To address the material negative impact of inadequate application of human rights standards, we have defined the following actions: identifying and assessing impacts and risks, tracking effectiveness through human rights self-assessments, and conducting training and awareness-raising on human rights. These actions are developed based on the outcomes of the initial stage of the human rights due diligence process. This process involves cooperation between Group Human Rights Experts, local focal persons, and subject matter experts, and is informed by consultations with internal stakeholders, external experts, and affected rights holders. For the material topic S1 Human Rights, none of our actions exceeded our key action monetary threshold of EUR 5 mn, and therefore these data requirements have not been addressed.
No material risks or opportunities were identified regarding the topic of human rights during the materiality assessment. To mitigate the negative impact on our workforce resulting from the inadequate application of human rights standards, OMV has allocated the following resources: three human rights experts – two at OMV and one at OMV Petrom. Additionally, a team of four social compliance experts at Borealis steers and supports the implementation of human rights due diligence. They provide tools, guidance, training, and subject matter expertise to conduct the human rights due diligence steps as described above. These efforts are supported by human rights focal persons and respective subject matter experts within the business. For information on whether and how external developments have been considered regarding dependencies turning into risks, see ESRS 2 General Information.
Impact and Risk Identification and Assessments
Impact and Risk Identification and Assessments serve as preventive measures to ensure our business activities do not cause or contribute to negative impacts on impacted rights holders, including our own workforce, value chain workers, and communities, and that we address negative human rights impacts wherever they cannot be prevented sufficiently. OMV has therefore developed due diligence tools and techniques to identify and assess actual and potential human rights impacts and risks related to our business, even before we launch or acquire a business in a new country or region. Human rights are one of the components considered when making the decision to engage in a new country or a major project. The relevant human rights impacts and related risks are presented to the respective Executive Board member to factor into the decision on whether or not to enter a country. We use these assessments to derive concrete due diligence measures to ensure an activity’s compliance with our human rights responsibilities.
Due diligence starts with an initial risk mapping at country level: every country we operate in (or plan to operate in) is assessed based on comprehensive human rights-related data and rated as a low, medium, high, or extreme risk country. Based on this rating, further due diligence actions and human rights training needs are defined with the objective of ensuring we don’t cause or contribute to negative human rights impacts on our rights holders and addressing all potential adverse impacts accordingly. Internationally recognized third-party experts support OMV in conducting human rights due diligence in countries with high human rights risks.
The Human Rights Compliance Check is a tool used to identify potential human rights impacts and risks related to business relationships. With this questionnaire-based assessment, we aim to identify a potential business partner’s capability to comply with our commitments and responsibilities as outlined in our Human Rights Policy Statement and Human Rights Responsibility Matrix. The goal is to prevent contributing to negative human rights impacts through our business relationships. The assessment examines a business partner’s policies and processes addressing human rights issues such as forced labor, child labor, human trafficking, just and favorable working conditions, communities and indigenous peoples, diversity and non-discrimination, and the availability of grievance mechanisms.
In 2024, we conducted three country entry checks that included assessments of human rights risks related to OMV’s potential business activities in that country and proposals for concrete mitigation measures in the case of positive entry. As part of these checks, we analyzed to what extent OMV could potentially be involved in adverse human rights impacts on its own workforce, value chain workers or affected communities when deciding to engage in a planned activity, and how to address them.
Furthermore, we conduct dedicated country risk assessments regarding the labor rights of our own workforce to determine and monitor the legal situation and future changes. As well as monitoring relevant labor rights risks, we work closely with various employee representatives according to the type of risk and potential impacts. With our annual initial risk ranking, we also identify countries with elevated risks of severe human rights abuse such as forced labor, child labor, or restrictions on the freedom of association. Within our country portfolio, 12 out of 484 (25%) countries (e.g., Yemen, Libya, and Brazil) show an elevated risk of child labor. Some 18 out of 48 (38%) countries (e.g., Yemen, Libya, and China) have an elevated risk of forced labor. The freedom of association is generally limited in 14 out of 48 (29%) countries (e.g., UAE, China, and Malaysia). We inform the respective General Managers and human rights focal persons about the elevated risk levels in their countries and recommend specific mitigation measures, for example human rights training for employees and discussing the mentioned human rights issues and adequate management measures in contractor meetings. This process is relevant for our current and future business activities globally and focuses on our own workforce as well as our business partners’ activities. It is an ongoing process.
Tracking Effectiveness
In 2024, we conducted a Human Rights Self-Assessment in OMV Tunisia with the support of external human rights experts. The findings and key recommendations were discussed with the team and external experts during workshops. The review showed that OMV Tunisia has some formalized systems in place to manage human rights impacts, which help in integrating and implementing human rights commitments. However, a detailed human rights impact assessment is recommended to identify the actual and potential impacts of business activities and operations on workers and communities in more depth. This would help in better understanding the severity of the impacts and adjusting human rights impact management measures where applicable. Additionally, engagement with rightsholders and effective monitoring of management measures should be strengthened. This action applies to our own operations in Tunisia, and was finalized in 2024.
OMV is committed to ensuring that our practices do not cause or contribute to material negative impacts on our own employees by conducting regular assessments of our current and future operations. These assessments are designed to identify and evaluate actual and potential human rights impacts and risks, including those related to diversity and non-discrimination, just and favorable working conditions for our employees, and freedom from forced labor, child labor, and human trafficking. Conducting Human Rights Self-Assessments is crucial in tracking the effectiveness of our measures to address human rights impacts on our workforce. As a result, no severe human rights incidents or incidents related to child labor or forced labor have been reported since 2017.
Training
We pay special attention to training and awareness raising to bring our human rights commitment to life and prevent negative impacts related to the application of human rights principles. We provide training on human rights, which helps equip our employees with an understanding of our human rights management process and gives them a space to work on concrete operational issues and business-specific challenges. These range from human rights in armed conflict environments and human rights due diligence responsibilities in joint ventures and other business relationships to personal legal liability and employee human rights (incl. freedom of association), risks of forced labor, human trafficking and child labor, and grievance channels.
All employees are required to complete our interactive e-learning course on human rights, which is part of the training curriculum and as such mandatory for all our employees worldwide. The course provides a basic understanding of human rights in the business context and insights into our specific responsibilities, for example related to diversity and non-discrimination, the labor rights of our own and contractors’ employees, human rights in security setups, and the rights of our communities, as well as severe human rights violations such as child labor, forced labor, and human trafficking. It also provides an insight into our due diligence tools and what to do in the event of observed or alleged human rights abuse.
Our subsidiary Borealis provides a mandatory human rights e-learning course for the entire Borealis workforce in nine languages, covering all relevant human rights aspects and including transparent information and lessons learned from the PDH Kallo incident in 2022. In addition, the Borealis ethics Code of Conduct e-learning covers human rights topics including discrimination, harassment, diversity, inclusion, bribery, and corruption.
Regarding specific labor rights issues, the rights and obligations of our employees are set out in employment contracts. We keep our employees up to date via our various internal channels of communication (e.g., employee intranet, emails, and news feed) in the event of legal changes or new available information. For questions and specific information, local P&C contacts and employee support hotlines are available. In 2024, 6,868 employees completed the human rights e-learning, and a total of 23 participants in instructor-led sessions learned about human rights in the business context, new and upcoming regulatory requirements, the OMV Human Rights Management System, and additional focus topics, aligned with the participants’ backgrounds and needs. As an example, we had a webinar for a project team working with a lot of contractors, where we focused on value chain workers’ rights, including diversity and non-discrimination, just and favorable working conditions (e.g., working hours, decent wages), and the risks of forced labor, child labor, and human trafficking, and how to detect them.
By the end of 2024, 80% of employees of Borealis, OMV Petrom and OMV had been trained in human rights. To track the effectiveness of our training, we ask participants for feedback in a standardized questionnaire, which includes questions about the perceived usefulness and relevance of the training experience, if it seemed easy to apply, and an open question for key take-aways. Additionally, 85% of the Borealis workforce completed the ethics Code of Conduct e-learning covering human rights in 2024. The target group of the training described in this section is employees in our own workforce. However, training is also provided to workers in our upstream value chain. To learn more about our training offers for workers in the value chain, see S2 Workers in the Value Chain. This is an ongoing process.
Since its launch in 2023, all OMV employees have had access to a dedicated Human Rights Learning Path in the Sustainability Academy, which provides learning materials about human rights in general and in the business context, human rights at OMV, human rights of employees (our own as well as those of contractors and suppliers), human rights of external stakeholders, and human rights and security. The provision of additional resources (e.g., links to online webinars and reading material from renowned external providers such as the ILO, UN, Ipieca, ICRC) allows colleagues to delve further into specific topics which include, for example, diversity and non-discrimination, labor conditions, forced labor, child labor, human trafficking, and other human rights issues.
Awareness Raising
We also implement internal awareness-raising campaigns throughout the Group to inform our staff about our policies and activities related to salient human rights issue areas like child labor and human trafficking.
In 2024, we continued working on engaging the highest level of management in human rights. As the key figures and co-owners of human rights in the OMV Group, the CEO and CFO actively participated in two in-person briefing sessions with our Group human rights experts, discussing updates to our policies and due diligence activities. Human rights topics were also discussed in two quarterly meetings of the Supervisory Board Sustainability & Transformation Committee and at several meetings of the OMV Sustainability Coordination Forum in 2024. Our awareness raising campaigns target our own employees and occur throughout the year.
Wherever applicable, we are committed to remediating adverse negative impacts on our own workforce through our grievance mechanisms, such as the SpeakUp Channel. This process is relevant for our current and future business activities globally spanning our entire value chain and is an ongoing process. The effectiveness of our mitigation measures is tracked using the Human Rights Self-Assessment, which helps identify gaps and formulate further strategies.
The Human Rights Self-Assessment is used to evaluate the effectiveness of our Human Rights Management System and due diligence approach. Such assessments create internal awareness, capture how we perceive our human rights performance, and facilitate the identification of gaps and further actions. Identified gaps can relate to any of the human rights issues mapped in our Human Rights Responsibility Matrix, such as inaccessible grievance mechanisms, non-respect for the freedom of association, unfair or nontransparent dismissal processes, or failure to address modern slavery risks. Based on the outcomes of these assessments, we develop action plans, which might include further capacity building for local experts or peer and business partner initiatives to tackle local challenges, among other activities.