Corporate Sustainability Due Diligence

Responsible supply chain

Dustin supports international standards in human rights, labour conditions, environment and anti-corruption. Conventions and frameworks such as the Universal Declaration of Human Rights (UDHR), the Children’s Rights and Business Principles, UN Guiding Principles for Business and Human Rights, ILO International Labour Standards, OECD Guidelines for Multinational Enterprises and UN Global Compact, has guided Dustin in how we work to support and uphold human rights, business ethics and environmental protection.

Continuous due diligence is an important tool to ensure we work with third parties and business partners who share our values regarding sustainability topics and business ethics. It is also a means to identify and mitigate potential adverse impacts that we may cause or contribute to through our own activities, or which may be directly linked to our operations, products or services. The Sustainability Due Diligence at Dustin is based on the OECD Due Diligence Guidance for Responsible Business Conduct and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

1. Embed Responsible Business Conduct into Policies and Management Systems

Dustin has adopted a business code of conduct. Dustin’s Code of Conduct applies to all employees, in-house consultants, officers and board members of Dustin, in all markets and at all times. Likewise, we expect our suppliers that deliver goods and/or services to Dustin to enforce the relevant requirements as stipulated in Dustin Supplier Code of Conduct. In addition, Dustin has also adopted a Conflict Minerals Policy to address the specific high-risk areas in our value chain. Policies are approved by the Dustin Group Board of Directors and are reviewed and updated regularly.

2. Identify and Assess Adverse Impact in operations, supply chains and business relationships

Risk assessments within the sustainability areas are continuously performed in order to keep Dustin’s sustainability work updated and to secure Dustin upholds human rights, business ethics and environmental protection throughout the operations and value chain.

The risk assessment is included in the general risk management process. The risk assessment is then used as a filter within Dustin’s operations to identify high-risk procedures in the value chain. The main sustainability related risks identified is connected to the supply chain, whereas the day-to-day sustainability due diligence is tailored to be included in these processes at Dustin. Through the risk assessment process it was identified that the area in the value chain that holds the highest risk areas is in the supply chain, more specifically in the mining and extraction of minerals for the production of electronics. The more salient risks here is categorized under human and labour rights. During 2022, an in-depth Human Rights Risk Assessment were performed by an external party. The most salient risks were associated with electronics production in Asia. The potential risks specifically identified were child and slave labour, employment conditions, restrictions regarding freedom of association, discrimination, health and safety. 

3. Cease, Prevent or Mitigate Adverse Impacts

Dustin identifies risks and verifies compliance in accordance to the Supplier Code of Conduct mainly by five ways.

•    Dustin Supplier Compliance Capability Assessment is a self-assessment launched to measure compliance at suppliers and distributors. 
•    Dustin’s sustainability audits are performed on site at premises of suppliers or their subcontractors by Dustin in-house auditors or by third party auditors.  
•    Dustin utilizes tools and information provided by the RBA (Responsible Business Alliance) for responsible supply chain, such as risk maps, self-assessments and audit protocols. 
•    Dustin utilizes the Responsible Minerals Initiative (RMI) templates to facilitate Conflict Minerals compliance. 
•    All Dustin employees must attend training on Dustin Code of Conduct every year. Dustin also provides training within the supply chain for identified target group each year.
•    Continuous reviews of external analysis and reports from NGOs are used to identify potential actual risks.

All compliance check tools are launched using a risk-based approach.  Dustin Supplier Code of Conduct is stipulated to be cascaded down in the production chain. For suppliers that provide Dustin own brand products, additionally also on-site audits are performed by Dustin. Read more about our work with the supply chain here.

4. Track Implementation and Results

In case any non-conformances are identified during the audits, suppliers are expected to submit corrective and/or corrective actions plans for Dustin’s approval. The non-conformances will be followed up and closed by Dustin sustainability team until the actions are implemented with sufficient evidence. Dustin continuously reviews results from supplier assessments, audits, contractual and governance dialogues etc in order to oversee suppliers’ performance with aim for improvement. Other channels may also be social dialogue, NGO consultations or industry collaborations.

5. Communicate How Impacts are Addressed

The overall Sustainability Progress, including Sustainability Due Diligence, at Dustin is reported and communicated through Dustin’s Annual and Sustainability Report as well as through Dustin’s website. Dustin also communicates through various channels with a wide range of stakeholders continuously about progress and ambitions within the sustainability framework and responsible business agenda.

6. Provide for or Cooperate in Remediation When Appropriate

Dustin provides access to an anonymous whistleblower system. The whistleblower function is a secure web-based reporting system. Details on the whistle-blower system are provided on the Dustin Group Intranet by accessing the link “Whistleblower”. Dustin Supplier Code of Conduct stipulates that suppliers shall ensure that workers have a mechanism to report grievances (and seek remediation for their employment issues). Dustin has developed internal guidance on how and when to provide remediation.

Dustin Responsible Supply Chain Report

Dustin’s Responsible Supply Chain Report is published annually and provides an update on our due diligence efforts across the supply chain. Since Dustin’s financial year runs from September 1 to August 31, this report covers the previous full fiscal year. In the report, we outline how we identify and manage supply chain risks, our work to improve supplier standards, and our commitment to transparency and continuous improvement. Read the Dustin Responsible Supply Chain Report here.

Continued Improvements

Dustin has identified areas for improvement in the Due Diligence Process and will continue to develop and to expand the reach both vertically in the value chain towards full transparency in the production chain, as well as horizontally to include all business areas eventually. At this point in time, some tiers are known in the various production chains (including at minerals extracting level), but typically not the full chain. Dustin is committed to work continuously to improve supply chain transparency over time, especially the production chains of sourced electronics.