Commitments

The Human Rights Policy

The Human Rights Policy is the key document on the Group’s commitments to human rights. This commitment is fully in line with the Group’s strategic vision and its due diligence approach. Adopted in 2019, the Human Rights Policy was developed in consultation with internal and external stakeholders (including NGOs and unions). The Policy is signed, at the highest level of governance, by all members of the Executive Committee. In 2023, to comply with the IRMA process, it was revised in conformity with the Group’s new standard.

Employees and representatives

TOPICS OF INTEREST
Employee and subcontractor health and safety, working conditions, non-discrimination, harassment, unions, etc.

Communities

TOPICS OF INTEREST
Health and safety of communities, natural resources, resettlement, cultural heritage, indigenous communities’ cultures and traditions, etc.

Suppliers and Subcontractors

TOPICS OF INTEREST
Duty of care in the value chain
(health and safety, working conditions, etc.)

Key Standards and Golden Rules

To be more operational, we enacted golden rules specifically relating to human rights (forced labour, working conditions, etc.). They apply throughout the Group, including all entities and subcontractors. They give descriptions of human rights along with examples for more clarity.

Know the Group’s human rights standards
Ensure good working conditions
Respect indigenous populations
Respect employee housing standards
Ensure the right to collective bargaining and union rights
Assess your impacts and risks on human rights
Zero tolerance of forced labour
Discrimination of any type is forbidden
Be attentive to your security
Zero tolerance of child labour
Harassment of any kind and violence is forbidden
Respect communities’ human right

Avoid and mitigate negative impacts on communities
Preserve the local cultural heritage
Do not access land without prior clearance
Respect community health and safety
Have a grievance mechanism
Protect temporary local staff

Human rights are integrated into the Eramet Management System through a Key Standard.
From 2023 onwards, compliance with this document will be monitored by the Group’s Internal Control 0Department and through regular audits.

The Ethics Charter

The Ethics Charter is the second most important Group document on human rights, encapsulating key topics such as discrimination, health, safety and harassment. This document is shared with and signed by the contractors and suppliers the Group works with. The Charter was constructed in consultation with and approved by unions and key experts.

The Supplier Code of Conduct

The Supplier Code of Conduct is a document that highlights the Group’s commitments to human rights (quoting from the Human Rights Policy and the Ethics Charter) and is signed by suppliers that work or wish to work with Eramet.

The CSR Roadmap

Eramet manages its CSR performance through is Act for Positive Mining roadmap, a global tool that addresses its challenges and risks and includes its contribution to the United Nations Sustainable Development Goals. The roadmap links CSR priorities to the pillars of its strategic vision.

Governance

The Social Impact and Human Rights Department

The Social Impact and Human Rights Department was created in 2021 within the Sustainable Development and Corporate Commitment Department because this area was considered a key CSR issue for the Group. The Social Impact and Human Rights team is responsible for meeting the Group’s human rights agenda, by implementing standards, steering action plans and supporting sites in this area.

The Human Rights Representatives network

Created in 2022, following the first assessment of Group sites’ compliance with the Human Rights Policy; action plans were drafted and the Representatives were selected by the sites’ management to guide the plans and ensure they were implemented. These Advisors are the main point of contact between the Human Rights Officer and the site. Each Eramet site has a Human Rights Representative. Human rights concerns are regularly discussed by each subsidiary’s management committee.

Eramet’s salient risks

Since the adoption of the 2017 Duty of Care law in France, Eramet has conducted three successive human rights risk mappings with the support of independent experts (in 2017, 2020 and 2023). In 2023, to remain in line with international standards on human rights (e.g. United Nations Guiding Principles – UNGPs) and the French Duty of Care law, Eramet conducted a more detailed human rights risk mapping than previous exercises. All risks are now specified with appropriate granularity and strong action plans.

More info in our 2023 Human Rights Report (page 27)

Risks due to activities that can lead to severe injuries for the workers involved, such as work at height, mechanical equipment or vehicles (cars or trains). Some of these activities can also lead to a risk to communities living around the sites.

Risks linked to activities that can have impacts on indigenous peoples in locations where operations are in close proximity to indigenous communities.

Risks linked to stress and burn out, harassment, conflict or external factors such as threats, assaults etc.

Risks of differences in treatment, discrimination or sexual harassment on the basis of one’s gender.

Risks linked to areas with a high density of industrial plants and other industrial facilities, which can trigger cumulative environmental impacts on water (quality, quantity), biodiversity (decrease) or erosion, as well as societal impacts such as loss of land and loss of livelihood, traffic-related issues, worsened air quality or public order disturbance.

Risks of violation of human rights (such as safety or modern slavery) across the supply chain due to its size and sometimes at-risk procurement segments (for example, specific materials or specific countries).

Eramet’s human rights journey

In recent years, Eramet has grown and developed, and with this growth has come a path of improvement on all CSR topics including human rights.

Eramet’s milestones

Evolution of the legal framework

1st MAPPING
of human rights risks and implementation of the whistleblowing system

2017

France
Law on Duty of Care

Adoption of the CSR roadmap
with a target focused on human rights

2018

TRAINING
“The pillars of community relations”

MEMBERSHIP
of the Global Compact

ADOPTION
of the Human Rights Policy signed by the Board of Directors

2019

2nd MAPPING
of human rights risks

AWARENESS RAISING
for employees with a human rights e-learning programme and ethical kits

FPIC* IS OBTAINED
from indigenous populations in Argentina in accordance with Convention 169

2020

USA
Uyghur Human Rights Policy Act

* Free, Prior and Informed Consent (FPIC) Consent based on: engagement that is free from external manipulation, coercion and intimidation; notification, sufficiently in advance of commencement of any activities, that consent will be sought; full disclosure of information regarding all aspects of a proposed project or activity in a manner that is accessible and understandable to the people whose consent is being sought; acknowledgment that the people whose consent is being sought can approve or reject a project or activity, and that the entities seeking consent will abide by the decision.
Source: IRMA Standard for Responsible Mining IRMA-STD-001 June 2018, Glossary of Terms p.189. IRMA_STANDARD_v.1.0_FINAL_2018-1.pdf

RECORDING
of the company’s Corporate Purpose in its bylaws

CREATION
of the Social Impact and Human Rights Department

1st ASSESSMENT
of sites’ compliance with the Human Rights Policy – Initial compliance rate: 88%

2021

GERMANY
Supply Chain Due Diligence Act

CREATION
of a network of human rights referents

HUMAN RIGHTS ACTION PLAN
on all sites

AUDIT
of mine complaints mechanisms by an independent third-party expert

2022

USA
Uyghur Forced Labor Prevention Act

NORWAY
Duty of Care

EU-Corporate Sustainability Reporting Directive

EU-Proposed Regulation on prohibiting products made with forced labour on the EU market

EU-Proposed directive on Sustainability Due Diligence

WORLD
COP15 on biodiversity (impact on communities)

PUBLICATION
of the Golden Rules

UPDATE:
3rd human rights risk mapping

NEW E-LEARNING
on human rights

HUMAN RIGHTS PUBLICATION

COMPLIANCE RATE
with Human Rights Policy end of 2023: 99%

2023

Major trends in claims

Claims on salient risks in human rights from integrity line

Claims raised by reporters from June 2020 to December 2023

Gender-based violence 3%
Human rights violations 10%
Discrimination and unfair treatment 35%
Harassment 52%

Locations of claims raised by reporters from June 2020 to December 2023

France 33%
Gabon 26%
Norway 2%
New Caledonia 19%
Senegal 7%
Argentina 12%
USA 1%

Types of grievances from 2020 to 2022

67%
anonymous

33%
non-anonymous

Trends in community grievances (2020-2022)

Mine community complaints 2020

Setrag 17%
Eramine 4%
Eramet Grande Côte 15%
Comilog 27%
SLN 37%

The main topics of these complaints were: impact on property, noise, dust and compensation claims.

Mine community complaints 2021

Setrag 19%
Eramine 1%
Eramet Grande Côte 22%
Comilog 33%
SLN 25%

The main topics of these complaints were: compensation, resettlement and nuisances (noise and dust).

Mine community complaints 2022

Setrag 54%
Eramine 2%
Eramet Grande Côte 15%
Comilog 19%
SLN 10%

Plant community complaints 2020

ENO 97%
CDK 2%
EMI 1%

Comilog Dunkerque is located in an industrial area and Eramet Marietta is located outside of the city area.

Plant community complaints 2021

ENO 100%
CDK 0%
EMI 0%

Plant community complaints 2022

ENO 98%
CDK 2%
EMI 0%

 

The main topics of these complaints were noise and dust.

Our Human Rights Report

  • CSR | Group

    Eramet publishes its first Human Rights report

    Eramet has published its very first Human Rights report, designed as a guide to the Group's commitment to respecting the fundamental rights of all its stakeholders: employees, partners and communities. The report includes : Message from Christel Bories, CEO of the Eramet group Eramet Executive Committee members' views on respect for human rights Key [...]

    22 December 2023

    #Human rights