Bayer

Lobbying
Bayer discloses a list of trade associations of which it is a member. Moreover, it provides a clear and detailed framework for assessing alignment of its trade associations with its climate policies, based on alignment with the Paris Agreement as well as Bayer’s own policies on lowering GHG emissions and renewable energies. The company applies the framework biannually across selected associations and reports on misalignment.

Stakeholder engagement
Bayer discloses its process for engaging with stakeholder groups, including frequency and channels, beyond its materiality assessment or an equivalent. Moreover, its stakeholder engagement activities cover nature, nutrition and social areas.

Sustainability strategy and accountability
Bayer discloses its process for identifying and prioritising its most relevant sustainability impacts as well as the outcome of this process, in relation to its sustainability strategy. Also, it has group-wide targets on key sustainability topics for the most material parts of its value chain and reports consistently against all its targets. Furthermore, the company provides evidence of linking performance criteria in senior executives’ remuneration policies to targets and objectives which cover nature, including biodiversity, and social issues. Lastly, it provides evidence that its highest governance body has expertise with respect to the company’s most material sustainability topics.

Ecosystem conversion and restoration
Bayer is committed to restoring ecosystems.

GHG emissions
Bayer discloses its target to reduce scope 1 and scope 2 emissions by 42% by the end of 2029 and reports year on year reduction for scope 1 and scope 2 emissions. Its scope 1 and scope 2 emissions targets are aligned with a 1.5-degree trajectory. Additionally, the company aims to reduce scope 3 emissions by 12.3% by 2029.

Resource exploitation and circularity performance
Bayer discloses activities to improve soil health or agrobiodiversity in its production or sourcing practices.

Solid and air pollution
Bayer requires its suppliers to reduce the release of hazardous substances in the environment. Further, it discloses that the volume of hazardous waste has been reduced. It also discloses the proportion of hazardous waste treated to reduce pollution compared to total waste, the hazardous waste diverted from disposal and the waste directed to disposal. The company reports regularly on air quality parameters of emissions of harmful air pollutants. It also demonstrates commitment and partakes in activities related to plastic use reduction and transitioning towards sustainable packaging.

Water
Bayer reports a decrease in water pollution. Also, it demonstrates reducing water withdrawal in its own operations, and reports how much water is withdrawn for its own operations in water-stressed areas. Additionally, it engages with suppliers to reduce water withdrawal. The company also regularly reports on water pollution metrics, and discloses its processes for managing and monitoring discharge water quality. Moreover, the company has a commitment to respect the right to water. It also requires access to water and sanitation, including refraining from negatively affecting access to safe water, to be included in contractual arrangements with its business relationships.

Indigenous Peoples’ and land rights
Bayer has a requirement for its business relationships to identify and acknowledge Indigenous Peoples who may be affected by their projects. It also emphasises the importance of obtaining the free, prior, and informed consent of these Indigenous Peoples in determining whether and how to proceed with the projects.
Additionally, the company mandates that its business relationships establish a process for identifying legitimate tenure rights holders. Special attention should be given to those who may be vulnerable or marginalised in society. It is also expected that negotiations will take place with these tenure rights holders to ensure they receive appropriate compensation for their involvement in the projects.

Act ethically
Bayer has a public commitment to protect personal data and a policy prohibiting bribery and corruption. It also identifies bribery and corruption risks by means of Bayer risk management system. Additionally, it includes anti-bribery and anti-corruption clauses in its contracts with direct business relationships and has a grievance mechanism for stakeholders to raise concerns about bribery and corruption. The company’s approach to lobbying and political engagement is outlined in a policy statement, where it specifies that it does not make political contributions and requires third-party lobbyists to comply with its policy.

Provide and promote decent work
Bayer has a publicly available policy statement in which it commits to respecting the health and safety of workers in its operation and supply chain. It also discloses how it monitors the health and safety performance of its business relationships.
In addition, it states that it pays all workers a living wage, and describes how this wage is determined. The company also publicly limits working hours, stating that workers shall not exceed 48 hours in a regular week or 60 hours with overtime. It also discloses the proportion of employees covered by collective bargaining agreements.
It breaks down its workforce by employee category and age group, and discloses the proportion of women in each employee category. The company is committed to gender equality and women’s empowerment, with targets to increase the proportion of women in top management, aiming for gender parity at all management levels by 2030. Finally, it reports that 45% of its supervisory board is composed of women.

Respect human rights
Bayer has a publicly available policy statement committing it to respect human rights and describes its processes for identifying human rights risks both in its own operations and supply chain. It also assesses these risks and discloses its salient human rights issues. Moreover, the company provides a case study on how it has acted on a significant human rights risk. Additionally, it has a human rights grievance mechanism accessible to all workers as well as to external stakeholders who may be adversely impacted.

Lobbying
The company does not report on its advocacy practices on nature-related issues, nor whether these activities align with its sustainability strategy. Additionally, it has an opportunity to show leadership by integrating biodiversity in the criteria for its industry association review.

Stakeholder engagement
The company discloses the topics it engages with some of its stakeholders such as associations, investors, rating agencies, NGOs. However, it could disclose the issues raised by other stakeholders such as customers, employees, local communities, and regulators.

Ecosystem conversion and restoration
The company does not have a commitment to ensure zero conversion, and does not disclose activities to achieve conversion-free supply chains. While the company has a target to achieve conversion-free supply chains, certification models are not specified so there is no guarantee that it is DCF-aligned. Furthermore, the company does not disclose details and outcomes of ecosystem restoration projects in areas affected by its own operations or by its suppliers.

GHG emissions
The company reports an increase in its scope 3 emissions from last year, yet it should reduce its scope 3 emissions and report progress against its scope 3 targets. Additionally, its scope 3 targets are on the pathway to a 2 °C trajectory acknowledged by the SBTi. However, the company should improve its targets to be aligned with a 1.5-degree trajectory.

Impact and dependencies assessment
While the company acknowledges that farming activities impact biodiversity, it still has an opportunity to assess its impacts on nature, including biodiversity, within its own operations and disclose the methodology and results of these assessments. It also has an opportunity to assess its dependencies on nature both within its own operations and upstream business relationships.

Invasive species
The company has not identified any activities that could lead to the introduction of invasive alien species in its own operations.

Key areas and species
While the company utilises the Integrated Biodiversity Assessment Tool and acknowledges the proximity of some sites to protected areas, there are areas for further disclosure. Specifically, the company has the opportunity to provide the names of its locations that are in or adjacent to areas important for biodiversity, as well as species populations existing in those areas. In addition, it could disclose the locations and species populations in or adjacent to areas important for biodiversity concerning its suppliers. Finally, the company could enhance transparency by disclosing the status of identified species in accordance with national and international conservation lists.

Resource exploitation and circularity performance
The company has an opportunity to disclose its inputs according to an international standard, and to report quantitatively on its group-wide circularity performance. It could further disclose a target to improve soil health in its production or sourcing practices and to report progress against it.

Solid and air pollution
The company should commit to avoid developing or marketing new chemicals or products with SVHC (substance of very high concern) properties, as well as work on reducing the production of hazardous substances. It discloses the amount of waste generated and hazardous waste disposed, however, it has an opportunity to report on the amount of plastic waste generated, and proportions directed from or to disposal. While the company describes its activities to reduce plastic use and transition towards sustainable packaging, it has an opportunity to disclose the associated quantitative data. It could also set and disclose time-bound targets to reduce air pollutants across its operations.

Water
The company has an opportunity to disclose a time-bound target to reduce water withdrawal and water pollution. Additionally, it could disclose its processes for implementing preventive and corrective action plans for identified specific risks to the right to water and sanitation in its own operations.

Indigenous Peoples’ and land rights
The company does not disclose its processes to identify and recognise the rights of Indigenous Peoples when activities in its own operations may impact their rights or describe how it obtains Indigenous Peoples’ free, prior and informed consent.

Safe, clean, healthy and sustainable environment
The company discloses that it aims to operate facilities in a way that that they do not pose any inappropriate risks to neighbouring community. However, the company has an opportunity to commit to respect the right to a safe, clean, healthy and sustainable environment of local communities. Furthermore, the company tracks the environmental incidents that resulted in the release of substances into environment. However, it should provide evidence of tracking that includes both scale (the outcome of the impact; frequency) and scope (the number of individuals who are or could be affected; frequency; geographies) evidence of tracking its actual or potential negative impacts on the health of local communities. Additionally, the company should disclose a policy statement that shows its commitment to zero tolerance for acts of violence, threats, intimidation or judicial harassment committed against land and environmental rights defenders.

Act ethically
The company discloses information about its lobbying expenditures but could further specify whether these expenditures cover all locations where it lobbies or only specific countries or regions.

Provide and promote decent work
While the company expects its suppliers to pay a living wage, it has an opportunity to elaborate on how it supports this payment. Additionally, the company could disclose the ratio of basic salary and remuneration of women to men in its total direct operations workforce, broken down by employee category and significant locations of operation.

Respect human rights
The company has a publicly available policy statement committing it and its suppliers to respect the right not to be subject to discrimination, forced labour, and child labour, and respecting the right to freedom of association. Also, it states that it may engage in collective bargaining according to the applicable legal regulations, and expects its supplier to respect the right of their employees to associate freely and engage in collective bargaining, however, it could clarify whether these commitments cover all contexts and locations.
Also, it could strengthen the language in its supplier code of conduct that covers the International Labour Organization (ILO)’s fundamental rights at work, to make it a binding policy commitment.