Background Overview: Background Sustainability and CSR International frameworks: guides for global business Benefits for companies CSR national Overview: CSR national National CSR Forum CSR Policies in Germany CSR international Overview: CSR international The EU's CSR policy CSR: the global dimension
NAP Overview: NAP About the NAP Overview: About the NAP Objectives Development of the Action Plan Four action areas of the NAP Original version of the NAP Monitoring UN Guiding Principles NAP International Commitment of the Federal Government Overview: Commitment of the Federal Government The state's duty to protect Activities of the Federal Government Cooperation with stakeholders Corporate due diligence Overview: Corporate due diligence Federal Government expectations Five core elements of due diligence Access to remedy and remediation Supply Chain Act Overview: Supply Chain Act Background and development Implementation by enterprises FAQ Europe Overview: Europe EU supply chain law initiative EU regulation on conflict minerals EU Timber Regulation EU Forced Labour Regulation G7-Presidency 2022 Implementation support Overview: Implementation support Sector dialogues Overview: Sector dialogues Automotive Industry Energy Sector Dialogue About the dialogues Setting up the dialogues Cross-sector conferences and online seminars Information, advice, training and networks Overview: Information, advice, training and networks Information and advice Networks and training Guidance documents Overview: Guidance documents General guidance documents Sector-specific guidance documents #FairSupplyChains dialogues
CSR Background CSR national CSR international Business & Human Rights NAP About the NAP Commitment of the Federal Government Corporate due diligence Supply Chain Act Europe Implementation support Sector dialogues Information, advice, training and networks Guidance documents

Risk prevention in the construction and operation of energy infrastructure

The energy sector will commission large volumes of construction projects in the near future. This includes, for example, new energy generation plants, the expansion and renewal of electricity and gas transmission and distribution networks, energy storage facilities as well as heating networks.

Depending on the type of project, activity, and degree of subcontracting, specific human rights risks may arise on construction sites. In addition to occupational health and safety risks, these include precarious working conditions, low wages, lack of access to social security systems and discrimination. This particularly affects migrant workers, such as posted workers. The German Institute for Human Rights writes that networks and structures for the systematic exploitation of posted workers are on the rise (Human Rights Report 2024). The German government developed the National Action Plan against Labor Exploitation and Forced Labor to address these issues.

Against this backdrop, a working group of the Energy Sector Dialogue has been specifically addressing the topic of labour conditions in the construction of energy infrastructure since January 2024.

The aim is to develop effective preventive measures, apply them in corporate contexts, and enable mutual learning. Coordinated by the secretariat of the sector dialogue, the working group approaches relevant stakeholders, establishes networks, and lays foundations for partnership-based cooperation along the supply chain.

In-depth risk assessment

The working group began by developing an in-depth understanding of the causes of labor exploitation, of the current state of knowledge on the actual prevalence of the risk, and of possible approaches to risk prevention. To this end, experts from academia, advisory services, and labour inspectorates were consulted.

Development of effective measures

In consultation with the respective specialist departments of the participating companies and with the support of experts on corporate due diligence, a toolbox containing 13 interrelated measures was developed. The objective was to enable each company to address the issue in its own way. The toolbox is supplemented by three guidelines as well as training material for awareness-raising.

Individual implementation and peer-learning

Since October 2024, the members of the Energy Sector Dialogue have been implementing selected measures individually and jointly, accompanied by peer learning formats. They compiled knowledge on specific risk factors according to construction project types, developed training materials for internal awareness-raising, worked out possibilities for individual information campaigns, and discussed opportunities for joint exchange with partners in the supply chain.

In cooperation with the Dutch International RBC Agreement for the Renewable Energy Sector, a networking event was organized in Brussels. Through general outreach and dissemination of results, contact with other industries with similar challenges, such as public transport or telecommunications, was intensified.

Achievements

The members of the sector dialogue have incorporated their experiences from implementing the measures into a slide deck “Creating decent working conditions.” It summarizes the key findings of relevant studies and reports on the situation of migrant workers on European construction sites, highlights the relevance of the issue for the energy industry, and describes thirteen measures.

Including key questions guiding implementation and a description of the intended impact, these measures are intended to support the development and introduction of effective and efficient due diligence measures at individual businesses, as well as to monitor their implementation. The slide deck is aimed at decision-makers and actors in corporate sustainability, purchasing, and compliance divisions.

Interested companies can use the slide deck for their own risk assessment and use the measures described as a framework for their own processes and activities.

Download

The toolbox and the supplementary training material (available only in German) can be downloaded here:

The fact sheet below provides information on the measures to be prepared and implemented by the working group in 2024 and 2025:

Further Information