Resilient Supply Chain
Declaration of values on human rights
It is also important to us that our business partners share similar values.
Our commitment to preventing human rights violations – both within our own company and throughout our supply chain – and to continuously improving working conditions is firmly embedded in our processes:
- Internal guidelines ensure that our values are put into practice in our day-to-day work and that effective risk management is in place.
- Our Social Compliance Policy for private-label brands integrates binding requirements into key procurement processes.
- A Code of Conduct for business partners defines clear expectations for responsible conduct in our collaboration.
In addition, we work closely with partners and industry initiatives to increase our impact. For example, we are involved in the Consumer Goods Forum’s Sustainable Supply Chain Initiative, which makes sustainability standards comparable and contributes to the harmonization of audit processes.
The Supply chain due diligence act (LkSG)
Effective January 1, 2023, the supply chain due diligence act requires companies in Germany to identify, prevent, and, if necessary, remedy human rights and environmental risks along their supply chains. This applies to both the company’s own business operations and its direct suppliers – as well as, in specific cases, its indirect suppliers.
Overview of legal aspects
Human rights and environmental risks
With reference to the human and labour rights laid down by the United Nations (UN) and the International Labour Organisation (ILO), the German Act on Corporate Due Diligence in Supply Chains specifically mentions the following human rights and environmental risks.
Production of products with added mercury, use of mercury and mercury compounds (Minamata Convention)
Environmental risk
Production and Use of Persistent Organic Pollutants and Non-Environmental Handling, Storage and Disposal of Waste (Stockholm Convention)
Environmental risk
Import and Export of Hazardous Waste (Basel Convention)
Environmental risk
Harmful Pollution of Soil/Water/Air, harmful Noise Emissions, excessive Water Consumption
Human rights risk
Unlawful Clearance and Deprivation of Land, Forest and Waters
Human rights risk
Withholding of a Reasonable Wage
Human rights risk
Use Security Services and Violation of Human Rights by these Services
Human rights risk
Unequal Treatment at Work and Discrimination
Human rights risk
Disregard of Freedom of Association
Human rights risk
Disregard of occupational health and safety
Human rights risk
Child labour, forced labour, slavery
Human rights risk
The mechanism
Social compliance risk management system
In order to meet the requirements of the supply chain act and fulfil its due diligence obligations, METRO AG has set up a social compliance risk management system that incorporats the following seven steps.
1. Responsibilities / governance
Definition of responsibilities within the company including Human Rights Officer
2. Risk analysis
Annual regular analysis i.e. identification, assessment and prioritization of human rights and environmental risks for own operations and direct suppliers as well as incident related analysis for own operation, direct suppliers and indirect suppliers
3. Preventive measures
Establishment of appropriate preventive measures to minimize and avoid risks e.g. through respective procurement strategies, trainings and supplier audits
4. Complaint mechanisms
Publicly available mechanism to receive complaints and reports on risks and violations, for anybody potentially affected e.g. suppliers and employees i.e. internal or external whistleblowing system - confidential and anonymous: METRO Whistleblowing System
5. Corrective actions
Establishment of appropriate remedial measures after a risk is identified to prevent, stop or minimize the violation
6. Effectiveness monitoring
Control of effectiveness of preventive and remedial measures and complaint mechanism
7. Documentation / reporting
Human Rights policy statement and annual public report on identified human rights and environmental risks, measures and evaluation of their effectiveness and submission of report to enforcement authority.
The Federal Office for Economic Affairs and Export Control (BAFA) has published additional information on the law (German) here in the form of FAQs and guidance documents.
Our responsibility throughout the supply chain
For us, respect for human rights and environmental standards does not end within our own company. We take responsibility throughout our supply chain and work together with our partners to drive improvements.
Our social compliance risk management translates our values into concrete measures and processes and serves as the foundation for responsible conduct – toward employees, business partners, and other stakeholders.
Code of conduct for business partners
As an international wholesale company, we work with a wide range of suppliers and producers. Our Code of Conduct for Business Partners defines clear expectations for responsible conduct. It is based on internationally recognized standards, including the UN and OECD Guidelines, ILO core labor standards, and international human rights standards.
In addition, it includes requirements regarding environmental protection and business ethics, with a particular focus on combating corruption and bribery, antitrust and competition law, and data protection. These requirements are embedded in our contractual relationships and form the basis for our collaboration with our business partners.
Risk management along the supply chain
A central element of our approach is the regular risk analysis along the supply chain – in accordance with the requirements of the Supply Chain Due Diligence Act. This is conducted at both the abstract and concrete levels in collaboration with suppliers on an annual basis as well as on an ad hoc basis. Our policy statement is updated accordingly on an ongoing basis.
Prevention and remediation
Based on our risk analyses, we implement targeted preventive measures. These include, among other things, training for employees and suppliers, the integration of social compliance requirements into contracts and policy documents, and the embedding of risk management into core business processes. When violations are identified, we take appropriate corrective actions to address them or minimize their impact. In doing so, we adhere to the principles of proportionality and effectiveness in accordance with the Supply Chain Due Diligence Act.
Complaint mechanism
Suspected cases of human rights or environmental violations can be reported at any time confidentially and anonymously (whistleblowing system) – by both employees and external stakeholders.
Fair and socially just working conditions for our private-label brands
METRO works with numerous suppliers and producers worldwide. We see particular potential for promoting socially just working conditions in our private-label product range.
While we generally expect all suppliers to comply with human rights-related requirements in accordance with our Code of Conduct, expanded requirements apply to our private-label brands. By 2030, we aim to ensure socially just working conditions across our private-label procurement channels.
Social compliance is integrated into our purchasing processes – based on our Social Compliance Policy. This policy applies to all international and local suppliers, with a particular focus on private-label suppliers.
Systematic assessments, audits, and clear principles
We regularly assess our private-label suppliers to identify risks related to human rights and working conditions at an early stage. This process is based on established international data sources and risk analyses. Suppliers posing an elevated risk are identified and asked to minimize their risks through targeted questionnaires, independent audits – such as those based on standards like the amfori Business Social Compliance Initiative (amfori BSCI) or the SMETA audit by Sedex – or through training measures.
For METRO, these measures are not an end in themselves. They form the basis for continuous improvement processes. After each audit, measures are defined, implemented jointly with partners, and tracked. The goal is to contribute to improving working conditions – not merely to verify compliance with requirements.
In cases of particularly serious violations involving child labor, forced labor, or occupational safety, clear guidelines apply:
- Existing orders are continued under controlled conditions
- new orders are suspended
- cooperation may resume once appropriate improvements have been made
Training & Capacity Building
Long-term improvements can only be achieved in collaboration with our partners. That is why we place a strong emphasis on training and support – both for our employees and for our suppliers. Our international procurement organizations work closely with local producers to clarify social standards and promote their implementation.
Further information can be found in the Annual Report 2024/25 starting on page 92.
Responsibility for our employees
We create a work environment characterized by safety, fairness, and respect. This includes promoting diversity and equal opportunity, supporting the personal development of our employees, and consistently upholding employee rights and occupational safety standards.
Policy on human rights and environmental issues
Our corporate policy elaborates on the principles regarding human rights and environmental issues enshrined in our declaration of values. It ensures that these principles are implemented in our day-to-day work and are binding across all METRO companies.
At the same time, it forms the basis for our social compliance risk management for employees and supports compliance with the requirements of the supply chain due diligence act.
Social dialogue
Effective social compliance risk management thrives on exchange: Through continuous dialogue and knowledge transfer, employees and teams learn from one another – including when interacting with employee representatives.
Through the biannual “Voice it” employee survey, METRO regularly gathers feedback and uses it to further improve working conditions.
At the European level, the Euro Forum, as the European Works Council, represents the interests of employees. In addition, METRO collaborates with the international trade union federation UNI Global Union.
Occupational safety and health
Safety is a top priority at METRO. We are committed to providing our employees, partners, and customers with a safe and healthy work environment. Our goal is to identify risks early on, prevent accidents, and consistently integrate safety into all work processes.
Our group-wide Occupational Safety Management System (OSMS) is based on international standards such as ISO 45001 and is implemented through various process descriptions and regulations. It helps us systematically identify risks, implement appropriate measures, and continuously improve our processes. In this way, we create transparency and ensure that we meet both our own requirements and international standards.
Below is a summary of the OSMS that outlines the key points it covers.
Whistleblowing system
METRO provides employees and external stakeholders with various reporting channels to report potential violations, suspected misconduct, or risks within METRO’s business environment and along the supply chain. Employees can contact their supervisors or the Local Compliance Officers, who serve as local reporting points.
In addition, reports can be submitted confidentially – and anonymously, if desired – via the IT-based whistleblower system “SpeakUp.” Reports may relate in particular to compliance issues, human rights, environmental standards, fair working conditions, harassment, and violations of legal requirements and internal policies.
The basis for handling reports is the METRO Policy on the Protection of Whistleblowers, which ensures a clearly defined process for receiving, evaluating, and investigating reports, as well as for protecting whistleblowers.
Visit the METRO Whistleblower System website (secure, external website):
Deforestation-free supply chains
Deforestation of natural forests is a major driver of climate change and is often accompanied by other environmental and social consequences – such as the loss of biodiversity or the adverse impact on local communities.
This issue is particularly relevant to the food sector, as key raw materials such as soy, palm oil, beef, coffee, cocoa, and wood and paper products are often linked to deforestation.
As a wholesaler, we take responsibility for the origin of these products. Our goal is to structure the procurement of these raw materials in a way that prevents deforestation – for example, through transparent supply chains, defined requirements for our suppliers, and the promotion of sustainable alternatives.
Our approach – making a difference together
We have consolidated our previous individual guidelines on raw materials such as palm oil, soy, wood, and meat into a comprehensive procurement policy for deforestation-free supply chains. In doing so, we also take into account the requirements of the European Deforestation Regulation (EUDR).
A central component of our approach is collaboration along the entire value chain. Given the complexity of global supply chains, sustainable solutions can only be implemented in partnership with others. That is why we work closely with suppliers, producers, industry initiatives, governments, and nongovernmental organizations – for example, through data sharing, common standards, and the further development of procurement practices. For example, we are involved in international initiatives such as the Consumer Goods Forum, the Round Table on Responsible Soy (RTRS), and the Roundtable on Sustainable Palm Oil (RSPO) to drive industry-wide solutions and promote uniform requirements.
Sustainable solutions can only be implemented in the long term if environmental, social, and economic factors are considered together. That is why we are committed to partnership, transparency, and continuous improvement.
Consumer Goods Forum Forest Positive Coalition
The Consumer Goods Forum (CGF) has established the Forest Positive Coalition of Action (FPC), which is supported by approximately 20 companies with a combined market value of about 2 trillion U.S. dollars.
METRO is a member of the coalition and is actively involved in the working groups on palm oil, soy, and beef.
The FPC’s goal is to halt deforestation, forest conversion, and forest degradation along global supply chains. Through collective action, the coalition aims to make progress in four areas:
- Promoting deforestation-free supply chains
- Setting higher standards for traders
- Promoting change in key production regions
- Defining measurable outcomes and reporting transparently
The coalition is supported by the Tropical Forest Alliance (TFA) and Proforest and works closely with the CGF initiative against forced labor.
Since 2021, METRO has been providing financial support for two landscape projects in key source countries. The goal of these projects is to combat deforestation and land use issues in specific regions and to improve the living conditions of local smallholder farmers. The initiatives are:
| Initiative | Raw Materials | Partner |
|---|---|---|
| Development of a Digital Toolkit for Implementing the Tocantins Forest Code | Soy and Beef | Conservation International |
| Stopping deforestation and promoting sustainability in West Kalimantan | Palm Oil | Rainforest Alliance |
Biodiversity
The protection of biodiversity is essential for functioning ecosystems and sustainable food production. Many natural processes on which our value creation depends are directly linked to intact habitats and to plant and animal species.
We recognize that our business activities have an impact on biodiversity. To better understand this impact, we systematically analyze our sites and their surrounding areas. In a pilot project, for example, we investigated whether our sites are located near sensitive protected areas – such as UNESCO World Heritage Sites or IUCN protected areas.
Water protection
For METRO, responsible water management is a key component of sustainable business practices. Our Water Policy defines the strategic framework for protecting this resource.
We have set a goal to efficiently reduce water consumption in our own business operations: By 2030, we aim to reduce specific water consumption per square meter of retail space by 10% compared to the base year 2020/21. We have already achieved this goal ahead of schedule: In fiscal year 2023/24, the figure was 12.1% below the baseline level.
Transparency and traceability
We take a transparent approach to sourcing products and using resources. Direct, long-term relationships with our business partners form an important foundation for this.
In addition, we have developed a cross-industry, international digital traceability solution based on GS1 standards in collaboration with our partners.
With our PROTRACE solution, we provide batch-specific traceability information from various data sources. This enables customers and stakeholders to better track the origin of products and gain greater transparency throughout the supply chain.
Transparent supply chain for fish and meat
Initially, we deployed PROTRACE primarily for sensitive product groups such as fish and meat. Here, customers can access detailed information on origin, processing, quality, and sustainability aspects – directly via an app.
This is made possible by unique product labeling and the continuous provision of relevant data by our suppliers. Throughout the entire supply chain – from the producer to the retailer – all stakeholders contribute to providing the necessary information.
In addition to traceability, PROTRACE now also offers insights into production processes and product-specific background information. The solution is designed to be flexible and can be gradually expanded to include additional product groups.
In this way, we give our customers greater insight into the origin of products and create a better foundation for informed purchasing decisions. At the same time, the increased transparency helps identify risks in the supply chain – such as those associated with illegal practices like illegal fishing.
Social responsibility in the supply chain
Our comprehensive understanding of human rights and environmental issues is reflected in our commitment to ensuring that internationally recognized human rights and environmental standards are upheld both in our own operations and throughout our supply chain.