In 2020, Deutsche Telekom carried out a human rights impact assessment at its subsidiary T-Systems India. One of the core elements of the assessment was the cooperation with a large number of interest groups and rights holders.
Background
The UN's Business and Human Rights Guidelines expect companies to establish ongoing and systematic policies and procedures to proactively identify, prevent, mitigate and combat adverse human rights impacts in which they may be directly or through their business relationships. Deutsche Telekom fully supports these Guiding Principles and has integrated respect for human rights into its strategy and basic guidelines, in particular the Guiding Principles and the Code of Human Rights & Social Principles. In addition, Deutsche Telekom aims to monitor and ensure that these guidelines are implemented in practice across the entire breadth and depth of its business activities and supply chain. One way of achieving this is through in-depth human rights assessments in specific business units, which are determined by a risk-based analysis. In 2020, Telekom visited its subsidiary in India to conduct such an assessment.
Methodology
The evaluation was divided into four phases:
- Phase 1 - Setup and preparation
- Phase 2 - Human rights impact assessment
- Phase 3 - Analysis and follow-up
- Phase 4 - Joint implementation of management measures
Additional and new approach
In the run-up to the on-site appointment in India, we conducted an online employee survey on human rights issues. All employees were invited to take part. This online employee survey is anonymous and voluntary.
On site, we conducted intensive human rights workshops with management and individual employees. Topics such as discrimination, working hours and health issues were addressed.
Key areas
The main human rights impacts, risks and opportunities relevant to the ICT sector, in particular for India and T-Systems India, that were considered and identified in the evaluation were
- working conditions of employees including working hours, use of overtime
- health and safety, such as the existence and implementation of sound health and safety standards and management systems
- Discrimination issues such as equal pay for equal work, integration of minority groups into the world of work, opportunities for people with disabilities
- Data protection, for example measures to protect employee and customer data from hacks, viruses and/or illegal information requests; provision of appropriate training on the protection and use of data
- working conditions in the local supply chain, such as access to complaints mechanisms, forced labour, working hours, remuneration and health and safety at work
- Environmental impacts both in the local supply chain and in our own operations
Results and next steps
The evaluation showed overall positive results with many systems and processes already in place, a dedicated and conscientious management team and a largely satisfied workforce. An action plan was agreed to drive forward the identified improvement opportunities. This action plan focuses in particular on strengthening the management of employees' working hours and overtime, raising awareness and training for specific internal policies, improving processes for the disposal of electronic waste, raising general environmental awareness and closer cooperation between central functions in the involvement and monitoring of the local supply chain. In addition, Deutsche Telekom is striving to incorporate the knowledge gained into guidelines and processes at a global level and to use this experience to further develop the global human rights due diligence approach.
