In 2018 Deutsche Telekom carried out a human rights impact assessment at its T-Systems Singapore subsidiary. One of the core elements of the assessment was engagement with a diverse range of stakeholders and rightsholders.
The United Nations Guiding Principles on Business and Human Rights (UNGPs) expect businesses to put in place ongoing and systematic policies and processes to proactively identify, prevent, mitigate and address adverse human rights impacts with which they may be involved directly or through their business relationships. Deutsche Telekom fully endorses the UNGPs and has integrated respecting human rights into our fundamental policies, especially the Guiding Principles and our Code of Human Rights & Social Principles. In addition, Deutsche Telekom also seeks to deepen its understanding of the actual impacts of operations and business relationships on rightsholders across the breadth and depth of our operations and supply chains. One way in which the company achieves this is through deep-dive human rights impact assessments at specific business units, identified through risk-based analysis. In 2018 DT visited its subsidiary in Singapore to carry out one such assessment.
The assessment was divided into four phases:
- Phase 1 - Set-up and preparation
- Phase 2 - Assessing human rights impacts
- Phase 3 - Analysis and follow-up
- Phase 4 - Collaboratively implementing mitigation and management measures
The main human rights impacts, risks and opportunities relevant for the ICT sector, for Singapore and TSS specifically, considered and identified in the assessment were:
- Working conditions of employees including working hours, use of overtime
- Health and safety such as the presence and implementation of robust health and safety standards and management systems
- Discrimination topics such as equal pay for equal work, the integration of minority groups into the work force, opportunities for people with disabilities
- Privacy, for example measures taken to protect both employee and customer data from hacks, viruses and/or illegal requests for information; provision of adequate training on how data is protected and used
- Working conditions in the local supply chain such as access to grievance mechanisms, forced labour, working hours, remuneration and health and safety
- Environmental impacts in both the local supply chain and own operations
Results and Next Steps
The assessment showed overall positive results with many strong systems and processes already in place, a dedicated and conscientious management team and a largely satisfied workforce. An action plan was agreed on to take forward the identified opportunities for improvement and the companies are working together to implement the final recommendations. These focus especially on strengthening the management of employee working hours and overtime, improving awareness and training on specific internal policies, improving e-waste disposal processes, increasing general environmental awareness and deeper collaboration with DT corporate on local supply chain engagement and monitoring. In addition, Telekom is seeking to incorporate lessons learned into global level policies and processes and to use this experience to continue to evolve the global human rights due diligence approach.