April 2019 Ethical Consumer searched Bayer’s website, www.bayer.com, for information about its supply chain management reporting and practices. The Sustainability section of the website was viewed, in addition to Bayer’s human rights statement. Bayer’s Supplier Code of Conduct was also downloaded.

Supply chain policy - reasonable
Bayer’s Supplier Code of Conduct included a section on labour which contained adequate provisions on use of child labor (“consistent with the International Labour Organization’s core labor standards and the United Nations Global Compact principles”), forced labor, discrimination, working hours ("shall not exceed the maximum set by the applicable national law and by ILO standards.") and compensation ("should aim at providing an adequate standard of living for employees and their families.") Overall Bayer’s Supply Chain Policy was considered reasonable.

Stakeholder engagement - poor
Bayer was a member of the Pharmaceutical Supply Chain Initiative (PSCI) and the Together for Sustainability Initiative (TfS). However, as there were exclusively industry initiatives these were not considered adequate and were not considered to equate to membership of a multi-stakeholder process. There was no evidence of engagement with trade unions or of an anonymous helpline that workers could use in their own language to to report violations. Overall Bayer's Stakeholder engagement was rated as poor.

Auditing and reporting -rudimentary
Bayer stated that it conducted online assessments through EcoVadis and a portion of high risk suppliers were audited physically by external, independent auditors. Detsil on remediation were weak, although Bayer stated "A supplier receives a critical result if a serious violation or several major findings in sustainability performance are identified. In 2018, this applied to 17 suppliers (2% of all assessed and audited suppliers; 2017: 3% (20)). In these cases, Bayer requests that the suppliers remedy the identified weaknesses within an appropriate timeframe based on specific action plans. We monitor the implementation of these activities by way of re-assessments or follow-up audits. Bayer reserves the right to terminate a supplier relationship if no improvement is observed during a re-evaluation. In 2018, Bayer had to end one supplier relationship due solely to sustainability performance."

No further information could be found regarding a schedule of audits or information regarding who bore the cost of audits. The company's auditing and reporting was considered rudimentary,

Difficult issues - poor
No discussion of difficult issues could be found.

Overall Bayer received Ethical Consumer’s middle rating for its Supply Chain Management.

In May 2019 Ethical Consumer viewed the pharmaceutical Transparency Index run by the campaigning organisation All Trials, started by Dr Ben Goldacre and Dr Sile Lane at Sense About Science. All Trials argued that transparency in clinical trials was not being sufficiently respected by pharmaceutical companies, with seriously detrimental effects on medicine.

The Index rated 46 pharmaceutical companies on their commitment to transparency.

Ethical Consumer marked down all companies who appeared below the top ten. This included ViiV Healthcare, which was in 36th place, Sanofi, in 25th place, Johnson & Johnson, in 15th place, and Bayer, in 11th place.

In May 2019 Ethical Consumer viewed the 2018 Access to Medicine Index. This was a project of the Bill and Melinda Gates foundation and the UK government. It stated that it “evaluates 20 of the world's largest pharmaceutical companies on their actions to improve access to medicine. The Index covers 106 low- and middle-income countries and 77 diseases, conditions and pathogens.”

All companies that scored in the bottom half were marked down for secondary criticism in the human rights category. Beyer was among them.

In April 2019 Ethical Consumer viewed the “Subsidiary and affiliated companies of the Bayer
Group as of December 31, 2018, pursuant to Section 313 of the German Commercial Code.” A number of subsidiaries were based in countries considered by Ethical Consumer to be governed by an oppressive regime at the time of writing. These included: Russia, Kazakhstan, China, India, the Philippines, Bangladesh, Thailand, Pakistan, Vietnam, Israel, Colombia, Venezuela, Nigeria, Zimbabwe, Iran and Honduras.