Month: February 2024

A diverse and inclusive workforce inspires innovation and is fundamental to our company’s success. Having an environment composed of people from different dimensions of diversity also helps us better understand the unique needs of the customers, health care providers and patients we serve.

Below are some of the ways we celebrate our diverse workforce and a culture of equity, empowerment, engagement and belonging:

01.

Supporting a disability-confident workforce

At our company, everyone should feel empowered to help deliver on our purpose of using the power of leading-edge science to save and improve lives around the world. This includes our colleagues who live with disabilities.

Our Global Disability Inclusion Strategy Council recognizes and values the importance of a disability-confident workforce and offers resources to ensure people with disabilities — including physical, neurological, mental, rare or any other forms of disabilities — are included and prepared to succeed in all areas of our business.

“My hope is for our company to be an example of what’s possible.”

Michael Klobuchar
Executive vice president and chief strategy officer, and executive sponsor of the Global Disability Inclusion Strategy Council

Key programs and partnerships include:

capABILITY in Action, a joint program launched with Accenture and run in partnership with workforce solutions company Rangam to attract, recruit and retain neurodivergent talent.Valuable 500, a global partnership of 500 companies committed to accelerating disability inclusion through best practices such as digitally accessible technology, mental health awareness and more.

02.

Building a pipeline of diverse talent

With our Skills-First approach to hiring, we’re shifting the ways we attract, develop and advance talent. For appropriate roles, this new approach increases the focus on skills instead of a four-year degree, creating equitable access to meaningful career opportunities for diverse candidates.

Key partners in our efforts include:

OneTen, a coalition of leading companies helping to close the opportunity gap for Black talent in the U.S.Year Up, a nonprofit that offers economically disadvantaged youth six months of training followed by a six-month corporate internship.Hiring Our Heroes, an organization that connects the military community to civilian employers and helps upskill service members in preparation for post-service careers.

“OneTen provides an opportunity to create a workforce that reflects the diverse communities we serve, and make a significant long-term impact.”

Ngozi Motilewa
Associate director, talent acquisition, and Skills-First/OneTen lead

03.

Economic inclusion and business diversity

We’ve been championing business diversity and underrepresented entrepreneurs for nearly 40 years, recognizing that a diverse supply chain creates a competitive advantage for our company and positively impacts the global community.

We continue to exceed industry best practices by spending more than 10% of our purchase budget with minority-, women-, veteran-, LGBTQ+-, disability-owned and small business enterprises. And we’re continuing to push ourselves to do more: As a member of the Billion Dollar Roundtable, we’ve made a long-term commitment to spend $4.4 billion with diverse suppliers and small businesses by 2030.

“We’re thinking broader and bolder, and we’ll continue enriching a global diverse business community, reaffirming our commitment to creating healthy and equitable outcomes for our business, patients and communities.”

Susanna Webber
Senior vice president and chief procurement officer

Key initiatives include:

The Merck Drexel Advanced Leadership Program for Diverse Suppliers, in partnership with Drexel University, provides diverse business owners and executives opportunities to enhance their networks, build business and leadership acumen and more.Our Economic Inclusion Virtual Lab offers monthly opportunities for diverse and small-business owners to engage with our supply chain professionals, prime suppliers and advocacy organizations.

04.

Celebrating global diversity and inclusion

Since 2015, we’ve celebrated Global Diversity & Inclusion Experience Month in September to foster meaningful discussions and learning around diversity, equity and inclusion, while highlighting diversity and inclusion–focused work and the people who make our company unique.

This monthlong celebration builds diversity and inclusion capabilities among the workforce and creates a platform for employees to speak up about their experiences.

“We’ve strengthened our commitment to making diversity and inclusion a central strategy to business growth.”

Celeste Warren
Vice president, diversity & inclusion center of excellence

05.

Employee business resource groups (EBRGs)

With more than 21,500 members across 10 groups, our EBRGs play a critical role in driving an inclusive culture and supporting employee career growth. They represent diversity within our company and reflect the communities in which we live and serve.

“I’m proud of our long-standing commitment to diversity, equity and inclusion.”

Marcos Roberto da Costa
Vice president, operational excellence, MMD, and executive sponsor for Merck’s EBRG supporting colleagues with disabilities and their allies

“It has made us a more innovative and agile company — one that’s better attuned to the needs of our employees, patients and customers.”

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Have you seen a movie or television show where an employee acts out and strikes their co-worker, or a reckless manager injures that one employee they don’t like? After you watched that scene, have you thought, “Surely that wouldn’t happen at my job?” Unfortunately, this is a real thing that does happen, and workplace violence examples seem to pop up in headlines more and more these days. To combat these incidents in California, Governor Gavin Newsom signed Senate Bill No. 553 (CA Labor Code § 6401.9), requiring every employer in the state to create and implement a workplace violence prevention plan by July 1, 2024.

Which Businesses or Companies Does this Apply To?

This applies to all California employers, with a few exceptions. Worksites with less than 10 employees are exempt. If the worksite has less than 10 employees present “at any given time” and is not “accessible to the public,” and the employer complies with the injury and illness prevention Cal/OSHA regulation, then the worksite may be exempt from the new law. It only applies to California companies and California employees. If you have employees outside of California, they would not be included. Healthcare facilities are exempt because they should be adhering to Cal/OSHA’s Workplace Violence Prevention in Health Care requirements.

Types of Workplace Violence

Violence can take many different forms and involve people with varied associations to your business. The bill aims to point out four distinct types of workplace violence examples and how they differentiate. These are important as it relates to evaluating the risk of an incident like this at your business.

“Type 1 violence,” which is committed by a person who has no legitimate business at the worksite and includes violent acts by anyone who enters the workplace or approaches workers with the intent to commit a crime.“Type 2 violence,” which is directed at employees by customers, clients, patients, students, inmates, or visitors.“Type 3 violence,” which is committed against an employee by a present or former employee, supervisor, or manager.“Type 4 violence,” which is committed in the workplace by a person who does not work there but has or is known to have had a personal relationship with an employee.

Animal attacks also fall under workplace violence and should be recorded in the incident logs.

The regulation defines “workplace violence” as:

The threat or use of physical force against an employee that results in, or has a likelihood of resulting in injury, psychological trauma, or stress, regardless of whether the employee sustains an injury.An incident involving a threat or use of a firearm or other dangerous weapon, including the use of common objects as weapons, regardless of whether the employee sustains an injury.

California Workplace Violence Prevention Plan Requirements

So, what is required under this new regulation? Businesses and employers need to develop a written workplace violence prevention plan (WVPP) and demonstrate that it is implemented. The plan can be a standalone document OR be included as part of your Injury and Illness Prevention Plan (IIPP).

Written Plan

The plan should include:

Name or job title of the person responsible for implementing the plan.Active involvement of employees in the development of the plan.Methods you will use to coordinate implementation of the plan with nearby employers, where applicable.Procedures for employees to report incidents and for the employer to respond to such reports.Procedures for training all employees and supervisors.Procedures for responding to actual workplace violence emergencies.Procedures to identify and evaluate workplace violence hazards, including periodic inspections to identify unsafe conditions and to correct the identified hazards.Procedures for post incident response, investigation, and reporting.

Workplace Violence Prevention Training

Keep in mind, simply having a plan is not enough. Training is key. Employees are to receive training on the plan upon its implementation, and then annually afterwards. Workplace violence prevention training should include:

The WVPP’s definitions and requirements.How to obtain a copy of the plan at no cost to the employee.How to report workplace violence incidents or concerns without fear of reprisal.The workplace violence hazards specific to the employees’ jobs and the corrective measures the employer has implemented.How to seek assistance to prevent or respond to violence, and strategies to avoid physical harm.The violent incident log and how to obtain copies of the records.

Finally, employees are to receive initial workplace violence prevention training and continued training annually if they are working in the state of California. If there are any changes to the WVPP, such as new material or a new threat has been identified, then additional training should be provided to go over these changes.

Workplace Incident Logs

When filling out the logs for incidents of workplace violence, the who, what, when, where, and how are always important for accurate recordkeeping. This includes who the perpetrator(s) are, the type of violent incident that occurred, and what specific actions were done to prevent further harm to others.

Recordkeeping

Training records are to be kept for one year. Workplace violence hazard identification, evaluation and correction, violence incident logs, and incident investigations are to be kept for five years.

6 Steps to Start Creating a California Workplace Violence Prevention Plan (WVPP)

Now that you know the basic requirements of the California Workplace Violence Prevention Plan, here are some first steps for getting started.

Identify who is responsible for implementing the plan. Who in your organization is responsible for the WVPP?Identify employees that would be interested in providing input into the plan. You can create an employee WVPP task force.Outline how employees can report incidents or threats of workplace violence.Detail how the company will identify and correct workplace hazards.Create procedures for responding to emergencies.Identify how to develop and provide training. If your business has more than one site in the state of California, companies can use the same basic plan, BUT be sure to tailor the specifics for those individual sites.

Records

Record it, record it, record it. To show evidence of implementing your plan, be sure to keep adequate records. This includes maintaining records of the following:

Identification, evaluation, and correction of workplace violence hazards.Violent incident logs.Workplace investigation records.Training records.

Additional Information

When an injury does occur, you only have to report to Cal/OSHA for “serious” injuries, as well as filling out the OSHA 300 log, just as you would with any other injury that occurs.

Make EHS Well-being a Priority 

Remember, a safer workplace is not just about preventing workplace violence – it’s also about nurturing the mental well-being of those who work tirelessly to keep everyone safe. Encourage your organization to adopt practices that support both the physical and emotional aspects of workplace safety, ensuring a more resilient and sustainable work culture for everyone involved.

Learn how Antea Group can help lighten the load for your EHS team with our Health & Safety (EHS) Consulting.

DGE Group’s Finnish experts analyzed the legal application of the Corporate Sustainability Reporting Directive (CSRD) throughout 2023 and followed the steps taken throughout the process. In this article, we provide a case example of the legislative implementation process in our native country and delve into the knowns and unknowns of the CSRD and its national implementation in Finland and beyond.

A full on-demand webinar on CSRD in practice is also available here.

The Scope of the CSRD within the EU 

In 2025, companies must first report their sustainability data under the new obligations for the financial year of 2024. In this first wave, CSRD will apply to those large companies that were already subject to its predecessor, the NFRD (Non-Financial Reporting Directive). The scope of the applicability covers the companies with an average of more than 500 employees, and companies, whose securities are listed on a regulated market, such as companies listed on the stock exchange. In addition, credit institutions and insurance companies employing more than 500 people must report their data in 2025.

From 2026, companies that meet the criteria for large companies as defined in the Accounting Directive 2013/34/EU will be subject to the reporting obligation. At the time the CSRD was adopted, this covered companies that exceeded two of the following three thresholds:

More than 250 employees40 million EUR in net turnover20 million EUR in balance sheet

However, in October 2023, the EU Commission adopted an initiative that will increase the balance sheet and net turnover thresholds by 25%. The increase is based on the EU Commission’s obligation to review the thresholds and amend them, if necessary, to adjust for inflation effects. In the future, the above-mentioned thresholds for a large company will be:

More than 250 employees50 million EUR in net turnover25 million EUR in balance sheet

The delegated directive based on the initiative was published in the Official Journal of the European Union on the 21 December 2024 and the amendments must be transposed in the member states by 24 December 2024 at the latest. This increase will reduce the number of companies covered by the CSRD, and several respondents in the Expert Group that Commission consulted for the amendment, opposed this adjustment as it would weaken the ambition of the CSRD, especially regarding the new threshold for large companies.

Finland – ahead of the curve as an example

In many ways, the CSRD and its application in EU countries is still very much a living process. Countries can adapt the directive into national legislation as they see fit, but the CSRD sets the minimum standard for ESG reporting within the EU. The ongoing changes and amendments mentioned above create an extra layer of complexity for the national application of the directive.

Finland is in many ways slightly ahead of the curve in its national application, but many questions, responsibilities and sanction mechanisms remain unclear. EU countries must bring the CSRD provisions into force by the 6th of July 2024 at the latest. In Finland the provisions related to the CSRD entered into force on the 31st of December 2023.

The complexity of the implementation process is reflected in the national adaptation process with different EU countries being at very different stages. EU Directives are not directly applicable legislation in the member states, and they must be transposed into the national legislation separately.

As a preface, it is important to note that there isn’t a separate Sustainability Reporting Act in Finland, and the requirements established by the CSRD can be found in several different Acts and Decrees, mainly in the amended Accounting and Auditing Acts. The preparation of the regulations in Finland has been conducted by the Ministry of Economic Affairs and Employment, and the national implementation was achieved by amending already existing acts – which may or may not have impacted the speed with which CSRD was adopted.

For the most part, Finland has implemented CSRD under the minimum conditions. However, the CSRD allows for an extended scope of application on a national level. Finland has decided to widen the scope of the application with large co-operatives and large pension providers added to the directive’s scope. With the extended scope, approximately 1300 companies in Finland need to report their sustainability data according to the ESRS – the European Sustainability Reporting Standards.

The Directive provides member states the opportunity to require the companies to make the report available to the company’s own website, and Finland has used this option. According to the new legislation in Finland, the annual report, including the sustainability report, as well as the financial statement, must be available to the public, free of charge on the company’s website.

The supervisory aspects of the CSRD are still in many ways a work-in-process. According to the directive, the European Securities and Markets Authority ESMA will issue guidelines on the supervision of sustainability reporting. ESMA expects to publish the final guidelines in Q3 of 2024. In Finland the sustainability reporting of listed companies, credit institutions, insurance companies and pension providers is monitored by the Financial Supervisory Authority. Large companies, that are not listed, seem to be – at this point – excluded from this supervision.

Each Member State must ensure that the undertaking’s administrative, management and supervisory bodies have collective responsibility for reporting. In Finland the board of the company and the managing director have this responsibility and they may be liable for damages caused to the company.

The member states must ensure that there are effective, proportionate, and dissuasive penalties applicable to possible infringements. In Finland the sanctions are at this point administrative and include fines, late-filing fees and other sanctions that can be imposed by the Financial Supervisory Authority. During the legislative implementation process, criminal liability (sustainability reporting crime) was considered, but the content requirements for sustainability reporting were not considered to be precise enough.

In addition to the administrative sanctions that companies can be directly subjected to, new administrative sanctions for sustainability auditing companies were laid down.

Push and pull – The future of the directive amidst political shifts 

While the application of CSRD into the Finnish regulatory framework has already started, there has been a somewhat radical shift in Finnish politics, which, in turn, might have broader implications. As of early February, Finland plans to pull its support for the Corporate Sustainability Due Diligence Directive, joining Germany in its intent to abstain from a Council vote. Finland’s argument for pulling its support was that aspects of the proposal would be incompatible with Finnish legislation and aspects of civil liability. This is certainly an example of how the future of sustainability-related legislation may end up in the crosshairs of political power struggles.

Even though the CSRD and CSDDD are different directives with different goals, they overlap in many areas, especially with the CSDDD also supporting the CSRD in setting due diligence standards for the information reported under the latter. The CSRD aims to add transparency and disclosure requirements to corporate activities, while the CSDDD has a very concrete goal of making sure that companies take real actions to reduce, mitigate or stop the harmful impacts their operations might have. The CSDDD has a stronger focus on the supplier base and its extended scope would therefore reach beyond the EU, whilst the CSRD is in many ways EU-centric.

Without concrete and concise supervision mechanisms and sanctions, there’s a risk of the directive and its purpose being watered down. As such, it is important for consultants to have a responsive and analytical approach towards the adaptation process and to be open about the uncertainties included in the process. 

At this point, it remains to be seen if the administrative sanctions are effective enough in the practical application of the reporting requirements. It seems likely that the public relations’ and stakeholder effects rising from the publication requirements, will have a greater impact on the sustainability standards of companies than the administrative sanctions, which – at this point – are not particularly significant.

The evolution of the CSRD represents a significant step in the EU’s commitment to sustainability and corporate responsibility. As we have seen in Finland’s case, the directive’s implementation is a complex but crucial process that requires careful balancing of regulatory demands with the operational realities of businesses.

In Conclusion

Looking ahead, the true measure of the Directive’s impact will be observed in how it influences corporate behavior towards more sustainable practices and transparent reporting. It is essential for companies to not only comply with the technical requirements but to embrace the spirit of the directive, fostering a culture of sustainability that goes beyond mere compliance.

This cultural shift, coupled with the evolving regulatory landscape, will play a pivotal role in shaping the future of corporate sustainability in the EU. By staying adaptable and proactive, companies can turn the challenges presented by the CSRD into opportunities for innovation, growth, and positive societal impact. Ultimately, the success of the CSRD will be judged by the tangible improvements it brings about in environmental and social governance, potentially setting a new benchmark for corporate responsibility globally.

Check out how our consultants can help with your global sustainability reporting needs including CSRD.

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