Risk management
Mars, Incorporated, the ultimate parent of the Mars group, has established and maintains a human rights risk management system that incorporates AniCura Deutschland GmbH and its subsidiaries (“AniCura Germany”); the AniCura legal entity covered by the LkSG. Advancing respect for human rights is a cross-functional responsibility embedded within our global business and applied locally. A dedicated global human rights team, working with our Ethics & Compliance team, establishes our human rights policy, strategies and programs and provides guidance to colleagues around the world. The applicability of certain programs may vary depending on the nature of the business. Our risk management system is informed by the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the ILO Declaration on Fundamental Principles and Rights at Work, and more specific guidance, such as the ILO-IOE Child Labour Guidance Tool for Business. It also incorporates environmental impacts as defined in the German Supply Chain Due Diligence Act (LkSG). Such impacts relate to the Minamata Convention on Mercury, the Stockholm Convention on Persistent Organic Pollutants (POPs), Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (“covered Environmental Conventions”).
To govern the global application and implementation of our human rights policies, Mars, Incorporated’s Human Rights Steering Committee meets regularly to review our global progress, the effectiveness of our preventive and remedial efforts and grievance mechanisms, and challenges and opportunities. The Board of Directors of Mars, Incorporated is periodically updated about Mars, Incorporated’s human rights plans and performance. AniCura AB, the ultimate owner of AniCura Germany, has appointed persons who monitor and review risk management related to the AniCura Germany business (including the effectiveness of the preventive and remedial measures once a year and on an ad hoc basis if we expect a significantly changed or significantly expanded risk situation in our own business or at our direct suppliers) and report to the managing directors about their work at least annually. We update our procedures without undue delay, where necessary.
Risk analysis
Mars’s risk analysis approach begins with an abstract risk analysis, understanding potential adverse impacts to people in our own business area, and at direct suppliers. We conduct abstract risk analyses for AniCura Germany and its direct suppliers regularly, at least annually, and if necessary, on an ad hoc basis. We screen our own AniCura Germany sites and direct suppliers to AniCura Germany based on country and sector risk. On the basis of this abstract analysis and our own data, we conduct further risk analysis. We weight and prioritize the identified risks in our own business area and AniCura Germany’s direct suppliers. This analysis drives the development of our strategic human rights programs.
We further assess human rights risk in our own workplaces through our Responsible Workplace Program. These on-site assessments include a focus on service providers and contingent labor at our sites, given this group of workers is often more vulnerable to risks.
We further assess AniCura Germany’s direct suppliers’ human rights and environmental risk and performance based on risk, including through on-site assessments.
The results of our AniCura Germany human rights risk analysis are shared with the management and directors of AniCura and Mars, where relevant.
AniCura Germany’s operations are located exclusively in Germany. On the basis of our risk analysis, we have not identified any priority human rights and environmental-related risks for our own operations in 2024.
Our risk analysis identified no major risks in the AniCura Germany supply chain, but we are conducting further checks related to indicators of forced labor, work hours, wages and indicators of child labor regarding a small number of suppliers.
Preventive measures and remedial action
Own Business Area
The Mars, Incorporated Human Rights Policy provides guidance to Mars, Incorporated Associates (employees of any company of the Mars group). The Mars, Incorporated Workplace Code of Conduct details our human rights and environmental standards and expectations of our own Associates to help all workplaces comply with our human rights and environmental commitments. Through the Mars, Incorporated Responsible Workplace Program, we identify potential or actual breaches of the prohibitions in the LkSG in our own operations and take steps as needed so that issues are promptly prevented, minimized, or brought to an end without undue delay. AniCura Germany’s health, safety, and environment programs also assess and address risk related to the covered environmental topics and Environmental Conventions in its own business area, as well as health and safety.
Direct Suppliers
Our human rights and environmental expectations of our direct suppliers are found in the Mars, Incorporated Supplier Code of Conduct, which is embedded in our procurement process and contracts. The Supplier Code of Conduct describes the standards we expect our direct suppliers to uphold and cascade to their suppliers. We also provide supporting guidance and capacity building through the Mars, Incorporated Supplier Code of Conduct Guidebook, which provides examples of management systems that enable companies to more effectively tackle social, ethical, and environmental challenges, and meet our code expectations.
If relevant, we would conduct assessments of higher risk AniCura Germany direct suppliers to identify potential imminent or actual breaches of the obligations in the LkSG. We would expect them to conduct corrective actions within a specified time frame to prevent, minimize, or bring impacts to an end, without undue delay. When suppliers fail to participate in our programs or do not address severe human rights risks, the situation is escalated to senior decision-makers. In some instances, we support capacity building by third parties to help suppliers address issues and weaknesses in their systems.
Indirect Suppliers
To understand risk in Mars, Incorporated’s supply chain, expert third parties provide analysis on human rights risk at the country and regional level, drawing on publicly available data. Based on our broad risk assessments and identification of salient issues at the global level, Mars, Incorporated conducts more detailed human rights risk assessments in certain parts of the extended supply chain, i.e. at indirect suppliers. In some instances, Mars, Incorporated provides financial support for third party experts to build the capacity of prioritized suppliers to understand and address issues in their sourcing areas that are identified. When issues in AniCura Germany’s extended supply chain are brought to our attention, we use our leverage to support their resolution.
If, at AniCura Germany, we have actual indications for a violation of a human rights-related or an environment-related obligation related to one of our indirect suppliers within the meaning of the Supply Chain Due Diligence Act (LkSG), supported by our global teams, we carry out an ad hoc risk analysis, lay down appropriate preventive measures, draw up a concept to address the issue and, if necessary, update this Policy Statement.
Complaints procedure
Mars, Incorporated has established several complaints mechanisms available to its Associates and other potentially impacted individuals in its supply chain, including an accredited Ombudsman program for Mars's own sites, and an Ethics and Compliance hotline. The latter is publicly available and AniCura Germany participates in these complaints mechanisms.
Apart from dealing with each complaint in due course, Mars, Incorporated's global Ethics & Compliance team annually reviews the complaints and shares the – where necessary anonymous – results with the global human rights team to inform our human rights programming and strengthen its effectiveness.
Documentation and reporting
Mars, Incorporated continuously documents its human rights and environment-related due diligence and, as part of that, AniCura Germany has access to the documentation of Mars, Incorporated to the extent required. AniCura Germany’s documentation is kept for seven years from its creation.
AniCura Germany will publish annual reports on due diligence on its website as required under the German Supply Chain Due Diligence Act (LkSG).
December 30th, 2024
AniCura Germany GmbH:
Daniela Cleven Alexander Steinmetz Thomas Rieker Wolfgang Aldrian
Managing Director Managing Director Managing Director Managing Director
General Manager Finance Head Deutschland Head of Medical Head of M&A