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In January 2019, Robert Bosch LLC was listed on USASpending.gov as having contracts with the US Department of Defense in 2018 worth $2,915,568 including communication equipment contracts.

In addition, a directly owned subsidiary of Robery Bosch LLC, Bosch Security Systems Inc, was found to have been awarded contracts worth $764,335 to the Department of Defense including communications equipment.

Robert Bosch LLC therefore lost a whole mark under Arms and Military Supply.

Reference:

Spending data January 2019 (10 January 2019)

In January 2021, Bosch Rexroth was listed on USASpending.gov as having contracts with the US Department of Defense in FY2020 worth $7.9 million for 'maintenance, repair and rebuild' and 'aircraft launching equipment' and 'powered valves' and 'power and hand pumps'.

Reference:

Spending data January 2019 (10 January 2019)

In February 2022, Ethical Consumer search the Bosch website for its supply chain management policy. The company's Code of Conduct for Business Partners was downloaded dated 06/2018, along with its 2020 Sustainability Factbook.

Supply chain policy (poor)
Bosch's Code of Conduct for Business Partners contained sufficiently robust clauses on forced labour, freedom of association and non-discrimination. The clause on child labour was considered insufficiently detailed. It stated that business partners should "only employ persons who have reached the minimum legal age for work according to the legislation applicable in the country of employment." A robust clause would explicitly prohibit the employment of a child under 15 (or 14 if ILO exempt).

Similarly, Ethical Consumer expected suppliers to pay a living wage and restrict working hours to 48 hours plus 12 overtime (ideally specifying these hours and that this is without exception). Bosch's Code of Conduct stated that suppliers should "pay wages and social benefits equal to or higher than the rates prescribed by national or regional authorities, legal standards, or other labor agreements" and that "applicable regulations governing working hours and vacation entitlements [should be] observed."

Given the weaknesses in its child labour, wages and working hours clauses, Bosch's supply chain policy was considered to be poor.

Stakeholder engagement (rudimentary)
Ethical Consumer deemed it necessary for companies to demonstrate stakeholder engagement, such as through membership in a multi-stakeholder initiative such as the Ethical Trade Initiative, Fair Labour Association or Social Accountability International. Companies were also expected to engage with Trade Unions, NGOs and/or not-for-profit organisations which could systematically verify labour standards audits, and for workers to have access to an anonymous complaints system, free of charge and in their own language.

Bosch did have a web-based compliance hotline for workers throughout their supply chain to anonymously report compliance violations. The service was operated by a "specialized service provider", was available around the clock and in multiple languages.

Bosch's stakeholder engagement was therefore considered to be rudimentary.

Auditing and reporting (poor)
Ethical Consumer also deemed it necessary for companies to have an auditing and reporting system. Results of audits should be publicly reported and quantitatively analysed. The company should have a scheduled and transparent audit plan that applies to its whole supply chain, including some second tier suppliers. The company should also have a staged policy for non-compliance. The costs of the audit should be borne by the company.

Bosch stated: "As part of the regular assessment of our suppliers' sustainability performance, two methods have been established for on­site verification: CSR quick scans and more comprehensive CSR drill­deep assessments." The quick scans did not appear to include audits. The drill-deep assessments were said to be used in potentially high risk regions or industries, and did appear to include some auditing.

However, drill-deep assessments were said to be "at the discretion of the competent purchasing management responsible for supporting the given supplier." Therefore no schedule was given, nor committment to audit the whole supply chain.

The company stated: "The findings of the CSR drill­deep assessments are documented in our supplier database. Improvement potential is recorded in a specific action plan. The plan supports the supplier as well as the auditor, who subsequently also accompanies and follows up on the implementation of measures. Suppliers are expected to start implementing the measures immediately after the results are made available. Those suppliers who satisfy the requirements in general are still made aware of any noncritical gaps identified." While this suggested a policy for non-compliance, it was vague, and did not discuss actions taken if non-compliance was ongoing. While checks were "at the discretion" of purchasing managers, this was concerning and was not accepted as a staged policy.

No audit results were found.

Bosch's auditing and reporting was therefore considered to be poor.

Difficult issues (poor)
Ethical Consumer also deemed it necessary for companies to address other difficult issues in their supply chain. This would include ongoing training for agents, or rewards for suppliers, or preference for long term suppliers. It would also include acknowledgement of audit fraud and unannounced audits, and other measures taken to address the issue of living wages, particularly among outworkers, and illegal freedom of association.

Regarding purchasing, the company stated that "associates in the purchasing department who receive regular training on sustainability issues" and that "sustainability performance" was taken into account when making purchasing decisions. However, it was unclear whether workers' rights issues were included in the term "sustainability", and given the environmental focus of the report, it seemed unlikely.

Bosch's approach to difficult issues was considered to be poor.

Since Robert Bosch GmbH's stakeholder engagement was considered rudimentary and its supply chain policy, auditing and reporting, and approach to difficult issues were all considered poor, the company received Ethical Consumer's worst rating for Supply Chain Management and lost a full mark in this category.

Reference:

Code of Conduct for Business Partners (June 2018)

In February 2022 Ethical Consumer viewed Robert Bosch GmbH website, in search of the company's conflict minerals policy. The Bosch Group Policy for Conflict Raw Materials, dated May 2019, was found and downloaded.

It stated:
* Bosch joined the Responsible Minerals Initiative (RMI) in 2014
* We demand from our suppliers respect and compliance with existing legal requirements concerning the mining of raw materials in conflict and high-risk territories
* Bosch does not directly source any of these minerals from mines in the high-risk territories or elsewhere
* Bosch supports the approach of validating smelters and refiners for 3TG as they play a key role in the supply chain from the mining site to the final product.
* Bosch respects the OECD’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.”
* We ask our respective suppliers to report the origin and the certification status of the smelters and refiners involved. We regularly report the outcome of our data collection and analysis of the certification status.
* Relevant suppliers and sub-suppliers are asked to collaborate with smelters and refiners that are conformant with the Responsible Minerals Assurance Process (RMAP) by RMI. The RMAP identifies smelters and refiners that can verify that their raw materials do not originate from suppliers contributing to conflicts in the high-risk areas. We also highly encourage our suppliers to participate in the RMI or similar relevant industry initiatives with the intention to improve the conditions in the extractive industry.

Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of Congo (DRC). The minerals in question are Tantalum, Tin, Tungsten and Gold (3TG for short) and are key components of electronic devices, from mobile phones to televisions.

Ethical Consumer deemed it necessary for any company manufacturing electronics to have a policy on the sourcing of conflict minerals. Such a policy would articulate the company's commitment to conflict free sourcing of 3TG minerals and its commitment to continue ensuring due diligence on the issue. The policy should also state that it intends to continue sourcing from the DRC region in order to avoid an embargo, which would hurt local workers even more.

A company should also:
- support conflict free initiatives in the region
- require conflict minerals policies throughout its supply chain
- explain its due diligence procedures
- use established conflict minerals reporting templates
- commit to only using 3TG minerals from smelters that have been audited and verified as conflict free, ideally listing them

Since Robert Bosch GmbH had some of these things but did not state its commitment to continue to source from the DRC region, it received Ethical Consumer's worst rating for conflict minerals and lost a full mark under Human Rights and Habitats and Resources.

Reference:

bosch.com (15 February 2022)

In August 2020, Ethical Consumer viewed a report via the Business & Human Rights website, first published by the Australian Strategic Policy Institute (ASPI) in February 2020, entitled “Uyghurs for sale ‘Re-education’, forced labour and surveillance beyond Xinjiang”.

The findings of the report were summarized as follows: “The Chinese government has facilitated the mass transfer of Uyghur and other ethnic minority citizens from the far west region of Xinjiang to factories across the country. Under conditions that strongly suggest forced labour, Uyghurs are working in factories that are in the supply chains of at least 83 well-known global brands in the technology, clothing and automotive sectors, including Apple, BMW, Gap, Huawei, Nike, Samsung, Sony and Volkswagen.

In all, ASPI’s research has identified 83 foreign and Chinese companies directly or indirectly benefiting from the use of Uyghur workers outside Xinjiang through potentially abusive labour transfer programs as recently as 2019”. Bosch was listed as one of these companies.

Business & Human Rights had contacted all of the companies named in the report and published their responses. At the time of writing, no response had been received from Bosch, however, it was noted in the original ASPI research that Bosch stated that it had no direct contractual relationships with any of the suppliers implicated in the report, but could not rule out a link further down the supply chain.
As a result, the company lost half a mark under Human Rights.

Reference:

Australian Strategic Policy Institute (ASPI) report: Uyghurs for sale (3 December 2020)

In February 2022 Ethical Consumer viewed Robert Bosch's list of subsidiaries on the D&B Hoovers corporate database, this showed that the company had operations in 12 countries considered by Ethical Consumer to be governed by oppressive regimes at the time fo writing: Russia, Saudi Arabia, Turkey, Mexico, Philippines, China, Egypt, Bangladesh, Nigeria.

The company's 2020 Annual Report also mentioned operations in Israel and Iran.

Robert Bosch GmbH therefore lost a whole mark under Human Rights.

Reference:

Generic Hoovers ref (2022)