Responding department: Business Continuity – Sustainability and Continuity Planning
Does your company have a publicly available commitment to respect human rights?
Infineon Technologies refers to human rights in its Corporate Social Responsibility Policy, Principles of Purchasing & Code of Ethics.
How are human rights governed in your company?
The human rights topic within Infineon is managed by the Business Continuity – Sustainability and Continuity Planning (BC SCP) department, which reports to the company’s CFO and board member Mr. Dominik Asam.
Our Business Conduct Guidelines ([link]) outline our responsibilities to our customers, our employees, our suppliers, our communities and societies around the world, as well as our shareholders, including the respect and protection of human rights. Our CSR Policy ([link]) describes our strategic CSR focus areas and voluntary self-commitment to fulfill those. One of those focus areas is “Human Resources Management and Human Rights”. Both our strategic considerations and our day-to-day business must always be based on high ethical and legal standards.
How are human rights managed within your company?
As a UN Global Compact participant, Infineon has made a commitment to abide by its principles also in the Human Rights matters.
We carried out various human rights assessments worldwide in our production sites in order to assess if our activities are in line with the International Bill of Human Rights ([link]) and with the Fundamental ILO Conventions ([link]).
Based on the results of the assessment we carried out, some topics were identified as to be able to be a potential human right issue.
Afterwards, we identified which group of people could be vulnerable to that possible issue and defined mitigation actions for that. We continue monitoring the results of those mitigation actions to ensure that the issue is sufficiently covered by those measures.
As an example: Due to the special regulation situation in the Asian countries where Infineon operates, we identified “recruitment agencies procedures” as a potential issue. Therefore we developed special processes, and included special clauses in the HR Policies and local relevant hiring processes in order to manage the relationship and requirements for the recruitment agencies. These agencies are being regularly audited by an Infineon audit group to ensure that the defined requirements are being met and avoid that way any possible human rights abuses. Furthermore, at local level, for countries where our employees use dormitories, special dormitory evaluations (e.g. distance, standards, and travel situation) and special audit processes have been defined, in order to ensure that our CSR standards are being adhered.
Thanks to all processes we have in place we can affirm that Infineon activities are in line with the International Bill of Human Rights and with the Fundamental ILO Conventions.
Regarding new potential suppliers, these are also screened against Human Rights criteria before being registered as new suppliers. If they do not comply with those criteria, they cannot do business with Infineon.
Training is an essential tool to ensure human rights respect. For that reason, all employees are trained on the Business Conduct Guidelines ([link]), which reflect our self-commitment to respect and to uphold international human rights, with video sequences showing case studies from day-to-day working situations at Infineon that are descriptive and easy to grasp for employees at every level. The training is repeated at regular intervals and new hires to the company are automatically enrolled for training.
In addition, we have implemented external hotlines which our employees, suppliers, customers and business partners can contact, even anonymously. All reported cases are investigated by our Compliance experts.
What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?
Our Business Conduct Guidelines ([link]) outline our responsibilities to our customers, our employees, our suppliers, our communities and societies around the world, as well as our shareholders, including the respect and protection of human rights.
The Business Conduct Guidelines ([link]) are binding to all employees. Participation in training in this field is mandatory to all employees and is repeatedly carried out at regular intervals.
In 2015, Infineon, including International Rectifier led 5,850 training hours on the individual “codes of conduct”. This included information on human rights. In the last two years all employees were compulsorily trained.
As a socially committed company, we consider a voluntary approach to make an ongoing positive contribution to the development of the local communities in which we operate. Corporate Citizenship, understood as our voluntary commitment to these communities, is therefore a key component and one of the six pillars of our CSR concept. Infineon has created a Corporate Citizenship strategy to ensure proper care and attention is given to this topic. That strategy is reflected in the so-called Corporate Citizenship and Sponsoring Rule and supported on a personnel structure both at site level and at corporate level, headed by the Corporate Citizenship Panel, that reports directly to the Management Board.
The Corporate Citizenship and Sponsoring Rule defines the 4 strategic focus areas in that field:
- Activities in the field of ecological sustainability;
- Addressing local social needs;
- Education for future generations; and
- Emergency aid for the victims of natural and humanitarian disasters.
Under more than one of these focus areas, local activities with impact on human rights issues are regularly developed and/or supported.
Priority human rights issues: What are some of the priority human rights issues for your company?
The company selected the following from a check list:
- Health (including workplace health & safety, prevention of pollution)
- Workplace diversity / non-discrimination
- Freedom of association and trade union rights
- Conflict minerals
- Migrant workers
In July 2010, the USA’s Dodd-Frank Act (Dodd-Frank Wall Street Reform and Consumer Protection Act) ([link]) was adopted. It contains disclosure and reporting obligations for companies listed in the USA concerning the utilization of so-called “conflict minerals” that originate from the Democratic Republic of Congo (DRC) or its adjoining countries. The avoidance of conflict minerals throughout Infineon’s supply chain is a firm contribution towards the prevention of human rights abuses. For that purpose, we have determined a Group-wide approach to this topic with the aim of guaranteeing the necessary transparency within our own supply chain based on a standardized process established by OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ([link]).
In the 2015 fiscal year, Infineon identified 100 percent of its potential suppliers of conflict minerals and evaluated them with regard to their use. Based on the thorough response of our suppliers and in accordance with the requirements of the OECD guidance, we can duly state that Infineon products are fully DRC conflict-free. Moreover, we request our suppliers to continue purchasing only raw materials from smelters that meet the CFSI requirements or those of an equivalent auditing program.
As an international company, the diversity of our staff is particularly important to us. Our global diversity management provides the framework for a corporate culture which values the individuality of each staff member and promotes equal opportunities – irrespective of age, disability, ethnic-cultural origin, gender, religion, belief, or sexual identity. The focal points of our commitment to diversity may vary from one location to another and are tailored to suit local needs. For example, the diversity team in the Asia-Pacific region concentrates in particular on ethnic-cultural diversity and the demographic trend.
Infineon employs 35,424 persons of different nationalities. The five most prevalent nationalities represent a total of 74.8 percent of the workforce, with Malaysian nationals accounting for 26.2 percent and German nationals for 25.0 percent. A further 90 nationalities have a share of the total workforce of less than 1 percent each.
How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?
As a participant of the UN Global Compact Initiative, Infineon made a voluntary commitment to abide by the 10 principles included in it. Principles 1 and 2 deal with the topic of human rights. On our annual report, we publish our communication on progress on the UN Global Compact participation, which is also available in our website.
Training for all employees on the Business Conduct Guidelines ([link]), which reflect our self-commitment to respect and uphold international human rights is developed at regular intervals and new hires to the company are automatically enrolled for training. The number of participants in 2015 was approximately 16,700.
Additionally, we also demand that our supply chain uphold these principles. For this reason we have determined a Group-wide approach to this topic with the aim of guaranteeing the required transparency throughout our own supply chain. We expect our suppliers to give a commitment to uphold the values set out in our Principles of Purchasing ([link]).
What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?
All employees, business partners, customers or other stakeholders who would like to report possible violations of national regulations or internal guidelines can make their report through our Complaint Portal ([link]), openly or anonymously. Anonymous reporting and reports are treated confidentially and include a non-retaliation policy.
This portal is available to employees, suppliers, customers and other third parties including local communities, and also considers local languages in addition to English. In Europe, an ombudsman phone line is also available.
Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?
Infineon is a signatory company of the UN Global Compact since 2004 and publishes yearly it’s communication on progress. We also recommend our suppliers to become participants of this initiative and at least require them to adhere to its 10 principles.
We have also adopted the California Transparency in Supply Chains Act of 2010. This law requires large retailers and manufacturers doing business in the state of California and having annual gross worldwide sales of over $100 million dollars to disclose their efforts to eradicate slavery and human trafficking from their supply chain.
As reflected in our commitment to the United Nations Global Compact we respect and observe the internationally proclaimed human rights, including the rights to personal dignity, privacy and cultural practices. As set forth in our Business Conduct Guidelines ([link]) as well as in our Principles of Purchasing ([link]), we shall not condone human rights abuses, neither in the form of direct nor beneficial nor silent complicity and we are against any form of forced labor. We strictly oppose any form of human trafficking and slavery. More information is available in our Policy Statement regarding the California Transparency in Supply Chains Act of 2010.
Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.
Definition of a CSR Policy applicable worldwide
Our CSR Policy describes our strategic CSR focus areas and voluntary self-commitment to fulfill those. One of those focus areas is “Human Resources Management and Human Rights”. Both our strategic considerations and our day-to-day business must always be based on high ethical and legal standards. Our CSR Policy is binding for all employees and includes our commitment to respect and observe internationally proclaimed human rights, including the rights of personal dignity and privacy. We ensure that we are not complicit in human rights abuses, whether directly or by way of beneficial or silent complicity. Our Suppliers shall comply with these principles too, as reflected in our Principles of Purchasing, which is the document containing our requirements to suppliers.
We carried out various human rights assessments worldwide in our production sites
With the help of the Maplecroft global risk portfolios Infineon analysed in which countries there could be risks in terms of human rights. At the same time, the ratification of the relevant ILO conventions by the different regions and countries has been used as an evaluation criterion too. Based on the results of the assessment we carried out, some topics were identified as to be able to be a potential human right issue.
Afterwards, we identified which group of people could be vulnerable to that possible issue and defined mitigation actions for that. We continue monitoring the results of those mitigation actions to ensure that the issues are sufficiently covered by those measures.
Suppliers Human Rights Management
New suppliers are screened against Human Rights criteria before being registered in the SAP system. If they do not comply with those criteria, they cannot be registered in SAP and therefore they cannot do business with Infineon.
What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?
We carried out various human rights assessments worldwide in our production sites and based on these assessments we have concluded that Infineon activities are in line with the International Bill of Human Rights ([link]) and with the Fundamental ILO Conventions ([link]).
The percentage of our business activities to be at risk is due to external factors like the regions where our facilities are placed at. Therefore the total mitigation of the risks is impossible. The only action possible is the one carried out by Infineon: update the risk evaluation regularly, define clear measures whenever any mitigation action is necessary and monitor the implementation of such.