Introduction
At Distrelec Group, we believe in the importance of safeguarding human rights and decent working conditions. We are committed to maintaining and developing appropriate measures to promote a safe and secure working environment within our business and supply chain. We work to advance this commitment through our policies and due diligence practices.
This report was developed in order to comply with the legal requirements set out in the Norwegian Transparency Act that entered into force on 1 July 2022. The report describes how we are organised, how we work on human rights due diligence, how we have embedded responsible business conduct in our management systems, identified risks of adverse impacts and measures to mitigate these.
About Distrelec Group
Distrelec Group, headquartered in Manchester (UK) and Nänikon (CH), is a leading B2B distributor of electronic and technical components. Beyond our main markets of Switzerland and Sweden, we also have a strong market presence in 15 European countries. Our product portfolio has a significant focus on MRO components and targets B2B customers.
Our Norwegian office is based in Oslo and consists of 8 employees whose roles cover Sales and Customer Services. The products sold to our customers in Norway are distributed from the Central Distribution Centre based in Netherlands.
Our supply chain consists of 984 suppliers 828 of which are based in Europe and 156 based in APAC region, which includes suppliers from Canada and USA. Our vendors are grouped into 5 categories (A, B, C, D and E) based on the amount of spend in a 12 months period. All those suppliers supply goods.
Policies and procedures
We have number of group wide and location wide policies that set out our commitment and expectations in relation to fundamental human rights and decent working conditions.
We also expect our partners, contractors and other hired personnel who work in our operations to meet our standards and respect our values as outlined in our policies.
Furthermore, a Supplier Code of Conduct was adopted to ensure that our suppliers are aware of and uphold Distrelec’s expectations on human rights and labour rights, among others.
Other Distrelec policies also set out principles that are important for our human rights efforts, such as our discrimination, bullying and harassment policy and our diversity and inclusion policy.
Due diligence at Distrelec
For the purpose of preparing this report an analysis was undertaken of human rights and decent working conditions risk in our operations and supply chain.
Between January 2023 and June 2023, Distrelec carried out a risk assessment which was based on risk factors relating to location and specific suppliers to identify human rights risks across our business operations in our supply chains. The risks were based on the rankings of human rights and rule of law index which captures the extent to which people are free from government torture, political killings, and forced labour and to which people have property rights and enjoy the freedoms of movement, religion, expression and association.
The risk assessment will be revised on a yearly basis or as needed to ensure that Distrelec remains responsive to changing circumstances and emerging risks.
The supplier analysis also included spend data that enabled us to identify our largest purchasing categories, including supplies and services most critical to our business, enabling us to assess our human rights risks further down the supply chain based on materiality.
We have identified and prioritised human rights risks that are relevant to Distrelec Norway operations. We have assessed our prioritised areas based on severity and likelihood of potential adverse impacts. Distrelec risk areas are:
• Working hours, wages, and benefits
• Discrimination and harassment
• Health and safety
• Supply chain
• Privacy
• Labour and union rights
• Minority rights
• Children’s rights
Due diligence observation
Observations from the due diligence process indicates that Distrelec generally operates in a low-risk environment with regard to adverse impacts on fundamental human rights. Our operations are free of forced or compulsory labour. All of our employees in the Norway office are above the legal employment age and are recruited and provided with working conditions, including wage payments and benefits, in compliance with applicable laws and regulations. Distrelec considers the risks related to our own operations to be well managed through existing systems, policies and procedures. The below policies apply to the Norway office.
• Code of Conduct
Our Code of Conduct outlines our commitment to respect human rights and labour rights in our own operations. Based on this conviction, Distrelec Group follows the ten principles relating to human rights, labour standards, environmental protection and anti-corruption initiatives. Distrelec is committed to laying down binding standards of conduct that we expect and to take appropriate disciplinary action in the event of any violations. The Code of Conduct was approved by Distrelec’s board of directors and sets out principles related to: human rights, labour rights, anti-corruption, environment.
• Whistleblowing
Our whistleblowing procedure gives employees, board members, and third parties cooperating with Distrelec a channel to report suspected breaches or non-compliance with Distrelec Code of Conduct including those relating to modern slavery and other human rights concerns.
• Bullying and harassment
All employees have the right to work in an environment where they are shown respect and consideration at work, and in which the dignity of each and every
individual is valued and maintained. Distrelec is committed to the development and promotion of a positive workplace culture that is free from harassment and bullying, and aims to ensure that any allegation of harassment or bullying at work is taken seriously, investigated and dealt with effectively.
• Modern Slavery
Distrelec is fully committed to ethical working practices, and, as a company, regards inhumane conditions such as slavery, worker exploitation, and human trafficking as completely unacceptable either within our own business or through our supply chains.
• Equality and Diversity policy
All employees are equal, we provide an environment where everyone is shown respect and consideration and is treated in an equivalent fashion. Distrelec fully supports the principles of equal opportunities in employment and opposes all forms of unlawful or unfair discrimination. The Company is fully committed to eliminating discrimination and encouraging diversity amongst its workforce. It is paramount to the Company to ensure that each member of staff feels respected and has a working environment that promotes dignity, equal treatment, where each worker is able to give their best and their contributions are valued and recognised.
• Your Voice
This option is accessible to all employees and is well suited to voicing concerns about potential violations of fundamental human rights and decent working conditions.
Distrelec’s supply chain relating to Norway operations is mainly located in European countries that are highly regulated in the areas of labour rights and health and safety, with high levels of human development and low risk of violations of fundamental human rights. Most of the countries are above average in the human rights and rule of law index ranking which puts them in a low risk group.
The high risk suppliers we identified using the human rights and rule of law index are based in the APAC region with China being third highest risk country in the ranking. Based on our suppliers spend data analysis products sold in Norway from our suppliers in China account to 5% of total sales which minimises and controls the risk.
Plan put in place to control and minimise the risk
• Supplier Code of Conduct
We introduced a Supplier Code of Conduct which is issued to all our new suppliers and its commitment is being renewed with existing suppliers. Our Supplier Code of Conduct shows commitment to the ten principles of the UN Global Compact relating to human rights, labour standards, child labour, health and safety, environmental protection and anti-corruption initiatives. The Code of Conduct applies to all suppliers, consultants, agents and partners of all companies, subsidiaries and brands of Distrelec Group.
Distrelec, on behalf of all of its companies, subsidiaries and brands, considers the requirements of this Supplier Code of Conduct to represent a minimum standard for sustainable supplier management. Therefore, this Supplier Code of Conduct forms the basis of our business relationship. We are confident that by strictly adhering to the requirements of this Supplier Code of Conduct, we are jointly creating added value for all parties involved.
• Supplier Selection Questionnaire
Any supplier entering into a trading agreement with Distrelec must comply with human rights and labour standards and will be assessed based on the evidence of the documents they provide for the following:
Code of Conduct
GDPR policy
Anti-corruption/bribery policy
Whistleblowing policy
Health and safety policy
Modern slavery policy/statement
• Supplier pre-qualification process
A key stage for our vendor management strategy is to have a pre-qualification process methodology whereby suppliers of particular goods and/or services are assessed against pre-determined criteria and then only those suppliers who satisfy the pre-qualification criteria are invited to proceed to the next on-boarding stage.
• Whistleblowing
A dedicated whistleblowing e-mail for the Supplier if they learn of any known or suspected improper behaviour by the supplier or by employees of the Distrelec company, its subsidiaries or its agents.
Measures and areas for further improvement
Our ambition is that our due diligence processes contribute to real improvement in our own operations as well as in our supply chains. This work is a continuous process, and we will continue to systematically follow-up identified risk areas. Distrelec is planning to implement new procedures and stricter criteria for supplier selection process. Distrelec will also work on a risk assessment framework that will help us to analyse, monitor, assess and develop our suppliers. Distrelec will continue making our Supplier Code of Conduct checks on our current suppliers, especially those in high risk regions, and will not enter into a trade agreement with any supplier that refuses to adhere to the Supplier Code of Conduct. The aim of these measures is to drive progress towards reducing potential adverse impacts in our supply chains. Wherever possible and beneficial we will engage with stakeholders to promote human rights and decent working conditions in all aspects of our operations and supply chains.
We recognise that achieving the desired outcomes requires ongoing work to monitor and evaluate the effectiveness of our mitigation measures and close collaboration with our suppliers.