work to extract mica chips as they get old-
er. In India, where an estimated 22,000 children 
S A L I E N T  H U M A N  R I G H T S  I S S U E S
“The relationship between development, 
environmental, and social justice can 
only be as integrally defined as much 
as it is naturally predetermined. Any 
kind of development that seeks to thrive 
disregarding such a basic natural order 
can never be described as sustainable, 
and only stands the test of time”. 
Sister Catherine Mutindi, RGS Founder, Bon 
Pasteur Kolwezi (DRC), April 2020 
“A 
million 
children 
are 
exploited 
in small-scale mining, with tens of 
thousands in the mica supply chain. 
Mica is in the products we use every day: 
in paints, in cosmetics, phones, laptops, 
household appliances and cars. It is the 
responsibility of companies and investors 
to do everything possible to ensure value 
chains are free of child labour and other 
forms of child exploitation. Companies 
can improve children’s lives by 1) doing 
their due diligence as outlined in the 
UN Guiding Principles on Business and 
Human Rights, meaning that companies 
make an effort to screen their whole 
supply, upstream and downstream, 
2) committing to social investment 
and getting to know the reality on the 
ground, 3) actively participating in multi-
stakeholder coalitions for action such as 
the Responsible Mica Initiative, not only 
financially but especially in content.”
Terre des Hommes Netherlands, 2020

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work in mica mines in Jharkhand and Bihar, 
much of the mining occurs at illegal artisanal 
mines where labor laws are not enforced. The In-
dian government is moving to legalize the mines 
to curb child labor, however the practice is still 
widespread. In Madagascar, an estimated 11,000 
children are working in mica mines, and at least 
50% of the country’s mica is mined by minors. 
Child labor is prevalent in many other commod-
ities used in the sector. Tin, tantalum, tungsten, 
and gold (3TG) mined in the DRC may be mined 
by children, in addition to fueling violence and 
conflict. In Bolivia, an estimated 3,000 children 
as young as six work in tin mines. Natural rubber 
used in car tires may be produced with child la-
bor in Burma, Cambodia, Indonesia, Liberia, the 
Philippines, and Vietnam. Rubber tapping is very 
labor intensive and requires the use of sharp tools 
and exposure to pesticides, which poses serious 
health risks to children. Exploitation of student 
workers has been reported in electronics facto-
ries in China, often linked to abuses in vocational 
school programs that require working excessive 
hours in factories. Children herding cattle in Bra-
zil, Chad, Costa Rica, Ethiopia, Lesotho, Maurita-
nia, Namibia, South Sudan, Uganda, and Zambia, 
and tanning leather in Bangladesh, Pakistan and 
Vietnam, are often subject to hazardous working 
conditions as well.
Forced Labor
As with child labor, forced labor risks are pres-
ent in the automotive supply chain because many 
critical raw materials are sourced from geogra-
phies where underlying political factors, systemic 
poverty, and other forces contribute to the per-
sistence of this illegal practice. Forced labor, also 
known as modern slavery, can take many forms. 
Employers often use coercive practices, such as 
threats of violence or withholding of wages, to 
prevent workers from escaping from conditions 
of forced labor. Debt bondage occurs when an 
individual is forced to work to pay back a per-
sonal debt. Workers may also be physically iso-
lated in a rural area and rely on their employer to 
provide housing and other basic needs, leaving 
workers completely dependent on the employer. 
Forced labor impacts men and women, adults 
and children.
An investigation by the Australian Strategic Policy 
Institute found that major automakers are among 
the companies sourcing from factories in the Xin-
jiang Uighur Autonomous Region (XUAR), where 
Uyghurs and other Muslim minorities are being 
subjected to forced labor by the Chinese govern-
ment. Uyghurs are trapped in government-spon-
sored work assignments that are difficult to escape 
due to surveillance and fear of further detention, 
as these work placements are part of a larger gov-
ernment-sanctioned “re-education” scheme. In 
reality, this is a system of detention camps and 
S A L I E N T  H U M A N  R I G H T S  I S S U E S
“The automotive sector is one of the most 
significant segments of the economy, 
in addition to being one of the most 
profitable. Raw material inputs used by 
this sector, such as charcoal (pig iron), 
cattle (leather), and carnauba (car wax), 
are drivers of slave labor exploitation 
in Brazil. The automotive sector has 
significant leverage to influence supplier 
practices and impact social and cultural 
behavior throughout the supply chain. 
Automotive 
companies 
should 
be 
transparent, make public commitments 
in defense of human rights and human 
dignity, and lead suppliers in the 
search for collective solutions which 
promote industry collaboration and the 
propagation of responsible practices. 
Only then we will be able to combat 
labor exploitation in the supply chain.”
Mércia Silva, Executive Director, InPACTO, 
2020

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political indoctrination. It is very difficult, if not 
impossible, for companies to carry out human 
rights due diligence in this area since the Chinese 
government is responsible for creating this system 
of detention and forced labor, and is actively de-
nying that they are violating Uyghurs’ rights. 
Charcoal, which is processed into steel for use in 
automotive parts, is smelted with iron ore to pro-
duce pig iron. Pig iron sourced from Brazil may 
contain charcoal produced under conditions of 
forced labor and child labor. Brazil maintains a 
“dirty list” of companies with known forced labor 
risks. Natural rubber used in car tires may be pro-
duced with forced labor in Burma, Cote d’Ivoire, 
and Liberia. Electronics manufacturing in China 
and Malaysia has been associated with forced la-
bor risks. 
US Custom and Border Protection recently issued 
a number of Withhold Release Orders (WRO) de-
taining imports of products into the U.S due to 
forced labor and child labor concerns. If a WRO 
were issued for an automotive commodity due to 
evidence of production using forced labor, this 
would present business continuity risks. 
Workplace Health & Safety
From raw material extraction to auto parts man-
ufacturing and vehicle assembly, automobile 
production requires workers to carry out labor-in-
tensive work, often in hazardous environments, 
across the value chain. At the commodity level, 
children and adults working in mines, particu-
larly hand-dug artisanal mines, are at increased 
risk of injury and other poor health outcomes 
due to the hazardous working environment and 
lack of protections. The harvesting of commodi-
ties like natural rubber requires the use of sharp 
tools, carrying heavy loads, and exposure to 
pesticides. Steps along the leather supply chain, 
from cattle ranching, trimming and tanning of 
hides, require dangerous work. In parts manufac-
turing and assembly, workers are often working 
with heavy machinery, hot materials, chemicals, 
among other hazards. In the supply chain and 
in manufacturing operations, these jobs require 
the enforcement of strict safety protocols and the 
provision of personal protective equipment (PPE), 
and when workers do not have these protections, 
risks of injury and other poor health outcomes 
increase. 
Working Hours and Wages
Workers extracting and harvesting materials used 
in the automotive supply chain are often compen-
sated very little, equivalent to a few US dollars 
per day, for dangerous and labor-intensive work. 
When employers require workers to meet quotas 
that are incredibly difficult to reach, workers are 
forced to work excessive hours, which can have 
negative impacts on health and wellbeing. Adult 
workers may also bring their children to work in 
order to meet the quotas or to earn the income 
necessary to meet the household’s basic needs. 
There is currently no standard calculation for de-
termining a “living wage” for different jobs in dif-
ferent countries, however it is clear that workers 
living in extreme poverty and unable to cover ba-
sic needs without bringing their children to work 
are not receiving a living wage. Factory workers 
producing electronics and other components 
for the automotive industry often face the same 
pressures of working excessive hours to meet de-
manding quotas. In U.S. auto plants, union work-
ers have gone on strike to demand higher wages 
and improved benefits. 
Freedom of Association and Collective 
Bargaining
Although the rights to freedom of association and 
collective bargaining are recognized as univer-
sal labor rights, not all workers in the automo-
tive industry have the ability to freely exercise 
these rights, as automakers and suppliers do not 
always explicitly protect them within company 
codes of conduct or other internal policies. Auto 
manufacturing workers employed by major U.S. 
OEMs have fairly strong representation through 
the United Auto Workers (UAW), however many 
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foreign automakers have non-union plants. Com-
panies with anti-union cultures may retaliate 
against employees who attempt to organize. In 
the supply chain, low-wage workers in geogra-
phies with weak enforcement of labor laws have 
virtually no ability to organize to demand better 
wages or improved working conditions from their 
employers.
Discrimination and Harassment
Freedom from discrimination is a basic human 
right, and workers should be protected from dis-
crimination based on one’s race, ethnicity, na-
tionality, sex, gender, age, disability, religion, 
political affiliation, union affiliation, or other 
status. In practice, workers in the automotive in-
dustry still face discrimination in the workplace. 
Discrimination may play out in the form of be-
ing passed up for job opportunities and promo-
tions or other forms of unequal treatment in the 
workplace. Harassment may include the of racist 
language, hate speech, threats, and intimidation, 
among other tactics. Racist incidents have been 
reported in domestic auto plants, including at 
OEM and supplier facilities.
Conflict-Affected Areas
In addition to the risk of contributing to human 
rights abuses and conflicts, companies sourcing 
from conflict-affected and high-risk areas should 
take additional measures to address risks to work-
ers. These risks may be heightened by state and 
non-state actors who are often involved in human 
rights violations, particularly where there is ab-
sence of the rule of law and economic vulnerabil-
ity. Sourcing from such regions has the potential 
to contribute to sustainable development, but the 
use of conflict minerals, including tin, tantalum, 
tungsten, and gold (3TG), by the automotive in-
dustry exposes automakers and suppliers to risks 
of being linked to human rights violations in con-
flict-affected areas in the DRC or one of its nine 
neighboring countries. When 3TG minerals are 
purchased from conflict-affected areas, this pro-
vides an income stream to armed groups, which 
can perpetuate violent conflict in the region. 
While companies are legally required to report 
on conflict minerals due diligence under Sec-
tion 1502 of the Dodd Frank Act, this reporting 
requirement does not guarantee that companies 
are following responsible sourcing practices for 
3TG minerals. 
Climate Change
Transportation is one of the leading sources of 
greenhouse gas emissions contributing to cli-
mate change. Those most vulnerable to climate 
impacts as a result of factors like discrimination, 
age, income, and geography are among the first to 
face direct consequences, though they often have 
contributed the least to rising emissions. Not only 
this, but transport-related emissions in the form 
of air pollution are distributed inequitably across 
the world and pose serious risks to human health. 
Needed solutions include increasing the use of 
electric cars, public transportation infrastructure, 
more fuel efficient vehicles, and other sustainable 
innovations to address rising risks associated with 
transportation and climate change.
Environmental Health & Degradation
Many commodities are resource intensive, con-
tributing to greenhouse gas emissions in the 
harvesting, production, or processing of materi-
als. Others present risks to environmental health 
through the leaching of heavy metals or pol-
lutants. Some are exploited from resource-rich 
natural habitats. Leather is a major driver of de-
forestation, which may result in displacement of 
indigenous communities, threats to human rights 
defenders who take actions to oppose deforesta-
tion, and contributes to climate change. 
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Unique Risks Linked to the Coronavirus Pandemic
As the world faces a global health pandemic of 
enormous magnitude, the nature of the business 
model of the automotive industry may replicate 
inequities. While many American OEMs rightful-
ly acted swiftly in March 2020 to suspend non-es-
sential production to protect the health of their 
workforce and communities, this step caused 
ripple effects throughout global operations and 
supply chains. Questions remain around access 
to paid leave, long-term job security, and safe 
working conditions such as adequate person-
al protective equipment and social distancing 
accommodations. As companies resume oper-
ations, there may be risks for workers of being 
exposed to COVID-19, which makes it more im-
portant for companies to take adequate precau-
tions and closely follow public health guidance 
and provide avenues for employees to raise con-
cerns without fear of retaliation. In the midst of 
business disruption, the challenges will be more 
acute for workers in the supply chain who often 
have less job security or formal working relation-
ships, and do not have benefits like paid time off 
and health insurance. Increased economic in-
security and vulnerability is likely as is a risk as 
brands may suspend payments of contracts due 
to disruptions in manufacturing activities. Suppli-
ers that already have precarious working condi-
tions that do not adequately protect workers are 
also less likely to follow guidelines for social dis-
tancing or provide adequate personal protective 
equipment. They may resort to forced labor or 
child labor to maintain workforce. This context 
may also result in violations of working hours re-
strictions once business activities resume to make 
up for lost time. In this context, normal protec-
tions for workers, such as labor law enforcement, 
may also be disrupted. As the industry responds 
and recalibrates to the impact of COVID-19 and 
its aftermath, it must focus on resilience, sustain-
ability, equity, and protecting workers. This may 
require systemic changes and new business mod-
els.
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Under the UNGPs and the OECD Guidelines for 
Multinational Enterprises, all business actors, in-
cluding institutional investors, have a responsi-
bility to respect human rights. Investors may be 
exposed to a wide range of human rights risks by 
being widely invested across a large number of 
companies and sectors. As such, they are expect-
ed to undertake efforts to prevent, mitigate, and 
where appropriate address real and potential ad-
verse human rights impacts involved with their 
investment portfolios. These efforts should take 
place throughout the investment life-cycle and 
across asset classes.
In most cases, minority shareholders in public 
companies will be directly linked to adverse hu-
man rights impacts that are caused or contrib-
uted to by portfolio companies. In these cases, 
investors are expected to use their leverage with 
portfolio companies to enable the prevention, 
mitigation, and remediation of adverse risks and 
impacts. Investor leverage may be exercised in 
diverse ways, including by publicly committing 
to respect human rights throughout an investor’s 
investment activities and communicating an ex-
pectation that all businesses respect human rights 
to its financial advisors, portfolio companies, and 
other business relationships. Investors are also 
expected to consider human rights standards 
at the point of investment decision-making (in-
cluding when deciding on broader business re-
lationships), when assessing risks in investment 
portfolios, and when prioritizing engagements 
with companies, either alone or in coordination 
with groups such as IASJ.
When a company fails to disclose its human rights 
performance in line with the UNGPS or is unre-
sponsive to engagement around human rights, in-
vestor efforts to conduct their own human rights 
due diligence are undermined. Information on 
whether a company is effectively managing its 
salient human rights risks and impacts is critical 
for responsible investors, and, in cases where a 
company is consistently and continuously unre-
sponsive, institutions may determine that divest-
ment is appropriate. 
Regulatory expectations are also emerging for 
responsible investment, especially in Europe. 
For example, in December 2019, a new set of 
rules requiring European investors to disclose the 
steps they have taken to identify and address the 
impacts of their investment decisions on people 
and the planet came into force. European inves-
tors will be required to start reporting in line with 
these new rules in March 2021. This has signif-
icant implications for companies, as investor 
human rights due diligence efforts will increase 
the need for companies to meaningfully disclose 
how they manage risks to people. On April 29, 
2020, the European Commissioner for Justice 
announced a commitment to introduce rules for 
mandatory corporate environmental and human 
rights due diligence within the next year. This 
I N V E S T O R  C A L L  T O  A C T I O N
“Wherever 
Maryknoll 
Sisters 
are 
missioned, they promote human rights 
and the dignity of work. As share 
owners, they use their investor voice to 
hold companies accountable for human 
rights practices. The Shifting Gears 
initiative has focused attention on the 
human rights risks in a vast, global and 
complex sector - the automobile supply 
chain - and enabled the Sisters to be part 
of a shareholder effort to end child and 
forced labor and hazardous working 
conditions in car manufacturing.” 
Cathy Rowan, Maryknoll Sisters, April 2020

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comes weeks after investors with $5 trillion in as-
sets under management released a statement in 
support of this growing momentum, calling on 
governments to put in place regulatory measures 
to require mandatory human rights due diligence. 
Companies should seek to align their public poli-
cy and lobbying activities to support these regula-
tory efforts to create an enabling environment for 
meeting human rights commitments.
In addition to regulatory requirements, human 
rights (including human capital) risks are mate-
rial for the automotive sector. They present legal, 
financial, reputational, and business continuity 
risks, as discussed above. For example, failure to 
respect workers’ rights around health and safe-
ty or non-discrimination may result in lawsuits, 
labor disputes, supply chain disruption, negative 
financial impacts, reputational harm, an inability 
to attract and retain top talent poised to lead busi-
ness innovation, and other material impacts.
IASJ recognizes this context and has mobilized its 
investor Affiliates to join the Shifting Gears initia-
tive to advocate for industry-wide adoption of hu-
man rights due diligence practices. While there 
have been discrete engagement initiatives, such 
as the Principles for Responsible Investment co-
balt engagement, it is time for more investors to 
join this call. The industry will be influenced by 
a clear and consistent voice from a broad range 
of investors about the expectations for human 
rights practices and disclosure. To that end, inves-
tors are encouraged to support engagements and 
shareholder proposals in the sector. At the 2020 
annual shareholder meetings at Lear, General 
Motors, and Tesla, shareholder proposals will be 
considered on human rights impact assessment 
and disclosure on the effectiveness of policy im-
plementation. A strong vote on these advisory 
proposals would reinforce this signal. 
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Given the number of various commodities and 
intricacies of each supply chain, severity of the 
human rights risks, and sector-wide nature of its 
challenges, there are specific strategies and tools 
that are important for effectively addressing hu-
man rights risks in the automotive industry. 
Monitoring Effectively & At Scale 
While supplier audits are useful and all compa-
nies should conduct them, they have limitations 
and do not offer a complete solution for identify-
ing human rights risks in the supply chain. Many 
supplier audits do not include human rights cri-
teria. Auditors may lack training and expertise on 
human rights. Announced audits allow suppliers 
to take actions to avert scrutiny. Workers may not 
be interviewed or do not feel comfortable speak-
ing freely with the auditor. Audits may not be 
conducted by an independent third party. Given 
the number of suppliers, audits may not be con-
ducted frequently enough to effectively monitor 
compliance with law and expectations, and some 
suppliers may never be audited. Some companies 
identify suppliers to audit based on the spend 
(materiality) rather than the human rights risks 
(saliency), which may not direct the oversight to 
the most important areas of risk. 
Automotive industry companies that do moni-
toring primarily rely on supplier self-assessment 
questionnaires. Templates have been developed 
by various multi-stakeholder initiatives, such as 
the Automotive Industry Action Group (AIAG). 
This is useful for lowering the burden on suppliers 
and creating consistent, industry-wide expecta-
tions. However, if the information is not verified, 
a self-assessment provides little value and cannot 
be relied upon for business decisions. This can 
undermine the utility of the self-assessment ques-
tionnaire, contributing to a “buyer don’t care, 
supplier don’t care” mentality. 
An effective alternative is to adopt the work-
er-driven social responsibility (WSR) model, 
which is created, monitored, and enforced by 
workers themselves and includes legally bind-
ing commitments. It has led to transformative 
change in global supply chains, pioneered by the 
Coalition of Immokalee Workers (CIW). There, it 
has helped end forced labor, sexual harassment, 
S E C T O R  S P E C I F I C  S T R AT E G I E S  T O  S U P P O R T 
E F F E C T I V E  H U M A N  R I G H T S  D U E  D I L I G E N C E
“The Worker-driven Social Responsibility 
(WSR) model eliminates and prevents 
forced labor in complex supply chains 
by making workers in the supply chain 
the frontline monitors of their own 
rights, providing them an independent, 
accessible grievance mechanism that is 
backed up by binding and enforceable 
legal 
commitments 
by 
the 
major 
corporations at the end of the supply 
chain, who agree to cut off purchases 
from suppliers who don’t comply or who 
retaliate against complaining workers. 
Those 
two 
essential 
ingredients--
the worker’s right and ability to file a 
complaint without fear of retaliation, and 
the corporate buyer’s legally-enforceable 
promise to apply market consequences 
to offending suppliers--are the only 
recipe proven to end forced labor, as 
demonstrated in the Florida tomato 
industry by the Coalition of Immokalee 
Workers’ Fair Food Program as well as 
other industries where WSR has been 
implemented.” 
Gerardo Reyes, Coalition of Immokalee 
Workers, 2020

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and wage theft among other abuses and pro-
vides an effective enforcement mechanism. Re-
cently, workers in Lesotho signed a binding WSR 
agreement to address gender-based violence and 
sexual harassment in the apparel supply chain. 
Automotive companies can create avenues to 
hear worker voices and foster an enabling envi-
ronment for workers in their supply chains to or-
ganize, and when presented with an opportunity, 
sign agreements with workers to create effective 
WSR agreements to ensure that workplace im-
provements are implemented and maintained. 
Responsibility to Address Root Causes
Many of the human rights impacts in the auto-
motive supply chain are linked to underlying, 
systemic factors in sourcing regions. Such root 
causes include conflict, poverty, inequality, cor-
ruption, and inadequate access to education and 
housing. Companies must invest in solutions to 
address the enabling environment for system-
ic and entrenched human rights abuses in the 
supply chain in order to effectively contribute to 
transformative change. This must be done in part-
nership and consultation with impacted stake-
holders. Some strategies companies may pursue 
include:
1.	 Commit to pay a living wage throughout 
business relationships. This would reduce 
poverty and drivers of forced labor and 
child labor in some instances and further 
the capacity of workers to provide access 
to education for their children.
2.	 Support initiatives to uphold the rule of 
law and combat conflict and corruption in 
sourcing countries. This might include ef-
forts to promote legal mining activities in 
geographies with weak enforcement of la-
bor standards.
3.	 Address the structure of relationships in 
the value chain that enable or encourage 
negative human rights outcomes. Explore 
more direct sourcing relationships between 
OEMs and raw material suppliers to create 
greater transparency and accountability in 
the sourcing relationship. Direct sourcing 
also cuts costs lost to intermediaries and 
increases profits for the raw material sup-
pliers, which can be cascaded to increased 
wages for workers. 
4.	 Commit to provide price premiums and 
other business incentives such as long-term 
contracts for guaranteed responsible sourc-
ing. 
5.	 Invest in and participate in pilot projects to 
test alternative sourcing models and inno-
vation to mitigate supply chain risks. Pilots 
should be designed to include meaningful 
participation, oversight, and input from 
impacted workers and communities, civ-
il society groups, governments, and oth-
er stakeholders. Place-based projects that 
seek to address root cause issues, such 
as those that enable access to schooling, 
increase worker pay, and provide alter-
native income-generating activities, have 
the potential to create real change in com-
munities. Learnings from pilots should be 
captured and applied across salient risks to 
address larger business model issues to re-
alize the full benefits. 
Stakeholder 
engagement: 
Only 
3 
companies have an explicit commitment 
to stakeholder engagement (BASF, GM, 
and Nucor)
Effective Participation in Multi-
stakeholder Initiatives
The systemic nature of the human rights impacts 
of the automotive industry in the supply chain re-
quires sector or multi-sector wide action. Com-
mitment and collaboration between OEMs and 
suppliers is essential to ensure expectations are 
realized throughout the supply chain. Compa-
S T R AT E G I E S  T O  S U P P O R T  H U M A N  R I G H T S  D U E  D I L I G E N C E

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ny participation in multi-stakeholder initiatives 
(MSIs) can provide a forum for companies to work 
together at the pre-competitive phase to address 
shared obligations for respecting human rights, 
access educational resources, develop tools that 
can be shared across suppliers to ease the burden 
of compliance, and share best practices. A com-
prehensive list of the relevant MSIs for the sector 
is available in page 116. 
The effectiveness of MSIs depends on the re-
sources that they provide to companies and the 
extent to which those resources are deployed. 
These initiatives are most effective at driving hu-
man rights outcomes when they have criteria 
required of participants and have the following 
characteristics: governance by a range of stake-
holders including experts, community members, 
and workers; standards for membership that align 
with international legal standards and a require-
ment to use the tools to improve practices within 
corporate business activities; support risk assess-
ment and prioritization of action; a mandate to 
address the root causes that contribute to human 
rights impacts; and commitments to robust trans-
parency and supply chain disclosure. MSIs do not 
serve as a certification body, and membership in 
an MSI alone does not equate to human rights 
due diligence.
Many companies disclose the MSIs in which they 
are members, but generally do not disclose how 
they apply the available tools and shared learn-
ings from MSIs to influence their own actions. 
This makes it difficult for investors and stakehold-
ers to evaluate the value, impact and relevance 
of their participation in addressing human rights 
risks. 
Increased Transparency of Automotive 
Supply Chains is Needed
Traceability – or knowing the suppliers and lo-
cations of each input a company is sourcing– is 
important to establish, monitor, enforce, and in-
centivize expectations around respecting human 
rights. Yet, this is publicly disclosed by only a few 
companies in only the highest-profile commodi-
ties. It is possible for automotive OEMs and sup-
pliers to improve supply chain transparency to the 
raw material level, and companies likely main-
tain some of this information internally. However, 
due to considerations about proprietary supplier 
S T R AT E G I E S  T O  S U P P O R T  H U M A N  R I G H T S  D U E  D I L I G E N C E
In the assessment of company 
participation in MSIs, key findings 
include: 
•	 BMW and Ford are most active in 
multi-stakeholder initiatives.
•	 13 companies provide some informa-
tion about participation in at least one 
MSI, but most lack information about 
how that participation contributes to 
improved performance or practices. 
•	 Groupe PSA, Nucor, Lear, Genuine 
Parts, Nissan, Denso participate in no 
multi-stakeholder initiatives. 
“Respect for the human rights, the 
environment 
and 
the 
communities 
in which we operate have been core 
principles of the international automotive 
industry for many years. Our automakers 
and 
suppliers 
demonstrate 
their 
commitment to these values through 
corporate policies and collaborative 
initiatives 
aligned 
with 
consistent 
industry 
expectations, 
focused 
on 
delivering improvement throughout our 
complex global supply chain. Engaging 
suppliers, 
business 
and 
NGOs 
to 
address sustainability will continue to be 
paramount as the industry evolves.” 
Tanya H. Bolden - AIAG Director, Supply Chain 
Products & Services, April 2020

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relationships and the costs of chain of custody ef-
forts, among other factors, initiatives to increase 
visibility and traceability have not been widely 
prioritized. While there is emerging legislation in 
the UK, France, and Australia aimed at improving 
transparency in the supply chain to address risks 
of modern slavery, in the absence of extensive 
regulatory requirements or consumer demand, 
there is no incentive for companies to do this. 
Responsible, proactive companies that have vis-
ibility in their supply chains, manage human 
rights risks, and maintain ongoing due diligence 
will see the long-term benefits of supply chain 
resilience and business continuity. Blockchain 
initiatives have been piloted by some automotive 
companies to keep a digital ledger to increase 
transparency and chain of custody from the mine 
to the finished product. This can have a positive 
impact on increasing supply chain traceability 
and transparency. However, blockchain technol-
ogy in isolation does not address the human rights 
impacts in the supply chain. Companies must 
couple traceability initiatives with on-the-ground 
projects to establish expectations for responsible 
sourcing, provide the tools to meet those expec-
tations, and prevent future human rights impacts 
in communities in which they operate. 
Traceability appears to be lacking across 
the companies surveyed, with limited 
exceptions for conflict minerals and a 
few high-risk commodities that have 
been the subject of significant media 
attention, such as mica and cobalt. 
Twelve companies, including OEMs and 
Tier 1 suppliers, have zero information 
about transparency and traceability. Eight 
companies have partial commitments 
or information on one supply chain.  
Of the focus companies, 6 have supply 
chain pilot projects, such as blockchain 
partnerships. For example, Ford has 
a strong program in the Democratic 
Republic of Congo with the goal to 
increase transparency in the cobalt 
supply chain. 
S T R AT E G I E S  T O  S U P P O R T  H U M A N  R I G H T S  D U E  D I L I G E N C E
“Global 
supply 
chains 
are 
more 
complex, and now, more than ever, 
we need robust processes and strong 
management practice. Shifting Gears 
puts intense focus on sub-tiers of the 
manufacturing supply chain—including 
the extraction of natural resources—
where information and enforcement is 
the most challenging. This report makes 
the case for the industry to commit to 
greater action.” 
David Berdish, Executive-in-Residence, Supply 
Chain Management and Analytics, Virginia 
Commonwealth University School of Business 
and former Social Sustainability Manager at 
Ford Motor Company, 2020

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R E C O M M E N DAT I O N S  F O R  A U T O M O T I V E 
S E C T O R  C O M PA N I E S  O N  H U M A N  R I G H T S 
D U E  D I L I G E N C E
Strengthen human rights commitments to 
better align with the International Bill of Hu-
man Rights, the ILO’s Declaration on Funda-
mental Principles and Rights at Work, and 
the UN Guiding Principles on Business and 
Human Rights. Adopt a Supplier Code of 
Conduct that requires suppliers to respect hu-
man rights by conducting human rights due 
diligence in their own operations and com-
municating expectations to their business re-
lationships.
Identify and assess salient human rights im-
pacts in operations and the supply chain. 
Undertake human rights impact assessments 
and analyze findings of the risk assessment 
to inform human rights risk management 
strategies. Increase supply chain mapping, 
visibility, and traceability to facilitate the 
identification and assessment of human rights 
risks in the supply chain. 
Monitor and Track. Measure progress and 
track the effectiveness of actions and due dil-
igence systems. Assess supplier compliance 
with human rights expectations using qual-
itative and quantitative data, including data 
on grievances reported, to reduce negative 
human rights impacts of business and im-
prove outcomes for rights-holders. 
Create accountable frameworks for gover-
nance of human rights. Ensure board-level 
oversight of the implementation of human 
rights commitments, including by having at 
least one board member with human rights 
expertise and addressing human rights im-
pacts of company’s activities at board meet-
ings. Commit to increase the level of human 
rights expertise among those in leadership 
positions. Foster a corporate culture of re-
spect for human rights.
Establish effective systems to integrate hu-
man rights due diligence. Adopt and imple-
ment systems to assess and monitor business 
partners on human rights. Integrate findings 
from this human rights assessment into pro-
curement and other business decisions, pro-
viding favorable terms or incentives for strong 
human rights due diligence. Leverage com-
pany’s participation in multi-stakeholder ini-
tiatives to transform company practices to 
further respect for human rights, as well as to 
contribute to industry-wide solutions. Follow 
the OECD Due Diligence Guidance for Re-
sponsible Business Conduct. 
1
3
5
2
4
Investors have a responsibility to establish expecta-
tions for portfolio companies on Human Rights Due 
Diligence and assess company systems to identify, 
assess, mitigate, manage, and report on human 
rights risks. In this assessment, they should encour-
age companies to follow these recommendations.

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R E C O M M E N DAT I O N S  F O R  C O M PA N I E S
Provide access to Grievance Mechanism and 
Remedy. Ensure access to effective remedy for 
workers in operations and the supply chain 
and other rights-holders adversely impacted 
by business activities. Provide access to a 
grievance mechanism that is legitimate, ac-
cessible, predictable, equitable, transparent, 
rights-compatible, and a source of continu-
ous learning, in line with UNGP 31. Opera-
tional grievance mechanisms should extend 
beyond a corporate-level hotline. 
Improve Disclosure on Human Rights. Dis-
close evidence of implementation of human 
rights due diligence to demonstrate effective 
implementation of the human rights policy 
and supplier code of conduct, with indicators 
used to measure progress and assess effec-
tiveness. Align with expectations of the UN 
Guiding Principles Reporting Framework, 
the Global Reporting Initiative (GRI) and the 
Sustainability Accounting Standards Board 
(SASB). Disclose findings of human rights im-
pact assessments and relevant supply chain 
information, such as supplier lists and coun-
tries of origin for high risk raw materials. 
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A number of high-profile examples illustrate that 
the automotive sector continues to see significant 
human rights challenges in its long global sup-
ply chain. Some of the most prominent problems 
that have come to light recently are highlighted 
below. The entire sector clearly holds risks for hu-
man rights violations, particularly down the value 
chain, but the anecdotes below are not a com-
prehensive accounting of human rights violations 
within the research universe. 
Child Labor at Indian Mica Mines
A July 2016 investigation by The Guardian traced 
mica from three mines in India’s Tisri subdistrict—
where it had documented widespread child la-
bor under hazardous conditions—to three Indian 
exporters: Mohan Mica, Pravin and Mount Hill. 
Axalta, BMW, General Motors (GM) and Volk-
swagen (VW) were all exposed. Axalta and BMW 
went on to join the Responsible Mica Initiative 
(RMI), which The Guardian described as “the first 
comprehensive approach to tackling endemic 
child labour in mica mining since the industry 
was alerted to its existence more than a decade 
ago.” Nevertheless, companies’ disclosures on 
their mica supply chains remain thin, and none 
has publicly disclosed its mica suppliers. Axalta 
has since terminated its membership in the RMI.
Child and Forced Labor in DRC 
Cobalt Mines
In 2016, Amnesty International completed a 
traceability study that found automakers at risk of 
sourcing cobalt mined by children in the Dem-
ocratic Republic of Congo for electric vehicle 
battery production. GM and FCA were exposed. 
More recently, an April 2019 report from Re-
source Matters demonstrated that BMW, Renault 
and VW, among others, are involved in a cobalt 
supply chain that engages child labor in the DRC.
BMW, Renault and VW indicate that they align 
their approach to managing human rights risks 
in the cobalt supply chain with the Organization 
for Economic Cooperation and Development 
(OECD) Guidelines, are members of the Respon-
sible Minerals Initiative (RMI) and are using its 
Pilot Cobalt Refiner Supply Chain Due Diligence 
Standard. BMW and Renault indicate that they 
are members of the Responsible Cobalt Initiative, 
but VW is not. BMW and Renault have subse-
quently disclosed their cobalt smelters, but VW, 
FCA and GM have not. Disclosure of smelters is a 
step in the process of identifying forced and child 
labor in the supply chain, but does not cover tiers 
that are further upstream.
Tesla was one of the technology companies 
named in a December 2019 lawsuit filed by hu-
man rights firm International Rights Advocates, 
accusing the companies of aiding and abetting in 
the death and serious injury of children who say 
they were working in cobalt mines that supply the 
defendants. Tesla discloses more about its cobalt 
supply chain than many of its peers, and reports 
that it has a supplier audit program in place. This 
lawsuit may call into question the efficacy of the 
company’s approach.
Graphite Pollution & Suppression of 
Stakeholder Complaints in China
Reports in 2016 implicated Toyota, GM and other 
automotive companies along the graphite supply 
chain in severe environmental pollution in Chi-
na and the suppression of villagers’ complaints. 
None of the companies in this research universe 
report on their graphite supply chains.
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Lithium and Indigenous Rights 
Violations in South America
An April 2019 report from Deutschlandfunk im-
plicated BMW, Toyota and VW, among other 
automotive companies, in destroying the liveli-
hoods of indigenous people in the tri-border re-
gion of Bolivia, Chile and Argentina by way of 
the lithium supply chain. None of the companies 
in this research universe report on their lithium 
supply chains.
Forced Labor in Liberian Rubber 
Production
Bridgestone’s Firestone subsidiary has a history 
of significant human rights abuses in Liberia, ac-
cording to a PBS Frontline report, including forced 
recruitment and relocation of workers, dangerous 
working conditions and devastating punishments 
for workers who failed to meet quotas and more, 
with some lawsuits alleging conditions of modern 
slavery. Firestone has made strides in cleaning up 
its labor practices in Liberia in the last decade, 
but still made headlines in 2016 when it laid off 
7 percent of its Liberian workforce, reportedly in 
violation of a collective bargaining agreement. 
In May 2019, Firestone again announced layoffs, 
this time representing 13 percent of its Liberian 
workforce, saying it would conduct the layoffs in 
accordance with the collective bargaining agree-
ments it has in place. There are additional reports 
from an African business journal that Firestone is 
ending the provision of rice at a reduced price to 
its workers in Liberia, a concession it allegedly 
made to supplement low wages.
Bridgestone is far from the only company in the 
research universe with human rights challenges 
in its natural rubber supply chain. Continental 
provides the strongest approach to dealing with 
those challenges from among the companies 
evaluated here, but nevertheless provides little 
evidence of implementation.
Forced Labor in the Brazilian Pig Iron 
Supply Chain
Nucor’s forced labor policy and initiatives are 
the result of three years of intensive engage-
ment from shareholder advocates at Domini In-
vestments. This followed 2006 reports tracing 
the broader automotive supply chain to a work 
camp in northern Brazil, where enslaved workers 
produced charcoal for pig iron processing under 
extremely dangerous conditions. Ford and GM 
were among the companies whose products re-
portedly contained pig iron from that work camp. 
Pig iron from Brazil sourced by Ford, GM, BMW 
and Nissan has also been linked to illegal log-
ging, contributing to deforestation.
Violence by Security Forces at South 
African Platinum Mines
In 2012, an extended strike at a mine operated 
by BASF platinum-group metal (PGM) supplier 
Lonmin in Marikana, South Africa, culminated 
in a violent confrontation between mine work-
ers and armed South African police. The 34 fatal-
ities were mostly among Lonmin employees. The 
workers’ grievances included abysmal living con-
ditions lacking electricity and clean water, inade-
quate wages and dangerous working conditions. 
Following the event, BASF launched an extensive 
evaluation and audit process with Lonmin to im-
prove working conditions, and has demonstrated 
significant progress in the intervening years, in-
cluding by establishing a grievance mechanism. 
While BASF provides fairly robust disclosure on 
the steps it has taken with Lonmin following the 
Marikana event, BASF has not extended a similar 
level of disclosure to the rest of its operations.
Activities in Occupied Territories
Continental’s ContiTech subsidiary has attract-
ed some controversy for its activities in support 
of phosphate mining in the disputed territory of 
Western Sahara. The mining is carried out by 
a Moroccan state-owned company. Morocco 
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claims Western Sahara as part of its own coun-
try, while the local Sahrawi people of Western 
Sahara say they are under Moroccan occupation. 
The United Nations says the Sahrawi people have 
the human right of self-determination, a point on 
which Continental does not comment. Continen-
tal previously recognized Western Sahara as part 
of Morocco, an error for which it has since ex-
pressed “regret.” Continental confirmed in March 
2019 that its contract in Western Sahara is sched-
uled to expire in June 2020.
Honda’s official distributor in Israel operates a 
garage in an Israeli settlement, and manufactures 
armored buses that transport settlers. The Israeli 
military reportedly uses Ford vehicles to patrol 
and surveil Israeli settlements and GM vehicles 
at checkpoints. GM’s official distributor is also lo-
cated in an Israeli settlement. Israeli settlement 
activity in occupied Palestinian territory violates 
international law.
Involuntary Resettlement in China
The 2011 construction of a BASF polyurethane 
plant in China involved the involuntary resettle-
ment of farmers, some of whom reportedly did 
not feel they were adequately compensated for 
their land. Some of those who objected reported 
police intimidation and harassment, with some 
activists saying they were arrested on trumped-up 
charges to discourage dissent.
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Numerous Labor Rights Violations in Operations and Supply Chains
Most companies in the research universe have been implicated in labor rights violations, whether at their 
own facilities or in their supply chains.
•	 According to a March 2020 report from 
the Australian Strategic Policy Institute 
(ASPI), an Australian government-funded 
think tank, 83 automotive, technology and 
apparel firms—including BMW, GM and 
VW—employ factories that use Uighur 
and other ethnic minority labor in China. 
Uighurs are the targets of interrogation, 
surveillance, internment, forced labor and 
violence by the Chinese government. Ac-
cording to German media reports, BASF 
may also be exposed.
•	 In 2019, a judge ruled that Tesla had vio-
lated U.S. labor laws on multiple occasions 
when it interfered with its employees’ ef-
forts to unionize.
•	 In August 2019, Goodyear sustained criti-
cism from four members of the U.S. House 
of Representatives for its refusal to allow 
them to tour its Mexican tire plant during 
a recent fact-finding trip on labor condi-
tions in Mexico. The lawmakers’ interest 
stemmed in part from former employees’ 
allegations of poor working conditions and 
discrimination.
•	 In 2018, a judge approved a $22.5 million 
settlement for workers at U.S. Nucor steel 
mills who said they had been subjected to 
racial discrimination and intimidation.
•	 GM’s Thai subsidiary has been in conflict 
with labor activists over the last six years. 
Activists allege the company has pressured 
workers to resign, and seek an overall im-
provement to workers’ welfare. GM has not 
commented publicly.
•	 Labor organizers have accused Nissan of 
anti-union activities in recent year, includ-
ing in Mississippi and Tennessee. Allega-
tions include intimidation and harassment, 
threats of plant closure and summary firing 
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A  H I S T O R Y  O F  H U M A N  R I G H T S  V I O L AT I O N S
of employees. At one plant where 80 per-
cent of the workers are black, organizers 
have accused Nissan of civil rights viola-
tions. In 2017, the National Labor Relations 
Board charged the company with violating 
its workers’ rights.
•	 After racist graffiti and nooses were found 
at a GM factory in Ohio in 2017, GM is 
being sued by former employees who say 
the company did little to combat racism in 
the workplace. GM is offering a $25,000 
reward for information about a string of 
such racist threats at the plant.
•	 In 2015, the U.S. Department of Labor 
charged Lear over allegations that it had 
threatened and harassed workers who re-
ported health and safety violations at one 
of its Alabama plants, and fired a whis-
tleblower.
•	 In 2013, workers at the Honduras location 
of Lear affiliate-supplier Lear Kyungshin re-
ported being denied bathroom breaks and 
thus forced to wear diapers. 
•	 In 2010, labor activism primarily by mi-
grant workers in some of Denso’s Chinese 
production facilities led to improved pay 
and benefits. 
•	 Toyota has a history of serious labor rights 
violations at its own facilities, includ-
ing passport confiscation, excessive work 
hours and pay at less than half the mini-
mum wage.
•	 VW has been accused of labor rights viola-
tions in China, and failing to adhere to its 
own policies. 
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Highlights of each company profile are included on page 16 above. Controversies or human rights viola-
tions linked to the companies are not included in the profile, rather are compiled in the Section  “A History 
of Human Rights Violations” on page 38 above. 
C O M PA N Y  P R O F I L E S
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A X A LTA  C O AT I N G  S Y S T E M S
C O M PA N Y  P R O F I L E S
About Axalta Coating Systems
Axalta Coating Systems is one of the world’s largest car paint suppliers. It has 14,000 
employees. Axalta uses thousands of different raw materials that fall into seven broad 
categories: liquid res-ins, powder resins, pigments, solvents, monomers, isocyanates and 
additives. The company purchases raw materials from a diverse group of suppliers, with 
its top ten suppliers representing approximately 30 percent of its 2018 spending on raw 
materials. 
  1    Human Rights Policy
Axalta has a standalone human rights statement on its website, but it does not 
amount to a full policy. It includes a baseline commitment not to “engage in, or 
do business with, any third party that engages in, the use of forced or involuntary 
labor, human trafficking, or child labor.” Without offering details, Axalta says its 
human rights principles are aligned with the following international protocols:
•	 The UN Global Compact
•	 The UN Universal Declaration of Human Rights
•	 The Global Sullivan Principles
•	 The ILO Declaration on Fundamental Principles and Rights at Work
Axalta says it extends its human rights principles to its supply chain, without ex-
pounding on how it ensures compliance at every tier. The statement includes an 
expectation that its suppliers certify that their products were “developed through 
practices that respect human rights.”
Axalta’s standard supplier contract requires suppliers to warrant that they meet 
or exceed ILO Minimum Age Convention standards or applicable national law, 
whichever is higher. The company makes a general commitment not to use 
forced or involuntary labor, or to do business with any third party who does. 
Axalta does not elaborate, and does not appear to meet the standards set forth in 
the ILO’s Forced Labour Convention.
Axalta’s human rights statement does not include any reference to worker health 
and safety. The company’s Code of Business Conduct & Ethics includes a state-
ment entitling employees to a “safe, clean and healthy work environment,” and 
its Supplier Code of Conduct includes a similar expectation.
Axalta’s human rights statement does not include any reference to harassment 
and discrimination. The company’s Code of Business Conduct & Ethics includes 
a statement prohibiting both, as does its Supplier Code of Conduct.
O V E R A L L  
A S S E S S M E N T 
S C O R E
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A X A LTA  C O AT I N G  S Y S T E M S
  2    Human Rights Governance Embedding
Axalta has not embedded human rights in its governance structure, especially where it concerns the deep 
supply chain. The company’s board of directors is generally responsible for risk over-sight and assuring 
adherence to company policies, including the code of conduct with its human rights element, but there 
are no specifically articulated responsibilities for human rights in Axalta’s governance disclosures.
  3    Supplier Code of Conduct
Axalta has a Supplier Code of Conduct that came 
into effect in June 2016. It includes the follow-
ing expectations that are pertinent to this report, 
which Axalta says it “may” seek to verify:
•	 Suppliers shall seek to employ a diverse 
workforce, provide a work place free of 
discrimination and harassment, and treat 
employees fairly, including with respect to 
wages, working hours, benefits and work-
ing conditions.
•	 Suppliers shall ensure that the products and 
materials they sell to Axalta are not creat-
ed with child labor, forced labor or through 
the victims of human trafficking and shall 
take reasonable steps to eliminate such 
practices in their supply chains.
The code says suppliers “shall take reasonable 
steps” to eliminate child labor, forced labor and 
human trafficking from their own supply chains; 
it does not otherwise require that human rights 
commitments cascade beyond first-tier suppliers.
  4    Traceability and Supply Chain 
Transparency
Axalta does not make a company-wide commit-
ment to disclose and trace its raw material inputs, 
nor does it articulate the importance of tracing. 
Indeed, its limited communications on the sub-
ject are geared more toward emphasizing the dif-
ficulty of tracing. The company does not report 
on company-wide traceability choke points, and 
does not disclose its 3TG smelters/refiners or 3TG 
countries of origin. Axalta does not disclose any 
responsible sourcing pilot projects in the works.
Axalta directly addresses a single high-risk in-
put: mica. Acknowledging that mica “has been 
associated with the use of child labor in select-
ed jurisdictions in India,” Axalta reiterates its re-
quirement that suppliers only supply the company 
with products that have not been produced using 
child labor. The company notes it was a founding 
member of the Responsible Mica Initiative.
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  7    Participation or Leadership in Multi-Stakeholder Initiatives
Axalta is a member of the RMI. The company follows OECD Due Diligence Guidance for Dodd-Frank 
compliance.
Axalta is no longer a member of the Responsible Mica Initiative.
A X A LTA  C O AT I N G  S Y S T E M S
  5    Human Rights Due Diligence / 
Embedding
Axalta says it has a Supplier Sustainability Risk 
Management program, which it says it uses “to 
regularly evaluate our supply chain to ensure hu-
man rights issues are identified and addressed.” 
The company does not publish details about 
this program. Axalta does not disclose any hu-
man rights risk assessment process at the com-
pany-wide level. Its Supplier Sustainability Risk 
Management program “requests” that key sup-
pliers complete a questionnaire related to the 
company’s code of conduct. Axalta says nothing 
further on the subject.
Axalta does not disclose how it might integrate 
or otherwise act on any human rights risk as-
sessment findings at a company-wide level. The 
company says it provides training to its global 
procurement staff who work directly with its sup-
ply chain partners, but does not elaborate on the 
nature of that training. Axalta says that in 2018, 
training focused on supply chain risk identifica-
tion and the methodology of the company’s Sup-
plier Sustainability Risk Management Program.
Axalta has a Supplier Sustainability Risk Manage-
ment Program in place that “screens suppliers on 
the expectations outlined in the Supplier Code of 
Conduct.” It offers no further details. 
Axalta says it “may” seek to verify its suppliers’ 
compliance with the company’s supplier code of 
conduct, including through audits. The company 
acknowledges in its most recent Conflict Miner-
als Report to the SEC that it does not perform or 
direct audits of smelters, given its lack of a “di-
rect relationship” with them. Axalta instead relies 
on “publicly available third-party assurances and 
certifications.”
Axalta says its standard supplier contract express-
ly reserves the right to conduct onsite audits of its 
suppliers to evaluate compliance with the expec-
tations in the Supplier Code of Conduct, which 
includes a human rights component. The compa-
ny says it has conducted independent third-party 
audits of “several” supplier facilities. 
  6    Remedies and Grievance 
Mechanisms
Axalta maintains an ethics hotline that its employ-
ees, suppliers and customers can use to report vi-
olations of applicable law or the company’s code 
of conduct. The hotline has toll-free numbers for 
employees around the world, and supplies in-
terpreters as necessary. Except where prohibited 
by law, these reports may be made anonymous-
ly, and the company has a Whistleblower and 
Non-Retaliation Policy.
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B A S F
C O M PA N Y  P R O F I L E S
About BASF
BASF is a global chemical company that operates through six segments: Chemicals, 
Materials, Industrial Solutions, Surface Technologies, Nutrition & Care and Agricultural 
Solutions. It has 118,705 employees. In 2018, BASF purchased approximately 30,000 
different raw materials from more than 6,000 suppliers. Key raw materials include 
naphtha, natural gas, methanol, ammonia and benzene. The company also procures a 
number of mineral raw materials that it uses to produce mobile and process emissions 
catalysts and battery materials. BASF says it has more than 70,000 Tier 1 suppliers.
  1    Human Rights Policy
BASF publishes its standalone Position on Human Rights, last revised in 2011. It 
makes a baseline commitment to respect human rights across its activities. BASF 
says it is “committed to complying” with the principles of the following interna-
tional laws and standards:
•	 The UN Global Compact (BASF is a founding member)
•	 The UN Universal Declaration of Human Rights
•	 The International Covenant on Civil and Political Rights
•	 The International Covenant on Economic, Social and Cultural Rights
•	 The ILO’s eight core labor standards (BASF says compliance is mandatory 
across its worldwide operations)
•	 The Tripartite Declaration of Principles concerning Multinational Enter-
prises and Social Policy (MNE Declaration)
•	 The OECD Guidelines for Multinational Enterprises
•	 The Responsible Care Global Charter
BASF is vague in its human rights policy about how/if it extends that policy to 
suppliers. The company merely says it evaluates suppliers on the basis of “social 
standards,” among other things, and that those standards are incorporated into 
its procurement conditions. In the 2018 BASF Report, the company says: “As a 
participant in numerous global value chains, we are dependent on partners and 
demand that they likewise respect human rights and the associated standards. 
We offer to help our partners in their efforts to meet their human rights respon-
sibilities.”
BASF says in its human rights policy that it maintains an “intensive dialog” with 
relevant stakeholders, noting the company reports on this process in its annual 
BASF Report. The company has Community Advisory Panels (CAPs), primarily at 
its larger production sites, that meet regularly to discuss the needs of the neigh-
boring communities. Complaints can be raised directly or anonymously. 
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  2    Human Rights Governance Embedding
BASF does not appear to have embedded human rights in its governance structure, especially where it 
concerns the deep supply chain. In general terms, BASF says its Corporate Sustainability Board is its cen-
tral steering committee for sustainable development, comprising the heads of its business, corporate and 
functional units, and regions. A member of the Board of Executive Directors serves as chair. The company 
also says it has established an external, independent Stakeholder Advisory Council, comprising interna-
tional experts from academia and society who engage with BASF’s Board of Executive Directors.
B A S F
  3    Supplier Code of Conduct
BASF’s Supplier Code of Conduct includes hu-
man and labor rights standards. The company 
strengthened the code in 2018 in response to 
stricter requirements from the United Nations 
Guiding Principles on Business and Human 
Rights (UNGPs) and the ILO. BASF added issues 
such as modern slavery and human trafficking, 
along with a requirement that suppliers imple-
ment grievance mechanisms for their employ-
ees and stakeholders. The company also added 
a reference to its own compliance hotline, which 
suppliers and their employees can contact. Only 
those companies that have committed to BASF’s 
Code of Conduct actually become new suppli-
ers. BASF’s Supplier Code of Conduct does not 
explicitly require that human rights commitments 
cascade beyond first-tier suppliers.
  4    Traceability and Supply Chain 
Transparency
According to BASF’s 2018 Report, the compa-
ny tracks Dodd-Frank-defined conflict minerals 
to their origins to determine if they came from 
conflict regions. The company also says it will 
comply with the new E.U. Conflict Minerals Reg-
ulation coming into effect in 2021. The only other 
reference the company makes to traceability re-
lates to its palm oil supply chain. 
BASF is one of the partners in the GIZ pilot proj-
ect. While the company says neither it nor its sup-
pliers procure cobalt from DRC artisanal mines, it 
supports the project as part of its involvement in 
the Global Battery Alliance.
BASF says that in addition to the conflict min-
erals covered by U.S. and E.U. regulations, the 
company also “is committed to a responsible and 
sustainable global supply chain for cobalt and 
mica.” BASF says it mainly sources mica from its 
own mine in Hartwell, Georgia. The company 
says it requires its mica suppliers “to comply with 
internationally recognized standards, including 
the prohibition of child labor,” noting its partici-
pation in the Responsible Mica Initiative.
One of BASF’s platinum suppliers in South Afri-
ca was the subject of an extended strike by mine 
workers in 2012 that culminated in a deadly con-
frontation with local police. BASF has taken re-
medial action geared toward the supplier, rather 
than the commodity itself. Details are covered in 
the following sections.
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  5    Human Rights Due Diligence / 
Embedding
BASF says it established a guideline on compli-
ance with international labor norms in 2015, and 
that it applies “group-wide.” It does not speci-
fy that the guideline cascades down the supply 
chain. BASF has not made it publicly available. 
The company says the guideline forms the ba-
sis for its global management process, through 
which it monitors and evaluates whether the 
national law of all the countries in which BASF 
operates complies with international labor and 
social standards. If the national law contains no 
or lower requirements, BASF draws up actions 
plans “to successively close these gaps in a rea-
sonable time frame.” If conflicts with national 
law or practices arise, the company says it strives 
to act in accordance with its values and interna-
tionally recognized principles without violating 
the law of the country concerned. As part of its 
management process, BASF says it regularly fol-
lows up on and documents the results of its com-
parison between national law and the company’s 
guideline, as well as measures to implement that 
guideline. The company reports that it improved 
maternity leave at BASF companies with no stat-
utory requirements or lower requirements than in 
the BASF guideline, for example.
BASF says a country-based risk analysis forms 
the basis of its selection process for new suppli-
ers. Based on the country-related risks identified, 
BASF says it asked suppliers in South America 
and Asia in particular to commit to its Supplier 
Code of Conduct in 2018.
BASF says the following in its human rights policy 
about assessing human rights risks among poten-
tial suppliers:
“We inform our suppliers in writing about the 
standards we expect and raise their awareness of 
sustainability issues. Risk matrices help us to iden-
tify potential high-risk suppliers. Suppliers fill out 
a self-assessment questionnaire according to their 
risk potential. If we establish that suppliers do not 
meet our standards or only meet them partially, 
we visit them on site, agree on corrective mea-
sures and provide help in implementing these. 
Furthermore, BASF conducts training sessions 
on sustainability issues for suppliers in selected 
countries.”
BASF has some measures in place to integrate and 
act on assessment findings, although the extent 
to which this cascades down the value chain is 
only vaguely articulated. BASF says in its human 
rights policy that it provides compliance train-
ing for all its employees worldwide, which cov-
ers country-level codes of conduct that embed 
“group-wide basic values and principles.” The 
company says it also conducts supplier training 
on sustainability standards in “relevant procure-
ment markets” such as China. The company does 
not disclose human rights-specific information 
on training.
BASF is also a founding member of the German 
Business Initiative for Sustainable Value Chains, 
under which the first supplier training events took 
place in 2018 in China and Mexico. BASF also 
says it works in Brazil with Integrare, a non-gov-
ernmental organization (NGO) that promotes di-
versity in supply chains. Integrare supports small 
and medium-sized businesses run by people with 
disabilities or socially disadvantaged minorities 
by offering specialized training and encouraging 
partnerships with larger companies.
BASF says it integrates human rights due dili-
gence into purchasing decisions, but furnishes no 
evidence of implementation. The company says 
it integrates criteria for monitoring and comply-
ing with human rights standards into its supplier 
evaluation processes. The company is a founding 
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member of TfS, which conducted 3,767 sustain-
ability assessments—including both initial and 
follow-up assessments—in 2018.
BASF says it demands its suppliers “fully comply 
with applicable laws and adhere to international-
ly recognized environmental, social and corpo-
rate governance standards,” and that they ensure 
the same and replicate this with their subcontrac-
tors and suppliers along the whole value chain. 
Given the vague wording of this statement, BASF 
does not demonstrate that it cascades human 
rights expectations down the value chain.
Following fatal clashes between striking mine 
workers and local police at one of BASF’s South 
African platinum suppliers in 2012, BASF was 
instrumental in establishing the International 
Platinum Group Metals Association (IPA), which 
includes among its objectives the improvement 
of structural challenges in South Africa’s platinum 
mining belt. BASF does not disclose similar ef-
forts at other points in its value chain.
BASF has some tracking mechanisms for moni-
toring and evaluating the effectiveness of actions 
to respond to human rights risks and impacts, 
although its public disclosures are limited. The 
company says it has a goal to evaluate the “sus-
tainability performance” of 70 percent of its 
“relevant suppliers”—which it defines as Tier 1 
suppliers that its risk matrices and purchasers’ 
assessments have determined present elevated 
sustainability risk potential—by 2020. The com-
pany does not provide details specifically related 
to human rights.
BASF says it conducts supplier audits, both on 
its own behalf and through third parties. It is a 
founding member of TfS, which conducted 358 
supplier audits in 2018. Using TfS evaluations, 
BASF says it pursues a risk-oriented approach with 
clearly defined, BASF-specific follow-up process-
es. The company says it audited 100 raw material 
supplier sites on sustainability standards in 2018, 
and received sustainability assessments for 546 
suppliers from an external service provider.
BASF says if it identifies “potential for improve-
ment” in its suppliers’ performance, the compa-
ny supports suppliers in “developing measures to 
fulfill our standards.” BASF conducts follow-up 
reviews. If the weak points discovered were par-
ticularly severe and the company is unable to con-
firm any improvement, it “reserve[s] the right to 
terminate the business relationship.” This did not 
occur in 2018. BASF says it uses this approach to 
evaluate suppliers with an elevated sustainability 
risk at least every five years.
BASF says that among the audits it conducted in 
“the past few years,” it “identified some devia-
tions,” including some relating to occupational 
safety, working hours and minimum wage. The 
company conducted follow-up audits in 2018, 
and says it “found improvements in all areas,” 
finding no incidents of child or forced labor, and 
confirming that workers under 18 were exclud-
ed from overtime and dangerous work in keeping 
with ILO standards.
Following fatal clashes between striking mine 
workers and local police at one of BASF’s South 
African platinum suppliers, Lonmin, in 2012, 
BASF said it had “conducted periodic site visits” 
over the course of its 30-year relationship with 
Lonmin. This indicates that BASF’s site visits had 
not adequately detected risks. After the incident, 
BASF undertook a number of steps to ensure 
Lonmin was in line with BASF’s Supplier Code 
of Conduct, including an intensive third-party 
audit of Lonmin’s operations. BASF says it went 
on to support Lonmin in addressing weaknesses 
identified through the audit, including Lonmin’s 
firefighting capabilities, stakeholder engagement 
approach and grievance mechanisms. BASF has 
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conducted several follow-up audits to ensure 
compliance. Importantly, these remedial actions 
did not stem from a functioning risk assessment 
process at BASF. They were the product of an in-
ternational incident, the risk of which BASF’s pre-
vious audits had failed to uncover.
BASF does not address in its most current report-
ing whether its audits are announced or not. In 
some of its reporting from prior years, the compa-
ny said it conducted unannounced audits at high-
er-risk production plants, though this appeared 
to apply only to its own facilities, not those of 
suppliers. BASF uses third-party providers to con-
duct some portion of its supplier audits and as-
sessments, although it is not clear to what extent 
it relies on third parties for this purpose.
BASF does not systematically communicate ex-
ternally on how it addresses its human rights 
impacts. The company provides a more detailed 
description of its efforts to improve working con-
ditions at its Lonmin supplier (described earlier in 
this report), but this broader discussion followed 
a public outcry. The company has not offered a 
similar level of detail regarding other areas of its 
value chain.
  6    Remedies and Grievance 
Mechanisms
BASF provides limited disclosure on its human 
rights remedies and grievance mechanisms. The 
company says employees and third parties can 
report potential violations of laws or company 
guidelines to its complaint hotlines. It provides 
domestic, toll-free phone numbers for all of its 
areas of operation. BASF says its globally binding 
requirements for community advisory panels at 
its sites are based on the grievance mechanism 
standards in the UNGPs. The company has also 
worked with its Lonmin supplier to ensure that 
Lonmin has its own grievance mechanisms in 
place. However, BASF does not report exerting 
similar efforts at other suppliers that have not 
been in the media spotlight. BASF says it reviews 
and investigates all complaints, without elaborat-
ing.
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  7    Participation or Leadership in Multi-Stakeholder Initiatives
BASF is a founding member of the RCI, the Responsible Mica Initiative and the World Economic Forum’s 
Global Battery Alliance. It is a member of the Global Business Initiative on Human Rights, through which 
it consults with civil society representatives on an ongoing basis. BASF says it has been “actively involved” 
in the UN Global Compact’s Action Platform on Decent Work in Global Supply Chains since 2018. The 
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B M W
C O M PA N Y  P R O F I L E S
About BMW
Bayerische Motoren Werke (BMW) develops, manufactures and sells automobiles, 
motorcycles, and spare parts and accessories worldwide. It has 134,682 employees. 
BMW’s primary raw materials are steel, palladium, platinum, lithium, cobalt, 
aluminum, lead and copper. The company works with approximately 12,000 Tier 1 
suppliers in more than 70 countries.
  1    Human Rights Policy
BMW issued its Joint Declaration on Human Rights and Working Conditions in 
2005, and its supplementary Code on Human Rights and Working Conditions 
in 2018. The company signed the UNGC in 2001, and commits to abide by the 
ILO’s core standards. BMW says it is systematically implementing the UNGPs, 
and that it “considers” the OECD Guidelines. BMW says its human rights policy 
applies to employees, suppliers and authorized sales organizations. The compa-
ny’s human rights policy does not include an explicit commitment to stakehold-
er engagement, although there are several references in the policy to processes 
that include external consultation.
  2    Human Rights Governance Embedding
BMW’s governance structure includes mechanisms for sustainability manage-
ment and compliance, of which the company has made human rights a com-
ponent. The company has a Sustainability Board that comprises its full Board 
of Management and the heads of BMW’s Sustainability and Environmental Pro-
tection and Corporate Communications departments. The company does not 
report on the specifics of how human rights matters are managed within these 
structures. BMW says its managers are responsible for implementing its human 
rights policy, and that managers have a duty to support their employees in its 
implementation in day-to-day business.
None of BMW’s board members appears to have specialized human rights ex-
pertise. Supervisory board member Verena Zu Dohna-Jaeger has been a member 
of the UNGC board since 2012.
BMW includes sustainability factors in its board compensation parameters, but 
it only references this in general terms. Board members’ performance-related 
bonus is determined in part by “promotion of compliance and integrity, contri-
bution to the Group’s attractiveness as an employer, progress in implementing 
the diversity concept, and activities that foster corporate social responsibility.” It 
is not possible to gauge what proportion of this, if any, relates directly to human 
and labor rights. 
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BMW has Human Rights and Supply Chain Response Teams that are charged with managing issues that 
arise in the course of business and taking corrective action where necessary. The company’s Strategic Pur-
chasing employees are responsible for sustainability topics in the supply chain.
In its Sustainable Value report, BMW provides a mission statement: “The BMW Group is the world’s most 
successful and sustainable premium provider of individual mobility.” This mission statement does not 
appear on the company’s website or in its annual report. In its regular corporate communications, the 
company does consistently mention sustainability as a guiding principle. It is not clear that it considers 
human rights a fundamental business model issue, but it has embedded human rights into its governance 
structures more thoroughly than many of the other companies in this report.
B M W
  3    Supplier Code of Conduct
BMW’s Code on Human Rights and Working 
Conditions also applies to its suppliers. Addi-
tionally, BMW has a Supplier Sustainability Pol-
icy that includes human rights provisions. In it, 
the company “calls upon” all of its suppliers to 
observe the UNGC and the ILO standards, and 
to align their due diligence process with the 
UNGPs. BMW also spells out its sustainability 
requirements for suppliers, including human and 
labor rights provisions, with graduated levels of 
stringency depending on the size of the supplier. 
For instance, companies with more than 50 em-
ployees must have policies on child and forced 
labor, freedom of association, health and safety 
and more. Companies with more than 100 em-
ployees also must extend those requirements to 
their own suppliers, and have a review process in 
place for implementation. Companies with more 
than 500 employees must also have senior man-
agement responsibility for social sustainability, 
publish sustainability reports and codes of con-
duct and provide training on sustainability issues. 
BMW “calls upon” its first-tier suppliers to “make 
contractual arrangements” to ensure that their 
subcontractors comply with BMW’s Supplier Sus-
tainability Policy.
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  4    Traceability and Supply Chain 
Transparency
BMW makes general commitments in its sustain-
ability reporting to supply chain transparency, 
and discusses the topic in more detail at the com-
modity level. 
BMW is working with one of its suppliers on a 
pilot project to make its copper supply chain 
more transparent, using supply chain mapping to 
analyze risks.
Its collaboration with German development agen-
cy GIZ focuses on a pilot artisanal cobalt mine in 
the DRC to test approaches for improving work-
ing and living conditions there.
BMW says it worked on the pilot for a joint au-
diting program that aims to share audit results 
among the members of a German automotive in-
dustry group. The company does not elaborate as

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to the pilot’s current status, and it is not clear if it 
remains involved.
BMW says in its annual report that it is “involved 
in initiatives aimed at standardizing sustainability 
requirements and establishing verification mech-
anisms for critical raw materials.” The company 
identifies sustainable raw material procurement 
as a matter of “great importance,” and says it met 
with stakeholders in May 2018 to hold “joint dis-
cussions regarding critical raw material supply 
chains.” BMW mentions cobalt and the human 
rights risks associated with its mining in its Sus-
tainable Value Report. 
BMW provides additional information in its sus-
tainability report and supplemental materials, di-
rectly addressing its initiatives around steel and 
aluminum, cobalt, copper, natural rubber and 
conflict minerals. Its efforts to address human 
rights issues in each value chain generally in-
volve participation in various industry initiatives, 
as described in subsequent sections of this report. 
BMW provides the following additional details:
•	 Steel and aluminum make up the largest 
share by weight of the materials used in 
BMW vehicles. The company is working 
toward obtaining certification under the Al-
uminium Stewardship Initiative—of which 
it is a founding member—for its own man-
ufacturing processes and those of its sup-
pliers.
•	 BMW says its cobalt due diligence stan-
dards are “based on” the OECD Due Dili-
gence Guidance. The company says it is in 
“constant contact” with its battery cell sup-
pliers, and has asked them to disclose the 
origin of all cobalt they source for “some 
years now,” with the explicit aim of achiev-
ing “complete supply chain transparency 
for cobalt.” BMW began publicly disclos-
ing the names and locations of its cobalt 
smelters and refineries and the cobalt’s 
countries of origin in 2017. The company 
also discloses measures it takes to address 
risks in its cobalt supply chain, as detailed 
in the following sections of this report.
•	 BMW’s conflict minerals approach is also 
“based on” the OECD Guidance. The 
company says it has a goal to achieve full 
transparency in its conflict minerals supply 
chains by 2022.
•	 BMW requires increasing amounts of cop-
per as it electrifies its fleet. It says it is “com-
mitted to increasing transparency in the 
copper supply chain and ensuring sustain-
ability from mine to production line,” and 
is collaborating with industry, civil society 
and consumers to establish a cross-industry 
initiative that will develop a sustainability 
standard for copper.
•	 BMW says it is “seeking opportunities for 
dialogue and collaboration with the rele-
vant stakeholders” in order to establish a 
multi-stakeholder initiative on fostering 
sustainability in natural rubber supply 
chains.
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  5    Human Rights Due Diligence / 
Embedding
BMW says its human rights due diligence pro-
cess is “geared towards” the UNGPs. The compa-
ny says it conducted a group-wide human rights 
compliance assessment in 2017. It details its pro-
cesses for integrating assessment findings inter-
nally and taking appropriate action.
BMW says it uses “regular internal communica-
tions and training on recent developments” to 
ensure compliance with its human rights commit-
ments, and offers a wide range of targeted train-
ing courses for purchasers and suppliers to raise 
awareness of human rights and labor standards 
and communicate its expectations. In doing so, it 
also helps suppliers to comply with relevant stan-
dards.
BMW says criteria associated with its Sustainabili-
ty Standard are embedded throughout its purchas-
ing system, including in inquiries to suppliers, its 
sector-wide OEM Sustainability Questionnaire, 
purchasing terms and supplier evaluations. BMW 
publishes a redacted version of its supplier “re-
quest for quotation” form—an application doc-
ument for new suppliers—showing the sections 
that include human rights provisions and protec-
tions. The English-language version is poorly and 
confusingly worded, but nevertheless includes a 
requirement that suppliers comply with BMW’s 
Supplier Sustainability Standards, along with a re-
quirement that they “form binding requirements 
for integrating sustainability within the entire sup-
ply chain.”
BMW says human rights is an evaluation criterion 
in its supplier selection process and a component 
of its three-stage risk management process. This 
includes a risk filter, a media screening, a sustain-
ability self-assessment questionnaire for the au-
tomotive industry, a company-specific modular 
questionnaire, internal on-site assessments and 
external audits. Where BMW identifies potential 
shortcomings, it establishes a Supply Chain Re-
sponse Team to follow up. Where necessary, the 
company implements an escalation process and 
develops corrective action plans with the suppli-
er. Where a supplier fails to take effective action, 
BMW “may potentially terminate the supply con-
tract.”
BMW says all supplier contracts for both direct 
and indirect materials contain clauses regarding 
the company’s sustainability requirements. It does 
not publish its standard supplier contract. BMW 
also says it includes a requirement to comply with 
the company’s “social standards” in its contracts 
with dealers and importers, and will include a 
clause on human rights in all dealer contracts 
worldwide by 2020. The company does publish 
its International Terms and Conditions for the Pur-
chase of Production Materials and Automotive 
Components, which include human rights pro-
tections. The document includes a requirement 
that both BMW and the supplier “acknowledge 
their compliance” with the ILO’s Declaration on 
Fundamental Principles and Rights at Work, the 
UNGC and the UNGPs.
In its annual report, BMW says, “Sustainable busi-
ness management can only be effective, however, 
if it covers the entire value-added chain.” BMW 
says it expects its suppliers and partners to meet 
the company’s social standards and to require 
the same of their sub-suppliers. BMW’s General 
Terms and Conditions of Business and its Interna-
tional Purchasing Conditions stipulate that sup-
pliers must commit to respecting human rights, 
and that they must abide by the ILO Declaration 
on Fundamental Principles and Rights at Work. 
Suppliers are required to take similar measures 
with their sub-contractors by undertaking reason-
able and meaningful steps to ensure that these 
responsibilities are realized, such as by commu-
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nicating a supplier sustainability policy for their 
own suppliers.
BMW says it will procure cobalt for its next gen-
eration of battery cells directly from mines in 
Australia and Morocco starting in 2020, partly so 
that it can “put contracts in place to ensure com-
pliance with our sustainability standards.” The 
company’s participation in GIZ aims to improve 
working and living conditions of artisanal miners 
in the DRC. If successful, BMW may qualify those 
mines as direct cobalt suppliers.
BMW says it monitors for compliance with sus-
tainability standards in its supplier network by 
way of a three-stage risk management system, 
although it does not offer specifics on human 
rights. The company says it conducts spot-checks 
of supplier facilities as part of its sustainability 
audits and assessments, and that it collaborated 
with the Chinese Chamber of Commerce to de-
velop an auditing standard and process for its co-
balt supply chain.
BMW reports that it audits its suppliers on sus-
tainability criteria, but presents the information 
in a confusing manner that does not reveal what 
proportion of its audits deal with human rights 
issues. In 2018, BMW says it identified “sustain-
ability deficits” at 2,320 potential and existing 
supplier locations, including the absence of a hu-
man rights policy at the evaluated location. The 
company says it defined corrective measures at 
1,123 of those locations, without explaining why 
it did not take similar action at the other loca-
tions. Among the potential suppliers, BMW did 
not commission 193 of them in 2018 because 
they failed to meet the company’s sustainability 
requirements. It did not terminate any existing 
contracts, which it attributes to “the success of 
our approach of addressing and demanding sus-
tainability requirements early on in the procure-
ment process.”
BMW reports that it received nine reports through 
its grievance channels of potential supply chain 
breaches of its sustainability standards in 2018, 
concerning human rights in mining, working con-
ditions and child labor, among other issues. The 
company says only that it was “able to investigate 
and close all inquiries in 2018 before the end of 
the year,” without elaborating. Regarding its co-
balt supply chain, BMW is vague in its reporting 
on remedial action, saying only that “measures 
were imposed” at one smelter “based on the find-
ings” of an audit.
BMW reports that its supply chain due diligence 
process uncovered 541 suppliers in 2015 that did 
not fulfill the company’s sustainability require-
ments. The company spent the following three 
years working with those suppliers to improve 
their practices and performance, and reports on 
the subject in its Communication on Progress 
published in May 2019. It details the suppliers’ 
progress toward fulfilling BMW’s requirements 
to have a manager responsible for social sustain-
ability and business ethics, a health and safety 
policy, internal training sessions on sustainability 
topics, a sustainability report, a supplier sustain-
ability policy and communication of that policy. 
Reported progress toward the company’s 100 
percent compliance goal was generally positive, 
with nearly all indicators surpassing 95 percent 
in 2018.
BMW provides mandatory reporting in keeping 
with the U.K. Modern Slavery Act, in which it 
identifies four key countries—China, Hunga-
ry, South Africa and Mexico—that are import-
ant sourcing markets for the company but also 
pose increased human rights risk. BMW notes 
its policy to take corrective measures in cases of 
non-compliance, and reports on the progress of 
the 642 suppliers it identified for added scrutiny. 
(The company does not explain how it selected 
this group.) It shows significant progress from 
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2017 to 2018 toward achieving full compliance 
with MSA sustainability requirements in Hungary 
and China, but nearly stagnant performance in 
Mexico and South Africa over the same period. 
BMW does not offer analysis or discuss specific 
remedial actions in this report. 
BMW says it verifies that any remedial measures 
have been carried out at new suppliers by way 
of both internal and third-party assessments, and 
notes that DNV GL and PwC conduct some of the 
audits in its cobalt supply chain. It does not offer 
any further breakdown of the share of audits that 
are conducted by third parties.
  6    Remedies and Grievance 
Mechanisms
BMW has remedies and grievance mechanisms 
in place to address human rights issues, both in 
its own operations and its supply chains. BMW’s 
Compliance Contact helpline (available in En-
glish and German during defined weekday hours) 
and SpeakUP Line (available around the clock in 
34 languages) provide employees a way to raise 
queries or complaints relating to human rights is-
sues. The company treats such communications 
confidentially. As of 2016, BMW incorporates hu-
man rights as an integral component of its world-
wide Compliance Management System. In 2018, 
BMW launched a pilot version of a smartphone 
app that enables employees such as quality as-
surance engineers or purchasers to record suspi-
cious sustainability-related matters when visiting 
suppliers. In 2017, BMW established its Human 
Rights Contact Supply Chain, reachable at a Ger-
man phone number or by email, to enable report-
ing of human rights infringements in its supply 
chain. BMW’s Human Rights Response Team fol-
lows up on complaints and takes any necessary 
corrective action “to help resolve problems early 
on and prevent the individuals concerned from 
suffering more severe consequences.” Represen-
tatives from specialist departments or external 
stakeholders may also be involved, depending on 
the nature of the case.
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  7    Participation or Leadership in Multi-Stakeholder Initiatives
BMW is a founding member of Drive Sustainability, the Aluminium Stewardship Initiative and the GIZ 
joint pilot project. It is a member of the RMI, and the company’s head of sustainability in the supply chain 
sits on the RMI steering committee. BMW follows the RMI’s Responsible Minerals Assurance Process. 
BMW is a member of the Responsible Cobalt Initiative and is represented on the RCI board. The company 
is a founding member of the Global Battery Alliance, established in 2020. BMW also became the first 
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About Bridgestone
Bridgestone is the world’s largest tire and rubber manufacturers. It has 143,509 full-
time employees. Bridgestone uses large amounts of natural rubber in tires and other 
products, most of which are supplied from Southeast Asia. Bridgestone notes that the 
natural rubber supply chain is massive and fragmented, and made up of many layers 
of small holders and farmers, medium to large estates, raw material dealers, processing 
plants and rubber product manufactures. The company has approximately 2,450 Tier 1 
suppliers.
  1    Human Rights Policy
Bridgestone implemented its Global Human Rights Policy and its Global Sustain-
able Procurement Policy, in 2018. The company makes a baseline commitment 
to respect fundamental human rights and responsible labor practices through-
out its worldwide operations. Bridgestone’s human rights policy “respects” the 
UDHR, the UNGPs and “various” ILO conventions. In its sustainable procure-
ment policy, the company offers a caveat: “Implementing these norms is not 
as straightforward as writing them down in a policy or guidance document. 
Bridgestone must consider the unique characteristics and circumstances of each 
region from which it sources products and services, to identify ways to continu-
ally improve sustainability.”
Bridgestone’s human rights policy says it applies to its own employees and com-
panies, but that it “expects” its vendors and suppliers to “uphold” the policy as 
well. Bridgestone released its procurement policy to all Tier 1 and 2 suppliers in 
2018 and is rolling it out to Tier 3 suppliers in 2019. The company says at the be-
ginning of the policy that it applies to “all points” of its “various supply chains.” 
At another point in the policy, however, Bridgestone says, “Direct Suppliers are 
required to comply with the Policy and encouraged to extend/share it with their 
own suppliers, with the aim of reaching into the supply chain, back to the Point 
of Origin, if possible.” Ultimately, after 38 pages of internal inconsistencies, re-
petitive language and wordy generalities, the policy’s human rights requirements 
of suppliers largely boil down to legal and regulatory compliance. The company 
does reiterate its prohibition on forced labor and the worst forms of child labor 
in its sustainable procurement policy.
Bridgestone’s human rights policy does not include a commitment to stakehold-
er engagement. Its sustainable procurement policy says it “embraces” stakehold-
er engagement and the principles of free, prior and informed consent (FPIC), and 
“encourages” its suppliers to do the same. 
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  2    Human Rights Governance 
Embedding
Under Bridgestone’s Global CSR management 
system, the company says its Human Rights, La-
bor Practices working group verifies the progress 
of its global efforts and reports to its Global CSR 
Enhancement Committee (GCEC) and top man-
agement in each strategic business unit and re-
gional office. Bridgestone says it has appointed 
a Chief Human Rights Officer. It is unclear how 
senior this position is and what its reporting lines 
are. Bridgestone has incorporated human rights 
more thoroughly into its topline business mod-
el in the last two years, and has named human 
rights as one of its six management fundamentals. 
  3    Supplier Code of Conduct
While Bridgestone does not have a supplier code 
of conduct, its sustainable procurement policy 
fills a similar purpose, though it appears to be less 
binding. As noted in previous sections, Bridge-
stone says its supplier requirements are meant 
to cascade down the value chain, but its actual 
requirements—as opposed to suggestions—are 
currently limited in scope.
Bridgestone’s policy includes a commitment to workplace health and safety. It also requires suppliers “to 
make potable water, sanitation, rest areas, emergency exits, and emergency aid available and visible to 
all employees, as appropriate.” Bridgestone’s policy does not carve out protections for indigenous rights. 
Its sustainable procurement policy includes indigenous peoples among the stakeholders with whom it 
“embraces” engagement.
Bridgestone’s policy does not directly prohibit involuntary resettlement. The company’s sustainable pro-
curement policy says Bridgestone “believes that people should receive fair compensation and resettlement 
for land use activities that infringe on their rights and/or livelihoods,” and includes a general prohibition 
on land grabbing. The company’s policy prohibits harassment and discrimination and commits “to pro-
tecting the rights of individuals in traditionally under-privileged groups and expanding their employment 
opportunities.”
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  4    Traceability and Supply Chain 
Transparency
Bridgestone’s sustainable procurement policy in-
cludes a general commitment to traceability but 
lacks specifics. The company says it will share 
more information publicly as it makes progress. 
The company says its suppliers are required “to 
make best efforts” to have full knowledge of the 
products and services they supply to Bridgestone, 
and to furnish that information upon request. 
Bridgestone says it is evaluating traceability pilots 
based on its sustainable procurement policy cri-
teria, and is “promoting” full standardization of 
natural rubber industry practices and sustainable 
policies according to best practices to be estab-
lished by the new Global Platform for Sustainable 
Natural Rubber.
Bridgestone discusses its natural rubber supply 
chain, which is primarily located in Southeast 
Asia. The company says that when it conducts 
due diligence in its natural rubber supply chain, 
it “will refer” to the OECD Due Diligence Guide-
lines. Bridgestone is involved in industry initia-
tives to promote full traceability in its natural 
rubber supply chain.
  5    Human Rights Due Diligence / 
Embedding
In formulating its new sustainable procurement 
policy, Bridgestone says it conducted a “far-reach-
ing” survey on the issues and needs associated 
with its procurement activities, including human 
rights. The company says it consulted with exter-
nal stakeholders, including international consul-
tants, NGOs, materials suppliers, natural rubber 
farmers and key customers. It has not yet publicly 
identified its salient human rights risks and im-
pacts on an ongoing basis.
Bridgestone says all of its employees “have been 
introduced” to its new human rights policy, and 
managers are receiving in-depth training in 2019. 
The company says it hosts conferences and pro-
vides training for suppliers on its sustainable pro-
curement policy and human rights, but does not 
provide details specific to human rights. Bridge-
stone says it assesses the human rights and labor 
practices of potential new operations and proj-
ects, as well as new and existing suppliers. It pro-
vides no further details.
Bridgestone does not disclose how it monitors and 
evaluates the effectiveness of actions to respond 
to human rights risks and impacts. It does not ap-
pear that Bridgestone conducts supplier audits. 
The company refers only to “assessments,” which 
appear to be remote. Bridgestone says that if a 
supplier fails to meet the minimum requirements 
delineated in its sustainable procurement policy, 
it “may” support the supplier to bring it into com-
pliance. Should that fail, Bridgestone says it “will 
reconsider its relationship with that Supplier, up 
to and including termination of that relationship.” 
The company does not provide specific examples 
of remedial action. 
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  6    Remedies and Grievance Mechanisms
Bridgestone says it will increase its efforts to address various human rights grievances, such as discrimi-
nation or harassment, in the next three years. The company does not elaborate. The company says it has a 
global, 24-hour hotline available to all employees who have questions about its human rights policies or 
want to report concerns. Bridgestone also says it operates a Supplier’s Whistleblowing Channel, without 
offering details. It is not clear by what means communications are possible, if they are available free of 
charge in every country in Bridgestone’s value chain, etc.
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  7    Participation or Leadership in Multi-Stakeholder Initiatives
Bridgestone says it has “contributed to past work” with the Sustainable Natural Rubber Initiative (SNR-i). 
It is not clear if the SNR-i remains active. Bridgestone is a member of the GPSNR, and briefly describes its 
efforts with that group to improve traceability in its natural rubber supply chain. 
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C O M PA N Y  P R O F I L E S
About Continental
Continental develops products, systems and services for customers in various industries 
worldwide, including the automotive, railway engineering, machine and plant 
construction, and mining industries, as well as the replacement sector. Continental 
counts steel, aluminum, precious metals, copper and natural rubber among its key raw 
materials, and includes electronics among its key production materials.
  1    Human Rights Policy
Continental has a human rights policy, includes a commitment to human rights 
and fair working conditions in its annual report, and expanded its Code of Con-
duct in 2019 to include a section on human rights and fair working conditions. 
Continental says in its annual and sustainability reports that it “bears a respon-
sibility to respect human rights” in accordance with the UNGPs. The company 
uses similarly non-committal language in its human rights policy, saying, “we at 
Continental feel duty bound to actively promote the observation of human rights 
where we can.” Continental says it is committed to the UNGC. Somewhat nebu-
lously, the company says in its UK Modern Slavery Act disclosure that “the work 
on putting these principles to practice is led by” the UNGPs and ILO core labor 
standards. Its Code of Conduct says the ILO standards “guide our work,” and its 
Business Partner Code of Conduct says Continental “follows” the UN UDHR.
Continental says its Code of Conduct applies to its own operations, all of its sub-
sidiaries and minority holdings in which it exercises management control. The 
company says it commits its suppliers to its human rights and fair working con-
ditions principles by way of its Business Partner Code of Conduct and Natural 
Rubber Sourcing Policy. The former only requires that its business partners use 
their “best efforts” to require n-tier suppliers and subcontractors to comply with 
the code, while the latter explicitly requires cascading down the entire natural 
rubber value chain.
Continental’s Code of Conduct says it “firmly rejects” any form of child labor, 
but stops short of specifically committing to the relevant ILO conventions or the 
provisions therein. However, its Natural Rubber Sourcing Policy specifies that 
participants in its upstream natural rubber supply chain must comply with the 
relevant ILO conventions on child labor.
Continental’s Code of Conduct says it “firmly rejects” any form of forced labor, 
but stops short of specifically committing to the relevant ILO conventions or the 
provisions therein. However, its Natural Rubber Sourcing Policy specifies that 
participants in its upstream natural rubber supply chain must comply with the 
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  2    Human Rights Governance 
Embedding
Continental outlines senior level responsibility 
for human rights and the organization of day-to-
day responsibility for human rights across rele-
vant internal functions only in general terms. It 
discusses lines of responsibility for its sustainabil-
ity approach, of which human and labor rights 
are factors, but does not get into specifics.
Continental formed its new Sustainability de-
partment in 2018, with a position dedicated spe-
cifically to coordinating human rights-related 
measures. The department coordinates and de-
velops the company’s sustainability strategy, and 
coordinates Continental’s interdepartmental Sus-
tainability Committee. Additionally, Continental 
says, “sustainability experts have been deployed 
in the relevant purchasing departments.”
Dr. Ariane Reinhart is a member of Continental’s 
executive board, and is responsible for human re-
lations and sustainability.
Continental has an internal network of experts on 
labor relations and working conditions, which it 
expanded in 2018 to provide fixed contact peo-
ple in 11 countries, coordinating the work of 
more than 70 percent of the company’s employ-
ees. This network’s responsibilities cover Con-
tinental’s own operations, and do not appear to 
extend to broader human rights issues or to its 
supplier network. 
relevant ILO conventions on forced labor. Further muddying the waters, in its California Transparency in 
Supply Chains Act disclosure, Continental says, “We do not currently require that all suppliers certify in 
any written form that they comply with anti-slavery and human trafficking laws specifically.”
Continental has a general, company-wide commitment to stakeholder engagement, but this does not ap-
pear specifically in its overall human rights policies. However, its Natural Rubber Sourcing Policy specifies 
that participants in its natural rubber supply chain must comply with FPIC principles. 
Continental’s company-wide human rights policies do not address ethical recruitment. However, its Nat-
ural Rubber Sourcing Policy specifies that participants in its upstream natural rubber supply chain must 
comply with the relevant ILO conventions on minimum salaries, and requires the existence of written 
employment contracts. The policy specifically requires suppliers to respect the rights of migrant workers 
and exercise ethical recruitment practices, including no direct or indirect recruitment fees for workers.
Continental’s Code of Conduct includes protection for its employees’ freedom of association and third-par-
ty representation, without referencing the relevant ILO conventions. However, its Natural Rubber Sourcing 
Policy specifies that participants in its upstream natural rubber supply chain must comply with the relevant 
ILO conventions on freedom of association and collective bargaining.
Continental’s Code of Conduct says any form of harassment or abuse “will not be tolerated,” and includes 
a commitment to discrimination-free working environments. Its Natural Rubber Sourcing Policy specifies 
that participants in its upstream natural rubber supply chain must comply with the relevant ILO conven-
tions on discrimination.
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  3    Supplier Code of Conduct
Continental has a Business Partner Code of Conduct that describes human rights as “an essential princi-
ple” of the company’s business activities, and requires that its business partners—including suppliers—ob-
serve basic human rights set forth in the UDHR and the ILO’s Tripartite Declaration. The Business Partner 
Code of Conduct is relatively toothless, requiring only that its business partners use their “best efforts” to 
require n-tier suppliers and subcontractors to comply with the code, and is generally more limited than 
the company’s own Code of Conduct.
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  4    Traceability and Supply Chain 
Transparency
Continental has a Natural Rubber Sourcing Poli-
cy that is largely aspirational. The company notes 
that the policy “marks a starting point for a joint 
journey [with its business partners] towards a 
more sustainable value chain for natural rubber.” 
Continental describes a fragmented supply chain 
in which 85 percent of rubber tree areas world-
wide are owned by small farmers. As a midstream 
operator, Continental does not interact directly 
with farmers—dealers, processors and traders oc-
cupy the intermediary segments of the chain. The 
policy identifies the following human rights-relat-
ed “areas for development”:
•	 Engaging with suppliers and farmers: Con-
tinental describes in general terms its aim 
to collaborate with relevant partners in 
engaging with and training farmers, and 
says it has a pilot project in Indonesia to 
“improve the sustainability of the natural 
rubber supply chain.” It aims to develop a 
set of criteria on which it trains farmers and 
tracks rubber from farms to its production 
facilities.
•	 Stakeholder 
engagement: 
Continental 
makes a general commitment to engage 
1 If such projects are successful, and rubber supply shifts away from traditional sourcing regions, farmers and communities are 
likely to suffer additional hardships as their revenue streams dry up.
stakeholders in the natural rubber value 
chain, referencing its participation in the 
GPSNR.
•	 Traceability: Continental says it has a target 
of achieving full traceability of its natural 
rubber supply chain, but does not offer a 
target date. The company aims to establish 
audit and verification processes as part of 
this effort.
•	 Identifying alternative supply sources: Con-
tinental is researching the possible use of 
rubber derived from Russian dandelion 
plants, which can be grown in temperate 
regions.1 
Continental reiterates its commitment to FPIC and 
its opposition to land grabbing in its natural rub-
ber sourcing policy. It also requires its business 
partners to “respect people’s land tenure rights,” 
grant “access to land and produce” and “grant 
fair compensation to local communities to allow 
for conservation measures and/or commercial 
land use.” The company does not define these 
terms more specifically. The policy goes further 
than Continental’s company-wide policies when 
it comes to ethical recruitment and specific com-
mitments to ILO conventions. The company also 
explicitly says it expects suppliers “to cascade 
this policy down their respective supply chains.”
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  5    Human Rights Due Diligence / 
Embedding
Continental does not proactively identify its hu-
man rights risks and impacts on an ongoing ba-
sis. The company has identified its natural rubber 
supply chain as a risk area, and briefly mentions 
conflict minerals, but it does not indicate the 
presence of a clear global system. Continental 
provides limited disclosure on its general new 
supplier assessment procedures, which include a 
human rights component.
Continental provides online training on its Code 
of Conduct (which includes a human rights com-
mitment) to all new employees, and performs 
“regular” classroom compliance training ses-
sions at “various locations worldwide.” These are 
mandatory, particularly for employees who work 
in purchasing or who hold executive positions. 
Continental conducted a global workshop on 
sustainability and human rights in 2018 for the 
members of its internal labor relations network. 
However, in its California Transparency in Supply 
Chains Act disclosure, Continental says it “does 
not provide employees or contractors with train-
ing on human trafficking and slavery.”
Continental says it assesses human rights risks at 
potential suppliers prior to entering into any con-
tracts with them, primarily by means of a self-as-
sessment questionnaire. It does not disclose its 
response rate, the quality of the information it re-
ceives or what it does with that information. The 
company says its supplier contracts “include” its 
current Business Partner Code of Conduct “or its 
prior version.”
Continental’s Business Partner Code of Conduct 
only requires that its business partners use their 
“best efforts” to require n-tier suppliers and sub-
contractors to comply with the code, while its 
Natural Rubber Sourcing Policy explicitly re-
quires cascading down the entire natural rubber 
value chain.
Continental says it monitors compliance with 
its Business Partner Code of Conduct primarily 
through self-assessments. The company appears 
to conduct plant audits at some of its production 
materials suppliers on a limited basis. The com-
pany says it conducts plant visits as part of its 
review of potential new suppliers “to obtain an 
impression of the prevailing working conditions.” 
However, the company then says, “This is inte-
grated into the review if apparent deficits are as-
certained.” This language seems to suggest that it 
only conducts plant visits if its review—the nature 
of which it does not explain—finds problems—
the nature of which it also does not explain. In 
its California Transparency in Supply Chains Act 
disclosure, Continental is somewhat more specif-
ic, saying it requires all new production materi-
al suppliers to submit to a site audit. Continental 
says it “can” suspend the supply relationship in 
“extreme cases if agreed countermeasures do not 
yield the desired results.” The company does not 
elaborate.
Continental says in its Business Partner Code of 
Conduct that it “reserves the right to audit” its 
partners’ compliance with the code “in an ap-
propriate manner.” It is not clear whether this 
involves a physical audit or just a review of docu-
mentation. There is little evidence that Continen-
tal conducts unannounced audits. To the extent 
that it mentions the topic at all in its sustainabil-
ity reporting, the company says audits will be 
scheduled at “mutually agreed” times. Only in 
its California Transparency in Supply Chains Act 
disclosure does Continental say, “Announced and 
unannounced audits at existing supplier loca-
tions may be scheduled based upon unsatisfacto-
ry self-assessment results.” That disclosure is the 
company’s only element of public reporting that 
addresses the topic of third-party audits: Conti-
nental says that its own employees carry out site 
audits at potential new production materials sup-
pliers.
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  6    Remedies and Grievance 
Mechanisms
Continental has limited grievance mechanisms 
and remedies in place. The company says its 
Compliance and Anti-Corruption Hotline and 
website are available to both employees and ex-
ternal stakeholders to report code of conduct vio-
lations. Human rights are included in the code of 
conduct, although human rights violations are not 
listed among the issues the company says should 
be reported on its website. Reports can be made 
anonymously. The web reporting tool is available 
in multiple languages, and phone numbers are 
provided for multiple countries around the world.
Continental says it has a defined process to fol-
low up on complaints. By way of example, the 
company says it received a “large number” of re-
ports regarding its locations in Mexico in 2017 
and 2018, which it takes as an indication that the 
hotline is working as a reliable complaint mech-
anism and of a greater awareness of compliance 
issues. Continental says it conducted a system-
atic review of the cases, and found that the vast 
majority related to discrimination, unequal treat-
ment and mobbing. The company devised an ac-
tion plan to address the situation, which included 
the following steps:
•	 Sending letters to employees and business 
partners reminding them of fair working 
standards;
•	 Training local HR departments on case 
management and mediation; and
•	 Adding a new curriculum covering discrim-
ination, unequal treatment and mobbing to 
its existing Code of Conduct training, which 
99 percent of the “relevant employees with 
leadership and management responsibili-
ty” had completed by the end of May 2019.
Continental says it will continue monitoring these 
measures and their success in 2019. The compa-
ny does not provide a full global accounting of its 
remediation efforts.
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  7    Participation or Leadership in Multi-Stakeholder Initiatives
Continental is a member of the Global Platform for Sustainable Natural Rubber, a new initiative that has 
yet to finalize its operational strategy and build a track record.  
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D E N S O
C O M PA N Y  P R O F I L E S
About Denso
Denso manufactures and sells automotive components and systems, industrial products 
and home appliances. It has 171,992 employees worldwide. The company does not 
disclose details on its raw materials or supply chain.
  1    Human Rights Policy
Denso has a statement on its website called “Respect for Human Rights,” but its 
language is limited to matters of discrimination and harassment in its own op-
erations. The page is nested under the “responsibility to employees” section of 
its website. The company’s Declaration of Corporate Behavior contains a single 
statement under its “responsibility to employees” section saying it will “honor 
human rights” and “not tolerate any form of child or forced labor.” The com-
pany’s Code of Conduct contains both of these two elements, without adding 
anything additional.
Denso says it “consulted” the UDHR and “other international standards” in de-
veloping its human rights policy, but the policy itself bears little evidence of that 
fact. The company says it “has been requesting” that its partners abide by its 
“human rights” policy and Declaration of Corporate Behavior. It also says it re-
quires that suppliers “conclude a basic transaction contract that addresses issues 
such as… protection of human rights.” The company’s Supplier CSR Guidelines 
reiterate the above statements without elaboration, adding only a brief recom-
mendation that suppliers consider “human rights” in their own procurement and 
“take appropriate steps to avoid procurement of materials that can cause social 
problems (such as conflict minerals), or other human rights injustices.” 
Denso’s statement on “Respect for Human Rights” makes no reference to child 
or forced labor. Its Declaration of Corporate Behavior simply says it “will not tol-
erate any form” of child or forced labor. This statement appears under a section 
entitled “responsibility to employees.” There is no reference to ILO conventions 
or their provisions.
Denso says it is “working toward a management team that values dialogue with 
all stakeholders.” The company makes this statement generally, not with specif-
ic reference to human rights. The company includes a recommendation in its 
supplier guidelines that the “highest priority” be placed on health and safety 
programs, and says in its code of conduct that its own employees must comply 
with its Safety Standard. These topics are not framed within any human rights 
discussion.
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  2    Human Rights Governance 
Embedding
Denso provides no evidence of human rights gover-
nance embedding..
  3    Supplier Code of Conduct
Denso does not have a supplier code of conduct. 
The company’s Supplier CSR Guidelines reiterate the 
above human rights statements without elaboration, 
adding only a brief recommendation that suppliers 
consider “human rights” in their own procurement 
and “take appropriate steps to avoid procurement 
of materials that can cause social problems (such 
as conflicts minerals), or other human rights injus-
tices.”
  4    Traceability and Supply Chain 
Transparency
Denso briefly raises the issue of conflict minerals, 
acknowledging that it is “one of the most signifi-
cant social issues within the supply chain.” Denso 
says it has been involved in industry working groups 
that have been “retrospectively reviewing our sup-
ply chains step by step,” without elaborating. The 
company also says it “worked to establish efficient 
investigation methods that give consideration to the 
burden on suppliers.” It is not clear what this means, 
and Denso explains no further.
  5    Human Rights Due Diligence / 
Embedding
Denso says it trains all employees on its Code of 
Conduct, including the CSR elements, but does not 
provide any indication that it offers explicit human 
rights training. Its human rights policy says that it 
provides training on the topic, but the policy it-
self only addresses harassment and discrimination. 
Denso asks potential suppliers to complete self-as-
sessment questionnaires on CSR topics. In some 
cases, the company says, it follows up with on-site 
visits conducted by its own personnel. Denso does 
not elaborate, and the company provides no indi-
cation that human rights issues have ever affected 
a supplier relationship. Denso says it includes its 
Supplier CSR Guidelines in its supplier contracts, 
but offers no indication of any sort of enforcement.
  6    Remedies and Grievance Mechanisms
Denso says it has a Business Ethics Hotline that cov-
ers practices governed by the Code of Conduct. It 
offers no further details.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Continental is a member of the Global Platform for 
Sustainable Natural Rubber, a new initiative that 
has yet to finalize its operational strategy and build 
a track record. 
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F I AT  C H R Y S L E R  A U T O M O B I L E S
C O M PA N Y  P R O F I L E S
About Fiat Chrysler Automobiles
Fiat Chrysler Automobiles (FCA) designs, engineers, manufactures, distributes and sells 
vehicles, components and production systems. The company has 198,545 full-time 
employees. FCA’s primary raw materials are steel, rubber, aluminum, resin, copper, lead 
and precious metals (including platinum, palladium and rhodium). As the company 
implements various electrified powertrain applications, it says it will also depend on a 
significant supply of lithium, nickel and cobalt.
  1    Human Rights Policy
FCA publishes its Human Rights Guidelines in which it makes a baseline com-
mitment to internationally recognized human rights, although the language it 
uses is somewhat weak:
FCA is committed to the creation of long-term sustainable value for its stakehold-
ers, and is firmly convinced that the respect and support of fundamental human 
rights is essential for building a better future for our Company and the commu-
nities in which we do business. The global presence of the Group requires the 
adoption of generally accepted principles in every geographic area where FCA 
companies operate.
FCA says its Human Rights Guidelines are “consistent with the spirit and intent” 
of the UDHR, the SDGs, the OECD Guidelines, the ILO Declaration and the 
UNGPs. The company uses stronger language in its Code of Conduct, saying it 
“endorses” the UN Declaration on Human Rights, the ILO conventions and the 
OECD Guidelines.
FCA says it “promotes” its human rights principles “within its sphere of influ-
ence, expecting its suppliers, contractors and other business partners” to adhere 
to the standards set forth therein. The company’s code of conduct applies to its 
global workforce and subsidiaries, as well as “all temporary, contract and all 
other individuals and companies that act on behalf of” FCA. The code does not 
apply to companies in which FCA holds a minority interest, nor to its suppliers 
and dealers.
FCA’s Human Rights Guidelines say the company “does not use or condone” 
child labor. The company does not explicitly reference the relevant ILO conven-
tion, but sets the minimum working age at 15 “unless an exception is expressly 
supported by international conventions.” FCA does not say anything about lim-
iting hazardous work to those 18 or older—an additional element of the ILO 
convention. FCA’s Human Rights Guidelines say the company “does not use or 
condone” forced labor, without referencing the relevant ILO convention.
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  2    Human Rights Governance 
Embedding
FCA has various board- and executive level func-
tions that are charged with implementing its sus-
tainability policies, but the company does not 
disclose any specifics as to how these bodies 
might address human rights matters.
  3    Supplier Code of Conduct
FCA does not have a separate supplier code of 
conduct. The company uses vague language to 
indicate that it promotes and endorses its own 
Code of Conduct to suppliers, but they do not 
appear to be bound by it. FCA publishes its Sus-
tainability Guidelines for Suppliers that set out 
“expectations.”
  4    Traceability and Supply Chain 
Transparency
FCA has a target to increase traceability along its 
supply chain for “minerals that may be linked to 
human rights abuses” by 2020. 
FCA briefly addresses cobalt and mica, saying it 
uses and teaches its suppliers the OECD 5-Step 
Framework for Upstream and Downstream Sup-
ply Chains. The company does not elaborate on 
that process, offering no details as to whether that 
training is mandatory, how many suppliers par-
ticipate, how frequently it is administered, how 
efficacy may be monitored, etc. FCA also notes its 
participation in industry initiatives that deal with 
cobalt and mica. The company points to its use 
of the Cobalt Reporting Template based on the 
Conflict Minerals Reporting Template, without of-
fering any details as to how many suppliers have 
completed the template, what the results were, 
etc.
While FCA’s Human Rights Guidelines include an acknowledgment that it “promotes an open dialogue 
to ensure” that the “legitimate expectations” of the communities in its areas of operation “are taken 
into consideration,” the company stops short of a commitment to stakeholder engagement. FCA’s human 
rights guidelines say the company “respects” its workers’ freedom of association and collective bargaining 
agreements.
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  5    Human Rights Due Diligence / Embedding
FCA’s human rights guidelines says the company conducts an annual human rights survey as part of its 
standard audit process, “in order to cover” due diligence requirements in the UNGPs. FCA also relies on 
its Supplier Sustainability Self-Assessment (SSSA) to monitor human rights risks. The company requested 
SSSAs of 2,032 suppliers in 2018, of which only 38 percent responded. It is not clear if FCA imposes any 
penalty for non-response.
FCA says in its Modern Slavery Act disclosure that it trains its employees on its Code of Conduct, including 
human rights topics. The company says it “offers” training to its suppliers that it developed in collaboration 
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with AIAG “to help protect the rights and dignity 
of workers.” FCA also says it uses the training “to 
engage” its Purchasing and Supplier Quality de-
partments. The company does not provide further 
clarity or detail in its MSA disclosure. FCA also 
reports that it delivered Conflict Minerals and 
ethical sourcing training to 78 of its suppliers in 
2018. The company does not elaborate.
FCA says that for potential suppliers to meet its 
requirements, they “must demonstrate that they 
have adopted a code of conduct, a certified sys-
tem for managing employee health and safety, 
and a program that promotes sustainability, both 
internally and along the supply chain.” The com-
pany says it creates a risk map in its supplier as-
sessment that emphasizes countries with a poor 
human rights record. The supplier’s self-assess-
ment score and exposure to commodity risk is 
also included in the risk map, which helps FCA to 
prioritize supplier audits.
FCA says it requires any new supplier purchase 
order “to align with” its Code of Conduct and its 
Sustainability Guidelines for Suppliers, without 
elaborating. The company also says it monitors 
suppliers’ adherence to its Sustainability Guide-
lines for Suppliers, without elaborating.
FCA says it conducts audits at high-risk suppli-
er plants, but does not indicate specifically how 
human rights issues factor into that process. FCA 
says it plans to audit “all Tier 1 suppliers with po-
tential exposure to significant environmental or 
social risks” by 2020. The company says it con-
ducts its own audits and relies on third parties, 
but does not provide a breakdown of the two.
  6    Remedies and Grievance 
Mechanisms
FCA has basic grievance mechanisms in place, 
but provides no detail on remedies. Its human 
rights guidelines point to the company’s Ethics 
Helpline website for country-specific instructions 
on how to report potential misconduct. FCA in-
cludes a non-retaliation statement. While FCA 
says the helpline is available to its global work-
force, there appear to be some limitations on 
that. For instance, when navigating the website to 
find the country-specific guidance for Hungary, 
that guidance appears only in English, and refers 
to hotline prompts that are also in English. For 
Morocco, the website says FCA is “unable” to re-
ceive reports from that country, and encourages 
users in English to contact their supervisor.
FCA says its Ethics Helpline is also available to 
suppliers and other stakeholders “to request ad-
vice about the application of the Code of Con-
duct.” The company’s language is vague, and it is 
unclear if the wording is intended to imply that 
suppliers are restricted to using the helpline for 
inquiries, rather than reporting.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
FCA is a member of the RMI. The company notes 
that the RMI is collaborating with the Responsi-
ble Cobalt Initiative on a joint cobalt refiner pi-
lot audit program, but does not offer details as to 
its own role in that endeavor. FCA also serves as 
the co-lead of the AIAG Conflict Minerals Work 
Group and Conflict Minerals Smelter Engage-
ment Program. 
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F O R D  M O T O R
C O M PA N Y  P R O F I L E S
About Ford Motor
Ford Motor (Ford) designs, manufactures, markets and services a range of Ford cars, 
trucks, sport utility vehicles and electrified vehicles worldwide. It has 199,000 full-
time employees. Ford’s primary raw materials include base metals (steel, iron castings 
and aluminum), precious metals (palladium), energy (natural gas) and plastics/resins 
(polypropylene). The company has a complex supply chain with 1,200 Tier 1 suppliers 
and 10,000 indirect suppliers providing vehicle parts made of 1,000 different materials.
  1    Human Rights Policy
Ford has a policy letter on its Code of Human Rights, Basic Working Conditions, 
and Corporate Responsibility, last updated in 2012. The policy letter articulates 
the company’s “guiding principles” for human rights, labor and environmental 
standards throughout its operations worldwide. The company’s code of conduct 
does not specifically mention human rights; it points to and summarizes the 
policy letter, and provides expanded anti-harassment and health and safety sec-
tions. In its policy letter, Ford says its human rights principles are “consistent 
with, and in many instances derived from,” the following international human 
rights conventions, among others. 
•	 UN Universal Declaration of Human Rights
•	 UN Guiding Principles
•	 UN Global Compact
•	 OECD Guidelines
•	 ILO Declaration on Fundamental Principles and Rights at Work
•	 ILO Tripartite Declaration
Ford’s human rights policy letter is not binding on suppliers, though the compa-
ny says it “encourages” its suppliers to align their practices with the provisions 
therein and seeks to identify and do business with companies that do so. It also 
appears not to be binding on subsidiaries and affiliates, as the company says 
those entities “should adopt a similar directive.” 
Ford’s prohibition on child labor is consistent with the relevant ILO convention 
without explicitly mentioning it, although it does not address hazardous work. 
Ford prohibits forced labor, without referencing the relevant ILO convention. 
Ford’s policy letter does not include a commitment to stakeholder engagement. 
Its sustainability report includes a statement that says it collaborates with all of 
its stakeholders to combat human rights violations.
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  2    Human Rights Governance 
Embedding
Ford’s Sustainability and Innovation Committee 
is charged with improving the company’s social 
sustainability, among other things, and its charter 
specifically includes human rights. Ford says its 
vice president of sustainability, environment and 
safety engineering is responsible for “interpreting” 
its policy letter that deals with human rights, with 
the “concurrence, as appropriate,” of the compa-
ny’s executive vice president of global manufac-
turing and labor affairs, its group vice president 
of global purchasing and its group vice president 
and general counsel. The letter also names the 
company’s managers of social sustainability and 
supply chain sustainability. Ford further says that 
it has human rights managers in “many parts” of 
its organization, including human resources, per-
sonnel relations, purchasing, sales, safety, global 
labor strategy, sustainability, office of the general 
counsel and within its global business units.
  3    Supplier Code of Conduct
Ford’s own Code of Conduct makes no mention 
of human rights, although it does include anti-ha-
rassment and health and safety provisions. It does 
not have a separate code of conduct for suppliers.
  4    Traceability and Supply Chain 
Transparency
Ford says it “aspires” to source all of its raw mate-
rials responsibly. The company is a member of the 
Public Private Alliance for Responsible Minerals 
Trade, through which it says it works to develop 
traceability solutions.
Ford discloses some details about its 3TG smelt-
ers, including their names and countries, saying 
it expects its suppliers to source those minerals 
from smelters that conform to third-party sourcing 
validation programs such as the London Bullion 
Market Association (LBMA), Responsible Jewelry 
Council (RJC) and RMI’s Responsible Minerals 
Assurance Process (RMAP). While Ford recogniz-
es LBMA and RJC audit status, in contacts smelt-
ers and refiners directly to ask them to participate 
in RMI RMAP. According to its 2018 smelter as-
sessment, 100 percent of the tantalum in its sup-
ply chain comes from RMI-conformant smelters. 
However, 29 percent of the gold smelters in its 
supply chain are not RMI-conformant, along with 
eight percent of its tin smelters and seven percent 
of its tungsten smelters. Ford has been working 
with its suppliers to improve in this area, and has 
seen an increase in the number of its suppliers 
that use only RMI-conformant smelters or refin-
ers. It is also an active member of the RMI Smelter 
Disposition team and the AIAG Smelter Engage-
ment Team.
While Ford’s policy letter does not address ethical recruitment, the company is one of the few in the 
research universe with specific ethical recruitment provisions in its Supplier Social Responsibility and 
Anti-Corruption Requirements. It requires suppliers not to confiscate employees’ identity or immigration 
documents, use misleading or fraudulent recruitment tactics or charge recruitment fees.
Ford’s policy letter includes a recognition of indigenous people’s “interests,” along with a commitment to 
“work constructively” with those communities where relevant.
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Ford says it has joined an IBM-led project, along 
with LG Chem and Huayou Cobalt, to use a 
blockchain platform to digitally map cobalt 
throughout its value chain. One of the compa-
ny’s goals for 2019 is to develop the Responsible 
Sourcing Blockchain Network (RSBN) Minimal 
Viable Product with cross-industry partners and 
other supply chain partners to improve cobalt 
traceability. Ford expects to extend the project 
to 3TG and other materials, but does not offer a 
time frame for this.
Ford says it has processes in place to identify and 
responsibly source “materials of concern,” which 
it currently lists as tin, tantalum, tungsten, gold, 
cobalt, mica and rubber. Ford discloses the sus-
pected countries of origin of its 3TG inputs, which 
currently include covered countries: DRC, Zam-
bia, Uganda, Rwanda, Burundi and Tanzania.
While cobalt is not included in the Dodd-Frank 
definition of conflict minerals, Ford expanded its 
conflict minerals risk assessment to include initial 
due diligence on cobalt in 2018. It asked cobalt 
refiners to complete a smelter identification ques-
tionnaire and encouraged cobalt refiners to par-
ticipate in RMAP. Ford also participated in RMI’s 
cobalt pilot, surveying its strategic cobalt suppli-
ers using RMI’s Cobalt Reporting Template and 
providing feedback on the process. Ford provided 
this disclosure in its conflict minerals report to the 
SEC, even though it is not legally bound to do so. 
Ford briefly addresses mica, saying it monitors 
responsible sourcing through “regular dialogue 
with key coating suppliers.” The company says it 
maps its Tier 1 mica suppliers, reviews third-party 
mica mine audits and participates in cross-indus-
try investigations. Ford does not elaborate.
Ford briefly addresses rubber, saying it works 
with OEMs, tire manufacturers, civil society and 
consultants to promote sustainable natural rubber 
sourcing, and contributes to several multi-stake-
holder initiatives and third-party research.
  5    Human Rights Due Diligence / 
Embedding
Ford says it conducted a human rights saliency 
assessment in 2018 that was the first of its kind in 
the automotive industry. The assessment, which 
Ford “conducted in line with” the UN Guiding 
Principles Reporting Framework, identified the 
human rights issues “most at risk of having a se-
vere negative impact.” Ford says the assessment 
included a review of internal documents and 
media reports, interviews with stakeholders (in-
cluding employees, suppliers and investors) and 
industry experts and a workshop to validate find-
ings with internal and external stakeholders.
Ford says it has conducted more than 40 human 
rights assessments since 2004, evaluating how its 
facilities around the world align with its policy 
letter that deals with human rights. It has made 
the more recent ones available to the public. The 
company says it conducts an annual analysis of 
the human rights risks associated with its supply 
chain, incorporating input from external stake-
holders. The analysis considers commodity- and 
country-specific risk. As of 2019, Ford says it has 
a list of 22 high-priority countries. Ford says it has 
put together action plans to “address and reme-
diate” the issues it identified in its human rights 
saliency assessment. These include mechanisms 
to track the effectiveness of its efforts, and will 
inform a review and update of its human rights 
policy. The company says it will review its salient 
human rights issues annually and communicate 
its progress externally.
Ford says it trained 773 of its purchasing em-
ployees on its policy letter that addresses human 
rights and its supply chain sustainability program, 
“focusing on identifying and reporting warning 
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indicators for potential human rights violations.” 
The company says it has trained 4,741 of its sup-
plier technical assistance personnel to date. Ford 
also reports that more than 1,000 of its purchas-
ing staff participated in learning sessions in 2018 
that focused on “the role that purchasing can play 
in responsible sourcing, business ethics and pre-
venting human trafficking.”
Ford provides training to suppliers it prioritiz-
es on the basis of its annual human rights risk 
assessment, via both e-learning and in-person 
workshops delivered through the AIAG or Drive 
Sustainability, and says participants “must verify” 
that they have shared the information with their 
employees and direct suppliers. Ford gives no in-
dication that such supplier training is mandatory. 
The company reports on the total number of ses-
sions conducted and sites trained/retrained, but 
does not offer context. While Ford has a section 
entitled “training results” in its Sustainability Re-
port, it only reports on the number of suppliers 
and countries that received training, rather than 
any mechanism to assess impact.
Ford says it includes cobalt due diligence ques-
tions into its Request for Quotation for batter-
ies. Apart from that, it is not clear to what extent 
Ford integrates human rights due diligence into 
purchasing decisions. The company “invites” 
its suppliers to complete Drive Sustainability’s 
Self-Assessment Questionnaire. Ford says more 
than 1,000 suppliers have done so, representing 
a substantial majority of its supplier base. Ford’s 
Global Terms and Conditions for suppliers are 
not available to the public, but the company says 
they forbid the use of forced labor, child labor 
and physically abusive disciplinary practices. 
Ford’s Aligned Business Framework (ABF) works 
with select suppliers “to strengthen collabora-
tion and develop a sustainable business model to 
drive mutual profitability and technology devel-
opment.” Ford requires ABF suppliers to have a 
code of conduct that aligns with its own policy 
letter that deals with human rights, to provide in-
ternal training on that code and to verify that their 
own suppliers “are compliant with our shared 
standards and expectations.” As a priority status 
for key suppliers, ABF can be considered an in-
centive for good practices. Ford currently has 84 
production and 30 indirect ABF suppliers.
Ford says it conducts social responsibility audits 
and follow-up assessments at some supplier lo-
cations to evaluate how well those suppliers are 
meeting Ford’s expectations and “identify areas 
for improvement.” The company says in its sus-
tainability report that it has adopted the RBA’s 
Validated Audit Protocol (the name of which has 
since changed to Validated Assessment Program), 
which includes human rights factors.
Ford says it conducts social responsibility audits 
of its suppliers, though it does not disclose how 
human rights factors specifically play out in this 
process. The company says it requires suppliers 
to develop action plans to address “non-confor-
mances” uncovered by its audits. For more seri-
ous “non-conformances,” the company requires 
immediate containment plans and longer-term 
corrective plans that it reviews and monitors. Ford 
says it “reserves the right” to terminate a supplier 
relationship if that supplier fails to comply with 
the company’s requirements. Ford did not termi-
nate any supplier relationships over human rights 
violations in 2018. Ford ended its relationship 
more than a dozen years ago with National Min-
eral Trading after it emerged that the supplier had 
sourced charcoal made with forced labor. Ford 
does not disclose if it has had occasion to termi-
nate any other supplier relationships.
Ford reports that the “non-conformances” its 
2018 audit process uncovered involved working 
hours and consecutive days of work, fees charged 
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to employees, insufficient policies and proce-
dures to ensure compliance with forced and child 
labor strictures, discriminatory practices (includ-
ing pregnancy testing, requiring military status 
disclosure in the hiring process and insufficient 
religious accommodation) and health and safe-
ty issues (particularly ineffective emergency exit 
plans, insufficient fire extinguishers and missing 
personal protective equipment). While audits did 
not uncover any instances of child or forced labor, 
they did find several instances of workers aged 15 
to 18 performing night work. Corrective actions 
included the installation of electronic timekeep-
ing equipment, training, facility improvements 
and technical support.
All of Ford’s audits are announced and conducted 
by independent third parties.
  6    Remedies and Grievance 
Mechanisms
Ford’s “The Right Way” mobile app is a publicly 
available mechanism by which employees, sup-
pliers and other stakeholders can report human 
rights concerns from anywhere in the world. It 
is available at all hours in seven languages. The 
company references “telephone hotlines, web-
sites or email” that are available to its employees 
for reporting policy violations, saying that some 
of them allow for anonymous reporting. It does 
not elaborate, and does not appear to have a 
non-retaliation policy.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Ford says it participated in a cross-industry, 
multi-stakeholder task force led by GRI in 2018 
to develop a toolkit to assist businesses in their 
modern slavery reporting efforts. Ford is a UNGC 
signatory, and participates in the UNGC Supply 
Chain Sustainability Advisory Committee.
Ford is a member of the AIAG and its Corporate 
Responsibility Steering Committee and Board 
of Directors. The company also co-chairs the 
AIAG’s Supply Chain Sustainability Committee, 
and chairs the AIAG Smelter Engagement Team 
that coordinates outreach directly to smelters and 
refiners.
Ford is a member of Drive Sustainability. It was 
the first automotive manufacturer to join the 
Responsible Business Alliance, and currently 
serves on the organization’s board of directors. 
The company says it also participates in the RBA’s 
Responsible Labor Initiative, Validated Audit Pro-
cess workgroup and Tools workgroup.
Ford is a member of the Responsible Minerals 
Initiative, and an active member of RMI’s Smelt-
er Disposition team. The company says it is an 
active member of various RMI workgroups—
including Cobalt, Gold, Blockchain, Smelter 
Engagement Team, CMRT, Multi-stakeholder, 
Plenary and Due Diligence Practices—through 
which it contributes to the development of RMI 
tools and processes used to support the compa-
ny’s own programs.
Ford is a member of the PPA. It says its active par-
ticipation and leadership with PPA (Ford served 
on its governance committee from 2013 to 2017) 
have contributed to a series of PPA grants aimed 
at improving conditions for miners and build-
ing conflict-free minerals capacity supply in the 
Dodd-Frank-defined covered countries. Ford is 
also a founding member of the Global Platform 
for Sustainable Natural Rubber.
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About General Motors
General Motors (GM) designs, builds and sells cars, trucks, crossovers and 
automobile parts worldwide. It has 173,000 full-time employees. GM’s primary 
raw materials are steel, aluminum, resins, copper, lead and platinum group 
metals. 
Labor relations: In late 2019, GM was embroiled in a labor dispute with the 
United Auto Workers (UAW) union, which had launched a strike that lasted 
almost six weeks. Sticking points centered around wages, health care and the 
especially thorny subject of temporary workers. Temps, many of whom are 
union members, often work side by side with permanent employees, doing the 
same work for half the pay and far fewer benefits. Agreeing to let automakers 
increase use of temps was a concession as automakers floundered heading 
into the Great Recession a decade ago. Some temps work years and lack a 
clear path to being hired permanently. The UAW wanted a process in place 
to help those workers become permanent and, while under temporary status, 
to get pay and benefits that more closely matched that of their permanent 
counterparts. Temps make up 7 percent to 10 percent of GM’s workforce over 
the course of a year, accounting for about 4,100 workers at the end of 2018. 
The strike was the longest GM had sustained since the 1970s. The strike had 
knock-on effects on other GM employees not represented by the UAW, with 
GM laying off more than 1,200 workers. The strike ended in October 2019 
when the UAW and GM reached a contract agreement.
  1    Human Rights Policy
GM has a Human Rights Policy, and articulates additional human rights policies 
and practices in various other documents. GM appears at first glance to make 
a baseline commitment to human rights in its Human Rights Policy, although 
vague wording calls that commitment into question. For instance, it says the 
policy “strives to make clear and transparent how we define, approach, govern 
and support universal human rights and dignity of people throughout our op-
erations, our communities in which we operate, and our global supply chain.” 
[emphasis added] That statement does not actually assert support for universal 
human rights, but rather promises to explain the company’s position thereon. 
Subsequently, it says the policy “acknowledges internationally recognized hu-
man rights principles,” again not committing to the same. GM goes on to ad-
dress specific aspects of human rights, as detailed below, but when it comes to 
certain core human rights issues—particularly child and forced labor—GM’s 
Human Rights Policy only asserts compliance with applicable laws and unde-
fined “prohibitions.” 
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  2    Human Rights Governance Embedding
GM says its board member, Theodore M. Solso, has specialized human rights knowledge, but its basis for 
that assertion is solely that Solso has served as CEO of Cummins and Chairman of GM’s board, and oc-
cupied senior positions at other global public companies. This does not amount to specific human rights 
expertise. 
GM says it has created a compliance group within its Global Purchasing and Supply Chain function that 
is responsible for overseeing and enhancing its sustainability efforts, among other things, including its 
conflict minerals and supplier awareness programs. 
GM says its Human Rights Policy is “guided by” the UN Global Compact, and is “informed by” the UN 
Guiding Principles, International Bill of Human Rights and ILO Declaration on Fundamental Principles 
and Rights at Work. The company’s Human Rights Policy is vague as to its applicability. As noted above, 
the policy says it “strives to make clear and transparent” how it approaches matters of human rights, in-
cluding in its supply chain, and says the company “looks to partner” with businesses that share its “values 
and position on human rights.” However, the only actual expectation of suppliers GM articulates is that 
they comply with the laws and undefined “prohibitions” highlighted below.
Regarding child labor, GM’s Human Rights Policy asserts its compliance with “prohibitions on the employ-
ment of underage children,” without identifying those prohibitions. The phrase appears in a paragraph that 
otherwise asserts only legal compliance. The company’s Supplier Code of Conduct and Conflict Minerals 
Policy say it has a zero-tolerance policy against the use of child labor, without defining child labor or refer-
ring to external definitions. Regarding forced labor, GM’s Human Rights Policy includes only an assertion 
of legal compliance. The policy further asserts the company’s compliance with “prohibitions on human 
trafficking,” without identifying those prohibitions. The company’s Supplier Code of Conduct is slightly 
stronger, saying suppliers “will not use slave, prisoner or any other form of forced or involuntary labor.”
GM’s Human Rights Policy includes an affirmation that the company employs ethical recruitment practic-
es and prohibits recruiters from charging recruitment fees and withholding identity documents. The com-
pany also commits to providing employees access to their employment contracts, where such exist, and to 
paying “fair wages.” GM’s Supplier Code of Conduct is slightly weaker on this point, saying, “If necessary 
for a supplier to use a labor broker, the supplier will ensure the broker employs ethical recruitment prac-
tices, complies with applicable laws, and does not withhold identity documents.”
Regarding worker health and safety, GM’s Human Rights Policy includes only an assertion of legal com-
pliance. Its Supplier Code of Conduct is stronger on this point, with expectations that suppliers provide 
safety procedures and tracking tools with a goal of zero workplace safety incidents and asserting the right 
of suppliers’ employees to refuse unsafe work and report unsafe conditions.
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  3    Supplier Code of Conduct
GM has a Supplier Code of Conduct that ar-
ticulates its “expectations” of its suppliers and 
business partners. Much like its Human Rights 
Policy, the expectations in GM’s Supplier Code 
of Conduct are vaguely defined, and largely fo-
cus on legal compliance. GM says it “expects that 
its suppliers will cascade similar expectations 
through their own supply chains.”
  4    Traceability and Supply Chain 
Transparency
GM makes commodity-specific commitments to 
improved transparency and traceability. The com-
pany provides a list of its identified conflict miner-
als smelters and refiners. It does not disclose their 
locations. GM is working with the AIAG to define 
“cobalt refiner,” in order to help identify choke 
points in the cobalt supply chain. The company 
explains this is necessary because of “the limited 
number of known cobalt refiners.”
GM says it is working “directly and actively” on 
a cobalt subteam of the RMI to develop a Cobalt 
Reporting Template based on the CMRT. In addi-
tion to its cobalt refiner identification work, GM 
is also working to coordinate with other cobalt 
associations to establish a common assessment 
standard for cobalt refiners.
  5    Human Rights Due Diligence / 
Embedding
GM says it requires all of its supplier quality em-
ployees who visit supplier facilities to take AIAG 
training on responsible working conditions, in-
cluding child/slave labor. The company also says 
it holds webinars and provides external training 
to improve supplier operations, including on hu-
man rights matters. The company does not elab-
orate.
GM says it has a supply chain visibility tool that 
helps it generate risk scores for its Purchasing 
team to factor into the sourcing process. The 
company says the tool contemplates catastroph-
ic events, such as natural disasters, and isolated 
disruptions, such as factory fires and labor strikes, 
but does not disclose to what extent it factors in 
broader human rights criteria.
GM assesses human rights risks at potential sup-
pliers prior to entering into any contracts with 
them to see if they might run afoul of Dodd-Frank. 
There is no evidence that it does so for broader 
human rights risks. In order to comply with its ob-
ligations under Dodd-Frank, GM’s standard terms 
and conditions for purchase contracts include a 
requirement that its direct suppliers report their 
use of 3TGs. More generally, the company says 
it outlines its “expectations for supplier conduct” 
in its purchase contract terms and conditions, 
in which it says it “clearly states” its prohibition 
against child and forced labor. It is unclear if this 
is simply a reference to its Supplier Code of Con-
duct, or something additional.
GM says that when its suppliers “act responsibly,” 
it “rewards them with greater business opportuni-
ties.” The company does not disclose to what ex-
tent human rights performance is a specific factor 
in that. GM extends some human rights expecta-
tions beyond first-tier suppliers, but does not do 
so in a systematic, comprehensive manner.
While GM mentions supplier audits, these appear 
to focus on environmental matters. There is no 
specific mention of human rights considerations.
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  6    Remedies and Grievance 
Mechanisms
GM says its employees, suppliers, contractors and 
others can report any incidents or concerns relat-
ed to human rights using the company’s Aware-
line around the clock by telephone, Web, email, 
postal service or fax. GM also has a non-retalia-
tion policy in place, and allows for anonymous 
reporting where not prohibited by law. GM does 
not disclose anything related to remedial action.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
GM is a signatory to the UN Global Compact. The 
company is a founding member of the GPSNR. 
GM said it worked closely with relevant stake-
holders to ensure the GPSNR incorporated all el-
ements of the supply chain.
GM is a member of the RMI, as well as its Smelter 
Engagement Team. The company is working with 
RMI to identify choke points in the cobalt supply 
chain and promote better practices among cobalt 
refiners. GM is also a member of the AIAG, along 
with its Smelter Engagement Team.  
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C O M PA N Y  P R O F I L E S
About Genuine Parts
Genuine Parts Company (GPC) distributes automotive replacement, industrial parts and 
materials, and business products in North America, Australia, New Zealand, the United 
Kingdom, France, Germany, Poland and Puerto Rico. It has 50,000 full-time employees. 
GPC publishes no details on its raw materials or supply chain.
  1    Human Rights Policy
GPC does not have a human rights policy. The company makes only a brief 
mention of several human rights issues in its sustainability reporting. GPC does 
not make a baseline commitment to human rights. GPC requires its vendors 
to comply with company policies on child and forced labor, health and safety, 
discrimination, disciplinary practice, working hours/wages and compensation, 
as described below.
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  2    Human Rights Governance Embedding
GPC does not disclose any mechanisms that embed human rights into its gover-
nance structures. 
  3    Supplier Code of Conduct
GPC does not post a supplier code of conduct on its main website. Its GPC 
Global Sourcing subsidiary, which is the worldwide sourcing office for all di-
visions within GPC, lists a Vendor Code of Conduct and Social Responsibility 
Standards and Policy applicable to suppliers on its supplier on-boarding web-
site. However, it requires that users fill out a form to request the documents. Si2 
did so, and received nothing through the standard procedure. Eventually, our 
inquiries through the corporate secretary yielded the documents. In them, GPC 
prohibits forced and child labor, harassment and discrimination, and delineates 
baseline health and safety requirements. It also requires that suppliers in turn 
require their own suppliers to comply with GPC’s policy by written agreement.

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  4    Traceability and Supply Chain 
Transparency
GPC says it is committed to responsible and sus-
tainable sourcing, but offers no details.
  5    Human Rights Due Diligence / 
Embedding
GPC does not disclose any comprehensive pro-
cess for identifying, assessing and prioritizing hu-
man rights risks and impacts. The company says 
in its sustainability reporting that it “takes steps to 
measure and enforce vendor compliance” with 
its Social Responsibility Standards and Policy. 
GPC says it uses the SA8000 social auditing stan-
dard—which includes human rights provisions—
to that end. It says it has performed “hundreds” of 
supplier audits, without providing a time frame, 
and does not disclose its total number of suppli-
ers. GPC says, “Vendors that do not meet GPC’s 
social compliance standards must take corrective 
action in a timely fashion or risk termination of 
the business relationship with GPC.” The com-
pany offers no further details. GPC says its au-
dits are both announced and unannounced, but 
does not provide a breakdown. It relies on SGS, 
a third-party supply chain audit services provider, 
to conduct its audits.
  6    Remedies and Grievance 
Mechanisms
GPC has a global reporting hotline listed in its 
Code of Conduct. However, given that human 
rights are not covered in that code of conduct, 
it cannot be assumed that the hotline serves as a 
reporting mechanism for human rights violations.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
GPC does not report involvement in any 
multi-stakeholder initiatives aimed at address-
ing human rights risks in the automotive supply 
chain. 
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G O O DY E A R
C O M PA N Y  P R O F I L E S
About Goodyear
Goodyear Tire & Rubber (Goodyear) develops, manufactures, distributes and sells tires 
and related products and services worldwide. It has 64,000 full-time and temporary 
employees. Goodyear’s principal raw materials are synthetic and natural rubber. 
Carbon black, steel cord, fabrics and petrochemical-based commodities are also 
important raw materials for Goodyear.
  1    Human Rights Policy
Goodyear has a Policy on Global Human, although the term “human rights” 
appears only in the name of the policy itself. It does not make a baseline com-
mitment to human rights. It is not applicable to suppliers. The policy says Good-
year “does not engage in or condone the unlawful employment or exploitation 
of children in the workplace…” This is not an actual prohibition. The company’s 
Supplier Code of Conduct is stronger, requiring conformance with the relevant 
ILO convention. Goodyear makes no further references to international stan-
dards or conventions.
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  2    Human Rights Governance Embedding
Apart from a cross-functional team for Dodd-Frank compliance, Goodyear does 
not report any governance structures specifically focused on human rights.
  3    Supplier Code of Conduct
Goodyear says it requires compliance with its Supplier Code of Conduct, or 
the presence of an “equally substantial code of conduct.” Some of Goodyear’s 
language in its Transparency in Supply Chains Act reporting suggests that not 
all of the company’s suppliers have signed on to the Supplier Code of Conduct. 
The company offers no information as to what proportion of its suppliers have 
signed, whether it has a target date for full compliance, etc. The code says, “Sup-
plier shall cause its subcontractors to comply with the provisions of this Code as 
if it were Supplier itself.”

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  4    Traceability and Supply Chain 
Transparency
“Sustainable Sourcing” is one of the four pillars 
of Goodyear’s corporate responsibility strategy. 
Within that pillar, the company includes raw ma-
terial traceability as a focus area. Goodyear makes 
a specific commitment to achieve 50 percent raw 
material spend traceability by 2025, but does not 
say anything about the remaining 50 percent. The 
company says it is “looking to new technologies” 
to improve traceability, without elaborating.
Goodyear launched its Natural Rubber Procure-
ment Policy in 2018. A key element of the policy 
is a goal (without a target date) of 100 percent 
natural rubber traceability to the processor level.
  5    Human Rights Due Diligence / 
Embedding
Goodyear says it references the dated 2010 U.S. 
Department of Labor’s (DoL) List of Goods Pro-
duced by Child or Forced Labor that categorizes 
goods by country. Goodyear says that within its 
value chain, natural rubber out of Southeast Asia 
presents the highest risk of child and forced la-
bor. The company makes a general assertion that 
it is selecting suppliers “who uphold fair work-
ing conditions,” but offers no details or evidence. 
Goodyear also makes a general commitment to 
work with violating suppliers and possibly termi-
nating relationships, but again offers no details or 
evidence.
Goodyear says all of its procurement associates 
take an annual online training course on human 
rights issues. The company says it “may decline to 
make future purchases from a supplier that does 
not certify to the Goodyear Supplier Code of Con-
duct, or does not provide an acceptable version 
of their own code,” offering no details. The com-
pany says it conducts an ESG survey that includes 
human rights elements at its raw materials sup-
pliers, without elaborating. It says it is aiming for 
a 100 percent response rate by July 2019. As of 
October 2019, there was no indication yet as to 
whether or not this was achieved. Goodyear says 
it also has a goal to complete ESG assessments for 
new raw material suppliers prior to onboarding 
by the end of 2019.
Human rights provisions are included in the com-
pany’s Supplier Code of Conduct, but some of 
Goodyear’s reporting indicates that not all sup-
pliers have signed on. In its 2018 Conflict Min-
erals Report, Goodyear says its Supplier Code of 
Conduct is incorporated into the terms and con-
ditions of its purchase orders in the Americas and 
Asia Pacific, and that it is “in the process” of glob-
al incorporation.
Goodyear makes a general commitment to “sup-
port the livelihoods of smallholders to address… 
human rights issues,” offering no further details 
or evidence.
Goodyear says it “reserves the right to request… 
access to the suppliers’ facilities at any time to 
confirm compliance, including and especially as 
it relates to human trafficking and modern slav-
ery.” The company makes a commitment to regu-
larly audit all active natural rubber suppliers, and 
to “work with them” to comply with its policies. 
Goodyear says it audited 79 percent of its natural 
rubber suppliers in 2018.
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  6    Remedies and Grievance 
Mechanisms
Goodyear operates an Integrity Hotline for both 
associates and suppliers. It is available 24/7 and 
toll free from anywhere. The company offers no 
further details.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Goodyear is involved in the Tire Industry Proj-
ect, including its Global Platform for Sustainable 
Natural Rubber. The company also participates in 
RMI’s Conflict-Free Smelter Program.
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G R O U P E  P S A
C O M PA N Y  P R O F I L E S
About Groupe PSA
Groupe PSA (PSA) is a global automotive and mobility solutions group with a presence 
in some 100 countries. The company has 211,000 employees worldwide and more 
than 8,000 Tier 1 suppliers.
  1    Human Rights Policy
PSA’s Global Framework Agreement includes a standalone human rights policy 
that makes an explicit commitment to exceed legal compliance. PSA says it ad-
heres to the UDHR and ILO Conventions via its commitment to the UNGC, and 
that it is “committed to” the OECD Guidelines and UNGPs. The company says 
only “certain provisions” of its policy apply to suppliers, and that it “requests” 
that its suppliers apply the principles to their own operations. PSA’s Responsible 
Purchasing Policy includes many similar provisions. The company’s child labor, 
forced labor, freedom of association and collective bargaining, worker health 
and safety, and harassment and discrimination provisions all include direct ref-
erences to the relevant ILO conventions. It drafted and promulgated its policy 
in partnership with two international trade union federations and involved 90 
unions active in PSA’s operations. PSA makes a commitment to give preference 
to local hires in its global operations.
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  2    Human Rights Governance Embedding
PSA provides abundant disclosure on its general CSR governance practices, but 
very little as specifically relates to human rights. The company says its procure-
ment and human resources teams have responsibility for enforcing its prohibi-
tions on forced labor, but provides no further evidence that it has embedded 
human rights into its governance structures.
  3    Supplier Code of Conduct
PSA’s Responsible Purchasing Policy appears to function similarly to a supplier 
code of conduct, in that suppliers are required to sign it as part of the contracting 
process. It includes many of the provisions from its broader human rights policy, 
including references to relevant ILO conventions. The policy says the supplier 
“pledges its commitment to fulfill its responsibility toward respecting human 
rights and promotes their respect throughout its entire supply chain.”

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  4    Traceability and Supply Chain 
Transparency
PSA says it identifies “any supplier extracting raw 
materials such as mica and cobalt, and ensures 
that these materials are responsibly supplied.” 
Regarding conflict minerals, PSA says it requires 
“transparency from its suppliers about the origin 
of the minerals they use.” The company discloses 
nothing more.
  5    Human Rights Due Diligence / 
Embedding
PSA says it conducted a materiality analysis to 
identify CSR topics that are relevant to the com-
pany, among which human rights issues emerged. 
PSA’s disclosure on the process itself is opaque as 
to the specifics of human rights risk and impact 
analysis. The company says it conducts a global 
human rights risk mapping that enables procure-
ment teams to focus on parts, groups of goods or 
locations that the company has identified as being 
at risk. PSA identifies and monitors raw materials 
in its supply chain that it considers “strategic”: 
CSR considerations, including human rights, are 
one of the three evaluation criteria. In 2019, PSA 
has a target to determine its 30 most critical raw 
materials and develop a “cartography” for them 
that specifically considers human rights.
The company reports that in 2018, it required all 
of its human resources managers throughout its 
global operations to check practices within their 
areas of control related to ethical recruitment and 
temporary workers, including fees and other abu-
sive practices. The company does not disclose 
how those managers carried out this assessment 
or what they found. It also does not indicate that 
this assessment extended to its suppliers.
PSA reports that it trains a subset of its employ-
ees on human rights policies and procedures. Its 
reporting on this point is vague and internally in-
consistent, and appears to lump together training 
programs on peripheral issues—such as IT policy 
and conflicts of interest—with somewhat more 
human rights-oriented issues, such as anti-dis-
crimination. There is little indication in PSA’s re-
porting that it provides specific training on core 
human rights issues to front-line staff. The compa-
ny says simply that its operational buyers receive 
“ongoing training” on responsible procurement, 
including human rights.
PSA says human rights due diligence is a factor 
in its purchasing decisions, though it furnishes lit-
tle evidence to that effect. The company says in 
its guidance to suppliers that any potential sup-
plier that declines to participate in its EcoVadis 
evaluation process will be excluded from consid-
eration. PSA does not explain how that squares 
with its disclosure that it has an EcoVadis assess-
ment in place for 93 percent of its direct material 
suppliers. The company has a target to have an 
assessment in place for 60 percent of its indirect 
suppliers in 2019.
PSA says it conducts third-party evaluations of its 
suppliers on an ongoing basis, including during 
initial bidding. The company says it requires all 
suppliers to sign its Responsible Purchasing Pol-
icy, which includes human rights commitments 
that are mapped to international standards. PSA 
reports that in 2018, 94 percent of its suppliers 
had signed the policy, without explaining why it 
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retained the non-compliant suppliers in its pool.
By 2035, PSA aims to select suppliers based on 
their compliance with its human rights require-
ments such that they achieve 50/100 on the Eco-
Vadis assessment, and to eliminate a supplier 
from its pool immediately upon identification of 
“breach of fundamental human rights.”
PSA says it has a human rights monitoring pro-
cess in place “in line with” OECD recommen-
dations. The company reports that in 2018, 62 
percent of its suppliers “had actions in place to 
fight against forced and child labour.” PSA says 
it conducts “targeted” audits, and also commis-
sions third-party audits to ensure corrective mea-
sures implementation following a breach. PSA 
says it conducts “random,” third-party, on-site 
audits of suppliers it has deemed to be at risk on 
the basis of country of operation, product or pro-
cess. Audits cover a variety of CSR issues, includ-
ing human rights. Company procedures require 
the use of local auditors who speak the language 
of the audited site and “have a thorough knowl-
edge of the applicable local laws, regulations and 
practices applicable to the site must carry out the 
audit.” 
PSA reports auditing four suppliers for human 
rights in 2018, which constitutes 0.05 percent of 
its supplier base. It found no human rights viola-
tions. PSA also audited 13 suppliers for working 
conditions, including remuneration and working 
hours, and found 5 instances of critical non-com-
pliance. The company reports auditing 92 critical 
Tier 1-3 suppliers since 2008.
Auditors draw up an audit report describing any 
non-compliance and grade the deficits accord-
ing to four classifications (critical, core, minor 
and observations only), each requiring corrective 
action plans. In the case of ongoing non-com-
pliance, sanctions may be applied, and PSA re-
serves the right to terminate the relationship. PSA 
discloses more than most of its peers about the 
results of its corrective action plans. The compa-
ny reports on the number of assessed suppliers 
that are compliant, have room for improvement, 
non-compliant, critically non-compliant and re-
moved from its supplier base, providing these 
figures upon initial audit and again after action 
plans have been formulated. Between 2008 and 
2018, PSA has removed 10 percent of audited 
suppliers from its supplier base, and shows prog-
ress on the other categories.
  6    Remedies and Grievance 
Mechanisms
PSA’s Global Works Council is part of the com-
pany’s grievance framework. The company spells 
out a specific process in its human rights poli-
cy for reporting infractions through union rep-
resentatives, including escalation procedures, 
and makes a non-retaliation commitment. PSA’s 
Speak4Compliance whistleblowing system en-
compasses human rights violations, and is con-
fidential. PSA does not indicate that its grievance 
mechanisms are accessible to suppliers.
The company reports that its grievance mecha-
nisms in 2018 “led to local discussions in three 
countries” 
regarding 
female 
representation 
among production staff and non-discrimination in 
recruitment. PSA also says that its unions brought 
forward concerns about suppliers: one 2nd Tier 
and one subsidiary of a 1st Tier. The company 
does not offer details, but says it received no re-
ports in 2018 of violations of fundamental human 
rights.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
PSA is a UNGC signatory, and participates in the 
RMI. 
G R O U P E  P S A

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H O N DA  M O T O R
C O M PA N Y  P R O F I L E S
About Honda Motor
Honda Motor (Honda) develops, manufactures and distributes motorcycles, 
automobiles, power products and other products worldwide. The company has 
219,722 employees. Its primary raw materials are steel, aluminum, paints, plastics and 
zinc.
  1    Human Rights Policy
Honda has a weak, integrated human rights policy that makes a baseline com-
mitment to “basic human rights.” It says it “will not allow” child or forced la-
bor, and makes general statements in support of freedom of association, worker 
health and safety and non-discrimination.
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  2    Human Rights Governance Embedding
Honda says it has an internal committee for conflict minerals oversight and due 
diligence. Apart from that, the company provides no evidence of embedding 
human rights issues in its governance systems.
  3    Supplier Code of Conduct
None. Honda’s Supplier Sustainability Guidelines include general statements 
on non-discrimination and anti-harassment. The guidelines say Honda will “not 
tolerate” any form of forced labor. Its statement on child labor is strictly compli-
ance-based.
  4    Traceability and Supply Chain Transparency
Honda says it uses the RMI’s RMAP to identify compliant smelters, and it disclos-
es those smelters. However, the company says nothing about whether there are 
non-compliant smelters in its supply chain. It says it has collected information 
on “some, but not all” of the smelters and refiners in its supply chains.
Regarding conflict minerals, Honda says it communicates to its suppliers “what is 
expected of them,” without elaborating, and says it “encourages procurement in

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line with” its Supplier Sustainability Guidelines, 
which it does not make publicly available. In its 
conflict minerals disclosure, it acknowledges it 
cannot rule out the presence of conflict minerals 
in its supply chain. The company says its conflict 
minerals due diligence measures “have been de-
signed to conform, in all material respects,” with 
the OECD Due Diligence Guidelines. It was un-
able to determine the countries of origin of all 
3TG minerals in its supply chain.
  5    Human Rights Due Diligence / 
Embedding
Honda says it assesses its own operations for 
compliance with its Associate Relations Poli-
cies—which include a brief commitment to ba-
sic human rights—annually, offering no further 
details. The company says it “implements initia-
tives with consideration for” human rights with 
its global suppliers, without elaborating. It says 
it has added human rights “initiatives” to some 
of its multi-region purchasing meetings, and that 
it “confirms” its suppliers’ “initiatives” related to 
human rights. 
Honda says it audits its key suppliers through third 
parties, and that the audit evaluates human rights 
and labor matters. The company says it intends to 
expand its audit program to high-risk suppliers, 
without offering a target date. Honda provides no 
further information on the subject that is specific 
to human rights.
  6    Remedies and Grievance 
Mechanisms
Honda does not disclose any remedies or griev-
ance mechanisms.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Honda’s U.S. subsidiary participates in AIAG 
work groups, including Responsible Sourcing 
and Sustainability. It co-chairs the Working Con-
ditions Work Group, which Honda says has been 
providing human rights training to Tier 1 and 
sub-tier suppliers in Mexico.
Honda participates in the RMI, although this 
appears to be strictly for compliance purposes. 
Honda North American participates in the RMI’s 
Smelter Engagement Team. The company is a 
founding member of the Global Battery Alliance, 
established in 2020.  
H O N DA  M O T O R

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L E A R
C O M PA N Y  P R O F I L E S
About Lear
Lear designs, develops, engineers, manufactures, assembles and supplies automotive 
seating and electrical distribution systems and related components for automotive 
OEMs worldwide. It has 161,000 employees. Lear’s primary raw materials are 
leather, steel, electronics and copper. The company includes complex supply chain 
management among its core capabilities in its business proposition.
  1    Human Rights Policy
Lear says in its Sustainability Report that it is committed to protecting human 
rights in its local communities and within its global supply chain. This is less a 
policy than a statement of aspirations. Lear says it “respects and supports” the 
UDHR. In a Global Labor Standards statement, Lear says it will not use forced 
or involuntary labor or “tolerate physically abusive disciplinary practices.” The 
Global Labor Standards statement applies to Lear’s own operations, and does 
not appear to extend to its supply chain. Its statements on child labor, discrim-
ination and harassment only require legal compliance. Lear says it is “commit-
ted” to providing its employees with a safe and healthy working environment 
that “meets or exceeds applicable local standards.”
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  2    Human Rights Governance Embedding
Lear says it monitors and enforces policies “affecting workplace human rights” 
through a compliance program that includes oversight by a Compliance Com-
mittee, which reports to the board’s Audit Committee. The company offers no 
details.

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  3    Supplier Code of Conduct
Lear has a Supplier Sustainability Policy, but it 
does not have the strength of a code of conduct. 
It includes a commitment to human rights, a re-
quirement to comply with local child labor laws, 
and a prohibition of the use of forced labor and 
physically abusive disciplinary practices. It also 
states an “expectation” that suppliers prevent ha-
rassment, and statements against discrimination 
and in favor of freedom of association and col-
lective bargaining. The policy says Lear “strives” 
to keep conflict minerals out of its supply chain 
“wherever practicable,” and “asks” its suppliers 
to “source responsibly.” Lear says it expects its 
suppliers and subcontractors to identify risks in 
their own supply chains and address them, but 
this does not amount to a requirement that the 
policy cascade to lower tiers.
  4    Traceability and Supply Chain 
Transparency
Among the 427 smelters Lear’s suppliers identi-
fied in their 2018 conflict minerals reporting, 259 
were RMAP-conformant, while 6 were confirmed 
not to be. The remainder were under investiga-
tion. This particular disclosure is more detailed 
than that of most of its peers. Lear highlights sup-
ply chain complexity in its non-committal lan-
guage around conflict minerals.
 5 Human Rights Due Diligence / 
Embedding
Lear’s supplier terms and conditions include a 
prohibition on the use of forced and child labor 
and abusive employment, without defining these. 
The company provides no further disclosure on 
human rights due diligence and embedding.
  6    Remedies and Grievance 
Mechanisms
Lear says it has established a process for reporting 
concerns about any potential human rights risks. 
Employees and suppliers can make anonymous 
reports in their language via a toll-free phone 
call, email, online website or regular mail. The 
company provides no further disclosure.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
“Lear is considering taking steps to align with and 
become a signatory to the” UNGC. The company 
also participates in the AIAG and RMI. It provides 
no further details.  
L E A R

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N I S S A N
C O M PA N Y  P R O F I L E S
About Nissan
Nissan Motor (Nissan) manufactures and sells vehicles and automotive parts 
worldwide. The company has 138,893 employees. It does not disclose its primary raw 
materials. Nissan and Renault’s purchasing departments were consolidated under a 
single entity in 2014.
  1    Human Rights Policy
Nissan has a human rights policy “informed by” the UDHR and the ILO Decla-
ration. It also “strives to implement” the UNGPs and is a UNGC signatory. The 
policy is not applicable to suppliers. It prohibits child and forced labor without 
defining these.
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  2    Human Rights Governance Embedding
Nissan provides no indication that it embeds human rights issues into its gover-
nance structures.
  3    Supplier Code of Conduct
Nissan and Renault’s purchasing departments have been “sharing common 
values and processes with a worldwide network of suppliers” since 2006. The 
companies publish their joint Corporate Social Responsibility Guidelines for 
Suppliers, last updated in 2015. This does not carry the strength of a code of 
conduct. In the document itself, Nissan says it “requests the written commitment 
of suppliers” to the guidelines.
The guidelines require, among other things, that suppliers indicate whether the 
minerals they source “have social contagion pertaining to human rights,” and to 
deploy alternative sourcing in that case. They also prohibit discrimination and 
harassment, employment of minors younger than 15 and forced labor, and in-
clude vague statements of support for freedom of association and worker health 
and safety. The guidelines “request” that suppliers “promote CSR” within their 
own supply chains.

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  4    Traceability and Supply Chain 
Transparency
Nissan says it is working to eliminate conflict min-
erals from its supply chain, noting that it “agrees 
with the spirit” of the relevant Dodd-Frank pro-
visions. The company says it conducts annual 
supply chain surveys using the RMI’s CMRT, both 
independently and in collaboration with Japanese 
automotive industry groups, and makes a single, 
oblique reference to suppliers that do not reply. 
Nissan asserts that it found no smelters or refin-
ers “assumed to be connected to armed groups” 
in its supply chain in 2018, without elaborating. 
Considering peer companies’ reported struggles 
on this front, Nissan’s assertion strains credulity, 
despite the semantic sleight of hand.
  5    Human Rights Due Diligence / 
Embedding
Nissan does not report any mechanisms for hu-
man rights due diligence or embedding. The 
company requires suppliers to report any instanc-
es of non-compliance with its CSR guidelines, in 
which case it expects suppliers to undertake un-
defined “corrective countermeasures.” Failure to 
do so “may” result in a suspension of new busi-
ness or “other action, as appropriate.”
  6    Remedies and Grievance 
Mechanisms
Nissan does not report any remedies and griev-
ance mechanisms.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Nissan is a UNGC signatory and uses RMI for 
conflict minerals surveys. It discloses nothing fur-
ther.
N I S S A N

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N U C O R
C O M PA N Y  P R O F I L E S
About Nucor
Nucor manufactures and sells steel and steel products in the United States and 
internationally. It has 26,300 employees. Nucor’s primary raw materials are scrap steel, 
iron ore, ferrous scrap and scrap substitutes, such as pig iron, direct reduced iron (DRI) 
and hot briquetted iron (HBI). The company says it has “focused on securing access to 
low-cost raw material inputs” for the past decade.
  1    Human Rights Policy
Nucor has a new, standalone human rights policy “consistent with” the UDHR 
and UNGPs. The company’s contractors, subcontractors, suppliers and business 
partners are “expected” to comply with the policy. The policy includes general 
commitments to health and safety and community engagement, and to elimi-
nating forced and child labor, human trafficking, discrimination and harassment. 
Nucor has standalone policies on Combating Trafficking in Persons and Elim-
inating Forced Labor that more clearly define the issues and include specific 
requirements around responsible recruiting.
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  2    Human Rights Governance Embedding
Nucor’s board of directors annually reviews company efforts to eliminate forced 
labor in its Northern Brazilian pig iron supply chain, as described below.
  3    Supplier Code of Conduct
Nucor has a Supplier Code of Conduct that does not include the term “human 
rights,” although it makes a general commitment to “human dignity.” The code 
prohibits the use of forced labor. It also prohibits child labor, yet sets the bar low 
by defining a child as a person younger than a) 14, b) the minimum age for com-
pleting compulsory education in the country of manufacture or c) the minimum 
age for employment in that country, whichever is oldest. In effect, this means 
legal compliance unless the child is 13 or younger. The code includes a general 
prohibition on harassment and discrimination and requirement of a “safe work-
ing place for employees.” The remaining provisions related to human rights only 
require legal compliance.

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  4    Traceability and Supply Chain 
Transparency
Nucor has a policy on eliminating forced labor 
from its supply chain, with a focus on pig iron 
from northern Brazil:
Pig iron is an intermediate iron product created 
by smelting raw iron ore at high temperatures 
with a reducing agent. For pig iron produced in 
Northern Brazil, this agent is often charcoal. The 
charcoal production process in Northern Brazil is 
labor-intensive and traditionally had taken place 
in relatively remote and inaccessible areas. In the 
past some producers of charcoal created difficult 
working conditions, which included the use of 
forced labor and armed surveillance.
The company says it is working to ensure that the 
Northern Brazilian pig iron in its supply chain 
is not reduced with charcoal that has been pro-
duced using forced labor. It requires that pig iron 
come only from manufacturers licensed by the 
Brazilian government, and that manufacturers 
certify annually and with every shipment that 
no involuntary labor was used. Nucor retains a 
Brazilian law firm that monitors a government 
black list of employers who use slave labor. The 
company also details its requirements that char-
coal-based pig iron manufacturers participate in 
local initiatives to eliminate slave labor, and pro-
vides meaningful details regarding the challenges 
associated with the local operational context.
  5    Human Rights Due Diligence / 
Embedding
Nucor says, “In any areas of heightened risk, Nu-
cor engages with its contractors, subcontractors 
and suppliers to perform diligence, and to certify 
and audit supply chains to avoid directly or in-
directly benefiting from or promoting any such 
forced labor, child labor, human trafficking, or 
other related activities.” The company offers no 
further detail. Nucor says its procurement doc-
umentation requires suppliers to comply with 
its Supplier Code of Conduct. It says failure to 
comply with its supplier standards, particularly 
around forced labor, “subjects” a supplier to re-
moval from the company’s supply chain. Nucor 
offers no further details.
  6    Remedies and Grievance 
Mechanisms
Nucor says it has a hotline through which its em-
ployees are required to report human rights abus-
es in the company’s own operations or its supply 
chain. Its policy includes a statement of non-re-
taliation.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
None.  
N U C O R

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P P G  I N D U S T R I E S
C O M PA N Y  P R O F I L E S
About PPG Industries
PPG Industries (PPG) manufactures and distributes paints, coatings and specialty 
materials worldwide. It has 47,300 employees. PPG’s primary raw materials are epoxy 
and other resins, titanium dioxide and other pigments, solvents, sand and soda ash. 
PPG says it has aggressive sourcing initiatives to broaden its raw materials supply, 
including qualifying suppliers from Asia and other lower cost regions of the world.
  1    Human Rights Policy
PPG does not have a human rights policy. Its Global Code of Ethics includes a 
brief statement of “respect” for human rights. 
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  2    Human Rights Governance Embedding
Apart from basic functions to meet its obligations under Dodd-Frank, PPG dis-
closes no human rights embedding in its governance structures.
  3    Supplier Code of Conduct
PPG’s Supplier Code of Conduct says its suppliers “shall maintain and promote 
fundamental human rights.” That is the sole instance in the code of the term 
“human rights.” The code prohibits all forms of forced labor, and prohibits child 
labor in compliance with “relevant ILO standards.” The code includes an ex-
pectation that suppliers prevent discrimination and harassment and implement 
health and safety management systems and controls. The remaining statements 
on human rights topics simply require legal compliance.
  4    Traceability and Supply Chain Transparency
PPG says its pigments contain mica mined in India. The company notes child 
labor risks in Indian mica mines, and says it joined the Responsible Mica Initia-
tive as part of its response. It says Initiative members are working with the Indian 
mica mines from which they source to improve standards and performance. PPG 
laid out an audit plan in its first MSA disclosure, which it has since postponed. 
It is awaiting completion of the RMI’s efforts, and says that it will have finalized

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audits for low supply chain visibility by the end 
of Q2 2019. The company specifies that this will 
apply to suppliers that “either manufacture or 
process raw materials in the UK,” suggesting that 
it will not do so for suppliers to other markets.
  5    Human Rights Due Diligence / 
Embedding
PPG said in its 2017 MSA disclosure (the most 
recent available) that it aimed “to roll out mod-
ern slavery focused e-learning to their [employ-
ees] ranked from the most senior management to 
middle management/ mid-grade specialists with 
assigned email addresses” in 2018/2019. 
PPG says its New Supplier Qualification Form 
was updated in 2017 to include questions on 
child and forced labor, human rights violations, 
workplace safety violations, conflict mineral vio-
lations and supplier diversity. PPG offers no detail 
as to how it uses the information it receives.
PPG says new suppliers must sign its Supplier 
Code of Conduct. In its 2017 MSA disclosure, 
PPG says it enlisted the help of “specialist legal 
advisers” to review its “standard terms and con-
ditions to assess the extent to which they mitigate 
the risks of modern slavery occurring in [its] sup-
ply chains. A conclusion of that review was that 
there was scope for improvement and it is now 
proposed that this will be addressed as part of 
a broader overhaul [of] contractual terms.” The 
company discloses nothing further on this point. 
PPG says it “intends to incorporate” its Conflict 
Minerals Policy into new and renewed supplier 
contracts, without offering a target date.
PPG says it “periodically assesses” its top 100 
suppliers (approximately 25 percent of its annu-
al procurement spend) for human rights policies, 
among other factors. It also says its EMEA region 
evaluates approximately 85 percent of its suppli-
ers annually, including on human rights topics. 
PPG says these assessments help it to identify 
which suppliers and areas of its supply chain 
should be audited. The company offers no further 
detail.
In its Supplier Code of Conduct, PPG says it “as-
sumes that all of our global suppliers will adhere 
to” the code, and says suppliers must provide 
corrective action plans if they identify violations. 
This is essentially a requirement to self-report.
PPG says in its Supplier Code of Conduct that its 
suppliers must cooperate with “reasonable audit 
processes” the company requests, without elab-
orating. It says it audited 87 suppliers globally in 
2016 (the most recent year in its reporting), in-
cluding on human rights topics, and put action 
plans into place. The company offers no further 
details.
  6    Remedies and Grievance 
Mechanisms
PPG does not disclose remedies and grievance 
mechanisms for human rights issues.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
PPG is involved in the RMI and the National As-
sociation of Manufacturers Conflict Minerals Task 
Force. 
P P G  I N D U S T R I E S

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R E N A U LT
C O M PA N Y  P R O F I L E S
About Renault
Renault designs, manufactures, sells and distributes vehicles. It has 180,000 
employees. The company’s raw material inputs in its value chain include aluminum, 
copper, platinum, palladium, rhodium and cobalt. Renault and Nissan’s purchasing 
departments were consolidated under a single entity in 2014.
  1    Human Rights Policy
Renault’s Global Framework Agreement on Social, Societal and Environmental 
Responsibility covers human rights topics. It developed its framework in concert 
with two international trade union federations. The company commits to respect 
“fundamental social rights,” a term it appears to use to refer to human rights is-
sues. It uses the same term in French (“droits sociaux fondamentaux” as opposed 
to “droits de l’homme” or “droits humains”), indicating that this is intentional 
rather than a translation error. In other public disclosures, the company refers to 
“human rights.” The framework “commits to respect the principles” of the ILO 
Declaration and “adheres to” the UNGC and OECD Guidelines. Renault “asks” 
suppliers to commit to the human rights-related provisions of its framework, 
being careful to note that such a commitment on its suppliers’ part imposes no 
legal responsibility on Renault’s part. Its prohibitions on child and forced labor, 
freedom of association and collective bargaining, and harassment and discrimi-
nation reference the relevant ILO conventions.
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  2    Human Rights Governance Embedding
Renault says it has a department charged with ensuring that suppliers meet cer-
tain standards, including those related to traceability of conflict minerals and 
cobalt. It discloses nothing further with specific regard to human rights.
Renault had a board member with human rights expertise. Cherie Blair, a human 
rights and international law barrister, was a long-standing independent director 
on Renault’s board until she stepped down in 2019. Her departure left the com-
pany with no board members with human rights expertise.

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  3    Supplier Code of Conduct
Renault and Nissan’s purchasing departments 
have been “sharing common values and process-
es with a worldwide network of suppliers” since 
2006. The companies publish their joint Corpo-
rate Social Responsibility Guidelines for Suppli-
ers, last updated in 2015. This does not carry the 
strength of a code of conduct. In the document 
itself, Renault says it “requests the written com-
mitment of suppliers” to the guidelines.
The guidelines require, among other things, that 
suppliers indicate whether the minerals they 
source “have social contagion pertaining to hu-
man rights,” and to deploy alternative sourcing 
in that case. They also prohibit discrimination 
and harassment, employment of minors young-
er than 15 and forced labor, and include vague 
statements of support for freedom of association 
and worker health and safety. The guidelines “re-
quest” that suppliers “promote CSR” within their 
own supply chains.
  4    Traceability and Supply Chain 
Transparency
Renault has a basic policy on procurement of 
cobalt and minerals from conflict-affected and 
high-risk areas. It essentially requires suppliers of 
components containing 3TGs and cobalt to con-
duct due diligence around those materials and 
develop risk mitigation strategies, and to com-
municate all relevant details to Renault. In the 
case of 3TGs, the policy requires suppliers not 
to source from “illegal channels” and to “commit 
to promoting a responsible supply process.” The 
cobalt requirements are “based on” the OECD 
Guidelines, and include a requirement that sup-
pliers map the full supply chain and submit to 
third-party verifications and audits at the compa-
ny’s request. For the first time in 2018, Renault 
published the full list of its electric vehicle battery 
suppliers, along with the countries of origin of the 
cobalt they source: the DRC, Papua New Guinea 
and Russia. This was the result of a full a supply 
chain mapping for which Renault hired a special-
ist auditing firm. Renault also reports a joint in-
vestment with Nissan and Mitsubishi in a venture 
capital fund investing in, among other things, a 
company that develops cobalt-free batteries.
  5    Human Rights Due Diligence / 
Embedding
Renault says it is “studying” human rights training 
for its local ethics committees, without offering 
further information.
Renault says it “may ask” suppliers to submit to 
a third-party CSR assessment. The company says 
it requires all new suppliers to endorse its Glob-
al Framework Agreement, which only “asks” that 
suppliers comply with its human rights-related 
provisions.
Renault says it enlists “external organizations” to 
carry out “regular evaluations” of its suppliers, in-
cluding on human rights topics, and that it “asks” 
for action plans from suppliers that do not com-
ply with the company’s “guiding principles.” The 
supplier relationship “may” be suspended. If that 
action results in economic harm to Renault, the 
supplier “may be requested to pay reparations.” 
Renault says it sometimes performs follow-up au-
dits.
In 2018, Renault audited 43 suppliers in Algeria, 
China, India, Romania, Russia and Turkey. The 
company also reports that as part of its cobalt 
supply chain mapping, the specialized auditing 
firm it hired conducted on-site audits, though it 
provides no further details.
R E N A U LT

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  6    Remedies and Grievance 
Mechanisms
Renault has a whistleblowing mechanism avail-
able to its employees and suppliers that is meant 
to address human rights concerns, among other 
matters. A third party manages the system, which 
is accessible via internet or a multilingual phone 
line. The mechanism guarantees confidentiality 
where not precluded by law. Renault does not re-
port further on the subject.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Renault is a signatory to the UNGC and aligns its 
human rights policy with the same. The company 
is also a member of the RMI and RCI, and its ac-
tivities with both support its efforts to manage hu-
man rights risks in its conflict minerals and cobalt 
supply chains. The company is a founding mem-
ber of the Global Battery Alliance, established in 
2020.  
R E N A U LT

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T E S L A
C O M PA N Y  P R O F I L E S
About Tesla
Tesla designs, develops, manufactures and sells electric vehicles and energy generation 
and storage systems in the United States, China, the Netherlands, Norway and 
internationally. The company has 48,817 employees. The company’s raw materials 
include aluminum, steel, cobalt, lithium, nickel and copper.
  1    Human Rights Policy
Tesla’s Human Rights and Conflict Minerals Policy focuses exclusively on its 
suppliers. It does not make a baseline commitment to fundamental human 
rights. Tesla prohibits child labor without defining it: “Human trafficking, child 
labor and slavery are crimes under state, federal and international law. These 
crimes exist in countries throughout the world.” This seems to indicate that its 
requirement is strictly compliance-based. In its MSA disclosure, which is legally 
binding, Tesla only forbids illegal child labor. In its Supplier Code of Conduct, 
Tesla references the ILO in its child labor prohibition, and says suppliers may 
only employ people who are at least 15, have reached the completion age of 
compulsory education or meet the legal minimum age for employment, which-
ever is highest.
Tesla’s policy does not address ethical recruitment, but its Supplier Code of Con-
ducts prohibits withholding or destroying employee identity or immigration doc-
uments, passports or work permits.
O V E R A L L  
A S S E S S M E N T 
S C O R E
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  2    Human Rights Governance Embedding
Tesla discloses no evidence of human rights embedding in its governance struc-
tures.
  3    Supplier Code of Conduct
Tesla’s Supplier Code of Conduct does not include a baseline commitment to 
fundamental human rights. It does prohibit discrimination and harassment, 
forced labor and child labor, and requires suppliers to respect freedom of asso-
ciation and to adopt health and safety management systems.

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  4    Traceability and Supply Chain 
Transparency
Tesla reports on its cobalt supply chain initiatives 
in its Dodd-Frank conflict minerals disclosure, 
though it is not required to do so. The company 
visits/audits cobalt mines and processing plants 
around the world, and works with these suppliers 
to address various human rights concerns. Since 
2013, Tesla has reduced the amount of cobalt 
used in its nickel-cobalt-aluminum battery for-
mulation by approximately 60 percent. Panaso-
nic, Tesla’s battery supplier, announced in 2018 
that it was developing batteries that do not need 
cobalt at all, although industry observers remain 
skeptical that this is possible. Tesla’s CEO has sim-
ilarly said its next-generation batteries will use no 
cobalt, although he provides no firm timeline for 
such a development.
  5    Human Rights Due Diligence / 
Embedding
Tesla says it evaluates its supply chain for human 
rights issues, but provides no evidence to that ef-
fect. In its Human Rights and Conflict Minerals 
Policy, Tesla has a section on how it ensures sup-
plier compliance. In that section, the company 
says it trains “certain employees” on human traf-
ficking, child labor and slavery. The same section 
appears in Tesla’s MSA disclosure, which is legal-
ly binding, but the part on training is different: It 
simply says that “it is important” to Tesla to train 
employees on human rights issues. Nowhere in 
that disclosure does the company say it actually 
does so.
Tesla says it visits its 3TG suppliers and—no-
tably—sub-suppliers to evaluate human rights 
practices, among other things. The company does 
not disclose the number of suppliers audited, fre-
quency, etc.
The company says it “disciplines” contractors 
that violate its human rights policies, which can 
include contract termination. The company does 
not elaborate.
  6    Remedies and Grievance 
Mechanisms
In its human rights policy statement, Tesla pro-
vides a rather absurd explanation of its “griev-
ance mechanism”: “you” send a letter to Tesla’s 
corporate secretary by postal mail—which the 
company notes can be done confidentially—or 
email its legal team.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Tesla is a member of the Silicon Valley Conflict 
Minerals Forum and the RMI.  
T E S L A

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T OYO TA
C O M PA N Y  P R O F I L E S
About Toyota
Toyota Motor (Toyota) designs, manufactures, assembles and sells passenger vehicles, 
minivans and commercial vehicles, and related parts and accessories. It has 376,445 
employees. The company’s raw material inputs include steel, precious metals and non-
ferrous alloys including aluminum.
  1    Human Rights Policy
Toyota’s human rights policy includes a basic statement of respect for human 
rights, but does not address any specific human rights topics. It includes a state-
ment on conflict minerals that is essentially compliance-based. Toyota’s human 
rights policy says it “respects” the UDHR and UNGPs. The policy does not in-
clude a prohibition on child labor, but the company’s Sustainability Data Book 
does. Its Supplier CSR Guidelines go further, specifying that the minimum age 
for employment is 15, the local legal minimum or the age for completing com-
pulsory education, whichever is oldest, and prohibits hazardous work for those 
younger than 18. Similarly, its human rights policy does not prohibit forced la-
bor, but its Sustainability Data Book and Supplier CSR Guidelines do.
O V E R A L L  
A S S E S S M E N T 
S C O R E
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  2    Human Rights Governance Embedding
Toyota formed its Human Rights Working Group in 2011 that incorporates var-
ious functions within the company. The group holds “Sustainability Meetings” 
to discuss human rights issues. Toyota does not indicate how frequently these 
meetings are held.
  3    Supplier Code of Conduct
Toyota publishes Supplier CSR Guidelines that address human rights issues, but 
do not carry the same weight as a code of conduct. The guidelines “respectfully 
ask” for suppliers’ compliance. They include a prohibition on child labor that 
comports with the relevant ILO convention without referencing it, as well as a 
prohibition on forced labor that includes elements related to ethical recruiting. 
The guidelines also include general provisions on harassment and discrimina-
tion, worker health and safety and freedom of association.

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  4    Traceability and Supply Chain 
Transparency
Toyota publishes some information in its Sustain-
ability Report about its Dodd-Frank compliance 
efforts, which largely involve collaborating with 
various industry groups, in some cases on smelter 
engagement. Toyota’s approach to conflict miner-
als is still in its fledgling stages.
  5    Human Rights Due Diligence / 
Embedding
Toyota asks suppliers to complete a self-assess-
ment questionnaire that includes human rights 
topics. The company does not publish the ques-
tionnaire, nor does it say how many suppliers 
have responded, the quality of those responses, 
etc. Toyota indicates that it has requested correc-
tive action in some cases, without elaborating.
  6    Remedies and Grievance 
Mechanisms
Toyota has a compliance hotline operated by a 
third party. It appears to be only for employees, 
and the company does not indicate that it can be 
used to report human rights concerns.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
Toyota participates in the Japan Conflict-free 
Sourcing Working Group, under the umbrella 
of the Japanese automotive industry’s Responsi-
ble Minerals Trade Working Group. The former 
currently appears to identify smelters in the 3TG 
supply chain and “makes visits to organizations 
representing smelters.” It also presses for con-
flict-free certification, without explaining what 
that means. The Responsible Minerals Trade 
Working Group seems to exist in some tension 
with RMI, on the one hand collaborating but on 
the other hand pushing back on RMI policies and 
procedures. It was explicitly formed to deal with 
the impact of Dodd-Frank on Japanese compa-
nies.
Toyota has participated in AIAG working groups 
on conflict minerals. The company’s North Amer-
ican subsidiary has chaired the AIAG’s Smelt-
er Engagement Team, and joined the European 
Smelter Engagement Team.
Toyota participated in the first phase of the PPA, 
but gives no indication that it remains involved.
Drive Sustainability and its Raw Materials Obser-
vatory list Toyota’s European subsidiary as a mem-
ber, although the company does not include that 
information in its own reporting. The Observatory 
is a process for assessing the sustainability risks 
associated with the automotive sector’s top raw 
materials and identify ways to address that risk.  
T OYO TA

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V O L K S W A G E N
C O M PA N Y  P R O F I L E S
About Volkswagen
Volkswagen (VW) manufactures and sells automobiles primarily in Europe, North 
America, South America and Asia-Pacific. The company has 636,988 employees. Its 
primary raw materials are natural rubber, iron ore, rare earths, lead, aluminum, copper, 
lithium and cobalt. VW has more than 40,000 Tier 1 suppliers around the world who 
employ more than five million people.
  1    Human Rights Policy
VW makes a commitment to fundamental human rights in its Sustainability Re-
port. The company says it “rejects all forms of child, forced or compulsory la-
bor, modern slavery and human trafficking,” and that this applies to its entire 
value chain. The company also commits to freedom of association, collective 
bargaining and health and safety, and prohibits discrimination and harassment, 
and requires its suppliers to do the same. VW’s Code of Conduct also includes a 
commitment to fundamental human rights.
VW says it “follows” the UDHR, UNGPs, ILO Core Labor Standards, Conven-
tion for the Protection of Human Rights and Fundamental Freedoms, OECD 
Guidelines and the German government’s National Action Plan for Business and 
Human Rights.
O V E R A L L  
A S S E S S M E N T 
S C O R E
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Si2
  2    Human Rights Governance Embedding
VW has a sustainability council of international advisors, including trade union 
representatives and a founding director of the UNGC. The company has three 
board members who are trade union professionals. VW also has a Sustainability 
Procurement Network in place that is charged with implementing the compa-
ny’s human rights requirements, among other things.
  3    Supplier Code of Conduct
VW’s Code of Conduct for Business Partners includes extensive human rights 
provisions and is among the most robust in this research universe.

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  4    Traceability and Supply Chain 
Transparency
VW says its suppliers must disclose their 3TG 
smelters and refiners “upon request.” The compa-
ny does not report how many suppliers comply 
with reporting requirements, nor how fully it has 
been able to identify all the smelters and refiners 
in its supply chain. The company says non-com-
pliant smelters “must be replaced by compliant 
smelters,” without explaining the process for this. 
[Responsible sourcing pilot projects—block-
chain or other] VW says it is testing “innovative, 
interdisciplinary approaches to supplier man-
agement,” and organized a pilot project in 2018 
on the use of blockchain to track raw materials 
throughout the supply chain. The company does 
not elaborate.
VW says it has systems in place to address points 
in its supply chain at particularly high risk of hu-
man rights abuses. It requires suppliers to dis-
close the sources of 3TGs, cobalt, mica and any 
other materials that “may have some connection 
with human rights violations.” It uses RMI risk 
assessment protocols. In its cobalt supply chain, 
VW says it is “in close contact with companies 
from the mine to our tier 1 suppliers.” It says it is 
participating in a certification scheme for cobalt 
smelters.
VW says it held workshops in 2018 with mining 
companies from the copper and platinum indus-
try to “come up with joint plans and approach-
es for making improvements.” The company says 
it will “take further steps to better map out” its 
supply chain in 2019, and to focus on more raw 
materials.
  5    Human Rights Due Diligence / 
Embedding
VW says it has a risk management system in place 
that takes account of human rights issues, but 
does not report specifically on how human rights 
topics play out within that system. The company 
says it has a due diligence system in place for 
suppliers that requires they establish a manage-
ment system to deal with risks that include human 
rights, assess their own supply chains, implement 
a strategy, submit to third-party audits and report 
on their efforts.
VW says it trains suppliers on its sustainability 
requirements, without elaborating. The company 
says it trains target groups of employees—includ-
ing procurement staff—on human rights issues, 
but says data on the number of training hours are 
“non-collectable.” It provides general reporting 
on “sustainability” training, but does not provide 
specifics related to human rights.
VW says 28,000 supplier sites submitted self-as-
sessment questionnaires—which include human 
rights questions—in 2018, and that it works with 
suppliers to improve their “sustainability perfor-
mance.”
VW says suppliers cannot submit a bid without 
first “acknowledging” its Code of Conduct for 
Business Partners. The company includes human 
rights factors in its supplier sustainability rating, 
which will be integrated into its contract award 
process starting in 2019. VW says it integrates its 
Code of Conduct for Business Partners at the con-
tractual level. The company says it has additional 
contractual requirements in place for suppliers of 
“minerals from conflict-affected and high-risk ar-
eas,” without elaborating.
VW says it uses targeted monitoring instruments 
to ensure compliance with its Code of Conduct 
V O L K S W A G E N

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for Business Partners. It requires action plans of 
suppliers that violate its standards, and monitors 
their implementation. VW says a third-party pro-
vider audited 947 suppliers in 2018 for “sustain-
ability,” without providing specifics on human 
rights. In 551 cases, VW says an action plan was 
needed and that it monitors implementation. VW 
says it conducts “on-site visits” of DRC smelters 
and mines, without offering further detail.
  6    Remedies and Grievance 
Mechanisms
VW has a whistleblower system in place for em-
ployees, business partners and third parties that is 
intended to field human rights concerns, among 
other issues. Mechanisms include an online 
channel, telephone hotline, email inbox, person-
al contact with the company’s Investigation Of-
fice and external ombudspersons. Most of those 
assure anonymity. Information can be submitted 
in multiple languages, and VW says retaliation is 
not tolerated.
  7    Participation or Leadership in Multi-
Stakeholder Initiatives
VW is seeking to restore its membership in the 
UNGC, which was suspended over its diesel 
scandal.
VW is a member of RMI and Drive Sustainability, 
which it leverages in support of its raw materials 
initiatives. The company is a founding member of 
the Global Battery Alliance, established in 2020. 
 
V O L K S W A G E N

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Si2 evaluated each company on a series of factors, with a particular eye toward how value and risk cas-
cade through the supply chain. The research looked for any evidence of specific human rights policy 
implementation and disclosure. The assessment gives companies credit for disclosures that deal explicitly 
with human rights factors. A general risk assessment strategy around “sustainability” did not satisfy the 
criterion for human rights risk assessment, for instance.
The assessment seeks to align with established frameworks wherever possible and practicable, though 
the assessed criteria are broader in some instances, and more focused on the specific human rights risks 
in the automotive industry. These referenced frameworks include the United Nations’ Guiding Principles 
(UNGP) Reporting Framework, the Corporate Human Rights Benchmark (CHRB) Core UNGP Indicator 
Assessment, Know the Chain Benchmark and OECD Due Diligence Guidance, among others. (The Glos-
sary of Terms and Resource List, p. 111, provides a listing of current initiatives.) 
Si2 compiled available evidence for each of the indicators set below, then translated the qualitative find-
ings into a numerical assessment that ranged from 1 (strongest) to 3 (weakest) for each point. For each of 
the top-level indicators, the fractions in parentheses represent the indicator’s weight in the calculation of 
a company’s overall score.
1. Human Rights Policy (1/10)
Does the company have a human rights policy? How strong is it? This indicator is intended to align with 
the CHRB’s Theme A: Governance & Policy Commitments. For each of the following factors, where rel-
evant, we also considered whether the policy references and/or aligns with applicable ILO conventions.
For each of the following factors, the fractions in parentheses represent the factor’s weight in the calcula-
tion of the overall Human Rights Policy Score.
	
a) 	 Is the policy standalone or integrated within other commitments? (1/6)
	
b) 	Does it make a baseline commitment to respect fundamental human rights? (1/6)
	
c)	 Does it reference international laws and standards? If so, which ones? (1/6)
	
d)	 What is its scope? Is it applicable to suppliers? (1/6)
	
e)	 Does it prohibit child labor? (1/12)
	
f)	 Does it prohibit forced labor? (1/12)
	
g)	 Does it make a commitment to stakeholder engagement? (1/42)
	
h)	 Does it address ethical recruitment? (1/42)
	
i)	 Does it protect freedom of association and collective bargaining agreements? (1/42)
	
j) 	 Does it include a commitment to worker health and safety? (1/42)
	
k)	 Does it address indigenous rights? (1/42)
	
l)	 Does it address resettlement? (1/42)
	
m)	Does it prohibit harassment and discrimination? (1/42)

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2. Human Rights Governance and Embedding (1/10)
How have human rights policies and expectations been embedded into the company’s governance and 
management systems? Does it delineate responsibility and resources for day-to-day human rights func-
tions? This indicator is intended to encompass the CHRB’s indicator B.1.1, along with additional factors.
Each of the following factors are equally weighted in the calculation of the overall Human Rights Gover-
nance and Embedding score.
	
a)	 Is there a board member with specific human rights experience/expertise (i.e. relevant education, 
background, work experience)?
	
b)	 Are human rights factors included in the company’s compensation strategy?
	
c)	 Do any board committee charters include specific mention of human rights?
	
d)	 Does the company define roles with human rights responsibilities?
	
e)	 Does the company report human rights competence or qualifications among key staff?
	
f)	 Is there evidence that human rights is a fundamental business model issue?
3. Supplier Code of Conduct (1/10)
Does the company have a supplier code of conduct or its equivalent?
The following factors were equally weighted in the calculation of the overall Supplier Code of Conduct 
score.
	
a)	 How strong is it?
	
b)	 Does it include a requirement that human rights commitments cascade beyond first-tier suppliers?
4. Traceability and Supply Chain Transparency (2/10)
The following factors were equally weighted in the calculation of the overall Traceability and Supply 
Chain Transparency score.
	
a)	 Does the company make a commitment to disclose/trace materials with human rights risks, or ar-
ticulate the importance of traceability or a goal around responsible sourcing? (1/5)
	
b)	 Does the company disclose its traceability choke points (i.e. smelters)? 
	
c)	 Does the company have responsible sourcing pilot projects (i.e. blockchain)?
	
d)	 How does the company address high-risk inputs and sourcing countries? 
5. Human Rights Due Diligence / Embedding (3/10)
Each of the following first-level factors was equally weighted in the calculation of the overall Human 
Rights Due Diligence / Embedding score.
	
a)	 Does the company identify its processes and triggers for identifying human rights risks and impacts? 
This indicator is intended to align with the CHRB’s indicator B.2.1.
	
b)	 Having identified its human rights risks and impacts, does the company assess them and then prior-
itize its salient human rights risks and impacts? This indicator is intended to align with the CHRB’s 
indicator B.2.2.

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c)	 Does the company integrate its assessment findings internally and take appropriate action? This 
indicator emphasizes purchasing practices and cascading, and is intended to align with the CHRB’s 
indicator B.2.3.
i.	
Does the company have training programs to ensure relevant decision makers understand human 
rights risks and effectively implement company policies? How does the company assess training 
impact?
ii.	
Is human rights due diligence integrated into purchasing decisions?
iii.	 Does the company assess human rights risks at potential suppliers prior to entering into any con-
tracts with them?
iv.	
Does the company integrate human rights commitments into supplier contracts?
v.	
Does the company provide procurement incentives to first-tier suppliers to encourage/reward good 
standards?
vi.	 Does the company extend human rights expectations beyond its first tier of suppliers?
vii.	 Are there efforts to remove tiers in the supply chain or move toward direct purchasing?
viii.	 Does the company make a commitment to address root cause issues?
	
d)	 Does the company monitor and evaluate the effectiveness of actions to respond to human rights 
risks and impacts? This indicator is intended to align with the CHRB’s indicator B.2.4.
i.	
Does the company monitor the human rights commitments of supplier contracts?
ii.	
Does the company conduct supplier audits?
iii. 	 What percent of its supplier base does it audit?
iv.	
Does it disclose remedial action?
v.	
Are audits announced or unannounced?
vi.	 Does it conduct its own audits or use third parties?
	
e)	 Does the company communicate externally how it addresses its human rights impacts in a man-
ner that is accessible to its intended audiences, especially affected stakeholders who have raised 
concerns, providing enough information to evaluate the adequacy of the response? This indicator 
is intended to align with the CHRB’s indicator B.2.5.
6. Remedies and Grievance Mechanisms (1/10)
Does the company have appropriate and effective remedies and grievance mechanisms in place for hu-
man rights issues? This indicator is intended to align with the CHRB’s Theme C: Remedies and Grievance 
Mechanisms, and the criteria of UNGP 31. 
Given that there was little granularity among companies in the research universe on this indicator, a score 
was assigned based on the following factors without using them in a calculation.
	
a)	 Does the company have appropriate and effective grievance channels/mechanisms for workers?
	
b)	 Does the company have appropriate and effective grievance channels/mechanisms for external 
parties?
	
c)	 Does the company remedy adverse impacts and incorporate lessons learned?
7. Participation or Leadership in Multi-Stakeholder Initiatives (1/10)
Does the company participate in or lead multi-stakeholder initiatives related to human rights in the auto-
motive supply chain? If so, how robust are its activities?

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Tin, tungsten, tantalum and gold, the minerals Dodd-Frank speci-
fies in the Conflict Minerals Rule.
California Transparency in 
Supply Chains Act
Requires large retailers and manufacturers to provide California 
consumers with information regarding their efforts to eradicate 
slavery and human trafficking from their supply chains.
California Transparency in 
Supply Chains Act (CTSCA)
A California law passed in 2010 aimed at curtailing human traffick-
ing and slavery by requiring all manufacturers and retailers doing 
business in California with more than $100 million in annual rev-
enue to disclose publicly the extent of their efforts to prevent such 
abuses in their supply chains. Disclosures must cover verification, 
audits, certification, internal accountability and training.
Conflict Minerals Rule
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer 
Protection Act requiring publicly traded companies to report an-
nually on the presence of conflict minerals (such as tin, tungsten, 
tantalum and gold) originating in the Democratic Republic of the 
Condo or adjoining countries in the products the companies man-
ufacture or contract to manufacture if the conflict minerals are nec-
essary to the functionality or production of a product. Recent court 
challenges to the rule have prompted the Securities and Exchange 
Commission (SEC) to stop enforcing the requirement that compa-
nies conduct a due diligence review or sourcing audit.
E.U. Conflict Minerals 
Regulation
A new law aiming to help stem the trade in four minerals—tin, tan-
talum, tungsten and gold—that sometimes finance armed conflict 
or are mined using forced labor. It will come into full force on Jan-
uary 1, 2021 across the European Union. It reaches further than the 
U.S.’ Conflict Minerals Rule, defining conflict regions more broad-
ly, requiring that companies meet the OECD Guidance defined 
above. As currently written, the regulation appears fairly toothless, 
lacking any punitive measures for non-compliance.
German Business Initiative 
for Sustainable Value Chains
Founded by BASF, BMW Group and other German industrial giants, 
the initiative seeks to reduce negative environmental impact and to 
promote safer and fairer workplaces in companies’ value chains. 
Companies commit to creating global value-added networks for 
their suppliers.
G L O S S A R Y  O F  T E R M S  &  R E S O U R C E  L I S T

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G L O S S A R Y  O F  T E R M S  &  R E S O U R C E  L I S T
Global Reporting Initiative 
(GRI)
The most widely used international standard for sustainability re-
ports, endorsed by the UN Global Compact. The latest iteration of 
the group’s reporting guidelines is the GRI Standards, which were 
released in October 2016. They include two reporting options: 
Core and Comprehensive. Core provides the minimum level of in-
formation necessary to understand the nature of an organization. 
Comprehensive builds on the Core option by requiring additional 
disclosures on the organization’s strategy, ethics and integrity, and 
governance; it also requires reporting more extensively on the orga-
nization’s impacts by enumerating all the topic-specific disclosures 
for each material topic covered by the GRI Standards.
International Bill of Human 
Rights
Encompasses the UDHR, ICCPR and ICESCR.
International Covenant on 
Civil and Political Rights 
(ICCPR)
A key international human rights treaty, providing a range of pro-
tections for civil and political rights. The ICCPR obligates countries 
that have ratified the treaty to protect and preserve basic human 
rights, such as: the right to life and human dignity; equality before 
the law; freedom of speech, assembly, and association; religious 
freedom and privacy; freedom from torture, ill-treatment, and arbi-
trary detention; gender equality; the right to a fair trial; right family 
life and family unity; and minority rights.
International Covenant on 
Economic, Social and Cultural 
Rights (ICESCR)
An international human rights treaty that creates an obligation to 
respect, protect and fulfill economic, social and cultural rights, in-
cluding labor rights and the rights to health, education and an ade-
quate standard of living.
International Labour 
Organization (ILO) Abolition 
of Forced Labour Convention
Abolishes forced or compulsory labor a) as a means of political 
coercion or education or as a punishment for holding or expressing 
political views or views ideologically opposed to the established 
political, social or economic system; b) as a method of mobilizing 
and using labor for purposes of economic development; c) as a 
means of labor discipline; d) as a punishment for having partic-
ipated in strikes; and e) as a means of racial, social, national or 
religious discrimination.
ILO Core Labor Standards
Encompass the eight conventions listed above.
ILO Declaration on 
Fundamental Principles and 
Rights at Work
A 1998 declaration committing to respect and promote principles 
and rights in four categories: freedom of association and the effec-
tive recognition of the right to collective bargaining, the elimina-
tion of forced or compulsory labor, the abolition of child labor and 
the elimination of discrimination in respect of employment and oc-
cupation.

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ILO Discrimination 
(Employment and 
Occupation) Convention
Requires states to enable legislation prohibiting all discrimination 
and exclusion in employment on any basis, including race or color, 
sex, religion, political opinion and national or social origin, and to 
repeal legislation that is not based on equal opportunities.
ILO Equal Remuneration 
Convention
Enjoins members to take appropriate steps to ensure that rates of 
remuneration are equal for men and women workers for work of 
equal value.
ILO Forced Labour 
Convention
Prohibits all forms of forced or compulsory labor, which is defined 
as “all work or service which is exacted from any person under 
the menace of any penalty and for which the said person has not 
offered himself voluntarily.” Exceptions are provided for work re-
quired by compulsory military service, normal civic obligations, as 
a consequence of a conviction in a court of law (provided that the 
work or service in question is carried out under the supervision and 
control of a public authority and that the person carrying it out is 
not hired to or placed at the disposal of private individuals, com-
panies or associations), in cases of emergency, and for minor com-
munal services performed by the members of a community in the 
direct interest of the community. The convention also requires that 
the illegal extraction of forced or compulsory labor be punishable 
as a penal offence, and that ratifying states ensure that the relevant 
penalties imposed by law are adequate and strictly enforced.
ILO Freedom of Association 
and Protection of the Right to 
Organise Convention
Sets out workers’ and employers’ right to draw up their constitu-
tions and rules, to elect their representatives in full freedom, to 
organize their administration and activities and to formulate their 
programs, and prohibits any interference that would restrict or im-
pede the lawful exercise of this right.
ILO Minimum Age 
Convention
Sets the general minimum age for admission to employment or 
work at 15 years (13 for light work) and the minimum age for haz-
ardous work at 18 (16 under certain strict conditions). It provides 
for the possibility of initially setting the general minimum age at 14 
(12 for light work) where the economy and educational facilities 
are insufficiently developed.
ILO Right to Organise 
and Collective Bargaining 
Convention
Protects workers from acts of anti-union discrimination in hiring 
and employment.
ILO Tripartite Declaration 
of Principles Concerning 
Multinational Enterprises 
and Social Policy (MNE 
Declaration)
The only ILO instrument that provides direct guidance to enterprises 
(multinational and national) on social policy and inclusive, respon-
sible and sustainable workplace practices, founded substantially 
on principles contained in the ILO core labor standards above.

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ILO Worst Forms of Child 
Labour Convention
Seeks immediately to eliminate the worst forms of child labor, de-
fined as all forms of slavery or practices similar to slavery, such as 
sale of a child; trafficking of children, debt bondage or any oth-
er form of bonded labor or serfdom; compulsory labor, including 
forced or compulsory recruitment of children for use in armed con-
flict; commercial sexual exploitation of children (CSEC), including 
the use, procurement or offering of a child for: prostitution, or the 
production of pornography or for pornographic performances; and 
use, procurement or offering of a child by others for illegal activ-
ities, also known as children used by adults in the commission of 
crime (CUBAC), including the trafficking or production of drugs.
International Platinum Group 
Metals Association (IPA)
A non-profit association that represents the worldwide leading 
mining, production and fabrication companies in the global plati-
num group metals (PGMs) industry, comprising platinum, palladi-
um, iridium, rhodium, osmium and ruthenium. Its major aim is to 
act as a platform for discussion and information exchange between 
its members and with the outside world, and to serve as an early 
warning system for the PGM industry by monitoring legislation and 
industry related topics such as trade, health and safety and sustain-
able development.
OECD Guidelines for 
Multinational Enterprises 
(OECD Guidelines)
Issued by the Organization for Economic Cooperation and Devel-
opment, these guidelines set standards for responsible business 
conduct across a range of issues, including human and labor rights. 
They also establish a unique, government-backed, internation-
al grievance mechanism to address complaints between covered 
companies, and individuals who feel negatively affected by irre-
sponsible business conduct.
OECD Due Diligence 
Guidance for Responsible 
Supply Chains of Minerals 
from Conflict-Affected and 
High-Risk Areas (OECD Due 
Diligence Guidance)
Provides detailed recommendations to help companies around 
the world respect human rights and avoid contributing to conflict 
through their mineral purchasing decisions and practices.
Original Equipment 
Manufacturer (OEM)
A company whose goods are used as components in the products 
of another company, which then sells the finished item to users.
Responsible Minerals 
Assurance Process (RMAP)
Flagship program of the Responsible Minerals Initiative that uses 
an independent, third-party assessment of smelter/refinery man-
agement systems and sourcing practices. Employs a risk-based ap-
proach to validate smelters’ company-level management processes 
for responsible mineral procurement.

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G L O S S A R Y  O F  T E R M S  &  R E S O U R C E  L I S T
Shareholder Proposal
Matters that shareholders in a company vote on at an annual share-
holder meeting included in the proxy statement. The shareholder 
proposal process is regulated by the U.S. Securities and Exchange 
Commission (SEC). The process is outlined in SEC § 240 14a-8. A 
proposal can be submitted by a shareholder holding at least $2,000 
of shares for a period of one year, must be 500 words and comply 
with other criteria. Shareholder proposals are precatory. 
The Modern Slavery Act of 
2015 (MSA)
A law passed in 2015 in the United Kingdom to combat modern 
slavery. While not all sections apply to business, provision 54 on 
“transparency in supply chains” affects companies. It requires com-
mercial organizations with a global annual turnover of 36 million 
GBP or more who do business in the United Kingdom to disclose 
annually the steps they are taking to address modern slavery in 
their business and supply chain. The annual disclosure must be ap-
proved by the company’s board of directors and signed by a direc-
tor or equivalent.
Together for Sustainability 
(TfS)
A joint initiative of chemical companies founded in 2011, TfS pro-
motes sustainable practices in the chemical industry’s supply chain, 
and aims for global standardization of supplier evaluations and au-
diting. TfS has a global supplier engagement program, a risk analy-
sis and evaluation process, a supplier auditing program and more.
UN Global Compact’s Action 
Platform on Decent Work in 
Global Supply Chains
A cross-industry working group aiming to improve working con-
ditions in global supply chains as these relate to labor and human 
rights. Member companies have developed a voluntary commit-
ment to more effectively implement the main international stan-
dards—the ILO core labor standards, the 10 principles of the UN 
Global Compact and the UNGPs—in their respective supply chains 
through specific measures such as supplier training, collaboration 
with partners or greater transparency.
UN Guiding Principles on 
Business and Human Rights 
(“UNGPs”)
A set of guidelines for States and companies to prevent, address 
and remedy human rights abuses committed in business operations
UN Universal Declaration of 
Human Rights (UDHR)
A 1948 declaration by the UN General Assembly setting out funda-
mental human rights “to be universally protected.”
UN Women’s Empowerment 
Principles (WEPs)
A joint initiative of the UNGC and UN Women developed in 2010 
to provide a holistic framework to empower girls and women in the 
workplace, marketplace and community. The seven principles seek 
to elaborate the gender dimension of corporate sustainability. The 
formal mechanism for company engagement is through the CEO 
statements of support.

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Aluminium Stewardship 
Initiative (ASI)
The ASI, a global, multi-stakeholder, non-profit standards setting 
and certification organization that has developed a third-party cer-
tification program for sustainability and human rights principles in 
aluminum production, use and recycling.
Automotive Industry Action 
Group (AIAG)
A not-for-profit organization where OEMs, suppliers, service pro-
viders, government entities and academics collaborate to drive 
down costs and complexity in the automotive supply chain. The 
AIAG provides minimum human rights expectations for suppliers 
across the value chain.
Deutsche Gesellschaft 
für Internationale 
Zusammenarbeit (GIZ)
The German governmental agency for international cooperation is 
a joint pilot project launched in 2018 with BASF, BMW, Samsung 
SDI, Samsung Electronics and the Germany government that estab-
lishes a three-year pilot mining project to identify how to improve 
working conditions in artisanal mines, as well as living conditions 
in the surrounding communities in the DRC.
Drive Sustainability (DS)
Originally called the European Automotive Working Group on Sup-
ply Chain Sustainability, DS is a partnership of major automotive 
brands—BMW, Daimler, Ford, Honda, Jaguar Land Rover, Scania 
CV AB, Toyota Motor Europe, Volkswagen Group and Volvo—con-
vened to act for greater sustainability throughout the automotive 
supply chain. Facilitated by CSR Europe, DS aims to promote a 
common approach to the automotive supply chain within the in-
dustry and to support the integration of sustainability into procure-
ment processes. DS has a set of common guidelines—the Guiding 
Principles—that outline expectations for suppliers on key respon-
sibility issues including, but not limited to, business ethics, work-
ing conditions, human rights and environmental matters. Based on 
these guidelines, DS has developed a number of tools and resourc-
es, including a self-assessment questionnaire, training services, and 
local networks.
Global Battery Alliance (GBA)
An umbrella partnership of more than 70 members across the bat-
tery value chain, the public sector, civil society and relevant initia-
tives.

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Global Platform for 
Sustainable Natural Rubber 
(GPSNR)
An independent, Singapore-based platform launched in 2017 that 
aims to develop a fair, equitable and environmentally sound natu-
ral rubber value chain. Members include tire manufacturers, rubber 
suppliers and processors, vehicle makers and NGOs. The platform 
held its first general assembly in March 2019, and thus has yet to 
finalize its operations strategy and build a track record. 
Initiative for Responsible 
Mining Assurance (IRMA)
A global certification program for industrial-scale mine sites offer-
ing independent, third-party verification and certification against a 
comprehensive standard for all mined minerals. Regarded as one 
of the most robust initiatives, given its requirements of companies. 
Created with extensive stakeholder input.
Public Private Alliance for 
Responsible Minerals Trade 
(PPA)
A multi-sector initiative between leaders in civil society, industry 
and the U.S. government that supports projects to improve the due 
diligence and governance systems needed for ethical supply chains 
from the Dodd-Frank-defined Covered Countries. Works to develop 
traceability solutions and build civil society capacity to participate 
in a regional traceability and certification mechanism to support 
responsible sourced mineral sourcing and trade from the Covered 
Countries.
Responsible Business Alliance 
(RBA)
Formerly known as the Electronic Industry Citizenship Coalition, 
the RBA is a non-profit coalition of electronics, retail, automotive 
and toy companies committed to supporting the rights and wellbe-
ing of workers and communities worldwide affected by the glob-
al supply chain. It sets and holds members accountable to core 
standards and has launched several initiatives that are pertinent to 
this report: the Responsible Minerals Initiative, Responsible Labor 
Initiative and Responsible Factory Initiative.
Responsible Cobalt Initiative 
(RCI)
Founded in 2017 by the China Chamber of Commerce of Metals, 
Minerals and Chemicals Importers and Exporters (CCCMC) and 
corporate partners, the RCI aims to promote corporate due dili-
gence and increase transparency in the cobalt supply chain. The 
RCI is in the process of validating and refining an auditing standard 
and process for refineries and smelters through pilot audits in 2018 
and 2019. The RCI did not have a dedicated website in September 
2019.
Responsible Factory Initiative 
(RFI)
An initiative of the RBA, the provides a unifying architecture for 
RBA factory-level tools and programs for companies looking to as-
sess and develop their supply chain partners and factories at all 
levels of maturity.

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Responsible Labor Initiative 
(RLI)
An initiative of the RBA, the RLI is a multi-industry, multi-stake-
holder initiative focused on ensuring that the rights of workers 
vulnerable to forced labor in global supply chains are consistently 
respected and promoted.
Responsible Mica Initiative
An NGO created to build a sustainable mica supply chain in India 
by promoting responsible sourcing practices and eradicating child 
labor and unacceptable working condition. Members are drawn 
from industries associated with the mica supply chain in partner-
ship with civil society organizations and local stakeholders. The 
Guardian described the Initiative as “the first comprehensive ap-
proach to tackling endemic child labour in mica mining since the 
industry was alerted to its existence more than a decade ago.”
Responsible Minerals 
Initiative (RMI)
An initiative of the RBA, the RMI (formerly known as the Con-
flict-Free Sourcing Initiative) helps companies to address responsi-
ble mineral sourcing issues in their supply chains. Its Responsible 
Minerals Assurance Process (RMAP) offers companies and their 
suppliers an independent, third-party audit that determines which 
smelters and refiners can be verified as having systems in place to 
responsibly source minerals in line with current global standards. 
The RMI also provides a Conflict Minerals Reporting Template 
(CMRT), which helps companies disclose and communicate about 
smelters in their supply chains, and provides due diligence guid-
ance and stakeholder engagement activities. Fee-based member-
ship provides companies access to Reasonable Country of Origin 
(RCOI) data and related information associated with smelters and 
refiners.
Sustainable Natural Rubber 
Initiative (SNR-i)
A voluntary collaboration between the governments of Cameroon, 
Côte d’Ivoire, India and Sri Lanka, various rubber industry associa-
tions, intergovernmental organizations and natural rubber produc-
ers and purchasers that defines a set of sustainability standards for 
self-certification. One of the five criteria is respect for human and 
labor rights, with performance indicators around child labor and 
minimum age for workers, forced labor and freedom of association 
and collective bargaining, each reportedly aligned with the rele-
vant ILO conventions. It is not clear if the SNR-i remains active.
United Nations (UN) Global 
Compact (UNGC)
A non-binding, voluntary initiative based on CEO commitments to 
implement universal sustainability principles and to take steps to 
support UN goals.
I N D E X  O F  M U LT I - S TA K E H O L D E R  I N I T I AT I V E S

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I N V E S T O R  A D V O C AT E S  F O R  
S O C I A L  J U S T I C E  A F F I L I AT E S
Carmelite Friars
Congregation of Holy Cross, Moreau Province*
Congregation of Notre Dame
Congregation of the Passion
Daughters of Wisdom
Dominican Friars
Dominican Sisters of Hope
Franciscan Missionaries of Mary
Franciscan Sisters of Allegany, NY*
Maryknoll Fathers & Brothers
Maryknoll Sisters*
Mercy Investment Services
Province of St. Mary of the Capuchin Order
Religious of the Sacred Heart of Mary
RENEW INTERNATIONAL
Roman Catholic Diocese of Albany
School Sisters of Notre Dame,  
Atlantic-Midwest Province*
SCL Health
Sisters of Charity of Halifax
Sisters of Charity of Leavenworth
Sisters of Charity, New York
Sisters of St. Dominic, Amityville
Sisters of St. Dominic, Blauvelt
Sisters of St. Dominic of Caldwell*
Sisters of St. Dominic, Sparkill
Sisters of St. Joseph of Carondelet
Sisters of St. Joseph of Peace
Sisters of St. Joseph, Brentwood
Sisters of the Good Shepherd, NY Province*
Sisters of the Presentation of the  
Blessed Virgin Mary
Society of Jesus, USA Northeast Province
Society of St. Ursula
Society of the Holy Child Jesus
St. Philip the Apostle Foundation
Ursuline Sisters of Tildonk
Ursuline Sisters of the Roman Union,  
Eastern Province
*Filers or co-filers of shareholder proposal for 2020 AGMs

IASJ expresses gratitude to the IASJ Affiliates 
for their leadership in the Shifting Gears 
initiative and acknowledges the 
collaboration and expertise of the 
many civil society organizations, 
experts, investor partners and 
colleagues, multi-stakeholder 
initiatives, academics, and 
companies that have 
supported this work. 
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