Our Code of Professional Conduct

Human rights statement

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 as set forth in this statement.

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 labor, 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 United Nations 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’ rights of freedom of association, to take part in collective-bargaining processes, to agree to terms and conditions of employment voluntarily without coercion and to end their employment on appropriate notice freely. Further, we support the elimination of all forms of forced and compulsory labor and the effective abolition of child labor and human trafficking. We aim to pay all colleagues a living wage, and maintain pay equity. We are committed to fostering an environment that is free from harassment, discrimination, or retaliation.

Specifically, we are committed to compliance with all applicable laws regulating minimum working age for each individual’s position, including any laws pertaining to the employment, apprenticeship, 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 twelve languages and sets the standards and values we expect from suppliers. Our global Sustainable Procurement and Responsible Buying Policy 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 suppliers to improve the social and environmental impact of the goods and services they offer.

During the supplier sourcing and selection stages, our standard request for proposal template utilized by our sourcing team includes questions used to screen potential suppliers on practices and policies in areas including environmental sustainability, human rights, and data privacy.

New suppliers typically go through a rigorous onboarding process that includes risk-based due diligence to ensure the supplier follows applicable laws and meets our standards. During the onboarding process, we ask suppliers to agree to our Supplier Code of Conduct or indicate that they have a comparable code in place. Suppliers that meet certain risk thresholds are requested to complete an ESG questionnaire as part of the onboarding process. In addition, our process is to carry out periodic diligence checks to assess changes in suppliers’ circumstances at intervals determined by the suppliers’ risk profile.

After onboarding, additional ESG-specific risk-analyses are conducted on certain suppliers. Based on the results of this risk analysis, we may request that certain suppliers complete a more rigorous ESG assessment requiring document verification and review by an independent third party. Globally recognized guidelines and indices for human rights are used for the risk analysis and assessments.

Our standard contract template for supplier services incorporates the Supplier Code of Conduct and sets out our expectations and requirements of suppliers.

We deliver regular training to our procurement team. The training addresses and highlights ESG considerations relevant to the selection and management of suppliers.

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 adhere to the practices described herein for the prevention, mitigation, and defense against risks.

Firm members

We expect all firm members to adhere to our human rights and environment-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. All colleagues must adhere to our Code of Professional Conduct and all new colleagues 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 colleagues 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 Collaborators/Suppliers

We are committed to respecting human rights in our internal operations and expect the same from our business collaborators and suppliers.

We follow 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, suppliers are asked 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 incorporates the Code and sets out our expectations and requirements of suppliers. The Supplier Code of Conduct is an important part of the contractual relationship and prohibits all forms of forced labor, child labor, and human trafficking, and requires compliance with all applicable laws regarding discrimination, harassment, and retaliation. The Supplier Code of Conduct requires our suppliers to impose substantially similar obligations to their downstream suppliers.

Our process is to carry out periodic diligence checks to assess changes in suppliers’ circumstances at intervals determined by the suppliers’ risk profile. We also implement preventative measures, including providing training for our suppliers and buyers.

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 raise a 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: June 20, 2023