Corporate Integrity at Vestas is anchored in our responsibility to respect human rights and combat bribery and corruption. This is set out in the United Nations Universal Declaration of Human Rights, the International Labor Organization Declaration on Fundamental Rights and Principles at Work and according to the framework outlined in the UN Global Compact, the UN Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development’s (OECD) Guidelines for Multinational Enterprises’ recommendations on responsible business conduct. We abide by the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and local legislation requirements related to bribery and corruption. Our commitments in these areas are further outlined in our Codes of Conduct and other policies.
Embedding Corporate Integrity
The Compliance & CSR department works to embed human rights management and anti-bribery and corruption across the organisation. This includes the day-to-day responsibility of developing and updating the Human Rights Policy and Corporate-wide Human Rights Due Diligence, monitoring trends in the legal human rights landscape, and managing business ethics risks through policies and procedures.
The implementation of Vestas’ policies and procedures is done in collaboration with different stakeholders across the company at different levels. For example, with the sustainability department at a strategic level, with regional legal teams for the execution of regional compliance programs, and with sales and construction teams at the wind farm project level, to name a few.
The governance of corporate integrity at Vestas is also embedded in Vestas’ Sustainability Committee which oversees cross-functional sustainability initiatives across the entire organisation. This includes the oversight of initiatives related to human rights in our workforce and local communities in relation to Pillar 3 of the Sustainability Strategy that sets out the goal of becoming ‘the safest, most inclusive and socially-responsible company in the energy industry’.
Identifying and Assessing Risks and Impacts
To identify key issue areas within corporate integrity in our operations, Vestas subscribes to an externally led regular corporate-wide Human Rights Assessment (HRA) as well as an internal Anti-Bribery & Corruption (ABC) Survey. More information on our HRA can be found on the Corporate Social Responsibility site, and more information on our yearly ABC Survey can be found on the Sustainability Report.
In addition, Vestas has established due diligence processes to identify and assess third-party business ethics risks when entering new business relationships, and also social and human-rights related risks at the project level.
Vestas seeks to manage corporate integrity issues at a managerial level both through our policies and internal guidelines and at an operational level through different employee-level, business-partner, and site-level activities. On a site level, Vestas integrates its human rights management systems by conducting social due diligence on projects determined to be within the scope of this practice.
In terms of anti-bribery and corruption, Vestas has a yearly global and regional anti-bribery & corruption program which involves in-person training, online webinars, management training, and other initiatives across regions at an employee level. Vestas also actively manages ABC risks in its business relationships through business ethics screenings. Vestas seeks to work with suppliers around the globe who share our values and dedication to doing business with integrity. More detailed information on how we work with suppliers is available on the Sustainability Report on the Supplier Sustainability page.
At a corporate level, Vestas began reporting on corporate-integrity-related KPIs on the annual report in 2020. Our yearly KPIs used for tracking progress and setbacks in relation to human rights as well as the reasons for this, are the number of community grievances, the number of community beneficiaries, and the percentage of projects in scope for Social Due Diligence. In addition, Vestas’ annual report also includes the number of unsubstantiated and substantiated cases from our whistleblower hotline EthicsLine.
Data from the reports to our grievance mechanism and EthicsLine are assessed against patterns across topics or countries. Where found relevant, changes are made to processes to close gaps or the root causes of a recurrent issue.
At a supply chain level, we report on the number of suppliers that have undergone our due diligence covering business ethics and sanctions, as well as on the number of supplier on-site assessments to evaluate compliance with the standards of our code of conduct in our Sustainability Report.
At a project level, there is ongoing monitoring conducted by the staff on the site following up on occupational and community health and safety, labour conditions, impact on livelihoods, and where relevant follow-up with access to remedy. In some occasions, such as in the Lake Turkana Wind Power project, we conducted a post-impact assessment study in 2018 to evaluate the impact of the community development initiatives that Vestas together with the other project parties implemented during the construction phase.