Purpose
This statement is McKinsey & Company Inc.’s global human rights policy statement. As this policy statement currently covers elements of the Act on Corporate Due Diligence Obligations in Supply Chains (“LkSG”), this statement will be updated from time to time with the results of our ongoing risk assessments.
The principles set out herein apply to all our own domestic and foreign business operations as well as to our supply chain.
This statement affirms our established commitment to human rights and our commitment against contributing to, participating in, or enabling the use of child, forced, or exploited la-bor, forced or exploitative conditions, and human trafficking and against assisting our clients in doing so in any way.
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. We are committed to achieving net-zero climate impact by 2030.
We are committed to a merit-based work environment that supports, inspires, and respects all colleagues and our suppliers and their employees.
Guidance
As a participant in the UN Global Compact, McKinsey supports the Ten Principles on human rights, labor, 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 strive to adhere to the principles set forth in these standards, as aligned with those aspects that apply to us and the services we provide, and comply with all applicable laws, wherever we operate. We expect the same from our suppliers.
We respect our colleagues’ ability to agree to terms and conditions of employment voluntarily without coercion and to end their employment on appropriate notice freely. Further, we sup-port the elimination of all forms of forced and compulsory labor and the effective abolition of child labor and human trafficking.
Specifically, we are committed to compliance with all laws regulating minimum working age for each individual’s position, including any laws pertaining to the employment, apprentice-ship, and internship of youths and students. We also strictly prohibit the use of forced labor and exploitative working conditions. “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.”
We prohibit in any way and in any process, 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, forced, or exploited labor or forced or exploitative conditions; and assisting our clients in doing so in any way and in any process.
Due Diligence
Due diligence in supply chain
We seek to partner with and buy from suppliers that adhere to the same level of integrity and environmental, social, and governance (ESG) standards to which we hold ourselves. Our Supplier Code of Conduct is available in ten languages and sets the standards and values we expect from suppliers. Our global Sustainable Procurement and Responsible Buying Policy out-lines our ambition to deliver positive social and environmental impact through our selection, purchase, use, and disposal of products and services, and through the way in which we work with our suppliers to improve the social and environmental impact of the goods and services they offer.
During onboarding, we ask suppliers to agree to our Supplier Code of Conduct or indicate that they have a comparable code in place. Our standard contract template for supplier services in-corporates the Code and sets out our expectations of suppliers.
Suppliers are required to complete an ESG questionnaire before entering into a potential business relationship with us and are subject to further checks in certain cases. A risk classification is made for each individual company. Recognized guidelines and indices are used for the risk analysis, such as the UN Global Slavery Index for identifying high risk countries.
During supplier sourcing and selection stages, our standard request for proposal templates utilized by our sourcing team includes a questionnaire used to screen potential suppliers on practices and policies in areas including environmental sustainability, DEI, and data privacy. New suppliers go through a rigorous onboarding process that includes risk-based due diligence to ensure the suppliers follow applicable laws and meet our standards. We carry out periodic diligence checks to assess changes in suppliers’ circumstances at intervals determined by the sup-pliers’ risk profile.
We have deployed a training program called Buying Responsibly to all colleagues on our Procurement team. The mandatory training addresses the full buying life cycle and highlights how ESG considerations should be integrated throughout the process.
Due diligence in internal operations
Our Workplace Conduct Policy outlines our expectation that all firm members must be able to work in an environment free from harassment and discrimination. The policy enables reporting of all incidents of discrimination, harassment, or retaliation, regardless of the offender’s identity or position, via clearly designated reporting channels. Individuals who are found to be responsible for harassment, discrimination, or retaliation will be subject to disciplinary action, up to and including termination of employment.
Ongoing risk analysis is the core element of our due diligence process, enabling us to identify potential risks quickly and clearly. 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 ESG Report.
Addressing specific risks
As a firm, we are committed to positive social impact. We help to address societal challenges through the way we operate in the course of our business; through our engagement in our communities; and through the investments we make to support significant and lasting impact on pressing social issues.
As we identify particular human rights and environmental focus areas as part of our ongoing risk analysis, we will update this policy statement and address any identified risks in line with applicable requirements.
McKinsey's Human Rights Expectations
We expect our colleagues and suppliers to meet the minimum standards listed above and the corresponding requirements described herein for the prevention, mitigation, and defense against risks.
Firm members
We expect all firm members to adhere to our human rights and environmental-related related principles, guidelines, and policies, which are in particular anchored in the following documents:
We support our human rights-related policies with regular awareness building and training. New colleagues must adhere to our Code of Professional Conduct and participate in an onboarding session that informs them about our values, including inclusion, anti-discrimination, and anti-harassment. Annually, all colleagues must certify compliance with our core policies and complete Professional Standards and Risk training. Any potential breach of these ethical standards is subject to investigation and appropriate disciplinary action.
In addition to clearly defined internal channels, we have a global hotline that enables col-leagues to raise concerns relating to any human rights issues confidentially and, where legally permissible, anonymously. We do not tolerate retaliation of any kind against firm members who in good faith report potential or actual ethics or legal violations.
Business Partners/Suppliers
We are committed to respecting human rights in our internal operations and expect the same from our business partners and suppliers.
We follow a risk-based approach to ensuring respect for human rights across our entire value chain, starting with our supplier selection process. Each potential supplier must complete an ESG-questionnaire. Upon successful completion of the selection process, the supplier must accept compliance with our Supplier Code of Conduct. The Supplier Code of Conduct is an important and integral part of the contractual relationship and prohibits all forms of forced labor, child labor, and human trafficking, and requires compliance with all laws regarding dis-crimination, harassment, and retaliation.
We also attach great importance to preventative measures, including training and communications, in our relationships with suppliers.
Each business relationship is subject to ongoing risk analysis throughout the relationship. Further, risk analysis does not end with the direct supplier. Indirect suppliers are integrated into the process as part of the supply chain.
We may suspend or terminate our relationship with a supplier for violating our Supplier Code of Conduct and/or disclose the matter to the appropriate authorities if there is a violation of law.
Complaint Procedure
As outlined further in our Code of Professional Conduct, every firm member has the right to address human rights or environmental concerns without fear of retribution, including punishment or harassment from colleagues, supervisors, or firm management. We forbid retaliation of any kind against anyone who, in good faith, reports potential or actual ethical or legal violations.
In addition, external parties, in particular our suppliers and those working with them, are able to report any human rights or environmental concerns.
Got A Concern? enables both our colleagues and external parties to raise concerns relating to any human rights or environmental issues confidentially. 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.
When raising any human rights or environmental complaint, we assure the following:
- You can use Got A Concern? at any time.
- You can a raise concern verbally via telephone or in writing through the webform. Reports can be submitted in any language.
- You can submit your complaint anonymously, depending on the applicable law. However, we encourage you to identify yourself when raising a complaint, so we can follow up with you for additional information.
- We are committed to effective protection against disadvantage and punishment in connection with the submission of a complaint.
- We will review all complaints and ensure that further inquiry and review are handled in accordance with applicable laws.
- Everyone submitting a complaint receives a confirmation of the submitted report.
Appendix
Related guidelines are available at:
Date of Last Update: December 22, 2022