International Policy on Forced Labour - ALDI Nord
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International Policy on Forced Labour February 2021
INTRODUCTION
As companies with global supply chains, ALDI1 is aware of its responsibility to respect human
rights, in accordance with the UN Guiding Principles, and as laid out in ALDI's Human Rights
Policy Statement and its Additional Agreement on Social Standards. This includes the right to
freedom from slavery and forced labour, meaning that ALDI does not tolerate any form of
servitude or slavery, or forced, bonded, indentured, trafficked or non-voluntary labour.
ALDI has developed this Policy in alignment with the following key standards:
• Universal Declaration of Human Rights
• International Covenant on Civil and Political Rights
• ILO Forced Labour Convention, 1930 (No. 29)
• ILO Abolition of Forced Labour convention, 1957 (No. 105)
• United Nations Guiding Principles on Business and Human Rights (UNGP)
• OECD Guidelines for Multinational Enterprises
• ETI Base Code
• amfori BSCI Code of Conduct
• UK Modern Slavery Act 2015
• Australian Commonwealth Modern Slavery Act 2018
• California Transparency in Supply Chains Act
• Dhaka Principles for Migration with Dignity
1 ALDI’ refers to the ALDI SOUTH Group (hereinafter also referred to as ‘ALDI SOUTH‘) and ALDI
Nord Group (hereinafter also referred to as ‘ALDI Nord‘). Both are legally independent groups of
companies trading under the ALDI brand. The ‘International Policy on Forced Labour‘ is published
on the websites of the ALDI companies.
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Page 2OUR APPROACH
Scope There must be no discrimination in
For purposes of this document, the term ‘forced application of these norms on the basis of
labour’ covers all work or service which is sex, gender and gender identity, ethnicity,
exacted from any person under the threat of a nationality, race, colour, social origin, religion,
penalty and for which the person has not faith, age, legal status, political opinion,
offered themselves voluntarily. It aligns with disability, sexual orientation, pregnancy, or
international definitions of modern slavery in trade union membership or activity.
business, and includes any form of slavery,
servitude, trafficked labour, debt bondage, and Principles
other forms of labour exploitation.
Legal Requirements
Forced labour is not limited to situations ALDI commits, and requires all business
where the worker has been coerced by partners, to be fully aware of, and compliant
violence or intimidation, it also includes more with, all local, regional and international laws
subtle means of control, including deception and regulations on labour protection, as
and fraud, debt manipulation, retention of pay applicable in sourcing countries and importing
or identity papers, threats of denunciation to countries, and any other countries where
government authorities, or exploitation of business operations take place. Wherever there
vulnerability or power imbalances. Private is a conflict between ALDI requirements, local
individuals, business, or state authority can laws, and/or international standards, whichever
impose forced labour, and it can occur in any principle provides the highest protection to
industry (formal or informal). workers shall apply.
All forms of forced labour are strictly prohibited Freedom of Employment
in ALDI’s supply chains. ALDI commits to All workers shall have the right to choose their
implement measures which respect and fulfil employment voluntarily and freely, free of
the principles laid out in this Forced Labour deception and without the threat of a penalty.
Policy and all ALDI business partners and other The employer must not exact work or service
suppliers should do the same. ‘Other suppliers’ from any person under the threat of any
include all sub-suppliers, production facilities negative consequences. Work must not be
and production sites including factories, farms exacted on the basis of debt. Workers must be
and fishing vessels, service providers, cont- free from the threat of physical, psychological,
ractors and subcontractors relevant to ALDI’s sexual or gender-based violence or harassment.
supply chains and business processes. The
principles outlined in this document apply to the All employer-worker relationships must be
business processes of ALDI business partners agreed to on the principle of free and informed
and other suppliers in their entirety, and are consent. Each worker must receive and agree
not limited to production processes or services to a legally binding written contract prior to
directly connected to ALDI products. starting work or making any other irreversible
commitments such as terminating a previous
The principles apply equally to regularly job or departing their current residence to move
employed workers, informal workers, seasonal to the country or region of employment.
and temporary workers, contracted and subcon- The terms of the contract must be clear and
tracted workers, migrant workers, and transparent, in a language that the worker is
homeworkers. fluent in, and accurately describe the job,
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Page 3location, employer, working conditions, living Retention of Personal Belongings and
conditions, wages and benefits, length of Documents
contract, legal status of the worker upon arrival, A worker’s money and possessions, including
and other factors salient to the worker’s passports and other personal documents, must
employment. Any subsequent changes to the be accessible to the worker at all times, and
above conditions relative to the original contract must not be withheld by the employer.
must be recorded and freely agreed to by all
affected parties and must not be to the Wage Payments
detriment of the worker. Where necessary,
e.g. due to poor literacy, the terms of the Payment must at least correspond to the national
contract must be explained verbally in a clear or local legally mandated minimum wage, and
manner by a third party, in a language that workers must receive any additional benefits and
the worker is fluent in. Where employment social security that they are entitled to in accor-
contracts exist in multiple versions, e.g. due to dance with laws and/or collective agreements.
being translated, the content of these versions Wages and benefits must be paid on time, in
must match. accordance with a schedule determined by law,
contract and/or collective agreement. Employers
Workers must be free to change their employer must pay wages directly to the employee or an
whenever they wish, subject only to the normal employee-controlled account. Payments must
and/or legally mandated notice period. In case be documented in the form of payslips and
of resignation, there must be no threat, whether issued in a language the worker understands.
physical, psychological, financial or legal, to Documentation and payslips must accurately
the workers, to their families or to other third report regular and overtime hours worked,
parties. Resigning workers must be paid payment for regular and overtime work, and any
whatever outstanding wages and benefits are incentives and deductions. Employers must not
still owed in a timely manner, and in accordance engage in or require illegal deductions, deposits
with national or local law. Workers must not or disciplinary infractions.
be made to resign against their will, whether
through coercion, deception or other means,
such as via forged or pre-signed resignation
documents, or threatened with involuntary
resignation as a means of coercion.
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Page 4Leave, Leisure and Overtime Migrant Workers, Refugees and Internally
Working hours, consecutive working days, sta- Displaced People
tutory holidays, annual and parental leave must Aside from employers abiding by all the general
be compliant with national or local labour law, principles listed above, migrant workers,
including were special provisions are made for refugees and internally displaced people must
workers on the basis of gender, age, disability or be granted the same rights to safe and decent
other status. Any overtime must be voluntary on working and living conditions as other workers,
the part of the worker and must be accurately including direct and on-time payment, and worker
recorded. Workers must not be mandated or representation.
coerced into working beyond their contractually
agreed working hours and must be free to reject Debt Bondage
overtime work without suffering any negative Any employment relationships founded on
consequences. Overtime work must be compen- debts between the employee and the employer
sated according to national or local law. Off-the- or recruiter (or any other relevant third party)
clock work is prohibited. are strictly prohibited in ALDI’s supply chains.
Due to the risk of bondage and indenture ari-
Workers must be free to spend any time outside sing from the use of recruitment fees, ALDI and
of working hours at their own leisure, being free all its business partners are to abide the
and enabled to move and travel outside their ‘Employer Pays Principle’. This means that no
place of work and/or residence to the extent that worker should pay for a job, and all costs
is possible. Workers must be free from intimida- related to recruitment must be borne by the
tion or negative consequences for making use of employer. Employers must comply with the
this right. In the case of remote and/or hard-to- ILO’s ‘General Principles and Operational
access workplaces, the employer must provide Guidelines for Fair Recruitment and Definition
freely available transportation to workers, free of Recruitment Fees and Related Costs‘. No
of charge or at a cost that aligns with the local recruitment fees or related costs (e.g. relating to
market rate. training, equipment and medical examination)
may be charged, directly or indirectly (e.g. via
During working hours, reasonable accommodation deduction of wages or benefits), in whole or in
must be made to allow workers rest breaks and part, to any workers in ALDI’s supply chains.
to access sanitation facilities and potable water. Workers must not be allowed to incur debt with
Workers must be granted appropriate levels of their employer or recruiter (or any other relevant
privacy, both at their workplace and their place third party) through other means, such as loans,
of residence. fines or wage deductions. Any rent or other
daily living expenses charged by the employer
Production Targets and Piece Rates to an employee (e.g. in isolated workplaces)
Any production and yield targets must be must align with the local market rate, and allow
realistically calculated based on regular work the employee to save money without entering
schedules, and adjusted according to changing into debt.
circumstances (e.g. reductions in workforce).
Where workers are compensated by piece rate, Only legally licenced recruitment agencies
e.g. in the case of homeworkers or contract should be used for hiring workers, and any
workers, the payment they receive must be fair services from such agencies should only be
and proportional to the hours required for pro- procured via binding contracts. The employer
duction, and at least correspond to the national should ensure that any agency they use does
or regional legally mandated minimum wage. not exact fees from the worker or engage in
fraudulent or exploitative recruitment practices.
Recruitment services should not be subcontracted
beyond what is contractually agreed.
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Page 5Wages and benefits must be paid in legal Children and Youth
tender, cheque or bank transfer, and must not ALDI commits, and requires all business
take the form of vouchers or coupons. In-kind partners, to eliminate all forms of child labour,
payments must not be used to create a state of and to address any other risks related to the
dependency on the part of the worker. employment of children and youth in supply
chains. For more information on this specific
State-imposed Forced Labour and Prison topic, please refer to ALDI’s Child Labour Policy.
Labour
State-imposed forced labour refers to any labour
forced upon an individual by a government,
military, paramilitary, law enforcement, penal
system or other public or publicly sponsored
authority. As with other forms of forced labour,
state-imposed forced labour, including prison
labour, is prohibited in ALDI’s supply chains.
OUR IMPLEMENTATION
Management System • c
ollaborating with industry peers and suppor-
In order to implement the principles listed ting business partners in anti-forced labour
above, starting at a pre-recruitment stage, ALDI capacity building and monitoring
commits to put in place systems and procedures
to prevent forced labour in supply chains. When establishing new business relationships
or signing new contracts, any risks surrounding
All business partners should address forced forced labour should be taken into account
labour risks in their supply chains via a due during the procurement process, and all
diligence approach, and implement manage- business partners should commit to a zero-
ment systems relating to this topic. Appropriate tolerance stance on forced labour and any
measures include: existing or potential impacts found should be
actively addressed.
• e mploying staff with responsibilities and To prevent the risk of forced labour by subcont-
competencies related to addressing forced racted third parties, any further subcontracting
labour by one of the business partners must meet all
• training all relevant staff on managing forced relevant standards and requirements and be
labour topics explicitly approved in advance by ALDI. Subcon-
• establishing clear policies and codes of tracting checks must be conducted as needed
conduct in the context of internal and third party audits.
• identifying at-risk regions and industries
• conducting thorough monitoring of ALDI Prevention and Monitoring Process
production processes, both directly and In collaboration with external experts and civil
via social audits society partners, ALDI conducts assessments
• maintaining formal processes for reporting of major human rights risks in its supply chains,
and handling critical findings particularly at a raw material and a production
• developing and implementing mechanisms facility (including pre-production facility) level, and
for raising grievances and providing remedy is developing strategies to address them, as laid
for affected workers out on the Human Rights website of ALDI Nord.
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Page 6ALDI’s Corporate Responsibility standards are processes for addressing forced labour
legally binding for all business partners. ALDI’s findings and proactively preventing forced
business partners are evaluated based on their labour in its supply chains. This includes
responsible business practices and their capa- developing systems for grievance and remedy
city to respect human rights in ALDI’s supply in synergy with civil society and other industry
chains. ALDI engages business partners to stakeholders. ALDI is also developing stronger
address any capacity gaps identified, and seeks processes specific to forced labour, to address
to prioritise business to those business partners any findings in such a manner that protects
that demonstrate long-term commitment to victims, respects their needs and wishes,
addressing human rights risks. restores and/or compensates damages that
have taken place to the greatest extent possible,
Beyond binding requirements, ALDI publishes and prevents further abuses from taking place.
guidance papers and conducts E-learnings,
webinars, trainings and other capacity building Continuous Improvement
activities to help business partners set up appro- ALDI commits to the principle of continuous
priate management systems. ALDI maintains improvement. Any systems in place must be
partnerships with civil society organisations and regularly evaluated and assessed on the basis
multi-stakeholder initiatives and working groups of measurable effectiveness, in accordance
to address risks around forced labour and other with changing environments, and be adapted
issues related to corporate responsibility. or expanded as required. ALDI will review and
update this policy at regular intervals.
In terms of monitoring, ALDI maintains an
overview of production facilities in its supply Responsibilities
chains via a combination of third party social
audits and ALDI Social Assessments (ASAs), The Managing Director - International Buying /
which are conducted by ALDI staff based in the Corporate Responsibility / Quality Assurance
CR offices in Bangladesh and Hong Kong. ALDI of ALDI Einkauf SE & Co. oHG supports the
maintains a checklist for assessing forced labour implementation of the ‘International Policy on
risks when interviewing workers in the context Forced Labour’.
of ASAs. On farm level, ALDI conducts ALDI
Producer Assessments (APAs) jointly with an The Managing Directors of the companies of
external service provider to assess compliance the ALDI Nord Group are responsible for super-
with ‘ALDI’s Additional Agreement on Social vising the implementation of and compliance
Standards’ and to identify forced labour risks on with the ‘International Policy on Forced Labour’.
farms supplying to ALDI.
Remediation Published by
ALDI takes all incidences and allegations of ALDI Einkauf SE & Co. oHG
forced labour seriously, whether reported by Eckenbergstraße 16A
ALDI employees, workers, third party auditors, 45307 Essen
business partners, civil society, media, or other First Edition: 02/2021
stakeholders. ALDI’s primary approach is one of
remediation with business partners and pro- © ALDI Einkauf SE & Co. oHG | 2020
duction sites. ALDI may impose consequences
(including temporarily or permanently termina- Contact:
ting business relationships) where appropriate. Corporate Responsibility / Quality Assurance
Where necessary, the case may be referred to International (CRQAi)
the appropriate authorities and/or NGO partners.
Beyond this, ALDI is committed to strengthen its cr@aldi-nord.de, crqai-scr@aldi-nord.de
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