Human Rights Program Key Principles
- Do No Harm. Apply rigorous policies and procedures to prevent adverse human rights impacts in our operations and supply chains.
- Act with Integrity. Continuously raise the bar on ethical business conduct for our Firm and our industry.
- Protect and Empower Colleagues. Foster a workplace culture with reporting mechanisms where colleagues can raise concerns without fear of retaliation.
- Continuous Monitoring & Review. Continuous improvement is part of the DNA of our program and not a once-and-done activity.
Statement Purpose
This statement is the global human rights policy statement for McKinsey & Company, Inc. (“McKinsey”, “our”, “we”, “us” and “our Firm”). This statement also serves as the policy statement of McKinsey in accordance with section 6(2) of the German Act on Corporate Due Diligence Obligations in Supply Chains (the “LkSG”). McKinsey has company-wide policies and compliance procedures related to human rights. Specific details pertaining to compliance with the LkSG are set forth at the end of this statement.
This statement affirms our commitment to human rights; our commitment to not contribute to, participate in, or enable the use of child, forced, or exploited labor, forced or exploitative conditions, and human trafficking; and our commitment to not assist our clients in doing so.
Further, we recognize our responsibility to help protect the planet. We are committed to minimizing the impact our Firm has on the environment and supporting those who are working to improve global environmental sustainability.
As a Firm, we are committed to positive social impact. We help to address societal challenges through the way we operate our business; through our engagement in our communities; and through the investments we make to support significant and lasting impact on pressing social issues.
Our commitment to these principles is reflected in our governance, policies, and practices, so that human rights are respected in our own operations and throughout our supply chain.
Expectations for Employee and Third Parties
We are a values-driven Firm, and aspire to meet the highest professional, legal, and ethical standards. As a participant in the United Nations Global Compact, McKinsey supports the Ten Principles on human rights, labor, health and safety, environment, and anti-corruption; the Universal Declaration of Human Rights; the International Labour Organization’s (“ILO”) Declaration on Fundamental Principles and Rights at Work; and the UN Guiding Principles on Business and Human Rights. We expect the same from our employees and any entity or individual that is not an employee of McKinsey but provides goods or services to or performs work on behalf of or in partnership with McKinsey. This includes, but is not limited to, suppliers, advisors, contractors, consultants, agents, intermediaries, distributors, affiliates, and other business partners (“third parties”).
In addition, McKinsey specifically:
- Prohibits the use of forced labor1 and exploitative working conditions.
- Prohibits participating, enabling, or causing any individual under the legal working age to be employed or engaged by us; contributing to, participating in, or enabling any use of child labor; and assisting our clients in doing so in any way and in any process. We also are committed to compliance with all applicable laws regulating minimum working age.
- Aims to provide colleagues with pay equity and a living wage.
- Commits to fostering an environment that is free from harassment, discrimination, and retaliation.
- Prohibits physical violence, threats, corporal punishment, mental coercion, verbal abuse, bullying, and any form of disrespectful behavior.
- Respects workers’ right of freedom of association, including the right to form or join labor or trade unions, to join workers’ councils in accordance with local laws, and to participate in collective bargaining processes. Workers must be free to engage in these activities without retaliation, harassment, or intimidation.
- Supports workers’ rights to agree to terms and conditions of employment voluntarily without coercion and to end their employment freely on appropriate notice.
Risk Management
McKinsey strives to ensure that we uphold these commitments in our own operations and in our supply chain. To accomplish this, McKinsey has a risk management program. Effective risk management helps us ensure that we are doing what is right and necessary for our clients and our Firm. We consider risks in the short, medium, and long term in areas such as legal, regulatory environments, technology, as well as those arising from the physical impact of climate change. We continually seek opportunities to better identify, analyze, and mitigate risk.
Our Firm uses three lines of defense to manage risk and compliance. All colleagues are our first line of defense and play a critical role in bringing risk awareness and consideration into daily practices and decision making. Our second line of defense consists of colleagues in several dedicated control functions, including legal, ethics & compliance, and risk. The third line of defense is our Internal Audit group that provides an independent assessment of the effectiveness of our controls in mitigating risks, reporting its findings directly to our Firm’s Risk, Audit & Governance Committee (RAGC).
With respect to third parties, we have a risk management program built on a tiered risk assessment framework, including assessment of inherent risk, continuous monitoring and engagement with third parties through use of a third party tool to assess and manage supplier relationships and commitment to human rights and sustainability.
Policies and Procedures
We expect all colleagues to adhere to our human rights and environment-related principles, guidelines, and policies.
This is particularly anchored in the McKinsey Code of Conduct (“Our Code”). Our Code establishes the principles—fundamental elements that define who we are and how we build and maintain trust—that guide how we live our Firm’s purpose, mission, and values every day. It builds upon the expectation that we comply with all laws and regulations. Our Code of Conduct outlines our expected personal and professional conduct—from acting with integrity to speaking up. It guides us to act in ways that create an inclusive environment and drive sustainable growth around the world.
Other relevant internal McKinsey policies include:
- McKinsey Human Rights Policy
- McKinsey Policy Against Discrimination and Harassment
- McKinsey Whistleblower Protections & Anti-Retaliation Policy
- McKinsey Social Responsibility Policy
- Sustainable Procurement & Responsible Buying Policy
- Environmental Sustainability Policy
We also aim to partner with and buy from third parties that adhere to the same level of integrity and environmental, social, and governance (“ESG”) standards to which we hold ourselves. McKinsey’s Third Party Code of Conduct outlines McKinsey’s expectations for how third parties must conduct business. The Third Party Code of Conduct requires our third parties to impose substantially similar obligations to their downstream third parties. In the event of non-compliance with, or a violation of, the Third Party Code of Conduct, McKinsey may provide the third party with a reasonable opportunity to remedy the issue through agreed-upon corrective actions, unless the violation is severe, incurable, or constitutes a violation of law. In the case of a violation of the Third Party Code of Conduct or law, McKinsey may suspend or terminate its relationship with the third party. The Third Party Code of Conduct can be reviewed here in 20 languages.
Our Third Party Management Policy as well as our Standard on Sustainable Procurement and Supplier Engagement outlines our ambition to deliver positive social and environmental impact not only through how we select, onboard, purchase, use, and ultimately dispose of products and/or services, but also in how we work with our third parties to improve the social and environmental impact of the goods and services they offer.
McKinsey also produces a 2024 Sustainable & Inclusive Growth Report. Our goal at McKinsey & Company is to help accelerate sustainable and inclusive growth globally, and it’s a key metric by which we measure ourselves. This report describes our progress against that goal.
Due Diligence
We have the following due diligence processes in place to identify, assess, and manage such risks. We recognize that due diligence is a process of continuous improvement, and we review and refine our approach on an ongoing basis.
Due diligence in internal operations
Ongoing risk analysis is the core element of our due diligence process in our internal operations. As part of our human rights and environmental due diligence obligations, our internal teams proactively identify and mitigate potential risks.
We undertake an annual enterprise risk assessment with a continued focus on working conditions, promoting non-discrimination in employment and pay equity. The outputs of the risk assessment feed into prioritization and implementation of proactive and reactive measures. We continually evaluate and progress our risk assessment process each year with improvements in 2025 related to our scoring of these risks.
McKinsey is committed to compliance with all laws regulating minimum working age, including any laws pertaining to the employment, apprenticeships, and internships of youths and students, and the strict prohibition on the use of forced labour and exploitative working conditions. We run a monthly compliance and quality check to ensure there are no employees under age 15.
We participate in a sustainability assessment conducted by an independent third party organization to evaluate our Firm’s internal processes and practices as a supplier to our clients. The assessment requires document verification of policies, practices, and performance claims in the areas of environment, fair labour and human rights, business ethics, and sustainable procurement. The third party reviews our Firm’s documents against globally recognized standards and frameworks, including those for human rights.
We ensure complete, traceable, and long-term documentation of our risk management system and publish an update on our human rights program as part of our annual Sustainable Inclusive Growth Report.
Due diligence in supply chain
We are committed to respecting human rights and require third parties to do the same in their own operations and across their supply chains. We do not tolerate human rights violations in any form at any stage across the supply chain.
Third party onboarding utilizes a risk-based due diligence approach to ensure that our collaborators and supply chain follow applicable laws and meet our standards, including ensuring respect for human rights. Those parties that meet certain risk thresholds are requested to complete an ESG questionnaire as part of the onboarding process. As another component of the onboarding process, third parties are asked to agree to our Third Party Code of Conduct or indicate that they have a comparable code in place.
We also carry out periodic diligence checks to assess changes in third parties’ circumstances at intervals determined by the third parties’ risk profile.
We may request that certain third parties complete a more rigorous sustainability assessment requiring document verification and review by an independent third party. Globally recognized guidelines and indices for human rights are used for our risk analysis and assessments.
Contractual Provisions
Our standard contract template for third party services incorporates the Third Party Code of Conduct and sets out our expectations and requirements of third parties.
Addressing Specific Risks
As part of our due diligence initiatives, we seek to identify potential and actual human rights and environmental risks across McKinsey’s own operations and our global supply chain. Established processes (such as those described above), and the core pillars and stakeholder groups of our program guide the identification and prioritization of relevant risk areas, so that our analysis is both systematic and responsive to emerging concerns. The results of our analysis are integral to supplier selection, onboarding, and risk management processes, and inform the implementation of preventive measures where necessary.
In the event a significant risk is identified, we have processes in place to track, monitor, and remediate issues, as appropriate, and have taken preventive measures with these areas in focus.
Awareness Building and Training
We support our human rights-related policies with regular awareness building and training. All active McKinsey colleagues are required to participate in risk training and certify compliance with Firm policies and Our Code on an annual basis. Some of the topics covered in annual mandatory training include human rights, anti-harassment, workplace conduct, anti-corruption, conflicts of interest, information security, and environmental sustainability. Upon joining our Firm, all new colleagues are required to complete mandatory training to build an understanding of Our Code and policies and participate in an in-person or virtual onboarding session where they learn about McKinsey values and what is expected of them as colleagues. External workers are also expected to adhere to our policies and standards and complete the required learnings. The learning materials cover topics, including but not limited to, upholding our values, anti-corruption, and discrimination.
Our procurement team receives regular sustainability-focused training to guide third party selection and management.
We provide training for select third parties.
Complaint Procedure
As outlined further in Our Code, McKinsey maintains a global hotline—Got A Concern?—where both colleagues and external parties may raise concerns relating to any human rights or environmental issues confidentially and, where legally permissible, anonymously. Concerns can be submitted at any time verbally via telephone or through the webform and submitted in any language. If possible, a complaint should be submitted as precisely as possible, containing a description of the incident and underlying facts, e.g., what has happened; when; where; etc.
McKinsey reviews every concern raised in line with applicable laws and provides confirmation of receipt. We do not tolerate retaliation of any kind against those who in good faith report potential or actual ethics or legal violations.
McKinsey also has additional internal channels to raise complaints.
McKinsey Specific Disclosures with respect to the LkSG
This statement details the actions McKinsey has taken to assess and address human rights-related and environment-related risks in our operations and supply chains.
McKinsey has appointed a joint Chief Ethics and Compliance Officer (CECO) and Chief Human Rights Officer (CHRO) to oversee our Firm’s Ethics & Compliance and human rights programs, including risk management pursuant to the LkSG. The CECO/CHRO regularly (and at least once per year) reports to McKinsey on relevant ethics, compliance, due diligence and risk management matters.
As described above, McKinsey has a risk management and due diligence process focused on direct suppliers and our own operations. As we identify particular human rights and environmental focus areas in the course of our ongoing risk analysis, we will update this statement and address any identified risks in line with applicable requirements.
If McKinsey becomes aware of an imminent or actual violation of a human rights-or environment-related obligation in McKinsey’s own business area or at a direct supplier, we will, without undue delay, take appropriate remedial action to prevent, end or minimize the violation. The remedial action will be determined on a case-by-case basis, taking into account, among other things (1) the requirements of the LkSG, (2) McKinsey’s ability to influence the party directly responsible for the violation, (3) the severity, reversibility, and probability of a violation, and (4) McKinsey’s contribution, if any, to the violation. Possible remedial actions may include (among other actions) implementation of a corrective action plan, disciplinary action, or termination of the business relationship.
Within its indirect supply chain, if McKinsey has actual indications that suggest that a violation of a human rights-or environmental-related obligation at indirect suppliers may be possible (i.e., substantiated knowledge), we will carry out a risk assessment, take appropriate preventive measures to assess and address the violation, and update this statement (as needed).
The effectiveness of any preventive measures required by the LkSG, corrective action plans and other remedial measures will be assessed on an annual basis and, as appropriate, on an ad hoc basis. Findings from any complaints submitted through the complaints procedure will be taken into account in the assessment.
Further details on McKinsey’s complaint procedure under the LkSG are available here in English and German. McKinsey will review the effectiveness of its complaint procedure regularly, at least once a year, and on an as-needed basis.
This Policy Statement has been adopted by the senior management of McKinsey in accordance with Section 6(2) of the LkSG.
Date of Last Update: 15 December, 2025
Appendix
Related guidelines and additional information available below:
- Code of Conduct | McKinsey & Company
- Third Party Standards | McKinsey & Company
- Client Service Policies | McKinsey & Company
- UK Modern Slavery Act Statement 2025
- Australia Modern Slavery Statement
- Joint Modern Slavery Statement
- Norway Due Diligence Report 2024
1. “Forced labor” is defined by ILO as “work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself voluntarily.”