Code of Conduct
In our updated Code of Conduct, we have detailed OMV’s commitment to human rights, and we expect and request that our business partners adhere to the same principles. They shall identify and manage human rights risks and impacts and cascade this due diligence requirement down to their own suppliers and contractors. The Code of Conduct is our commitment to conducting our business in a responsible way, respecting the environment as well as human rights, and adding value to the societies in which we operate. In the area of People & Their Human Rights, the Code of Conduct lays down our human rights commitments to our own workforce, value chain workers, and affected communities. These include freedom of association, freedom from forced labor, child labor, and human trafficking, favorable working conditions, access to grievance mechanisms, freedom from discrimination and harassment, and security setups that respect human rights. OMV has implemented appropriate due diligence systems, measures, and ongoing checks to ensure that the spirit and the terms of our Code of Conduct are also applied in practice, including in our operations and value chain. The process for monitoring compliance with our human rights commitments and requirements laid down in the Code of Conduct is defined in the Human Rights Management System.
For the Code of Conduct, unless otherwise specified, the process for monitoring, the scope of the policy, involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered in E1 Climate Change.
Human Rights Policy Statement
The Human Rights Policy Statement provides guidelines to ensure that the negative impact on our workforce, related to the inadequate application of human rights standards, such as inaccessible grievance mechanisms, disregard for freedom of association in places where legislation prohibits formal employee representation, and failure to address the economic and social consequences of staff release, can be prevented.
As part of our Human Rights Policy Statement, OMV has summarized the salient human rights responsibilities related to our relevant stakeholders (especially our own employees, contractors and their employees) in the areas of our own and value chain workers’ rights, communities and vulnerable groups (including indigenous people), security provisions, and human rights related to the environment and climate change. They are mapped out in more detail in a comprehensive Human Rights Responsibility Matrix, which is part of our internal Human Rights Management System, constitutes the basis for our activities in the field of human rights, and serves as a fundamental tool for their implementation. OMV adopts a rights holder’s perspective, ensuring that both business-related risks and human rights impacts are professionally identified, assessed and addressed. This ongoing due diligence (DD) process includes continuous engagement with external stakeholders, utilizing both internal and external resources. The results of the human rights self-assessments and human rights spot checks, which are an ongoing process, are used to monitor the effectiveness of this policy.
This policy applies to all OMV Group employees, and we expect our business partners to comply with the same principles. By integrating these human rights commitments into our Code of Conduct, which is part of our contractual relations, it becomes binding for our business partners as well. The Human Rights Policy Statement is approved by OMV’s CEO, who has overall accountability for its implementation, and is applicable globally across all OMV Group business segments and fully consolidated subsidiaries.
OMV respects human rights as contained in the Universal Declaration of Human Rights and in internationally recognized treaties, including the International Labour Organization (ILO) core treaties. Accordingly, OMV, Borealis and OMV Petrom have signed the UN Global Compact and are fully committed to the UN Guiding Principles on Business and Human Rights as well as the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. This includes a commitment to upholding labor rights, such as decent living wages, working hours, employee representation, and provisions against forced labor, child labor, and human trafficking. We therefore also fully support the aims of the UK Modern Slavery Act 2015 and are committed to operating our business and supply chain free from forced labor, slavery, and human trafficking. The OMV Statement on Modern Slavery and Human Trafficking explains in detail the countermeasures taken in all parts of the business and supply chain. Our commitment to human rights is embedded in each business approach and supports adherence to the UN Sustainable Development Goals (SDGs).
Our Human Rights Policy Statement is updated based on feedback from peer reviews, benchmarking and ESG rating agencies, reporting standards, internal and external expert consultation, and existing and upcoming legal requirements. The OMV Human Rights Policy Statement and the OMV Human Rights Management System are coordinated with key internal stakeholders from various departments such as People & Culture, HSSE, Security, Procurement, Business, Community Relations & Development, Environment, and Data Protection. The works council is also consulted during the development or revision of the Human Rights Policy Statement. During the drafting and major review phases of this policy, input from external independent human rights experts is also incorporated. It is publicly available on our website. Within the Company, it is communicated to all employees via our intranet through internal blogs, training material and OMV’s Regulations Alignment Platform.
The specific human rights commitments outlined within this policy are detailed below.
Labor Rights
This includes decent living wages, working hours, employee representation, collective bargaining, and provisions against forced labor, child labor, and human trafficking. We support the five fundamental principles and rights at work outlined in the ILO’s Declaration. We are committed to respecting workers’ rights, in line with the ILO’s fundamental conventions on rights at work, and we expect our contractors, suppliers, and the joint ventures we participate in to do the same. Where local labor rights standards fall short of OMV’s standards, based on international human rights law, OMV is guided by its higher standards unless this is forbidden by law.
OMV strives to be a fair and responsible employer. Upholding and promoting labor rights is essential to achieving legal compliance in a local and international environment. It is also essential to ensuring that our global workforce can develop professionally and fulfill their personal aspirations in line with our business needs. Read more about our approach to this topic under Operational Changes and Minimum Notice Periods in S1 Own Workforce.
Security
This includes preventive, defensive, and community-oriented approaches to security, clear guidelines, supervision, and training, all in a manner consistent with relevant laws and international standards or initiatives, including the Voluntary Principles on Security and Human Rights (VPs) and the International Code of Conduct for Private Security Service Providers (ICoC).
Health and Safety
This covers the OMV’s health and safety management including its workplace accident prevention policy and management system, as well as community arrangements. Read more about our approach to this topic in S1 Health, Safety & Well-Being and S3 Affected Communities.
Property and Land Rights
We follow international best practices, which require avoiding involuntary resettlement, or at least keeping it to a minimum, and we furthermore have a zero-tolerance policy for illegitimate land grabbing. Where resettlement is unavoidable, all people affected should be compensated fully and fairly. We are committed to a fair and transparent procedure for land use and compensation paid to local communities or authorities. If exploration, development, or production activities have the potential to impact communities and/or their land, we consult with all relevant stakeholders ahead of time and obtain permission to use the land either temporarily or permanently. Read more about our approach to engaging with our communities in S3 Affected Communities.
Local Communities and Indigenous Peoples
We are committed to community consultation based on free, prior, and informed consent (FPIC) in accordance with IFC Performance Standard 7 and ILO Convention 169. We are aware of indigenous communities in the proximity of our operations in Māui, Pohokura, and Maari in New Zealand, as well as in the Arma district in Yemen. Read more about our approach to engaging with our communities in S3 Affected Communities.
Environment and Climate Change
OMV recognizes the right to a clean, healthy, and sustainable environment as a human right that is intrinsically linked to a wide range of others. With our OMV Strategy 2030, we are fully committed to supporting and accelerating the energy transition, practicing responsible resource management, and minimizing the environmental impacts of our operations. Cognizant of the social impacts that the energy transition entails, OMV is committed to contributing to a Just Transition for our employees and communities, and to addressing the social and economic effects of the transition to an environmentally sustainable economy.
Human Rights Management System
The OMV Human Rights Policy Statement is our commitment to respecting human rights in our business operations, to identifying any potential or actual adverse impact, and to addressing it adequately. The OMV Human Rights Management System is our internal guidance document, mapping out the salient human rights issue areas in a Human Rights Responsibility Matrix, that explains the due diligence process and tools and defines roles and responsibilities. In 2024, the Human Rights Management System was reviewed to comply with new and impending legal requirements (CSRD, CSDDD), as well as to align with the updated OMV Human Rights Policy Statement, which was revised in 2022.
OMV is committed to respecting the human rights and labor rights of all employees, as stipulated in the Universal Declaration of Human Rights (UDHR), the International Labour Organization (ILO) conventions, and the United Nations Guiding Principles on Business and Human Rights (UNGPs).
Our due diligence process and tools as documented in the Human Rights Management System help us to ensure compliance with our human rights commitments, including through monitoring measures such as the Human Rights Self-Assessment (HRSA), providing access to grievance channels, and other activities. We have identified our salient human rights issue areas at Group level and mapped them out in the Human Rights Responsibility Matrix, which is part of our internal Human Rights Management System. They are also reflected in our Human Rights Policy Statement:
- Equality and non-discrimination: OMV is committed to ensuring fair treatment and equal opportunities for all employees. Employees in our workforce and job applicants are not discriminated against on any grounds, and OMV has zero tolerance for discrimination, bullying, and sexual and other harassment in working relationships. We prohibit discrimination based on race, gender, sexual identity, age, color, ethnic or social origin, genetic features, language, religion or belief, political or any other opinion, membership of a national minority, indigenous origin, property, family status, disability, health status, including mental health, or any other status.
- Freedom from modern slavery and child labor: We are committed to contributing to the elimination of all forms of forced labor, modern slavery, and human trafficking, as well as child labor.
- Just and favorable working conditions: We are committed to transparent and fair approaches to hiring and dismissal, the provision of locally applicable decent living wages, adequate working hours and rest times, and providing safe and healthy workplaces for our workforce.
OMV respects the right to form and join trade unions, meaning it will not discourage membership or participation in trade unions and refrains from actions that undermine adequate collective representation, including collective bargaining. In the case of national law prohibiting the establishment of formal employee representation, OMV seeks to allow alternative forms of adequate representation of employees’ interests, always within the relevant legal framework.
We engage with our workforce by continually informing and consulting employee representatives about Company developments that may impact their interests. The works council is consulted on all matters related to employees, such as workplace conditions and data protection. When reviewing our human rights policies and processes, including the Human Rights Policy Statement in 2022 and the Human Rights Management System in 2024, we involved a variety of internal stakeholders in the gap analysis and consultation phase. Employee representatives were also consulted and endorsed our proposal to make human rights e-learning a mandatory training requirement for all employees.
OMV has publicly committed to addressing adverse human rights impacts in which we are involved, and to taking appropriate measures for their prevention, mitigation, and, where necessary, remediation. We view grievance mechanisms as vital tools for preventing and managing negative impacts on local communities, employees, and other stakeholders. Our goal is to address all grievances received, whether they are based on actual or perceived issues, and regardless of whether the complainant is known or anonymous, in accordance with the UN Effectiveness Criteria.
OMV respects human rights as contained in the Universal Declaration of Human Rights and internationally recognized treaties, including the International Labour Organization (ILO) core treaties. We have integrated specific requirements related to aspects such as working hours and rest times, adequate living wages, occupational health and safety, all in line with international human rights standards, into our Human Rights Responsibility Matrix, which forms the basis of all our due diligence activities. We also inform our workforce about these in the mandatory human rights e-learning. Wherever we identify gaps in the implementation of these international standards as mapped in UDHR, ILO, or OECD, we develop action plans to close them and be fully compliant with our commitment. Having signed the UN Global Compact, we are fully committed to the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. Our Code of Conduct and Human Rights Policy Statement explicitly address our stance on forced labor, child labor, and human trafficking and refer to the respective ILO conventions.
Human Rights Due Diligence
The human rights due diligence process follows the steps defined in the UN Guiding Principles in Business and Human Rights and can be summarized in four steps: identify, address, track, and remediate.
- First, human rights impacts and risks associated with our current and future business activities are identified based on the Human Rights Responsibility Matrix and various tools we have developed, such as Country Entry Checks, Impact & Risk Mapping, and Compliance Checks for business partners.
- To address adverse impacts, we develop actions and mitigation plans based on the outcomes of the initial stage. 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.
- The effectiveness of our mitigation measures is tracked using the Human Rights Self-Assessment, which helps identify gaps and formulate further strategies.
- When necessary, we are committed to remediating adverse impacts through our grievance mechanisms, such as the SpeakUp Channel and community grievance mechanisms.
Human Rights Responsibility Matrix
The Human Rights Responsibility Matrix is a preventive tool that helps us to identify and address the negative impacts that have been identified in connection with the application of human rights principles. At all stages of the ongoing human rights due diligence process, we use it as a universal standard, mapping out reality on the ground against the specific responsibilities as defined in the matrix, and identifying any gaps we need to focus on. This approach helps us identify any potential human rights impacts of our business activities, whether they relate to non-discrimination and diversity, labor-related issues (e.g., decent living wage standards and adequate rest times), indigenous peoples’ rights, or human rights in the supply chain, such as freedom from forced labor, child labor, and human trafficking. It also enables us to prioritize impact management activities.
The Human Rights Responsibility Matrix maps our responsibilities related to all our salient human rights issue areas, including those we identified as material negative impacts. This helps us to identify and address adverse human rights impacts throughout our human rights’ due diligence process. This includes access to grievance mechanisms for all impacted rights holders, the freedom of association, protection against forced labor, human trafficking, and child labor, as well as fair and transparent hiring and release procedures.
Since 2008, we have mapped out our salient human rights responsibilities in a comprehensive Human Rights Responsibility Matrix designed to serve as the foundation for our activities in this area. We use this tool to identify impacts, assess our human rights challenges and activities, and prioritize our actions as essential, expected, or desirable. In 2023, we initiated an update of the Human Rights Responsibility Matrix as a follow-up to our review of the OMV Group Human Rights Policy Statement in the previous year. Keeping the overall structure of our Human Rights Responsibility Matrix, we have improved the alignment of its content and language with international human rights due diligence standards and legislation. The update was completed in 2024 and integrated into the Human Rights Management System.