Human Rights Issues and Risks
Identification of salient human rights risks
Thule Group has conducted a Human Rights mapping to identify potential human rights risk associated with the company’s business.
Thule Group identifies human rights risks according to the UNGP principles
- Stakeholders prioritized human rights as significant issues in 2021, specifically child labour, health
and safety and discrimination. - We analyze the main business processes in our value chain where actual and potential human rights risks could occur such as in supply chain, production, corporate governance, sales and distribution.
- Key risks categories identified in the policy: labour conditions, health and safety, environment, and end-user/customer ethics.
Thule Group mapping of Human Rights Salient Issues & Risks in the value chain
Instructions to facilitate the understanding and use of Thule Group's Human Rights mapping
Product
Human rights risks associated with product includes potential risks and impacts related to research and design, product development and testing.
Overall, both the likelihood of human rights risks occurring, and the impacts are low for this category.
Providing safe and high-quality premium products is one of the top priorities for Thule Group. Our R&D, product design, and development teams are based in Hillerstorp, Sweden, where they are provided safe and inclusive work environments. We provide an environment where employees get training, opportunities for career transitions and career development, and performance-based reviews once a year.
Our products are designed, developed and tested by taking the health and safety of our workers, environment, customers and consumers into consideration. Thule Group follows the Restricted Substances List (RSL) in accordance with the European REACH Regulation, Stockholm Convention on Persistent Organic Pollutants (POPS) and the California Proposition 65.
There is also minimal human rights risks imposed on customers or end users in product design, development and testing, as we do not engage in business relations with known cases for corruption or bribery, and we do not engage in anti-competitive behaviors.
Our product design, testing and development are conducted with integrity and Thule Group products are protected by patents. Our business relationships and policies are strongly against anti-competitive behavior and policies, and we also have laws against counterfeit products.
Supply Chain (Procurement and Production)
Thule Group follows the Supplier Code of Conduct (SCoC) which applies to all business partners in the value chain including suppliers. Our SCoC and the Code of Conduct encompass key human rights values and principles, binding on all suppliers.
We have 650 suppliers based around the world, and we strive towards ensuring transparency and accountability in the supply chain, especially in terms of adhering to human rights issues. We conduct in-house and third-party supplier audits of labor conditions, workers' rights, occupational health and safety, and we further do not engage with suppliers who might compromise the quality and safety of our products, as well as Thule Group’s brand by using conflict minerals, or chemicals that are harmful to human health or the environment.
We acknowledge that achieving the lowest risk and impact status will require continuous improvement of our audit processes, including requirements from suppliers to evidence the protection of human rights across the supply chain.
Sales and Distribution (focus on end user and customer ethics)
Thule Group has a global omnichannel strategy, with a vast network of sales and distribution partners around the world.
We cater to the evolving purchasing patterns of customers in various digital and physical channels, which has been radically strengthened over the last two years, post pandemic. We focus on enhancing the customer experience by efficiently creating local solutions by collaborating with the best retailers and distributors in each market. Currently, we sell our products to more than 30,000 retailers in 140 countries through various sales channels.
Because of the vast network of sales channels, the potential human rights risks that could occur downstream in sales and distribution on aspects such as labor conditions, occupational health and safety, or environment is out of scope of our direct business control.
However, according to our Code of Conduct, we strictly do not engage with business partners with known cases of violating human rights, and we follow the Trade Sanctions Policy, where Thule Group restricts all dealings with a government of a targeted country, individuals or entities located, resident or organized in a country, to ensure the achievement of human rights objectives.
Corporate Governance (all other internal functions such as administration, marketing and finance)
There is minimal likelihood of human rights risks occurring, in corporate governance function of Thule Group, and impacts are likely to be minimal. Thule Group ensures a thriving and diverse work environment with equal opportunities for all employees, and a healthy work-life balance, and provides access to safe and clean workspaces and equipment for all employees.
Our business goals and ambitions are entwined with sustainability goals, because people need a clean and healthy natural environment to enjoy our products.