At the OMV Group level, due diligence tools and techniques were developed. These tools are also used in OMV Petrom to assess the risk of human rights violations related to our business before we launch or acquire a business in a new country. Human rights are one of the decision-making components determining OMV Petrom’s engagement in a given country and are presented to the respective Executive Board members before deciding to engage in a country. In 2020 OMV Petrom won an international tender held by the Georgian Economy Ministry, as the Company looks to expand its upstream activity in the Black Sea. To this end, we commissioned an external human rights expert to perform a Human Rights Country assessment for Georgia.
Current operations are also subjected to regular assessments of their exposure to the risk of human rights violations. Due diligence starts with an Initial Risk Ranking at the country level: every country from the OMV Group (or plan to operate in) is assessed based on comprehensive human-rights-related sources (Verisk Maplecroft, The Freedom House, US State Department, Human Rights Watch, Amnesty International) and consultation with internal and external experts.
The countries are ranked by low, medium, and high risk, countries with the highest manageable risk, and “no-go” countries with unmanageable risk. Based on this ranking, the yearly work plan, defining further due diligence actions, and human rights training is developed. In 2020, based on Country Risk Ranking at Group level, România is classified as a medium risk country in the OMV Human Rights Risk Ranking.
Human rights in the Supply Chain
The supply chain continues to be an important material activity for OMV Petrom. We expect that all our suppliers respect human rights. For this reason, we have included human rights requirements in our Code of Conduct, which is part of the suppliers’ contract with OMV Petrom. Tools like 360-degree feedback, supplier evaluations, and audits assess and monitor suppliers’ valuations to the principles outlined in the Code of Conduct. Through ethical and human rights supplier verifications, we aim to identify gaps in the compliance management system and implementation. We pay particular attention to findings that are considered potential markers of modern-day slavery, child labour, and collaborate with the suppliers to eradicate these.
OMV Petrom‘s supplier audits cover the most important human rights aspects related to purchases. The supplier audit conducted in 2020 for OMV Petrom’s suppliers is a KPI for the Procurement Department, and their results are described in more detail in the section “Supply chain.” We engage with our suppliers to help them understand our ethical requirements and how we do business. If the expectations are not met, we take appropriate actions regarding the contract agreements.
Our impacts on human rights, the grievances management, and the corrective measures
According to the UN Guiding Principles, an effective grievance mechanism is a crucial instrument for ensuring compliance with our human rights commitment. Our Human rights policy states that we must provide appropriate remediation if we cause or contribute to adverse human rights impacts. Also, OMV Petrom has an ethics helpline available to all our employees and third parties who want to communicate their concerns.
Human rights grievances are submitted through the community grievance mechanism and then analyzed at the local and corporate level (More information can be found in this section).
Reporting channels used for reporting any suspected misconduct relating to labour conditions or human rights violations are defined in specific channels. For example, the “Integrity Platform,” which is a professional whistleblowing system recently introduced within the Company, is available to anyone (both internally and externally) to report any misconduct and which ensures full anonymity of the whistle-blower. (More information can be found in section “Business Ethics and Compliance”).
Having in view that at the end of 2018, a sustainability assessment was carried out for our communities, including human rights evaluation, an action plan was concluded and submitted to the Executive Board. The action plan, which contains our approach in regard to remedies, established a set of activities that were implemented during 2019 and continued to be implemented in 2020. We covered all the recommendations, including a reorganization of the space in Petrom City with a special room for breastfeeding (and/or pumping) to be used by employees that decide to return to work earlier and are still breastfeeding or rest for a short time within the pregnancy period. The space was organized in such a manner that it can be used as a separate room for changing a baby if the parent is in transit in Headquarter. Because 2020 was a special year due to the pandemic, with working at home by 90% of the employees, the room is used as a medical cabinet for the ill persons, until the medicine urgency services are provided.
SDG3 Target: 3.7 By 2030, ensure universal access to sexual and reproductive health-care services, including for family planning, information and education, and the integration of reproductive health into national strategies and programs.
Also, OMV Petrom employees can report human rights concerns by directly contacting the PetrOmbudsman Department.
Analyzing these tools, in 2020 there weren’t reported any human rights incidents or grievances through formal channels (2019: no incidents). Also, during 2020, we have not identified any risks related to child labor, forced labor, or violation of human rights, labour rights, or discrimination.