Human Rights Policy
This policy applies to Wheat A/S and its subsidiaries.
The purpose of this policy is to formalize Wheat A/S’ commitment to respecting internationally recognized human rights and to define how human rights due diligence is integrated into our governance, risk management, and business practices.
Wheat A/S is committed to respecting all internationally recognized 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 recognized 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 uman rights risk assessment based on our top three procurement decisions by volume in the relevant fiscal year, we identify and prioritize human rights risks based on the severity and likelihood of impact on rights holders. When deemed necessary, we seek support and insights from industry or human rights organizations, trade unions, local governments, and other expert stakeholders on context-specific risks to inform our mitigation strategies.
We recognise that the textile and garment industry carries well-documented systemic human rights risks — including in working conditions, wages, freedom of association, gender-based violence, and the use of migrant labour. We approach and seek to mitigate and remediate these risks in line with the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector, while acknowledging that systemic risks of this nature cannot be resolved by any single company acting alone and require collective action with industry peers, trade unions, civil society, and governments.
5 Fair and Safe Work
In line with the UN Guiding Principles on Business and Human Rights, we recognize that our activities and business relationships may contribute to, or be linked to, impacts on the wellbeing of workers in our supply chain. Before entering any new business relationship, we conduct a risk assessment of suppliers and partners to confirm that workers are treated with dignity, respect, and fairness, in line with international labour standards, including the core conventions of the International Labour Organization (ILO) and the International Bill of Human Rights. Specifically, workers must not be subjected to harassment or discrimination of any kind, forced labour, retaliation, or inhumane treatment. Amongst others, workers have the right to good and safe working conditions, access to clean water and sanitation, fair compensation, a channel to raise their voice without fear of retaliation, freedom of association, and collective bargaining.
To extend these commitments to our suppliers, we apply a structured set of supplier due diligence systems, including: pre-engagement risk assessment of suppliers and partners, our Supplier Code of Conduct, supplier self-assessment surveys, third-party social audits, recognised certifications such as GOTS, corrective action plans for non-conformities, capacity building, grievance and training logs, and ongoing dialogue with suppliers as well as onsite visits when feasible. Our Supplier Code of Conduct sets out our expectations on human and labour rights, wages, freedom of association, inclusion, and anti-corruption amongst others.
6 Consumer Rights and Safe Products
We commit to respecting the human rights of our consumers in the countries where we operate
and where our products are sold. This includes ensuring that our products comply with all relevant laws and regulations in the countries where we operate, as well as those standards adopted by Wheat (e.g. Oeko-Tex Standard 100). We do this to protect the health and safety of consumers. We have defined chemical requirements and test reporting cycles to which all our suppliers commit, to ensure that no hazardous chemicals are found in our products, and that compliance is third-party verified by a laboratory or testing agency.
7 Responsible Design and Marketing Practices
Through the design and marketing of our products, we seek to embed the ethos of non-discrimination, respectful representation, and diversity. Our policies and procedures set out how we design, market, and communicate our products — promoting the aforementioned values to dismantle stereotypes and negative norms. This work is guided by our Marketing Policy, Communication Guidelines and JEDI Commitment.
Focusing on our consumer engagement, we strive to respect the privacy rights of consumers by ensuring safe storing of any personal data, as addressed in our Privacy Policy.
Focusing on our design, we respect the rights of indigenous peoples and other minority groups. If we use certain designs, prints, patterns, and techniques in which indigenous peoples have unique property rights, we will obtain consent from the indigenous peoples prior to using the designs, prints, patterns, and techniques.
Our products are directed to children, and in accordance with the UN Convention on the Rights of the Child, we ensure that our product design, communication, and marketing are conducted with respect for children's rights. This includes ensuring that our products are safe for children and that marketing and communication are carried out respectfully — without reinforcing discrimination and taking into account factors such as children's greater susceptibility to manipulation.
Human rights form part of Wheat A/S’ broader ESG strategy and commitment and are implemented through key policies, including but not limited to: the Supplier Code of Conduct, Policy on Responsible Business Conduct, Marketing Policy, Communication Guidelines, JEDI Commitment and Privacy 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.
Whistleblower channels:
Online form: www.wheat.dk/pages/whistleblower
Email: whistleblower@wheat.dk
Written submission to: Wheat att. Whistleblower, Grusbakken 12, 2820 Gentofte
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.
Related document: Supplier Code of Conduct
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.
Related document: Supplier Code of Conduct
12 Approval and Review
This policy is approved and reviewed at least every two years by management and board, or earlier if significant changes to our risk profile occur.