Does your company have a publicly available commitment to respect human rights? If so, please provide a link.
DONG Energy’s Responsibility Policy outlines our conviction to adhere to the principles of responsible business practice. Our work is based on the UN Global Compact’s ten principles –including in the areas of human rights. DONG Energy’s commitment is aimed at our employees and local communities in the markets in which we operate.
Does your company identify its salient human rights issues and does it have a due diligence process to manage them? If so, please list the issues and describe the due diligence process (key steps include: impact assessment, integrating & acting on findings, tracking responses & communicating how impacts are addressed).
For DONG Energy Operations:
In 2015, DONG Energy undertook a Human Rights Risk Mapping for its operations in order to identify salient human rights issues. Issues were identified for different rights holder groups (employees, suppliers/contactors, communities). We expect to repeat the mapping every few years in order to update findings and track any changes in salient issues over time.
The issues identified are part of our overall materiality assessment. The findings from the risk identification process have also been integrated into our 2016 sustainability theme and programme review process.
Human rights are included in our annual risk identification process and publically available. Issues identified include (inter alia):
- Health and safety
- Community impacts
- Business partner conduct
- Employee discrimination
DONG Energy has policies and programmes to address these issues including:
- Workplace safety and employee health programmes
- Local engagement policy and initiatives
- Responsible Business Partner Programme (see below)
- Diversity programme
Reporting is available through our annual data appendix.
We will be including details in our upcoming 2016 Sustainability Report as well as on our Web site in due time.
For DONG Energy Supply chain and Joint Ventures:
Human Rights due diligence in our supply chains is undertaking through our Responsible Business Partner Programme (RPP).
Our Code of Conduct for Business Partners is aligned with principle international standards, including the Guiding Principles on Business and Human Rights.
The Code covers issues related to Human Rights including:
- Human rights risk management and mitigation
- Grievance mechanisms
- Child labour, forced labour
- Fair labour conditions
- Freedom of association
- Health and safety
- Community impacts and land acquisition
- Community security
- Environmental impacts and livelihood
We conduct risk-based due diligence on our 25,000 business partners. This includes:
- continuous risk-screening of all contracts with a value of 400 000 Euros or more
- annual review of top 80% spend suppliers
- annual review of suppliers with contract value below 400 000 Euros
- Screening of all new joint venture partners
- Execution of assessments based on questionnaires or site visits for medium and high risk business partners
- Collaboration on development of improvement plans and continuous monitoring of implementation of improvement actions by our business partners.
Results from business partner assessments are reported quarterly to the CFO of each Business Unit. In addition, we report the number of very significant and significant findings opened and successfully closed in our annual sustainability report.
What criteria does your company use to identify communities that may be affected by renewable energy projects it is involved in?
DONG Energy Local community engagement Policy and Stakeholder engagement policy provides the overall framework for our activities at community level. This is to be complemented by new guidance on community engagement that is under development.
In each of our country offices, we have stakeholder relations departments responsible for engaging local communities. In addition, each at asset level, we seek to identify impacted communities.
As most of our operations are off-shore, we have limited immediate contact with communities.
How does your company consult with affected communities (on impact assessments, resettlement, benefit sharing plans, etc.)? Please describe what form consultations take and when they are carried out in a project’s cycle.
Our Local Engagement policy outlines benefit fund.
DONG Energy new developments are only offshore and are thus not impacted by resettlement. For existing assets on-shore (eg. power plants) we monitor how any changes to our operations affect neighbouring communities. An example is our reduction of coal consumption and substitution for sustainable biomass resulted in increased road traffic to power plants. A traffic-awareness project was successfully implemented (more information available here).
For our off-shore operations we identify relevant project impacted communities such as fisherman groups and operate necessary compensation programmes for fishermen’s whose activities are disrupted in the construction or operations phase of our projects.
In addition, we engage with local communities where we are present and help local companies to compete in our tenders. We also offer professional training for jobs in the energy industry.
Does your company ensure its consultations include the perspectives and respect the rights of all affected community members (including those who may be marginalised for reasons of gender, social status, age, religion, wealth or income or other considerations)? How is this ensured?
In the new guidance on community engagement, there is a specific provision for identification of vulnerable groups at project initiation stage. Such identification is to take place though research and stakeholder consultation to ensure adequate representation of marginalized groups.
Under what circumstances does your company commit to seeking an affected community’s free, prior & informed consent to a project? Please provide examples of projects where free, prior & informed consent was sought (if applicable).
Our on-shore footprint is low. Have not fully developed such a process.
For our supply chain, our Code of Conduct covers issues such as human rights and indigenous rights, land use and land acquisition, and community engagement. Through our Responsible Business Partner Programme, we engage relevant suppliers on participation and consultation of Indigenous communities affected by their operations.
What is your company’s process for obtaining and evaluating free, prior & informed consent?
See above
Has your company faced any challenges in its process to seek free, prior & informed consent for renewable energy projects? If so, please describe what steps your company has taken to overcome these challenges.
Not applicable at the moment.
What steps does your company take to ensure that its own personnel, private security companies it contracts with, and/or government forces providing security to its projects, respect the rights of workers and community members, including those who may oppose its projects?
Our footprint is primarily North-Western European and off-shore As such, we do not face direct issues with government forces providing security on our projects.
Private security companies provide services at our offices and project sites and are expected to follow DONG Energy’s Code of Conduct and procedures.
Does your company have a grievance mechanism in place at each project site for affected communities and workers to raise concerns about local impacts, including human rights abuses? If so, were affected communities involved in the design of the grievance mechanism, including its set-up and the types of remedies it provides?
DONG Energy operates grievance mechanism that is available to employees, business partners, suppliers, customers, and communities. The mechanism is publically available on our website.
In addition, there is always a contact person at each DONG Energy project site to receive grievances from potentially impacted communities.
Please provide any further information regarding your company’s policies and practices on human rights that you think is relevant.
DONG Energy engages a set of NGOs both bilateral and in an annual roundtable. During these engagements, we discuss both issues that we are in the process of addressing as well as those NGOs feel need to be brought to our attention.