Human Rights Policy
1 Applicability
This policy applies to Wheat A/S and its subsidiaries. It extends to our business relationships, including suppliers, vendors, retailers, agents, and other partners operating within our value chain.
2 Purpose
The purpose of this policy is to formalise Wheat A/S' commitment to respecting internationally recognised human rights and to define how human rights due diligence is integrated into our governance, risk management, and business practices.
3 Scope
Wheat A/S is committed to respecting all internationally recognised human rights. Our approach is guided by the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
Where national legislation provides lower protection than internationally recognised standards, we seek to uphold the higher standard while respecting applicable legal frameworks.
We conduct ongoing human rights due diligence to identify, prevent, mitigate, and account for adverse impacts linked to our operations, products, and business relationships, and to provide remedy where we have caused or contributed to harm. Human rights considerations are integrated into decision-making, supplier engagement, and strategic planning processes.
4 Salient Human Rights Areas
Through our Double Materiality Assessment and risk analysis, we identify and prioritise human rights risks based on the severity and likelihood of impact on rights holders. Our current salient areas are:
- Fair and Safe Work
- Consumer Rights and Safe Products
- Responsible Design and Engagement Practices
5 Fair and Safe Work
We are committed to treating workers with dignity, fairness, and respect. Forced labour, child labour, harassment, discrimination, and inhumane treatment are not tolerated. Workers must be able to exercise their rights to freedom of association and collective bargaining.
We promote safe and inclusive working environments in line with international labour standards and applicable local laws. We support fair wages and have a strategic focus on progressing towards living wages where relevant.
Suppliers are required to comply with our Supplier Code of Conduct. Compliance is monitored through dialogue, self-assessments, risk screening, and third-party audits where appropriate.
6 Consumer Rights and Safe Products
We respect the rights of consumers in all markets where our products are sold. Product safety and consumer health are non-negotiable.
We comply with applicable chemical and product safety legislation, including REACH. We prioritise materials certified under recognised standards such as GOTS, GRS, RWS, and OEKO-TEX® Standard 100. Suppliers are expected to align with AFIRM RSL and ZDHC MRSL requirements.
7 Responsible Design and Engagement Practices
Our design and engagement practices must reflect non-discrimination, respectful representation, and diversity. Further requirements are outlined in our Marketing Policy and JEDI Commitment.
We respect privacy rights and ensure secure handling of personal data in accordance with applicable data protection legislation and our Privacy policy.
Where designs or techniques are associated with Indigenous cultural heritage, we seek free, prior, and informed consent (FPIC) from relevant communities where appropriate.
Products directed at children are developed and communicated in accordance with the UN Convention on the Rights of the Child, recognising children's heightened vulnerability.
8 Governance
Human rights form part of Wheat A/S' broader ESG strategy and are implemented through key policies including the Supplier Code of Conduct, Environmental and Climate Policy, Marketing Policy, JEDI Commitment, Privacy Policy, and Partnership Policy.
The Board of Directors oversees human rights risk management. Ultimate responsibility rests with the CEO. Day-to-day implementation is managed by the Impact Manager.
Progress is monitored through our due diligence processes and reported as part of our ESG governance framework.
9 Remedy and Grievance Mechanisms
We are committed to providing effective remedy where we have caused or contributed to adverse human rights impacts.
Wheat provides grievance mechanisms for employees and external stakeholders, including suppliers, supply chain workers, and customers. Concerns may be raised through our whistleblower channels. Mechanisms are designed to be accessible, confidential, and free from retaliation.
Grievances and remediation outcomes are tracked to identify systemic issues and inform preventive measures.
Where impacts are directly linked to our business relationships, we use our leverage to encourage prevention, mitigation, and remediation.
10 Child Labour
If child labour in violation of law or international standards is identified, immediate action will prioritise the child's safety and best interests. Appropriate remediation measures may include removal from harmful work, access to education, and collaboration with suppliers, NGOs, and authorities. Business continuation depends on good-faith remediation efforts.
11 Forced Labour
If forced or involuntary labour is identified, affected workers must be released immediately. Recruitment fees and withheld wages must be reimbursed in accordance with the Employer Pays Principle. Suppliers must conduct root cause analysis and implement corrective actions, subject to monitoring and verification.
Failure to collaborate in remediation may result in suspension or termination of the business relationship and, where relevant, notification of authorities.
12 Review
This policy is reviewed at least every two years by management and board, or earlier if significant changes to our risk profile occur.