Devold Human Rights Policy

Board approved 29/04/2024

People lie at the heart of Devold – both those we have chosen and those who choose us. For over 170 years, our foundation has been that everyone working for Devold should have decent jobs. Today, this commitment covers the full length of our supply chain.

The purpose of the Human Rights Policy is to explain Devold’s commitment to respecting human rights. The commitments set out in this document continue to be implemented across our operations and supply chain.  

Our Human Rights Policy is based on the United Nations’ “Protect, Respect, Remedy” framework and the Guiding Principles on Business and Human Rights for its implementation, along with the OECD Due Diligence Guidelines for Responsible Business Conduct. While states bear the duty to protect human rights, businesses hold an independent responsibility to respect human rights and to address harm where it does occur. 

We know that human rights challenges exist in global supply chains, including our own. As a risk-reducing measure, we maintain our strategy of vertical integration, with our own knitting and cut-make-trim mill and dyeing plant, to ensure that our employees receive a living wage in safe working conditions. We exercise our best efforts to select business partners along our supply chain who uphold similar standards. 

Devold is committed to meeting its responsibility to respect all internationally recognised human rights and fully supports the international Bill of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work. This means acting with due diligence to avoid people’s human rights being harmed through our activities or business relationships, and to address harms that do occur. 

This commitment extends to ensuring that our activities do not cause or contribute to adverse human rights impacts through environmental harm. We recognize the interdependence and indivisibility of human rights, understanding that we cannot selectively disregard certain rights while upholding others. 

We are committed to environmentally responsible business practices and products, and fully endorse the right to a clean, healthy, and sustainable environment, as recognized by the UN Human Rights Council in 2021 and the UN General Assembly in 2022. Any impacts on climate and nature resulting from our operations, will be promptly and effectively remedied. 

Devold remains steadfast in supporting governmental efforts to create new or stronger environmental laws, policies, or programmes, to level the playing field for businesses. In instances when scientific evidence is clear, but the resources or the political will impede regulation, or when the precautionary principle gives reason for caution, we will take proactive steps. We are committed to comprehensive, transparent, accurate and accessible disclosure of our climate, environmental, and human rights performance. 

As part of these commitments, Devold encourage, and will not retaliate against, individuals who in good faith raise concerns regarding our respect for human rights. We encourage our employees, our suppliers and civil society to speak up, without retribution, about any concerns they may have. 

Devold will work collaboratively across our industry to promote practical solutions to respect human rights and engage with sector wide efforts to address entrenched issues where possible. We are members of the Ethical Trading Initiative (ETI) and publish our own and supplier data on Open Supply Hub to drive progress for human rights and the environment. 

We are firmly committed to strengthening the wool industry and supporting initiatives that enhance recruitment and provide quality employment opportunities for those whose livelihoods depend on sheep. To sustain these livelihoods, we are committed to respecting, and work with partners that respect, good animal welfare and the health of the land associated with our wool sourcing, including the right to water and the ownership and the use of land and natural resources. 

Our foremost priority is fostering mutually beneficial partnerships with our wool growers.  

• Devold’s Human Rights Policy is approved and owned by Devold’s Board of Directors. It will be reviewed annually by Group Sustainability, or earlier if found inadequate through Devold’s ongoing human rights due diligence process. 

• Devold’s Governance Documents concerning human rights are approved by Devold’s Management Board. 

• Group Sustainability has the responsibility to ensure that due diligence is folded into governing documents, policies, and procedures. Implementation is a line management responsibility. 

• Respecting human rights as a standard of conduct is part of Devold’s Sourcing Principles, with which we expect all our employees and suppliers to comply. Our strategic suppliers are consulted during the development of these Principles, which include a mutual human rights due diligence obligation. 

• We conduct risk-based due diligence and will continue to increase our capacity to effectively identify impacts and respond to concerns. Our due diligence starts when we form new partnerships. 

• Group Sustainability is responsible for engaging internal and external stakeholders in an annual double materiality assessment. Our salient human rights risks are reported biannually, or whenever significant new risks of adverse impact arise, to the Board of Directors, Devold’s Management Board, and relevant parties such as union representatives. 

• Devold maintains a cross-function team, with members from production, product development, sustainability, procurement, and finance, which convenes when necessary to address salient human rights risks, or resolve disagreements regarding potential supplier onboarding. 

Devold is committed to actively reporting to stakeholders. We will report in accordance with the EU’s Corporate Sustainability Reporting Directive (CSRD) in 2025 (for the fiscal year 2024). 

Reporting on our human rights performance in our supply chain is done through ETI (Ethical Trading Initiative in the UK) annual membership. The ETI reports undergo scrutiny by trade union and NGO members, with feedback provided to help review activities and improve. We annually report on our due diligence assessments in line with the Norwegian Transparency Act. 

Devold shares data through Open Supply Hub to benefit civil society users of the tool, enabling them to help alert us to new areas of risk. Together, these efforts provide interested stakeholders accessible means to assess our performance.