Human Rights Policy Statement
Foreword
As a global company, we are aware of our social responsibility and are committed to respecting human rights and the environment along our company's entire value chain, identifying human rights and environment-related risks, and responsibly mitigating identified risks.
In doing so, we are guided by international standards that help companies to define and continuously optimize their approach to human rights in particular. These include, in particular, the United Nations Guiding Principles on Business and Human Rights (UN Guiding Principles) and the Organization for Economic Co-operation and Development Guidelines for Multinational Enterprises (OECD Guidelines), the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and local laws as the UK Modern Slavery Act that is endorsed by our UK affiliates. They highlight the importance of a due diligence process that makes it possible to proactively identify, assess and at least mitigate violations of human rights or environmental obligations in order to protect the holder of the rights in question.
In implementing its human rights and environmental due diligence, QIAGEN is subject to the requirements of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG). Among other things, the LkSG requires pursuant to Section 6 para. 2 LkSG, the annual publication of a policy statement outlining the company's strategy for the protection of human rights and the fulfilment of its environment-related obligations. Key elements of this policy statement include a description of the procedures QIAGEN uses to fulfill its legal obligations and a description of the human rights and environment-related risks and expectations for our employees and suppliers identified on the basis of an annual risk analysis.
As a core requirement of the LkSG, we regard the area-wide risk analysis as an important basis for continuous progress in our human rights and environmental due diligence. The results of our risk analysis from financial year 2024 will be available to us at the end of 2024. Our policy statement will therefore be updated accordingly as of January 1, 2025.
Human Rights Strategy
All business activities of our company must always be in compliance with the applicable law and our Code of Conduct and Ethics. As far as possible, we integrate the human rights and environment-related due diligence requirements of the LkSG into our company's existing management systems, rules and procedures, for example for occupational health and safety, environmental protection, supplier management and site management. We also use the company-wide compliance and quality management system, for example in connection with the provision of protected complaint channels and the handling of incoming complaints, or for comprehensive risk analysis in accordance with the requirements of the LkSG.
In addition to this Policy Statement more detailed information on this topic as well as on the respective rules and procedures can be found in Rules and Procedure. Further information can be found in our company's annual reports, which are also published on the global QIAGEN website.
Human rights in the supply chain
Maintaining sustainable and fair supply chains is a core element of our efforts with regard to our human rights strategy. Therefore, QIAGEN expects all suppliers to commit to comply with our Supplier Code of Conduct. This Supplier Code of Conduct includes numerous behavioral obligations and, above all, safeguards the fundamental human rights of our suppliers' employees. In addition to the comprehensive obligation of our suppliers to comply with applicable law and other behavioral requirements, this includes:
- Standards to prevent corruption
- Ethical standards in research and development
- Fair trade and competition
- Environment, health and safety
- Fair standards for wages, benefits and working hours
- Freedom of association
- Non-discrimination and fair treatment
- Standards for the sourcing of conflict materials
These principles are part of our contractual agreements with our suppliers. We expect them to also commit to respect human rights and environmental protection, to commit to establish appropriate due diligence processes and to pass these principles on to their own suppliers.
Risk management
QIAGEN strives to systematically operationalize any human rights and environment-related risks along the value chain. The early identification of human rights and environment-related risks plays a key role in an effective risk management system. We have established a Human Rights Committee that consists of the Head of Corporate Procurement, Head of ESG Strategy & Impact Programs and the Head of Global Legal Affairs and Compliance to monitor our human rights risk management as requested by Section 4 para 3, 1 LkSG
Effective risk management enables us to deal more comprehensively and at an earlier stage with the assessment of any human rights and environmental risks in our operating business and to integrate the main risk areas. This includes so far:
- Regular risk assessment of existing suppliers and new suppliers during their onboarding process
- Results from the annual environment, health, and safety risk workshops,
- Our experience in dealing with critical/ controversial business activities, expertise of external human rights experts and
- Insights from dialogues with investors, NGOs, key opinion leaders and other stakeholders
The procedures complement the specific risk management systems in place within the company for the individual subject areas affected by the prohibitions of the LkSG.
In this way, we also ensure that the situation and expectations of relevant rights owners are taken into account, as well as through regular company-wide surveys of our employees. The dialogues and cooperation with employee representatives and between the collective bargaining partners are also important sources in this context.
More detailed information is available on the global QIAGEN website and in the QIAGEN Sustainability Reports.
In addition to business-related controls, we use our company's internal control system and the auditing of corporate units by our audit function to ensure and monitor the implementation of our human rights strategy.
Risk analysis
QIAGEN applies a risk-based approach to identify potential risks in our supply chain. Our processes for risk analysis cover the prohibitions of the LkSG to a large extent and in some cases go beyond the prohibitions set forth in the LkSG.
As part of the risk analysis for the individual prohibitions, our Human Rights Committee determines regularly (at least annually) whether human rights or environmental legal interests are violated in our own business operations or whether there is a risk of such a violation in the respective business operations or in the context of business activities of direct suppliers (according to Section 9 para. 3 LkSG in the case of substantiated information also indirect suppliers), taking into account the origin and the specifications of the delivered goods and materials. If risks for potentially affected parties or the environment are identified, such risks will be evaluated and prioritized in the context of our business scope, the root cause of the risk, our ability to remedy the risk and the materiality of the risk. The results of the risk analysis will be reported to QIAGEN’s Executive Committee.
Each new supplier is requested to complete a comprehensive questionnaire that will be analyzed by the members of our Procurement Department.
This risk analysis process will further be carried out on an ad hoc basis, in particular if we have substantiated knowledge of factual indications that suggest a violation of human rights or environmental obligations by an indirect supplier.
Prevention measures
As a general principle, our suppliers have to commit to our Supplier Code of Conduct and the embedded human rights and environmental principles and to implement these principles in their supply chain. As part of this commitment, our direct suppliers are obliged to allow the conduct of audits to monitor compliance with this Supplier Code of Conduct.
In the event of an identified risk, members of QIAGEN’s procurement department and are obligated to immediately develop and embed appropriate preventive measures or purchasing practices and to monitor them on a risk basis. The measures must be suitable for preventing or minimizing human rights and environmental risks. We also ensure that the defined measures are complied with and implemented in the individual business areas.
If a risk is identified with regard to direct suppliers, appropriate preventive measures are immediately established vis- à-vis the direct suppliers and their implementation is monitored on a risk-based basis. This contains clear specifications that the contractual partner must observe.
If we have substantiated knowledge of factual indications that suggest a possible breach of duty by an indirect supplier, we will also take appropriate preventive measures in this respect and thus also support our indirect suppliers in complying with human rights or environmental obligations. Suppliers are monitored according to the results from the risk analysis, taking into account learnings from whistleblower reports.
We offer web-based training on sustainability and human rights in the supply chain for our procurement staff.
The effectiveness of our prevention measures is reviewed by our Human Rights Committee annually and ad-hoc on an as-needed-basis, e.g. if new products or business areas are launched.
Remedies
If we become aware of possible imminent or actual violations of the prohibitions of the LkSG or our Supplier Code of Conduct, we will take immediate corrective action to prevent, end or minimize such violations. We will ensure that any information we receive or become aware of regarding possible violations of the provisions of the LkSG by QIAGENer its suppliers is immediately forwarded to the responsible employees.
In our own business operations, the remedial measures will result in the prevention or termination of the violation.
In the case of (imminent) violations in the business area of direct suppliers, we will develop a corrective action plan and associated schedule for ending or minimizing (or avoiding) the violation together with the affected suppliers and monitor its sustainable implementation, provided that the business relationship is to be continued. In the case of indirect suppliers, in the event of substantiated knowledge of a (threatened) violation, we will develop a concept for the prevention, termination or minimization of human rights or environmental violations and ensure its implementation.
We reserve the right to terminate the business relationship in accordance with the requirements of the LkSG, at least in exceptional cases. Exceptional cases include:
- Serious violations of the law
- No remedy through implemented measures after the specified time has expired,
- No milder means recognizable and ability to exert influence does not appear promising.
Complaints proceedings
QIAGEN offers all employees and all external third parties protected reporting channels to report violations of external and internal rules, including human rights or environmental risks as well as violations of human rights or environmental obligations arising from the economic actions of a direct or indirect supplier. All such reports are forwarded to and followed up by our compliance organization.
The Compliance Whistleblower System is a company-wide, transparent, public and barrier-free complaints procedure. The system offers a more secure reporting channel, through which information can be given around the clock, seven days a week worldwide in over 20 languages through our digital reporting platform, or by email. anonymously if desired.
Employees and managers as well as customers, suppliers and other stakeholders of our company can turn to the system, which is technically supervised by an independent operator. The data is stored on protected servers in Germany. The content of the reports is processed exclusively by QIAGEN. The confidentiality of the whistleblower's identity is respected unless the whistleblower prefers to report on an anonymous basis. In the event of verifiable violations, appropriate disciplinary measures will be taken.
QIAGEN tolerates no retaliation against complainants or whistleblowers. Violations of this prohibition will be punished as compliance violations.
Reporting obligations
Our commitment to respect for human rights and environmental protection as well as the implementation of the UN Guiding Principles on Business and Human Rights are monitored by the Executive Committee. Both progress and challenges are discussed and improvement measures are derived.
The Executive Committee has appointed the Human Rights Committee as function pursuant to Section 4 para. 3 LkSG. In this function, the Committee reports regularly and on a case-by-case basis to the Management Board on compliance with human rights, environmental and other obligations under the LkSG.
The annual reports of QIAGEN pursuant to Section 10 LkSG are available at Qiagen N.V. - Investor Relations - Financial Reports & SEC Filings - Financial Reports.
Further information can be found in the QIAGEN Sustainability Reports.
The aforementioned procedures for the implementation of human rights and environment-related due diligence according to the LkSG are reviewed regularly – at least once a year – and on a case-by-case basis. The risk analysis for the individual prohibitions of the LkSG also includes continuous monitoring of risk developments.
Findings from the handling of information from the appeal proceedings shall be taken into account in the review of procedures.
We expect to publish information on identified risks for the 2024 financial year, their prioritization, and defined preventive measures with the update of this policy statement by the end of 2024.