This article first appeared in The Edge Malaysia Weekly on January 19, 2026 - January 25, 2026

Early last year, Carlsberg Brewery Malaysia Bhd (KL:CARLSBG) developed a Brand Promoter Agency Accreditation process, aimed at preventing exploitation and raising awareness of brand promoters’ rights. This was followed by a Supplier Day in December, during which the company introduced a Human & Labour Rights Starter Kit and Self-Assessment Framework for its suppliers.

These actions formed part of Carlsberg Malaysia’s commitment to extending its sustainability agenda beyond decarbonisation. Last year, the company engaged KPMG Malaysia to conduct a human and labour rights risk assessment of its manpower-related suppliers and to identify gaps that need to be addressed.

“When we talk about sustainability upstream, it’s about the way of brewing, packaging and the way we sell; thus, we look into ways of responsible marketing and drinking. When we look at the downstream, we decided to focus on responsible sourcing, both on the environmental and human rights aspects. That means managing our suppliers’ way of sourcing and operating,” says Pearl Lai, Carlsberg Malaysia’s corporate affairs and sustainability director.

The first Supplier Day, held in 2024, focused on responsible sourcing. In 2025, human and labour rights were chosen as the theme for the second Supplier Day. This was timely, given the launch of Malaysia’s National Action Plan on Business and Human Rights 2025-2030 in August.

“Our focus is truly to uphold the human rights standard across the value chain. As long as they are in our value chain, we believe they should be in scope as well,” says Choy Yen Li, director of people and culture at Carlsberg Malaysia.

Carlsberg Malaysia developed an action plan following the risk assessment by KPMG, and began engaging suppliers regarding the findings last year. This was a task that involved many people in the company, including those from the legal, human resources and supply chain departments.

“It’s very commendable that some of the suppliers have already integrated human rights practices into their daily operations. We also found some common improvement opportunities. It’s a partnership between Carlsberg and the suppliers when it comes to upholding the human rights standards … That’s how we can work to ensure it is upheld throughout the value chain,” says Choy.

Carlsberg Malaysia’s manpower suppliers include part-time brand promoters at supermarkets, brand ambassadors at concerts and events, as well as security officers, cleaners and supply chain contractors.

Some of these individuals are exposed to situations that could put them in danger, and therefore, it is essential that safeguards are put in place and they know their rights. This is especially apparent in the Brand Promoter Accreditation process and the Brand Promoter Manual.

Among other requirements, the brand promoters in Malaysia must be 21 years old and above, and the agencies must conduct onboarding training for them.

“They need to be aware of their rights, especially when it comes to the area of harassment and bullying. They could be at the supermarket or restaurants promoting our products … We say very clearly that if they sense or experience any form of danger or risk of harassment, they should leave the venue immediately, and they always have their supervisors to support them,” says Choy.

There is also a grievance mechanism, where the promoters can report harassment. 

Carlsberg Malaysia already has a Human Rights Policy, Code of Ethics and Conduct, Group Supplier and Licensee Code of Conduct, as well as a Speak Up Manual to provide confidential channels for reporting violations. It also conducts due diligence before renewing contracts with its suppliers or engaging their services.

The new Starter Kit and Self-Assessment Framework complement these resources and are designed specifically to guide suppliers towards best practices in human and labour rights.

“These tools were developed based on international standards, like those of the International Labour Organisation, our local laws, including those governing workers’ minimum standards of housing and amenities, and the Carlsberg Group Human and Labour Rights Policy,” says Choy.

The Self-Assessment Framework is a set of 15 questions that gauges the supplier’s current level of readiness for adopting these standards, and covers areas including wages, working hours, health and safety and grievance mechanisms.

“With that, we can assess if they are meeting or exceeding the standards, and what are the areas we can further support our suppliers on,” says Choy.

The Starter Kit, meanwhile, comprises a set of templates and checklists for suppliers. These cover accommodation inspections, training, grievance logs, recruitment agency due diligence, disciplinary frameworks and other key human rights requirements, including compliance with the Workers’ Minimum Standards of Housing, Accommodations and Amenities Act 1990 (Act 446).

“After the assessment, we found some opportunities for suppliers to improve in terms of workers’ accommodation, and I must commend some of them for taking immediate action to improve it,” says Choy.

These tools are not mandated to be used by the suppliers. Rather, they are guidelines or reference points for them.

Getting suppliers, especially small and medium enterprises, to be on board with this agenda can be difficult, as they are not mandated to do so. Lai acknowledges this challenge, but shares that their suppliers have been very supportive so far. More than 60 people — including directors and decision makers — from 29 of Carlsberg Malaysia’s suppliers attended its Supplier Day in December.

Lai and Choy stress that it’s important to share knowledge and resources with the suppliers, for example, giving them the right tools and recognition where it is due. During the Supplier Day event, they also invited KPMG to share best practices.

“It’s like a free consultation session, which the suppliers appreciated, and there were a lot of questions asked. They were very open about the challenges they face,” says Lai.

Some of the common challenges include meeting requirements for workers’ accommodations. Others relate to establishing grievance mechanisms and disciplinary standard operating procedures, which also cover employee misconduct.

“It’s a long journey together with our suppliers. In the end, our ambition is really to build a supply chain that sets the benchmark for ethical, sustainable and responsible business, and that can only happen through a strong partnership with our suppliers,” says Choy.

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