Description
Human rights education is the teaching of the history, theory, and law of human rights in schools and educational institutions, as well as outreach to the general public.
A Guide for Integrating Human Rights
into Business Management
BUSINESS LEADERS INITIATIVE ON HUMAN RIGHTS
www.respecteurope.com www.realizingrights.org
2
Business Leaders
Initiative on
Human Rights
United Nations
Global Compact
and
the Offce of the
High Commissioner
for Human Rights
Disclaimer
The views expressed in this publica-
tion do not necessarily represent
the views of the Global Compact
Offce or the Offce of the High
Commissioner for Human Rights or
any of the individual companies
participating in BLIHR or whose
case examples are included. More-
over, the Global Compact Offce
and the OHCHR make no repre-
sentation concerning, and do not
guarantee, the source, originality,
accuracy, completeness or reli-
ability of any statement, informa-
tion, data, fnding, interpretation,
advice or opinion contained within
the publication. The publication is
intended as a learning document.
The inclusion of examples of com-
pany experiences does not in any
way constitute an endorsement of
the individual companies nor their
human rights policies or practices
by the Global Compact Offce and/
or the OHCHR.
photo credits page 4/ from left to right:
all photos © istockphoto.com except for
numbers 1 and 5, © United Nations Capi-
tal Development Fund/Roger Adams
Preface
Introduction
Getting Started
1 Strategy
2 Policy
3 Processes and
Procedures
4 Communications
5 Training
6 Measuring Impact
and Auditing
7 Reporting
Conclusion
Appendices
add photo captions
Contents
3
A growing number of companies are becom-
ing aware of the contribution they can make to
advancing human rights within their spheres of
infuence and the benefts such an approach can
have for their businesses. While human rights
continue to be the primary responsibility of govern-
ments, companies can do a lot within the context
of their own business to support and respect the
observance of human rights. Being proactive on
human rights can make good business sense, as
well as being the right thing to do.
This publication, a joint product of the Business
Leaders Initiative on Human Rights (BLIHR), the
United Nations Global Compact Offce, and the
Offce of the High Commissioner for Human Rights
(OHCHR), offers practical guidance to companies
that want to take a proactive approach to hu-
man rights within their business operations. It is
principally for business leaders and managers in
large and medium-sized enterprises, private and
state-owned, who would like to develop their un-
derstanding of human rights in business practice.
What is the Business Leaders Initiative on
Human Rights?
The Business Leaders Initiative on Human Rights
(BLIHR) is a business-led program that is developing
practical tools and methodologies for applying hu-
man rights principles and standards across a range
of business sectors, issues, and geographical loca-
tions. The ten member companies of BLIHR took the
lead in this Guide’s development, in which they share
some of their experiences and lessons they have
learned. For more information, see www.blihr.org
What is the United Nations Global Compact Offce?
The United Nations (UN) Global Compact is the
UN’s voluntary corporate citizenship initiative based
on ten universal principles in the areas of hu-
man rights, labor standards, the environment and
anti-corruption (see the Appendices). It has been
endorsed by all 191 Heads of State and Govern-
ments of the United Nations and has further been
legitimized through a consensus resolution by the
General Assembly. The frst two principles of the
Global Compact are derived from the Universal Dec-
laration of Human Rights, which is the foundational
framework of the international human rights system.
• Business should support and respect the pro-
tection of international human rights; and
• Business must not be complicit in abuses of
human rights.
The Global Compact Offce works with participants
and other stakeholders to provide support, commu-
nications, governance, and programs related to the
Global Compact initiative and principles. For more
information, see www.unglobalcompact.org
What is the Offce of the High Commissioner
for Human Rights?
The Offce of the High Commissioner for Human
Rights (OHCHR) is an important branch of the UN
human rights structure. The current High Com-
missioner, Louise Arbour, is responsible to the UN
Secretary General for encouraging the international
community and nation states to uphold universal
human rights standards. The Offce seeks to work
with an ever wider range of participants, including
the private sector, to promote respect for and com-
mitment to human rights as widely as possible.
For more information, see www.ohchr.org
Why we chose to produce this Guide
Human rights is one of the most challenging areas
of corporate responsibility for companies to ad-
dress; more human rights tools and guidance are
needed. This Guide is intended to help meet this
need and, in doing so, help companies make hu-
man rights a successful part of their business.
Preface
4 lNTRODUCTlON
Introduction
Human rights are the basic rights of each human
being, independent of race, sex, religion, political
opinion, social status, or any other characteristic.
Through international human rights conventions,
governments commit to respect, protect, promote
and fulfll the human rights of their citizens and
other individuals within and beyond their borders.
A list of the human rights contained in the Universal
Declaration, the International Covenant on Civil and
Political Rights, and the International Covenant on
Economic, Social and Cultural Rights – the three
fundamental United Nations agreements on human
rights – is included in the Appendices to this Guide.
Businesses should also be aware of the core con-
ventions of the International Labour Organisation. In
addition, a specifc body of law applies in situations
of armed conficts: international humanitarian law.
Its rules have two aims: frst, protecting people who
are not or no longer taking part in hostilities and,
secondly, regulating means and methods of warfare.
At this time in history, there are compelling reasons
why businesses should involve human rights in
their policies and practices. Businesses increasingly
need a stable international environment in which
to operate, with sustainable markets and a “level
playing feld” of opportunities. Human rights offer
a common framework for businesses to under-
stand societies’ expectations and deliver value to
stakeholders in a more sustainable way. This Guide
demonstrates that, in a business context, advancing
human rights is as much about realizing new op-
portunities and managing risk as it is about meeting
essential global standards.
For business, human rights provide a universal
benchmark for minimum standards of behavior.
Many national laws and regulations have evolved as
a result of a State’s obligation to implement human
rights standards. Business must, of course, observe
such laws in all countries and jurisdictions in which
they operate.
The debate about the nature and scope of com-
panies’ human rights responsibilities is a relatively
recent one, as is the idea of applying human rights
to business decisions and operations. A number
of international efforts have been undertaken to
elaborate on the content of human rights relevant
to business. One of the most comprehensive efforts
resulted in the “Draft Norms on the Responsibilities
of Transnational Corporations and Other Business
Enterprises with Regard to Human Rights” (Draft
Norms), developed by a United Nations expert
group, the UN Sub-Commission on the Promotion
and Protection of Human Rights. While the Draft
Norms have no formal legal status, the inter-gov-
ernmental UN Commission on Human Rights has
observed that they have useful elements. Many of
the companies that have contributed to this Guide,
especially the companies involved in BLIHR, agree
that the content of the Draft Norms provides a help-
ful framework for human rights in business.
5 lNTRODUCTlON
Vision
Empowerment
Leadership
Resources
Policies
Strategy
Processes
Innovation
Impact on
People
Impact on
Value
Chain Impact
on Society
Reporting
e
n
a
b
l
e
r
s
r
e
s
u
l
t
s
Global Compact
Performance Model
Structure
This Guide is based on a conventional management
system. It follows the Global Compact Performance
Model, which is a map for responsible corporate citi-
zenship. The model allows business to implement the
Global Compact principles without undermining their
other business goals. The Performance Model was
built on practical experience, identifying methods
that actual companies followed to mainstream the
Global Compact principles into their own business
operations and activities. More information about
implementing the Performance Model in practice
is available on the Global Compact website (www.
unglobalcompact.org) and in the publication entitled
Raising the Bar: Creating Value with the United Na-
tions Global Compact, listed in the Appendices.
This Guide is intended to be a technical manual and a
hands-on toolkit to help any company integrate prac-
tices consistent with human rights standards into an
existing management system. It is made up of seven
elements common to most management systems:
Strategy, Policy, Processes and Procedure, Communi-
cations, Training, Measuring Impact and Auditing, and
Reporting. The Getting Started section identifes the
initial steps a company should take to implement the
performance model, and in the Appendices at the end
of the Guide you will fnd tools and resources which
the BLIHR companies have found to be helpful in
bringing human rights into their businesses.
The examples in this Guide illustrate how aspects of
the model have been implemented and are designed
to inspire other businesses. The human rights
processes and procedures included in this Guide are
ongoing projects for the companies concerned.
There is much still to learn. We welcome com-
ments on the content of this Guide as we seek to
constantly improve the business and human rights
tools available to companies.
6
Getting Started
understanding human rights in a business context
Human rights in your business: getting started
1 Develop the business case for human rights
2 Familiarize yourself with the broad content of human rights and the
available resources
3 Understand the implications of the frst two principles of the Global Compact
4 Develop and encourage a rights-aware approach to your business
1. Develop the business
case for human rights
There is a strong moral and ethical case to support
the notion that business entities should integrate
human rights principles into their business practices
within their sphere of infuence. The concept of
businesses as a ‘force for good’ and as a powerful
actor in economic, environmental and social devel-
opment has been strengthened in recent years.
In terms of the ‘business case’ for human rights,
although the precise logic can vary between each
business sector and country of operation, the fol-
lowing main benefts have been identifed:
• Improved stakeholder relations
• Improved employee recruitment,
retention, and motivation
• Improved risk assessment and
management
• Reduced risk of consumer protests
• Enhanced corporate reputation
and brand image
• A more secure license to operate
• Strengthened shareholder confdence
• More sustainable business relationships
with governments, business partners, trade
unions, sub-contractors and suppliers.
Human rights can be a way of identifying new busi-
ness opportunities; sometimes what might be frst
perceived as a risk to a business can be converted
into an asset. The Human Rights Matrix, introduced
in the Strategy section of this report, is a good way
to map both risks and opportunities and the man-
agement approaches that can link the two.
In addition to the business case for human rights,
there are also important strategic reasons for busi-
ness to take a long-term interest in good governance
and a stable social environment in places where
they do business. There are many good resources on
the business and strategic case for human rights; a
selection is listed in the Appendices to this Guide.
GETTlNG STARTED
7
Getting Started
understanding human rights in a business context
2. familiarize yourself with the broaD content of human
rights anD the available resources
Which human rights are relevant to business?
The short answer is: all human rights are relevant.
Businesses should look frst at what is often
referred to as the “International Bill of Human
Rights” made up of three international agreements:
• The Universal Declaration of Human Rights
• The International Covenant on Civil and
Political Rights
• The International Covenant on Economic,
Social and Cultural Rights
A short description of the rights contained in
these documents is included in the Appendices
to this report.
A business should consider the full range of civil,
political, economic, social, and cultural rights
when examining the impact of its operations
(see Sphere of infuence overleaf). In addition, in
situations of armed confict businesses should be
aware of the rules of international humanitarian
law, in particular those contained in the Geneva
Conventions of 1949 and their Additional
Protocols of 1977.
The Business Leaders Initiative on Human Rights
has developed a Human Rights Matrix which
follows the Universal Declaration of Human Rights
and other international agreements. The categories
in the Matrix are those developed in the Draft
Norms; the content covers the following areas:
A General Obligations
B Right to equal opportunity and non-discrimi-
natory treatment
C Right to security in persons
D Rights of workers
E Respect for national sovereignty and human
rights
F Obligations with regard to consumer protec-
tion
G Obligations with regard to environmental
protection
H General provisions of implementation
The full content of the Matrix and explanatory
notes on the Draft Norms are available at www.
blihr.org and www.ohchr.org respectively. A longer
list of resources is included in the Appendices.
GETTlNG STARTED
8
3. unDerstanD the implications of the first two principles
of the global compact The frst two principles of the Global Compact call on businesses
to support and respect the protection of international human rights within their ‘sphere of infuence’ and to
make sure they are not complicit in human rights abuses. The two concepts of ‘sphere of infuence’ and
‘avoiding complicity’ are very useful when trying to decide what your business can do, and what tools are
needed, to ensure human rights consistent policies and practices in a business context.
Sphere of infuence
“ While the concept [of sphere
of infuence] is not defned in
detail by international human
rights standards, it will tend to
include the individuals to whom
the company has a certain
political, contractual, economic
or geographic proximity. Every
company, both large and small,
has a sphere of infuence,
though obviously the larger or
more strategically signifcant
the company, the larger the
company’s sphere of infuence
is likely to be.” (“The Global
Compact and Human Rights: Un-
derstanding Sphere of Infuence
and Complicity: OHCHR Briefng
Paper,” in ‘Embedding Human
Rights in Business Practice’
– listed in the Appendices.)
Understanding a company’s
sphere of infuence can be
accomplished by mapping the
stakeholder groups affected
by a business’ operations. A
key stakeholder group that
will normally lie at the center
of any company’s sphere of
infuence will be employees.
Other groups, such as business
partners, suppliers, trade
unions, local communities, and
customers will follow. The fnal
group will usually be govern-
ment and the wider society.
#OMPANY
#ONTRACTORS #OMMUNITY 3OCIETY
Fig: This diagram is developed from the publication: Business as Partners in Development: Creating wealth
for countries, companies and communities, Jane Nelson/The Prince of Wales International Business Leaders
Forum, in collaboration with The World Bank and The U.N. Development Programme, London: 1996
GETTlNG STARTED
9
Avoiding complicity in human rights abuses
“A company is complicit in hu-
man rights abuses if it autho-
rises, tolerates, or knowingly
ignores human rights abuses
committed by an entity associ-
ated with it, or if the company
knowingly provides practical
assistance or encouragement
that has a substantial effect
on the perpetration of human
rights abuse. The participation
of the company need not actu-
ally cause the abuse. Rather
the company’s assistance or
encouragement has to be to
a degree that, without such
participation, the abuses
most probably would not have
occurred to the same extent
or in the same way.” (“The
Global Compact and Human
Rights: Understanding Sphere
of Infuence and Complicity:
OHCHR Briefng Paper,” in
‘Embedding Human Rights in
Business Practice’ – listed in
the Appendices.)
Avoiding complicity in human
rights abuses is an important
challenge for business. As the
dynamics between govern-
ments, companies, and civil
society organizations change,
so too does the understand-
ing of when and how different
organizations should take on
responsibilities for human
rights issues. Four situations
help to illustrate how the no-
tion of complicity might arise:
1 When the company actively
assists, directly or indirectly,
in human rights violations
committed by others e.g.
where a company provides
information to a government
that it knows will be used to
violate human rights;
2 When the company is in a
partnership with a govern-
ment and knows, or should
have known before agreeing
to the partnership, that the
government is likely to com-
mit abuses in carrying out
its part of the agreement e.g.
forced relocation of peoples;
3 When the company benefts
from human rights violations
even if it does not positively
assist or cause them e.g.
abuses committed by secu-
rity forces, such as the sup-
pression of a peaceful protest
against business activities
or the use of repressive
measures while guarding
company facilities; and
4 When the company is silent
or inactive in the face of sys-
tematic or continuous human
rights violations e.g. inaction
or acceptance by companies
of systematic discrimination
in employment law against
particular groups.
Where an international crime
is involved, complicity may
arise where a company
assisted in the perpetration
of the crime, the assistance
had a substantial effect on
the perpetration of the crime
and the company knew that
its acts would assist the
perpetration of the crime
even if it did not intend for
the crime to be committed.
State-owned enterprises
should be aware that
because they are part of the
state, they may have direct
responsibilities under interna-
tional human rights law.
Business risk assessment and
management tools are needed
to identify the potential for
complicity as it arises and to
develop policies and proce-
dures to ensure non-complicity.
Some of these tools are being
developed and are referred to
in this Guide.
GETTlNG STARTED
4. Develop anD encourage a
rights-aware approach to
your business Understanding the
relationship a business has with human rights
means taking a ‘rights-aware approach’ to business
practices. This allows the business to understand
challenges and dilemmas from the perspective of
other stakeholders and to better manage social risk.
It will also enable the business to choose a globally
recognized strategic framework for the full range of
its economic and social activities – the ways in which
the business can be a ‘force for good.’ Human rights
provide a universal and legitimate framework that is
applicable everywhere and to any stakeholder group.
A human rights analysis can help highlight additional
risks and opportunities for a particular project before
any technical or investment decisions are made. In
this way, a rights-aware approach can enable better-
informed business decisions.
Starting to integrate human rights into business
management requires the support of senior execu-
tives, along with a shared understanding of the
advantages a rights-aware approach offers the
business. This often means some initial invest-
ment to fully understand the nature of the risks and
opportunities that human rights present to the com-
pany. One such investment might be sourcing the
necessary expertise from outside the business or
training in human rights for key members of staff.
Many of the BLIHR companies are able to provide
examples of where such an approach has delivered
business benefts.
The ‘rights aware’ approach
The ‘rights aware’ approach
A ‘rights-aware approach’
means that a business is will-
ing to accept that its stake-
holders have universal rights
and that any decisions made
by the business should strive to
respect these. Clearly, there are
still many dilemmas and also
‘competing rights’ in which the
interests of one stakeholder
group might oppose another. A
human rights-aware approach
would mean that a business
would:
1 Identify the rights at issue,
2 Identify its responsibilities
in terms of international hu-
man rights standards, and
3 Determine the appropriate
action.
10 11 GETTlNG STARTED
11 lNTRODUCTlON
Overview of the management components outlined in this Guide
1. Human rights in STRATEGY
1.1 Find out what you are already doing
1.2 Identify risks and opportunities and then the priorities for action
1.3 Develop a human rights strategy for your business
1.4 Defne and embed appropriate management responsibilities
1.5 Integrate human rights into your company’s activities
1.6 Develop your strategy through a circle of continuous improvement
2. Human rights in POLICIES
2.1 Include human rights in your existing policies
2.2 Develop specifc human rights policies where appropriate
2.3 Develop local policies to meet local situations
2.4 Ensure full implementation of your policies and review their outcomes
3. Human rights in PROCESSES and PROCEDURES
3.1 Consider the full scope of your business activities and functions
3.2 Establish procedures for identifying your human rights-related risks and opportunities
3.3 Establish control systems for managing human rights in your business
3.4 Learn from sector-wide business initiatives
3.5 Expect the unexpected – how to react when procedures are not enough
4. Human rights in COMMUNICATIONS
4.1 Share understanding of why human rights are important to business communications
4.2 Integrate human rights into your internal communications
4.3 Integrate human rights into your external communications
5. Human rights in TRAINING
5.1 Identify target groups in your business to receive human rights training
5.2 Review the different types of training materials available
5.3 Select, organize and evaluate the training program for target groups
6. Human rights in MEASURING IMPACT AND AUDITING
6.1 Set relevant performance indicators for measuring human rights impact across the different
functions of your business
6.2 Undertake human rights based audits
6.3 Analyze the results of audits and use the results to inform the strategic development of your business
7. Human rights in REPORTING
7.1 Decide which human rights impacts are priorities for you to report on
7.2 Consider who your main target audiences are
7.3 Develop an effective reporting format
7.4 Publish this information on its own or as part of a regular business report
7.5 Submit a link/description to the Global Compact website (Global Compact participants)
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10 11 GETTlNG STARTED
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Human rights in strategy: key steps for your business
1.1 Find out what you are already doing
1.2 Identify risks and opportunities and then the priorities for action
1.3 Develop a human rights strategy for your business
1.4 Defne and embed appropriate management responsibilities
1.5 Integrate human rights into your company’s activities
1.6 Develop your strategy through a circle of continuous improvement
1.1 finD out what you are alreaDy Doing The debate on the nature and scope of
companies’ responsibilities concerning human rights may be relatively recent, but many related issues are already managed
by business through established procedures and practices. Legal requirements, negotiated agreements and policies on such
issues as data protection, wage fxing, working hours and holidays, non-discrimination, occupational health and safety, and
product safety, are all founded in human rights and form part of a company’s relationship with stakeholders.
1.2 iDentify risks anD opportunities anD then the priorities for action
It is important for a company to map its existing policies and undertake a gap analysis to establish how well human rights issues
are covered and whether additional policies are needed. A crucial part of the gap analysis is to identify human rights risks and
dilemmas facing your business operations. There are many examples of human rights dilemmas faced by businesses around the
world on a daily basis; a few are listed here, but many more are cited in the resources listed in the Appendices to this Guide.
Human rights risks and dilemmas – some examples
• Corruption: how do you operate within international
standards when there are local corrupt fnancial prac-
tices, a lack of laws, and the improper administration of
justice, leading to limited respect for human rights?
• Security: how do you obtain protection for personnel
and plant when the state security forces are known to
use excessive violence and commit other human rights
abuses against the local population?
• Discrimination: how do you reconcile the realities of
traditional work and cultural practices with your own
policies and adherence to international standards? How
do you ensure disabled workers have equal job opportu-
nities within the company?
• Privacy: how do you balance the marketing advan-
tages of registering your customer information with their
legitimate request for protection of their right to privacy?
• Rest, leisure and paid holidays: how do you keep
production costs competitive when you operate in a
country where there is no legal mandate for paid holi-
days, but you wish to follow international standards?
• Housing: do you evaluate the fnancial impact of
upgrading staff quarters to international minimum
requirements when performing a due diligence of a
factory that you plan to take over?
1 Strategy
STRATEGY STRATEGY
13
Desirable
Expected
Essential
Once risks and opportunities are identifed, the next step is
to identify human rights priorities based on these conclu-
sions. The Human Rights Matrix designed by the BLIHR
companies (see diagram overleaf) can be used to allow a
business to map what it sees as its ‘essential’, ‘expected,’
and ‘desirable’ priorities against a broad spectrum of hu-
man rights categories. It allows risks and opportunities to
be shown together and helps to identify the human rights
content of a company’s ‘sphere of infuence.’
• Essential – is the action that must be taken by the
company to follow relevant legal standards, eg interna-
tional human rights law, national laws, and regulations,
including in situations where a government is unwilling
or unable to fulfll its obligations.
• Expected – is the action which should be taken by the
company to meet the expectations of, and accept its
shared responsibilities to, relevant stakeholders. What is
expected may vary according to your business sector.
• Desirable – is the action through which the busi-
ness could demonstrate real leadership. This can take
a number of forms depending on the circumstances,
but could include partnerships with other stakeholders,
philanthropic and charitable donations or the donation of
technical expertise to help the most disadvantaged.
The pyramid (left) shows that any
human rights strategy should align
the essential, expected and
desirable actions of a company.
It makes no sense for
a business to take
desirable actions to address a human rights concern,
such as providing charitable donations, if it is not already
demonstrating its essential and expected action in the
same area.
The Human Rights Matrix is a general version for the pur-
poses of example only. Your business would need to produce
its own version drawing on all the relevant data from your
company’s activities across specifc geographic areas. A
great advantage offered by a rights-aware approach is that
the categories (shown across the column headings of the
Matrix) are universal and therefore global in application, as
are many of the international standards upon which ‘essen-
tial’ actions are based.
Additional risks emerge if dilemmas are not properly managed.
These might include negative impacts on stakeholder relations,
such as with employees, contractors, local communities, local and
national governments, and others. There might also be possible
operational disruption or a negative impact on investor confdence
and share value. There is also a risk of negative publicity, gener-
ated locally and internationally. However, if dilemmas are properly
managed, they can become opportunities for your business.
Turning risk into opportunity is a key component of a strategic
approach to human rights in business. During the initial scoping
phase, a company may also identify other opportunities to promote
human rights in the conduct of their regular business activities.
Human rights opportunities – some examples
• Positive impacts upon stakeholder relations, including with employees, contractors, trade unions, local communities,
non-governmental organizations, local and national governments and others.
• A minimization of operational disruption.
• Better opportunities for positive public relationships with society, the press, and other media
• A positive impact upon investor confdence and share value
• Improving employee morale due to good safety performance
1 Strategy
STRATEGY STRATEGY
14 lNTRODUCTlON
C3. Right to
security of persons
C4. Security
arrangements
D5. Forced or
compulsory labour
D7. Safe and
healthy workplace
D8. Adequate
remuneration
D9. Freedom of
association /
collective
bargaining
E10. Respect for
national governance
practices
E11. Bribery E12. Contribution to
realisation of human
rights
H15.
Internal rules
of operation
H16. Monitoring H17. Reparations
Public statement of
commitment to
human rights
Equal opportunities
policy
Employee self-
protection advice /
training
Criteria in contracts for
for security services
Bribery and
corruption
prevention policy
On-going studies
into the safety of
products and
services
Environment policy Code of conduct 3rd party veri?-
cation of CSR
reporting
Public statements of
commitment to ILO
Core conventions,
UDHR, OECD
guidelines, etc.
Progressive
Maternity, Adoption,
Family leave,
Harassment policies
Supplier screening /
monitoring
Global HSE guide-
lines specifying
standards,
implementation and
compliance process
Pay at least living
wage in all
countries
of operation
Establishment of
Consultative
Committees (e.g.
Health and safety)
Commitment to
political neutrality
Board Committee
with terms of refe-
rence covering
environmental and
social issues including
human rights.
Committee)
Focused diversity
initiatives/
programmes and
leadership structure
Safety management
system
Pension provision
in all countries of
operation
Letter of Assurance
process
Procurement
process assessed
Annual review of
policies
Diversity awareness/
training for
employees
Publication of
performance data
Merit-based pay
and performance
system
Board Audit and
Compliance
Committee
Goals for reduction
of energy
consumption
Support for speci?c
programmes e.g.
black empowerment
in South Africa
Training for
employees and
selected
Third Parties
Wage level
incorporated into
supplier screening
criteria
Transparent public
reporting in Annual
Report
Established risk
management process
Public reporting of
basic performance
metrics
Participation in
industry safety
forums and
initiatives
Certi?cation of
ISO14001
environmental
management
programme(s)
Chairman's award
to promote best
practice
Employee personal
accident insurance
Withdrawal from
countries where
forced labour is
prevalent
Safety working
groups
Enhanced pension
schemes
Trade union
consulted on all
business changes that
impact employees
in relevant areas
Participation in
public good
governance debate
incl. corruption
Training on
compliance /
Grey zones
Matched giving
(support employee's
charitable giving)
Supplier development
programme
Internal audits of
social and environ-
mental performance
Membership of
forums promoting
diversity, gender
balance etc.
Employee Assist
(24 hour
con?dential
help line)
Community safety
education
programmes
Share ownership
schemes
Models to meet
employee needs in
countries with dif?-
cult of?cial policies
Training programs
and work placement
for vulnerable /
excluded groups
Public safety
awareness
campaigns
Targeted products /
services for
disadvantaged
groups
HIV/AIDS awareness
and treatment
programmes
Support to
educational
programmes /
local enterprise
Corporate standards
applied within
business partnerships
and supply chain
Corporate
foundation
giving
H. General provisions of implementation
A1.
General
obligations
D. Rights of workers C.Right to security of persons
F13. Obligations
with regard to
consumer
protection
G14. Obligations
with regard to
environmental
protection
E. Respect for national sovereignty and human rights
Community
Investment strategy,
policy and program-
mes focusing on
human rights issues
Business develop-
ment / due diligence
processes
incorporate human
rights risks
B2.
Right to equal
opportunity and
non-
discriminatory
treatment
E
X
P
E
C
T
E
D
Formal
environmental
management
system(s)
E
S
S
E
N
T
I
A
L
A
R
E
A
D
E
S
I
R
A
B
L
E
Cooperation with
Human Rights
related institutions
Corporate policy
on protection
for whistle-blowing
Internal audits of
human rights
complaints
mechanisms
Offer fair and timely
compensation
A Human Rights Matrix (template version)
Public reporting,
for example
according to GRI
or other reporting
standards
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
T
H
E
S
E
S
T
A
N
D
A
R
D
S
A
R
E
N
O
T
F
I
X
E
D
A
N
D
W
I
L
L
E
V
O
L
V
E
O
V
E
R
T
I
M
E
Do not interfere
with union
activities after
hours and
cooperate with
union and workers
to participate in
union business
during working
hours
Refrain from
exerting any
inappropriate
in?uence that
might jeopardize
the independence
of the union
Avoid actions
which may
undermine the
union’s credibility
with members
D6. Childrens’
rights
Train managers to
ensure they are
able to detect
different forms of
forced labour
Rigorously
inspect work
facilities to
ensure that
premises are free
from all forms of
forced labour
Rigorously
inspect suppliers’
facilities to
ensure that
premises are free
from all forms of
forced labour
Develop
understanding from
standards such as
the Voluntary
Principles on
Security and Human
Rights on how to
best manage
relations with
security staff and
engage in training of
relevant staff on the
protection of human
rights.
Work with the
local police
(public) or security
service providers
(private) in
advance of a
project to develop
a common
understanding and
agreement to
protect human
rights in the event
of a dangerous
situation requiring
intervention.
Carry out a risk
assessment study
of the home and
host countries
and of actors in
the supply chains
in both countries.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Public reporting,
for example
according to GRI or
other reporting
andards.
A Human Rights Matrix
15 lNTRODUCTlON
C3. Right to
security of persons
C4. Security
arrangements
D5. Forced or
compulsory labour
D7. Safe and
healthy workplace
D8. Adequate
remuneration
D9. Freedom of
association /
collective
bargaining
E10. Respect for
national governance
practices
E11. Bribery E12. Contribution to
realisation of human
rights
H15.
Internal rules
of operation
H16. Monitoring H17. Reparations
Public statement of
commitment to
human rights
Equal opportunities
policy
Employee self-
protection advice /
training
Criteria in contracts for
for security services
Bribery and
corruption
prevention policy
On-going studies
into the safety of
products and
services
Environment policy Code of conduct 3rd party veri?-
cation of CSR
reporting
Public statements of
commitment to ILO
Core conventions,
UDHR, OECD
guidelines, etc.
Progressive
Maternity, Adoption,
Family leave,
Harassment policies
Supplier screening /
monitoring
Global HSE guide-
lines specifying
standards,
implementation and
compliance process
Pay at least living
wage in all
countries
of operation
Establishment of
Consultative
Committees (e.g.
Health and safety)
Commitment to
political neutrality
Board Committee
with terms of refe-
rence covering
environmental and
social issues including
human rights.
Committee)
Focused diversity
initiatives/
programmes and
leadership structure
Safety management
system
Pension provision
in all countries of
operation
Letter of Assurance
process
Procurement
process assessed
Annual review of
policies
Diversity awareness/
training for
employees
Publication of
performance data
Merit-based pay
and performance
system
Board Audit and
Compliance
Committee
Goals for reduction
of energy
consumption
Support for speci?c
programmes e.g.
black empowerment
in South Africa
Training for
employees and
selected
Third Parties
Wage level
incorporated into
supplier screening
criteria
Transparent public
reporting in Annual
Report
Established risk
management process
Public reporting of
basic performance
metrics
Participation in
industry safety
forums and
initiatives
Certi?cation of
ISO14001
environmental
management
programme(s)
Chairman's award
to promote best
practice
Employee personal
accident insurance
Withdrawal from
countries where
forced labour is
prevalent
Safety working
groups
Enhanced pension
schemes
Trade union
consulted on all
business changes that
impact employees
in relevant areas
Participation in
public good
governance debate
incl. corruption
Training on
compliance /
Grey zones
Matched giving
(support employee's
charitable giving)
Supplier development
programme
Internal audits of
social and environ-
mental performance
Membership of
forums promoting
diversity, gender
balance etc.
Employee Assist
(24 hour
con?dential
help line)
Community safety
education
programmes
Share ownership
schemes
Models to meet
employee needs in
countries with dif?-
cult of?cial policies
Training programs
and work placement
for vulnerable /
excluded groups
Public safety
awareness
campaigns
Targeted products /
services for
disadvantaged
groups
HIV/AIDS awareness
and treatment
programmes
Support to
educational
programmes /
local enterprise
Corporate standards
applied within
business partnerships
and supply chain
Corporate
foundation
giving
H. General provisions of implementation
A1.
General
obligations
D. Rights of workers C.Right to security of persons
F13. Obligations
with regard to
consumer
protection
G14. Obligations
with regard to
environmental
protection
E. Respect for national sovereignty and human rights
Community
Investment strategy,
policy and program-
mes focusing on
human rights issues
Business develop-
ment / due diligence
processes
incorporate human
rights risks
B2.
Right to equal
opportunity and
non-
discriminatory
treatment
E
X
P
E
C
T
E
D
Formal
environmental
management
system(s)
E
S
S
E
N
T
I
A
L
A
R
E
A
D
E
S
I
R
A
B
L
E
Cooperation with
Human Rights
related institutions
Corporate policy
on protection
for whistle-blowing
Internal audits of
human rights
complaints
mechanisms
Offer fair and timely
compensation
A Human Rights Matrix (template version)
Public reporting,
for example
according to GRI
or other reporting
standards
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
T
H
E
S
E
S
T
A
N
D
A
R
D
S
A
R
E
N
O
T
F
I
X
E
D
A
N
D
W
I
L
L
E
V
O
L
V
E
O
V
E
R
T
I
M
E
Do not interfere
with union
activities after
hours and
cooperate with
union and workers
to participate in
union business
during working
hours
Refrain from
exerting any
inappropriate
in?uence that
might jeopardize
the independence
of the union
Avoid actions
which may
undermine the
union’s credibility
with members
D6. Childrens’
rights
Train managers to
ensure they are
able to detect
different forms of
forced labour
Rigorously
inspect work
facilities to
ensure that
premises are free
from all forms of
forced labour
Rigorously
inspect suppliers’
facilities to
ensure that
premises are free
from all forms of
forced labour
Develop
understanding from
standards such as
the Voluntary
Principles on
Security and Human
Rights on how to
best manage
relations with
security staff and
engage in training of
relevant staff on the
protection of human
rights.
Work with the
local police
(public) or security
service providers
(private) in
advance of a
project to develop
a common
understanding and
agreement to
protect human
rights in the event
of a dangerous
situation requiring
intervention.
Carry out a risk
assessment study
of the home and
host countries
and of actors in
the supply chains
in both countries.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Public reporting,
for example
according to GRI or
other reporting
andards.
16
Identifying human rights priorities – some examples
Energy Utilities National Grid has produced
a variation of the Human Rights Matrix, which
relates the different human rights areas of the
company’s responsibilities to different stake-
holder groups such as government, business
and domestic customers, local communities,
investors, employees, and suppliers.
Pharmaceutical Sector Novartis has used a
corporate citizenship matrix containing human
rights principles to help defne the sphere of
infuence of the pharmaceutical sector as it
relates to the Access to Medicines policy and the
ethical principles of the Declaration of Helsinki
on clinical trials.
Extractive Sector Statoil has applied the
Human Rights Matrix in detail as a strategic
tool to better understand the total impact of its
activities in Venezuela.
Media and Entertainment Industry MTV
Networks Europe has applied the Human Rights
Matrix to all On-Air and Off-Air operations in the
UK and Ireland and as a result is one of the frst
media companies to develop policies based on
human rights considerations.
For more information on the above examples,
please go to www.blihr.org or visit the company
websites shown in the Appendix to this Guide.
1.4 Define anD embeD appropriate management responsibilities
A strong commitment to human rights from a company’s senior leaders is a prerequisite for embedding
human rights into a company’s operations and activities. Support from senior leaders ensures that human
rights issues are taken seriously and become part of business strategy. A number of companies have found
that having a member of the board of directors or executive management team assume overall responsibil-
ity for human rights-relevant issues has been important in ensuring that these matters receive the required
degree of attention. Clear lines of accountability have also proven to be vital. These companies typically have
a designated senior manager who is responsible for implementing the company’s human rights policies and
driving performance improvement. The senior manager generally reports to the executive level and may be
responsible for one of several possible functions / departments in the company, such as human resources,
procurement, legal affairs, public affairs, or the sustainability department.
1.3 Develop a human rights strategy for your business
Having identifed the human rights risks and opportunities, it is necessary to set out what the organiza-
tion wants to achieve (the vision) and how it intends to achieve it (the strategy). For many companies, this
will entail setting out how they will integrate human rights considerations into their existing management
systems and cover issues such as leadership, planning, defning roles and allocating resources.
STRATEGY
17
Embedding management responsibilities – some examples
Articles of Association Novo Nordisk’s Articles
of Association specify that the company will ‘strive
to conduct its activities in a fnancially, environ-
mentally and socially responsible way.’ The Novo
Nordisk commitment to sustainable development is
anchored in the company’s corporate governance
and its fundamental business principles, called the
“Novo Nordisk Way of Management.” The Novo
Nordisk Way of Management explicitly refers to the
Triple Bottom Line (TBL) — social, environmental
and fnancial responsibility — as the company’s
underlying business principle. Since 1999, the Novo
Nordisk Way of Management has included a com-
mitment to support the United Nations Universal
Declaration of Human Rights and to integrate hu-
man rights considerations into its daily business.
Board-level representation National Grid’s board
subcommittee, the Risk and Responsibility Com-
mittee, is chaired by a Non-executive Director and
has responsibility for reviewing the management
of non-fnancial issues, policies, and standards and
for reviewing the performance of the Group. Where
appropriate, this includes that of its contractors
and suppliers. The Committee’s remit includes
occupational and public safety, occupational health,
environment, inclusion and diversity, human rights,
business ethics, and community involvement.
Executive level representation ABB’s human
rights policy is embedded in its social policy and
is the responsibility of the head of the Sustain-
ability Affairs group. He reports on the economic,
environmental, and social aspects of the group’s
business activities and the human rights poli-
cies and commitments to a member of the group
executive committee who has overall responsibility
for sustainability issues. Environmental and social
policies are monitored and enforced by country
and regional sustainability controllers in the 100
countries where ABB operates.
Ethical Guidance Council Copel, whose vision
statement makes explicit its aim to “become the
best company within the Brazilian power sector
by 2006, striking a balance between the interests
of the community and of its shareholders,” has an
Ethical Guidance Council whose role is to discuss
and guide Copel’s actions, examine submitted
cases, and recommend appropriate sanctions, to
ensure that the Company’s actions are conducted
in accordance with sound principles and to over-
see the dissemination and effective application of
the Copel Code of Conduct across all sectors of
the Company. To ensure its autonomy, the Council
is made up of the Company’s employees, each
representing their respective different professional
categories, and is coordinated by a representative
of civil society.
Mainstreaming Human Rights Novartis has
developed and implemented human rights related
Corporate Citizenship Guidelines and implemented
them through line management.
Direct involvement of the Chief Executive Offcer
The Managing Director of each Tata company is also
its Principal Ethics Offcer who nominates an Ethics
Offcer and a team of Location Ethics Counsellors.
Together this team is responsible for the Management
of Business Ethics (MBE) in the company and for
ensuring compliance of the Tata Code of Conduct – a
written document.
Human Resources In January 2005, the CEO of
Valeo, an automobile company based in France,
decided that the responsibility for implementing
and monitoring the Group’s Human Rights policy
should be an integral part of the Human Resources
function. The Group Human Resources Director is
now responsible for dealing with any human rights
violations, as are the Human Resources Directors
across the Group entities.
STRATEGY
18
1.6 Develop your strategy through a circle of continuous
improvement To help ensure that implementation efforts remain on track, it is a good idea
to adopt a continuous improvement approach from the start. The plan-do-check-act circle may help in the
process of learning and improving along the way.
• Define roles and
responsibilities
• Document
• Impose
operational
control
• Measure results
• Internal audit
• Records of results
• Management
review
• Identify risks and
opportunities
• Set goals
P
L
A
N
D
O
A
C
T
C
H
E
C
K
Fig: The plan-do-check-act circle of continuous improvement with examples of activities to be undertaken in different
steps [First developed by Walter Shewhart, it was popularized by Edwards Deming.]
2 Policy
1.5 integrate human rights into your company’s activities
Particularly in large companies, integration of human rights may be a complex process that involves several
organizational levels and different types of operations in different parts of the world.
To track progress, adequate indicators and goals must be developed for different activities; internal audits can
prove key in tracking progress. The main purpose of audits is to check that the system is working according to
plan, that new issues are captured by the system, and that performance is continually improved.
Often progress on an issue across an entire company is gradual and incremental. In the meantime, imple-
mentation efforts for the company as a whole can be complemented by local strategies and special plans for
certain operations and units. These ‘bottom-up approaches’ can be developed quickly to meet the challenges a
business faces in a particular geographic location or a specifc production process.
STRATEGY
19
2 Policy
2.1 incluDe human rights in your existing policies
A policy statement sets out the direction and gives the overall goals for a company in a certain area of
activity. It should drive the management of the activity in the company and be supported by programs and
objectives throughout the organization, to ensure that the policy and related commitments are implemented
and maintained. More and more companies include human rights either as a policy in itself or as part of
other policies in the governance structure.
Human rights in policies: key steps for your business
2.1 Include human rights in your existing policies
2.2 Develop specifc human rights policies where appropriate
2.3 Develop local policies to meet local situations
2.4 Ensure full implementation of your policies and review their outcomes
Including human rights in existing policies – some examples
Barclays Barclays developed a human rights
framework in 2004 to draw together a wide
range of existing policies relevant to its human
rights impact as an employer, purchaser of goods
and services, and provider of fnancial services
to customers. Policies were mapped using the
Human Rights Matrix to ensure areas of strength
and to identify any “gaps.” The framework was
formally approved by the heads of each business
line and supports the Corporate Responsibility
Board Governance Standard, one of a series of
standards through which the Barclays Board tracks
compliance with desired business objectives and
regulatory requirements. Since adoption of the
framework, work has continued in integrating
human rights considerations into practice. For
example, Sourcing management is strengthening
existing social and environmental supplier
screening/engagement criteria to incorporate
human rights aspects more explicitly into the
assessment of sourcing proposals. While it is
paramount that contracts deliver commercial
beneft, human rights aspects can be a signifcant
factor in decision-making. From a workforce
perspective, Barclays – like many businesses – has
longstanding policies on human rights-relevant
issues including health and safety, equality and
diversity, non-discrimination, and many others. The
human rights impact of lending, however, is the
area where most dilemmas arise, as the impact is
indirect. Here, Barclays’ human rights framework
focuses on risk management and the identifcation
of social and environmental risks in assessing and
sanctioning fnancial propositions.
POLlCY
20 20 21
Checklist for a human rights policy
q Does the policy comply with existing international human rights conventions and norms, such
as the United Nations Universal Declaration of Human Rights, the International Covenant on Civil
and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the
International Labour Organization’s Declaration on Fundamental Principles and Rights at Work?
q Is the policy relevant to your company and its sphere of infuence?
q Does the policy include a commitment to respect, protect and promote human rights and to
avoid complicity in human rights abuses?
q Does the policy extend to all parts of the organization and other existing policies such as
health and safety, procurement, and human resources?
q Does the policy include your company’s expectations of its partners, joint ventures, customers,
and supply chain?
q Has consideration been given to tie in with existing codes and guidelines where appropriate,
such as the Global Compact Principles, the ILO’s Tripartite Declaration of Principles Concerning
Multinational Enterprises and Social Policy, the Organisation for Economic Co-operation and
Development’s Guidelines for Multinational Enterprises, and Social Accountability 8000 (SA
8000)? A more detailed list of existing codes and guidelines is included in the Appendices.
2.2 Develop specific human rights policies where appropriate
A good human rights policy should give consideration to the points in the checklist below:
Including human rights in existing policies – some examples
Hewlett-Packard’s Global Citizenship Policy
states its commitment to the Universal Declaration
of Human Rights and includes specifc policies
on human rights and labor, as well as employee
privacy. HP’s Global Citizenship organization
provides the governance for human rights and the
other key aspects of its commitment to corporate
citizenship.
Human Rights are integral elements of Corporate
Citizenship at Novartis. To put the Novartis
human rights responsibilities in the wider context
of a fair societal division of labor, the Novartis
Corporate Citizenship Guideline on Human Rights
is supported by a commentary.
http://www.novartis.com/corporate_citizenship/
en/guidelines.shtml
POLlCY
Getting started
20 21
Companies that have been recognized for including human rights in policies
The Business and Human Rights Resource Centre
(www.business-humanrights.org) is a valuable
resource for people interested in understanding
different perspectives of business and human
rights. It lists companies that have taken the step
of adopting a formal company policy statement
explicitly referring to human rights.
It also notes which companies are participants in
the Global Compact.
2.3 Develop local policies to meet local situations
It may be benefcial for international businesses to use local policies based on corporate standards and
national requirements. These local policies need to be translated into local languages to facilitate their under-
standing and implementation. However, local policies should not contradict the general corporate standards.
For example, in some cultures it is common practice for bribes to be sought and made, while at the interna-
tional level such practices are unlawful as well as being irreconcilable with a commitment to human rights.
Human rights embedded in local policies –
some examples of tackling national and local discrimination
Equity (South Africa) Eskom has incorporated
issues of human rights - especially those relating
to employment equity and the local social needs
of the country - into its decision-making proc-
esses. In South Africa, Eskom developed employ-
ment equity policies, performance indicators and
reward systems to ensure that the organization is
representative of the country in which it operates.
Affrmative action, gender equity and the rights of
people with disabilities are key elements. Simi-
larly, targets and performance indicators are set
for procurement practices that proactively support
and develop Black Economic Empowerment (BEE)
and, in particular, Black Woman Owned business
and small and medium sized enterprises.
Professionals with disabilities (Mexico)
Through the Mexico-based program Congru-
encia, CEMEX Mexico has developed a policy of
inclusion for workers with disabilities, intended to
enhance their job opportunities and to raise com-
munity awareness on the issue of social equity.
This program is managed through a specialized
website that provides information on vacancies
and human rights. In 2004, the program was
opened to other companies and currently involves
more than 20 public and private institutions,
which promote favorable conditions for social and
labor inclusion.
POLlCY
22 23 22 23
2.4 ensure full implementation of your policies anD
review their outcomes Group and local policies should be the overall responsibility
of identifed individuals within the business who are tasked with ensuring the policies are fully implemented.
These individuals should ensure that there are suffcient resources for implementation, the results are moni-
tored, and the policies are regularly reviewed. Even the most clearly defned policies will require interpretation.
The policy owner should act as a focal point for dealing with human rights issues that arise through imple-
mentation and should have access to both local and international expertise.
3 Processes and
Procedures
Human rights embedded in local policies –
some examples of tackling national and local discrimination
Women’s rights (Sri Lanka) MAS Holdings
(an apparel manufacturer) has a business model
that supports the empowerment of women. With
92 per cent of the total workforce of 34,000
employees in the company being made up of
women, MAS has developed best practices in
its corporate citizenship program to empower
women. The “Go Beyond” program at MAS
recruits economically less affuent, rural women
and teaches them English language skills and
how to use IT-enabled tools to advance their ca-
reers. The female employees are also trained to
manage their fnances, to have an understand-
ing of sexual and reproductive health and to
achieve a better work-life balance. The work-life
balance initiatives recognize and support the
multiple roles played by career women and the
need for a healthy balance between work and
personal life. MAS also rewards high-achievers
in academia, sports, science, commerce, and
arts and culture. Employees are encouraged to
perform better through annual awards such as
the ‘Empowered Woman of the Year Award.”
Community initiatives, especially those that im-
prove educational and healthcare infrastructure
for young women, have been a long standing
tradition at MAS. The company ensures that
its predominantly female workforce has a high
level of confdence and self-esteem. This in turn
has helped the company to grow its business
POLlCY
22 23 22 23
3 Processes and
Procedures
Human rights in processes and procedures:
key steps for your business
3.1 Consider the full scope of your business activities and functions
3.2 Establish procedures for identifying your human rights-related risks
and opportunities
3.3 Establish control systems for managing human rights in your business
3.4 Learn from sector-wide business initiatives
3.5 Expect the unexpected – how to react when procedures are not enough
3.1 consiDer the full scope of your business activities
anD functions As part of human rights policy implementation, it is crucial to defne the pro-
cesses and procedures that will make the policy a reality. The processes and procedures may differ according
to business context within the same company. However, what they will all have in common is that they are
intended to achieve the same result, are documented, and have measurable indicators and outcomes.
The executive management team of the business is responsible for ensuring that roles, responsibilities,
authority, and resources are defned and allocated in a way that enables effcient implementation and main-
tenance of human rights management in the organization.
3.2 establish proceDures for iDentifying your human
rights-relateD risks anD opportunities As already outlined
in the section on Strategy, the key to managing human rights in an organization is to analyze and
understand the risks and opportunities in a company’s operations. Ensuring compliance with legal
requirements and international treaties is essential to this analysis and should be reviewed regularly
as part of the management process.
PROCESSES AND PROCEDURES
Getting started
24 25 24 25
Human rights as an important factor in a country risk assessment – an example
Statoil has formulated country and reputation
risk guidelines to ensure the company has wide-
ranging knowledge and understanding of local
conditions, business culture, and external factors
as early as possible in a business project. The
aim is to minimize Statoil’s country and reputa-
tion risk exposure through the early identifca-
tion, prioritization, and mitigation of risks that
may affect a project or business opportunity.
Risk mitigation alternatives are specifed for
every signifcant risk factor that is identifed; the
level of detail depends on how far the project
or business opportunity has progressed. Risk
mitigation measures refect Statoil’s corporate
social responsibility strategy and its require-
ments for social investment management. Risk
assessments are performed regularly and when
signifcant events occur. The risks are divided
into 19 factors within the following categories:
• Political risk elements
• Country-specifc operational risk elements
• Reputational risk
Human rights and possible violations are impor-
tant factors within the political risk category.
The Human Rights Matrix developed by BLIHR can help companies identify risks and opportunities.
Stakeholder panels may give advice on external concerns regarding a company’s operations and may also
provide input on possible solutions. Mapping a company’s sphere of infuence may also help to identify the
risk of complicity when operating in a country with a poor record on human rights. In addition, calling for
regular checks and updates is advisable if a particular country ranks low on an index of corruption levels
for instance. Finally, input from non-governmental organizations (NGOs) and external country assessments
can provide additional value.
3.3 establish control systems for managing human
rights in your business Once risks and opportunities have been identifed for each
business operation, a company should develop and implement adequate control processes for those op-
erations. Control processes could range from a supplier qualifcation process with a mandatory risk review
of customer projects, to a code of conduct that ensures equal opportunity and minority rights, or a checklist
and instructions for business operations in sensitive areas. Guidelines for suppliers and contractual agree-
ments with customers and suppliers have proven to be powerful tools for ensuring that risks are minimized
or eliminated and opportunities are maximized.
PROCESSES AND PROCEDURES
24 25
Introduction
24 25
Human rights in different types of control systems – some examples
Identifying market opportunities National Grid
does not have extensive operations in countries that
are considered to be ‘of urgent concern’ in relation
to some aspects of human rights. The utility com-
pany has therefore focused on extending its existing
risk management by identifying and understanding
the areas where the Group might be exposed to hu-
man rights risks and opportunities when developing
new business in emerging markets. As a result, it
has revised its business development procedures
to include an analysis of human rights risks when
identifying market opportunities. It has also devel-
oped protocols to enable an analysis of potential
target companies, to assess their approach and
record on human rights issues.
Editorial practices MTV Europe is developing
a Code of Editorial Conduct, which will be one
of the frst in the industry to be based on human
rights values. The Code and its procedures for
application will be based on MTV’s understand-
ing of its spheres of infuence and would provide
internal processes for creative thinking and
decision-making. This in no way will involve
censorship; instead it will enable the company to
take better-informed risks.
Purchasing practices Gap Inc. is working
towards better human rights compliance by im-
proving supply chain operations and embedding
labor standards directly into business practices.
Ultimately, Gap believes garment manufacturers,
most of whom are multinational corporations,
must take responsibility for conditions in the
factories they own and operate. To encourage
them to take that responsibility seriously, Gap is
developing a formal tool that will enable them to
consider a garment manufacturer’s compliance
record – along with criteria such as cost, speed,
quality, and innovation – when deciding where to
place orders. At the same time, Gap recognizes
that its own business practices can have an
impact on compliance, and is actively exploring
better ways to work with its manufacturers. To
avoid contributing to excessive overtime, Gap is
making a greater effort to ensure that garment
manufacturers have accurately assessed their
capacity and capabilities before orders are
placed with them. Gap is also working to reduce
ineffcient purchasing practices such as rush
orders and last-minute changes.
Lending assessments Human rights issues
such as the rights of indigenous peoples, are
included in the Equator Principles which defne
social and environmental criteria that apply to
project fnancial transactions (see the Appendices
for details). Barclays was one of the original group
of banks to adopt the Principles in June 2003
and, while the criteria is specifc to project-related
lending, Barclays extends the “spirit” of the Prin-
ciples when assessing other types of lending.
Performance standards for resettlement The
International Finance Corporation (IFC) is in the
process of adopting a new set of performance
standards that it will require its clients to adhere
to as a condition of lending. One of the perfor-
mance standards addresses involuntary resettle-
ment – a process in which governments move
people to make way for projects in the public
interest such as roads or water treatment plants.
In preparing the new performance standard, IFC
reviewed the human rights protections in the
right to housing and incorporated those aspects
of the right to housing that the private sector can
take action on within a project context.
(continued on next page)
PROCESSES AND PROCEDURES
26 27 26 27
Human rights in different types of control systems – some examples
(continued) For example, anyone moved must
be provided with security of tenure in their new
location, even if they did not have security of
tenure in their previous location. This refects
the right to housing with emphasis on providing
everyone with security of tenure – i.e. protection
against illegal eviction. If an IFC-fnanced project
involves involuntary resettlement, the company
must prepare a detailed plan for resettlement,
including plans for providing informal settlers with
security of tenure in a new location. IFC then
reviews and approves the plan as a condition
of fnancing. As a further condition of fnanc-
ing, the client must implement the plan, monitor
and ensure that the actions taken achieve the
objectives set out in the performance standard
and the resettlement plan. If the resettlement is
suffciently large or diffcult, IFC will require an
independent third party to monitor implementa-
tion of the resettlement activities.
Scheduled and unscheduled inspections Li
& Fung (Trading) Limited, based in Hong Kong, is
a global trading group that manages the supply
chain for high-volume, time-sensitive consumer
goods – particularly garments, furnishings, gifts,
home products, toys, and sporting and travel
goods. From Hong Kong, it co-ordinates the manu-
facture of goods through a network of offces in
almost 40 countries. All suppliers to Li & Fung
are required to commit to the Code of Conduct
to Vendors, which has 14 principles, including no
child labor and non-discrimination principles. A
signed copy must be returned to Li & Fung within
30 days, and failure to give a timely response will
cause it “to review its relationship with [the sup-
plier].” The code is enforced through scheduled
and unscheduled inspections.
Managing Third Party relationships The
objective of Novartis’ Third Party Guidelines is
to provide criteria, tools, and procedures for: (1)
the assessment and approval of Third Parties;
and (2) the continuous management of business
relationships. The standards set forth in this Third
Party Guideline apply to Corporate Functions
and all Novartis Divisions and Business Units. No-
vartis Divisions and Business Units either adopt
these guidelines as is or issue an equivalent
guidance note of their own. http://www.novartis.
com/corporate_citizenship/en/guidelines.shtml
Supply chain management Human rights are a
central focus of Hewlett-Packard’s Supply Chain
Social and Environmental Responsibility (SER) Pro-
gram. One of HP’s biggest challenges is to apply
its Human Rights Policy in its supply chain, where
it does not have direct control. One way HP is
addressing this is through the Electronic Industry
Code of Conduct (EICC), which HP co-developed
with Dell, IBM, and several large contract manu-
facturers in 2004. The Code provides an important
foundation for ongoing supplier audits and other
efforts to ensure compliance with the HP Human
Rights Policy. Most importantly, it makes supplier
performance easier to audit and verify.
Gap Inc. views SA8000 as a premier set of global
labor standards towards which they hope gar-
ment manufacturers will aspire. A few of their
suppliers have already received SA8000 certi-
fcation. As a member of Social Accountability
International’s Corporate Involvement Program,
Gap Inc. recently conducted a gap analysis of
their Code of Vendor Conduct relative to the
SA8000 standard and are examining areas in
which they can bring their policies and program
into closer alignment with SA8000. In addition,
they have asked their entire internal monitoring
team to take the SA8000 auditor course.
PROCESSES AND PROCEDURES
26 27
Getting started
26 27
3.4 learn from sector-wiDe business initiatives Some business sectors already
have an interest in sharing knowledge and experiences about human rights-based processes and procedures. It is
worthwhile researching which sector-specifc groups might be available to you and which might have valuable tools for you to
adapt to your business. Some examples are shown below:
Examples of sector-specifc initiatives with expertise
in human rights codes and procedures
3.5 expect the unexpecteD – how to react when proceDures are
not enough Given the rapidly changing nature of international business, processes and procedures constantly
require adaptation and review. Sometimes unexpected events can provoke human rights issues that had not been anticipated
or prepared for. In such situations, management is best able to deal with the situation if they have the knowledge (see the
section on Training) and resources to act quickly, professionally, and in ways that provide a just solution. Clear lines of ac-
countability within business strategies and policies make such fexibility possible, as does a commitment to transparency.
Reacting when confronted with unforeseen human rights issues
An example of responsiveness to unforeseen human rights
issues is how BP responded to Amnesty International’s
2003 Report on the Baku-Tbilisi-Ceyhan oil and gas
pipeline. The report highlighted a number of human rights
concerns relating to the Host Government Agreement
signed between the consortium of companies and the gov-
ernments of Azerbaijan, Georgia, and Turkey, and the ability
of these governments to uphold future human rights com-
mitments within the region of the pipeline. BP responded
by opening a dialogue with Amnesty International over a
period of several months during 2003. The talks resulted
in a legally binding additional contract designed to protect
the rights of the three host governments to promote and
regulate human rights and environmental issues.
(This case study appears in ‘Embedding Human Rights in
Business Practice’ – listed in the Appendices)
Business Sector Relevant Initiatives
Retail • Ethical Trading Initiative
• Fair Labor Association
• Social Accountability 8000
• Clean Clothes Campaign: Model Code
Mining • The Voluntary Principles on Security and Human Rights
• Kimberley Process (indirect human rights protection)
• The Extractive Industries Transparency Initiative (indirect human rights protection)
Financial Services • The Equator Principles
Oil and Gas companies • The Voluntary Principles on Security and Human Rights
• The Extractive Industries Transparency Initiative (indirect human rights protection)
Information Technology • Electronic Industry Code of Conduct
• Global e-Sustainable Initiative (GeSI)
PROCESSES AND PROCEDURES
28 29 28 29
4.1 share unDerstanDing of why human rights are
important to business communications The act of communicating is
in itself an essential part of a human rights approach; balancing freedom of expression with the protection
of personal or private information and the participation of stakeholders is essential. Your company’s human
rights policy, procedures, and performance should be documented and communicated to employees; for
instance, through codes of business conduct. They should also be made available through the corporate
website, company publications, annual reports, and notice boards – and in local languages, where ap-
propriate. In addition, companies should encourage suppliers to publicize to their employees the obligations
they have undertaken to uphold human rights in their business relations.
4.2 integrate human rights into your internal communications
Internal communication is critical to developing an effective human rights management system. Consistent
and well-presented top-down communication within a company serves to inform about human rights within
the business strategy. Employees should be informed about human rights risks and opportunities that the
company faces in its operations. The performance indicators that are used to monitor and measure the
effciency of the human rights management system should also be communicated to all. It is particularly
important for businesses to communicate to all employees the principal drivers behind human rights based
initiatives and their relevance to the long-term strategy of the company. The latter can prevent the marginaliza-
tion of initiatives and ensure that specialized departments handling human rights issues are fully integrated
into the company. An interactive approach to internal communications may generate greater understanding
and a fow of innovative ideas and proposals on how to improve established practices and procedures.
Effcient lines of communication with employees are also needed to ensure effective non-compliance reporting
and whistle-blowing. This requires clearly defned policies and procedures on the subject and clear contact
points in the organization. Human rights issues should be communicated using simple and straightforward
terminology, translated into relevant languages, and made widely accessible, including to employees with
disabilities. It may be useful to initially address human rights issues using business terminology, since human
rights may appear overly political or legalistic and may create barriers or misunderstanding. It is key that
communications are followed up by encouraging a culture of human rights recognition and respect in the
organization; it may be necessary to develop change management strategies to best facilitate this.
Human rights in communications:
key steps for your business
4.1 Share understanding of why human rights are important to business
communications
4.2 Integrate human rights into your internal communications
4.3 Integrate human rights into your external communications
4 Communications
COMMUNlCATlONS
28 29
Getting started
28 29
Human rights in internal communication – some examples
Communicating human rights within a
company’s code of conduct to employees
Human rights is a key part of Novartis’ code of
conduct. Setting out standards of professionalism
for the day-to-day conduct of associates around
the globe, the code describes how associates
should handle themselves ethically and safely in
a variety of potentially challenging situations. An
on-line e-learning package is being developed to
help managers and associates around the world
understand the real dilemmas that might occur in
the workplace and how the code can be applied.
Any effective human rights communication should
be appealing and attractive enough to awaken
and sustain the necessary level of interest, whilst
accurately presenting key messages. For this reason,
the Novartis Foundation for Sustainable Development
provides a human rights helpdesk for the whole
company and has also developed a ‘roll-out kit’ that
is available to potential users of the code.
Human rights within a ‘balanced scorecard’
used for staff appraisals Novo Nordisk has a
number of systems to ensure that it lives up to
its commitment to corporate responsibility. Each
year, the company defnes a number of corporate
responsibility targets that are contained in the
company’s “balanced scorecard.” Staff apprais-
als and management bonuses are dependent
on performance toward these targets. Facilita-
tors, who are a group of experienced staff with
an international background from the holding
company Novo A/S, make independent assess-
ments of individual departments’ compliance to
the Novo group’s values.
Communicating with staff throughout the
workplace The accomplishments of Taj Hotels (a
prominent member of the Tata Group) in the area
of human rights are largely the result of its em-
phasis on corporate ‘values.’ The company has
different ways of communicating and reinforcing
its values in the workplace, including e-mail foot-
ers, screen savers, posters, quiz programs and
billboards. A Performance Management System is
also used by the company.
A company needs to do more than just report on its human rights approach; it should ensure that human
rights are protected in all of its communications, including data protection, personal privacy, and company
confdentiality. Companies may also be responsible for the actions of their employees while at work, such
as the use of the internet or possible e-mail abuse.
4 Communications
4.3 integrate human rights into your external commu-
nications A company’s human rights record is central to its accountability and can affect its
reputation. To be accountable to stakeholders, a company must be transparent about its policies, ap-
proach and performance. Open and transparent communications on performance and a willingness to act
constructively following external advice are keys to success. The sphere of infuence of some businesses,
such as those involved in the media and communications, may lead them to have a signifcant impact
(positive or negative) on how human rights are viewed and respected in society.
COMMUNlCATlONS
Getting started
30 31 30 31
Human rights in external communication – some examples
Human rights on the high street As a
high street retailer, The Body Shop wants
to use its windows and daily contact with
thousands of customers to raise awareness
on human rights issues. Over the years, The
Body Shop has run numerous campaigns
to support human rights causes around the
world. Currently, the company is focusing
on issues facing customers, employees,
and the communities in which the com-
pany operates with a successful campaign
to Stop Violence in the Home, as well as
raising awareness of HIV/AIDS.
Stakeholder Advisory panel Although
most scientifc evidence states that
electric and magnetic felds do not result
in adverse health impacts, National Grid
recognizes that there is some limited
scientifc evidence suggesting the
opposite, and that parts of society are
concerned about this issue.
In 2003, National Grid took the initiative
to improve the dialogue between parties
with an interest in this issue by creat-
ing a Stakeholder Forum. The Group
engaged an independent body, the UK’s
Environment Council, to set up and
facilitate a workshop to which represen-
tatives from industry, Government, aca-
demia, professional bodies, and interest
groups were invited. This brought people
with differing views to the table for the
frst time. Although there was suspicion
of why National Grid had established the
Forum, involving some of the interest
groups in the planning for the meetings
helped overcome concerns. The partici-
pants in the Forum have now agreed
to establish a more formal Stakeholder
Advisory Group under the sponsorship of
the Department of Health.
Providing the opportunity for stakehold-
ers with opposing views to voice their
concerns has proved to be extremely
benefcial, both for the broader under-
standing of relative positions on the
subject and for the development of
sensible policy in this area.
Consultation with key stakeholders
Telefónica, a global telecommunications
company, has made a name for itself in
fostering equal opportunity and support-
ing the rights of people with disabilities.
Through the “Accessible Telefonica” plan,
the company uses stakeholder dialogue
and engagement to enhance equal op-
portunities and access to its telecommu-
nications services and products.
The plan is coordinated by Telefónica’s
CSR Department and involves a number
of business lines and subsidiaries. It
has been developed through a partner-
ship and framework agreement with the
main platform that represents people
with disabilities in Spain. As part of
the plan, consumers with disabilities
participate in consultation processes,
test products and services, and give
feedback about the degree to which
their needs and expectations are met.
The plan involves a range of projects in-
cluding the development of accessible
services and products, outreach and
awareness-raising with Telefónica’s
stakeholders, labor integration and
employment policies, internal regula-
tions that promote accessibility, and
research and development.
Human rights and on-air program-
ming For MTV Networks Europe, “hu-
man rights in external communications”
is less about communicating its internal
practices to the outside world than about
human rights in action: promoting hu-
man rights on air and on the ground, in
particular to its core youth audience.
The two strongest examples are two
ongoing multi-platform MTV human
rights campaigns: MTV’s Exit Campaign
to End Exploitation and Traffcking, and
the Staying Alive HIV/Aids Campaign. Both
campaigns comprise of MTV program-
ming (MTV specials such as the traffcking
awareness and prevention documentary
“Inhuman Traffc,” hosted by Angelina
Jolie, and the Staying Alive special “Meet-
ing Mandela”), awareness and prevention
events, multi-language websites www.
mtvexit.org and www.staying-alive.org,
and support for NGOs working to fght
traffcking and HIV/AIDS.
By developing and implementing such
campaigns on issues critical to its
core audience, MTV maximizes the
promotion and realization of certain
fundamental human rights within its
key spheres of infuence.
As for internal communications, a company should ensure that
human rights are protected in all of its external communications.
For example, if local communities want to communicate with
the company through protest, the company should respect their
right to freedom of expression and should not seek to repress
demonstrations or ask governments to do so, even if the com-
pany does not agree with the message or the style of communi-
cation. In gathering and retaining information about employees,
customers, or others, companies should follow data protection
rules and respect the right to privacy. This is especially true
where companies hold sensitive health or other private informa-
tion gathered for the company’s human resources fles.
COMMUNlCATlONS
30 31
Introduction
30 31
5 Training
Human rights in training: key steps for your business
5.1 Identify target groups in your business to receive human rights training
5.2 Review the different types of training materials available
5.3 Select, organize and evaluate the training program for target groups
5.1 iDentify target groups in your business to receive
human rights training General employee training needs to provide an understand-
ing of how human rights relate to the business and must raise awareness of human rights risks and
opportunities. A needs analysis of employees at particular business sites or of those who perform specifc
functions can help identify areas which the training should cover. Case studies can support this training.
Key employees throughout the organization should receive function-specifc training; for example, training
about specifc risks in their operations and how to handle them, or training on new procedures and tools.
Target groups for training could include:
• Procurement employees
• Sales and export staff
• Human resources
• Security staff
• All supervisors and managers
The company can also take steps to train key suppliers and contractors. Stakeholders and external partners
can help with training on specifc issues such as political, geographical, and cultural risks. Key staff should
also participate in external training where independent experts challenge others and give specialist insight into
specifc human rights issues.
5.2 review the Different types of training materials available
There are a range of different types of human rights training available: web-based and paper-based or in
person, held either in the workplace or at a special venue outside the business location.
TRAlNlNG
0.0 Xxxxxxxxxxxxxxxxxxxxxxx
Xxxxxxxxxxxxxxxxxxxxx.
Getting started
32 33 32 33
Human rights in different types of training – some examples
E-learning systems Novartis requires every
manager and associate to complete a number of
web-based courses as part of its commitment to
the group’s compliance initiative and its commit-
ment to hold all associates to the highest stan-
dards possible. Ensuring that Novartis employees
across 140 countries understand the company’s
Human Rights Guidelines and the strategy behind
them represents a huge challenge. Therefore, in
2005 all non-US Novartis associates with e-mail
access will complete four out of the following
six courses, each involving human rights as a
key element: Insider trading, Confict of interest,
Corporate citizenship, Sales practices, Marketing
practices, and Financial integrity.
Specifc training for business units National
Grid has over 8,000 active suppliers. The group’s
procurement teams are experienced in assess-
ing suppliers’ environmental, safety, and quality
performance, but not in assessing other human
rights-related performance. During 2005, the
Groups’ UK and US procurement team mem-
bers received human rights awareness training
and were introduced to a practical tool to help
prioritize their human rights assessments. The tool
is being used to assess the human rights risk as-
sociated with each purchased commodity and the
infuence that the purchaser has with suppliers of
each commodity. This analysis is used to identify
the level and priority of human rights-related
engagement with potential suppliers.
Staff induction Every employee at The Body
Shop is required to attend a staff induction that
includes a signifcant section on the company’s
commitment to ethical trade, community trade,
campaigning, environmental protection, and animal
welfare. In addition, in connection with the launch
of the campaign to Stop Violence in the Home, all
stores will be provided with training materials to
ensure that all employees understand the issues
and the importance of the campaign activities.
Management handbooks and primers
The Business and Human Rights Management
Primer produced by Shell in 1998 was one of the
frst of its kind in business. The primer is a key re-
source for human rights training programs within
the company and has been augmented by a series
of real-life management dilemmas for training
purposes. Another good example is the Human
Rights Guidance report developed by Rio Tinto.
Residential Multi-Business Human Rights
Training There is an increasing demand for resi-
dential training, which allows business managers
from a number of companies to gather in a less
formal setting. Some examples are listed in the
Appendices.
5.3 select, organize anD evaluate the training program
for target groups The selection of the appropriate training program is based on factors
such as cost, location, and the technology involved. It is worthwhile to ask other businesses and business as-
sociations which programs they have found the most useful, but remember that no two businesses are alike.
It is likely that stakeholders from the local community or NGOs will have much to contribute to any program
that is to be organized. It is essential in these circumstances that the business and NGO or community group
work together in partnership to clearly defne expectations and develop a productive working relationship.
TRAlNlNG
32 33
Getting started
32 33
6 Measuring
Impact and Auditing
6.1 Set relevant performance indicators for measuring human rights impact
across the different functions of your business
6.2 Undertake human rights-based audits
6.3 Analyze the results of audits and use results to inform strategic
development of your business
6.1 set relevant performance inDicators for measuring
human rights impact across the Different functions of
your business A company should develop quantifable performance indicators to monitor and
measure elements in its operations that have an impact on human rights. Performance indicators should
measure both the direct result of the company’s operations and the effciency of management processes
that infuence performance – such as training and the allocation of resources.
The indicators should be relevant to the company’s sphere of infuence, activities, and industry sector, and
should drive continuous improvement. They should relate to the organizational goals of the business and be
consistent with the risks and opportunities that the company has identifed. Measurements should be made
regularly and be communicated to employees and other interested parties. Since a company’s sphere of
infuence may change over time, performance indicators should be reviewed on a regular basis.
Measuring Impact – The Human Rights Compliance Assessment Tool
The Danish Institute for Human Rights has devel-
oped an interactive database for use by business
in any specifc national market. The web-based
tool contains approximately 350 questions for
business and more than 1,000 corresponding
human rights indicators, developed from the
Universal Declaration of Human Rights and
over 80 other major human rights treaties and
International Labour Organization (ILO) conven-
tions. Over 70 businesses were involved in the
development of the tool, and the database is now
being refned into some sector-specifc versions.
Human Rights in measuring impact and auditing:
key steps for your business
MEASURlNG lMPACT AND AUDlTlNG
34 35 34 35
Measurement of performance – an example
6.2 unDertake human rights-baseD auDits
Human rights-based audit programs should be part of a company’s governance procedures. Audits establish
whether management systems are working as planned; they focus on the causes of problems and the neces-
sary corrective measures. Human rights-based audits by qualifed personnel, preferably verifed by external
human rights experts, should be carried out regularly and made available publicly. Auditing is also a tool for
the Board and Executive Committee of a business to ensure that the strategies, policies, procedures, and
processes outlined in this Guide have been properly implemented across the company.
Human rights-based audits – an example
Building relationships with local NGOs
As part of its long-standing partnership with
Carrefour, the International Federation for Human
Rights (FIDH) set up a system of independent
monitoring of the company’s Charter, which is
based on human rights. By engaging with an
established NGO in this way, Carrefour was able to
ensure the credibility of the monitoring system.
MEASURlNG lMPACT AND AUDlTlNG
As part of its policy to develop a human rights-
aware approach in its business activities, ABB
developed a checklist for managers based on
the Global Reporting Initiative’s (GRI) guidelines
on human rights and the Draft Norms. ABB
established the checklist’s criteria by carrying out
a gap analysis between the Draft Norms and the
GRI guidelines (published in the second BLIHR
report – see the Appendices).
The risk assessment checklist mirrors human
rights categories listed in the Draft Norms – the
rights of workers, occupational health and safety,
non-discriminatory treatment, the rights of local
communities, transparency and business ethics,
and protection of the environment.
Acting on behalf of BLIHR, ABB is testing the
checklist within the parameters of its rural electri-
fcation program – called Access to Electricity – in
Tanzania and sub-Saharan parts of Africa. Initial
results show that while the checklist is suffcient
in some situations and countries, it needs to
include extra questions and be made more coun-
try-specifc for more sensitive nations.
A human rights-aware approach benefts all stake-
holders – villagers, local authorities, suppliers, and
the companies and organizations involved in Ac-
cess to Electricity. For ABB, it also means lowering
business risk through taking a wider approach on
the potential impact of such projects.
Working within the GRI’s internationally ack-
nowledged framework may help make the Draft
Norms easier to accept and implement for a
wider circle of transnational corporations. It would
provide a comparable reporting system built on
auditable performance criteria.
34 35
Getting started
34 35
The use and analysis of human rights in business audits – some examples
Auditing Equal Opportunities and Diversity
Each year, all business areas in Novo Nordisk de-
velop action plans for ensuring that equal oppor-
tunities and diversity (EO&D) are fully embedded
in all relevant business processes spanning the
employment cycle (recruitment, working condi-
tions, remuneration, development, promotion and
termination). EO&D targets are included in the
company’s “balanced scorecard,” the perform-
ance management mechanism used to drive all
key areas of business performance. These tar-
gets require the action plans to be submitted for
evaluation by the human resources function, and
that - as a minimum - 80% of the actions for the
year are achieved. The achievement of the EO&D
targets is directly linked to staff appraisal and
individual bonuses in management. Failure to
meet these targets in any of the business areas
is visible within the company, and initiates a
dialogue process between the human resources
function and the business areas involved.
Assessing risk to determine auditing needs
Every approved supplier to The Body Shop must
sign an agreement committing to meeting The
Body Shop Ethical Trade standards, which are
based on the Ethical Trading Initiative’s Base
Code. First-tier product suppliers are assessed
for potential risk based on their responses to
an initial screening questionnaire and take
into account factors such as their location and
relationship with The Body Shop. Each supplier
is ranked as high, medium, or low risk. High-risk
suppliers are audited by a not-for-proft audit
company or by a third-party agent. A buyer
from The Body Shop or a representative from a
local non-governmental organization will audit
a medium-risk supplier. Low-risk suppliers will
undergo an ethical assessment and is expected
to adopt the Body Shop Code of Conduct.
6.3 analyze the results of auDits anD use results to
inform strategic Development of your business
MEASURlNG lMPACT AND AUDlTlNG
36 37 36 37
7 Reporting
Human rights in reporting: key steps for your business
7.1 Decide which human rights impacts are priorities for you to report on
7.2 Consider who your main target audiences are
7.3 Develop an effective reporting format
7.4 Publish this information on its own or as part of a regular business report
7.5 Submit a link/description to the Global Compact website (Global Compact participants)
7.1 DeciDe which human rights impacts are priorities for you to
report on For the reasons mentioned in the Communications section, reporting on human rights is an essential part
of a business management system. A report is in its own right a business management tool. Many companies already report
on social and environmental performance in addition to their business results, and an increasing number have their reports
independently verifed. For companies over a certain size in some countries, basic reporting on social and environmental perfor-
mance is mandatory.
7.2 consiDer who your main target auDiences are Companies often report on
human rights issues linked to suppliers and employees, but neglect other areas. Good practice is to report on the company’s
full sphere of infuence. This means including issues and opportunities linked to customers and communities where the
company operates. Transparent reporting of successes, failures, and challenges sets an example for others, builds credibility
and trust, and maintains the company’s license to operate.
7.3 Develop an effective reporting format There are several ways to present human
rights data in a company report and it is worth reviewing a selection of those listed on www.business-humanrights.org. Ref-
erence can also be made to the 3rd Generation of reporting guidelines from the Global Reporting Initiative. These guidelines
provide an example of a thorough framework for human rights reporting. One key decision to be made is whether the report
should be purely web-based, paper-based, or both. A rights-aware approach also requires careful attention to accessibility,
particularly in terms of the languages used and meeting the needs of those with visual impairment or without the required
technology to access the report.
7.4 publish this information on its own or as part of a regular
business report Another key decision is whether your company is moving towards an integrated triple bot-
tom line approach to reporting (i.e. fnancial, environmental, and social) or whether the social issues are better served in their
own report or combined with environmental issues in a ‘sustainability report’. Many businesses see human rights as a sub-
set of wider social issues; some companies maintain a distinction between labor rights and human rights. However, as more
companies move towards a more holistic approach to human rights in business, we can expect that an increasing amount of
the ‘social space’ in company reports will be categorized as human rights.
REPORTlNG
36 37
Getting started
36 37
Human Rights in a Social Responsibility Report – an example
Gap Inc.’s 2003 Social Responsibility Report was widely
praised for its honest appraisal of the challenges facing a
company trying to uphold international human rights and
labor rights standards across global supply chains. Greater
transparency has led to newspaper headlines such as “Gap
admits factory abuses,” but this has been more than offset
by positive responses from employees, customers, investors,
and NGOs. Gap’s 2004 report continues transparent report-
ing against the ILO Core Conventions. In its 2004 report, the
company quotes US Supreme Court Justice Louis Brandeis
to capture its philosophy about reporting: “a bright light is the
best disinfectant”. The more open and honest a company can
be about conditions and challenges, the more helpful it can
be in addressing them. Gap’s report also contains construc-
tive criticism and learning from the Public Reporting Working
Group and stakeholder outreach sessions. Gap also presents
its work with the Global Reporting Initiative (GRI) to develop
consistent reporting standards that will make it possible to
compare performance across companies and over time.
Codelco, a successful Chilean mining company, has a
history of reporting on sustainable development issues,
including human rights. The company’s most recent Sus-
tainability Report was prepared by its Senior Vice-President
of Operational Excellence, Promotion, and Sustainability in
accordance with the latest Global Reporting Initiative (GRI)
Guidelines. Codelco’s report highlights its work on human
rights issues ranging from the company’s compliance with
a comprehensive occupational health and safety plan to
its approval of a document of commitments to indigenous
people. In addition, the company took its reporting a step
further and submitted it to an external independent review-
er. The aim of the review was to provide assurance of the
report’s accuracy and its adherence to the GRI Guidelines.
As part of the process, the independent reviewer visited
numerous Codelco facilities as well as the head offce in
Santiago, Chile.
The Global Reporting Initiative
Over 700 businesses now cite the Global Reporting Initiative
as the framework for their social and environmental report-
ing, with human rights included within their social indicators.
The GRI framework is one example of how to report on such
matters. At the time of writing, in early 2006, the Global
Reporting Initiative is involved in developing the 3rd genera-
tion of reporting guidelines. For more information, see www.
globalreporting.org
Communicating progress
7.5 submit a link/Description to the global compact website
(global compact participants) Participants in the Global Compact are expected to communicate,
on an annual basis, with their stakeholders about the progress they are making in implementing all ten Compact principles,
including the two human rights principles. The communication on progress is expected to include a statement of continuing
support by the company’s leadership for the Global Compact, a description of practical actions taken to implement the prin-
ciples, and measurement of outcomes using, as far as possible, standard indicators or metrics such as those elaborated in the
GRI’s Sustainability Reporting Guidelines. Communications on progress can be part of a broader annual or sustainability report
or a stand alone document that is web-based, paper-based or both. A link to or description of the communication on progress
is required to be submitted to the Global Compact website. Guidance materials for how to communicate progress are available
at: www.unglobalcompact.org/communicatingprogress
REPORTlNG
Introduction
The rapid development of ‘business and human rights’ as an area of concern and interest over the last de-
cade seems likely to continue. As it does, an increasing number of businesses around the world will identify
practical ways to integrate human rights into their business practices.
However, there is much work to be done to develop and refne the tools and systems needed for businesses
to manage human rights effectively. This Guide is very much a ‘frst attempt’ at exploring the practical
integration of human rights into business management, and it is hoped that businesses might be inspired by
its advice and examples to develop their own applications of human rights which, in turn, might be shared
more widely.
Conclusion
38 39 CONCLUSlON
lNTRODUCTlON
Appendices
1. International Bill of Human Rights
The International Bill of Human Rights consists of:
• The Universal Declaration of Human Rights (UDHR),
• The International Covenant on Economic, Social and Cultural Rights (ICESCR), and
• The International Covenant on Civil and Political Rights (ICCPR)
The UDHR and the Covenants can be read in their entirety at www.ohchr.org/english/law. Below you will fnd the
headings of the articles in the Covenants (excluding articles concerned with procedural or organizational matters).
International Covenant on Economic, Social and Cultural Rights (ICESCR)
Article 1: The right to self-determination for peoples.
Article 2: Non-discrimination in relation to all rights
Article 6: The right to work, including the right to vocational guidance and training
Article 7: The right to a minimum wage and equal pay, to safe and healthy working conditions, and to
rest, leisure and holidays with pay
Article 8: The right to form trade unions and join a trade union, and the right to strike
Article 9: The right to social security, including social insurance
Article 10: The right to a family life, to maternity leave and prohibition of exploitative child labor
Article 11: The right to adequate food, clothing, housing and fair distribution of food
Article 12: The right to the highest attainable standard of physical and mental health
Article 13-14: The right to education
Article 15: The right to participate in cultural life and the technological development and the right to
protection of moral and materiel interests resulting from one’s inventions
38 39 APPENDlCES
lNTRODUCTlON
Appendices
International Covenant on Civil and Political Rights (ICCPR)
Article 1: The right to self-determination for peoples.
Article 2: Non-discrimination in relation to all rights
Article 6: The right to life
Article 7: Prohibition against torture or cruel, inhumane or degrading treatment or punishment and
against medical or scientifc experimentation without free consent
Article 8: Prohibition against slavery, forced or other compulsory labour
Article 9 - 10: The right to freedom and personal safety (arrest and detention)
Article 11: Prohibition against imprisonment for non-fulfllment of a contractual obligation
Article 12: The right to liberty of movement and freedom to choose residence
Article 13: The right to seek asylum
Article 14-15: The right to a fair trial and prohibition against retroactive punishment
Article 16: The right to recognition as a person before the law
Article 17: The right to privacy
Article 18: Freedom of thought, conscience and religion
Article 19: The right to hold opinions and the right to freedom of information and freedom of expres-
sion
Article 20: Prohibitions against inciting war and against hate speech
Article 21: The right of peaceful assembly
Article 22: Freedom of association, including the right to form and join trade unions
Article 23-24: The right to form a family and the rights of the child
Article 25: The right to take part in public affairs
Article 26: Equality before the law
Article 27: Minority rights to culture, religious practice and language
40 41 APPENDlCES
lNTRODUCTlON
Appendices
2. The Ten Principles of the UN Global Compact
The Global Compact’s ten principles are derived from: the Universal Declaration of Human Rights; the Inter-
national Labour Organization’s Declaration on Fundamental Principles and Rights at Work; the Rio Declara-
tion on Environment and Development; and the United Nations Convention Against Corruption.
The Global Compact asks companies to embrace, support and enact, within their sphere of infuence, a set
of core principles in the areas of human rights, labour standards, the environment, and anti-corruption:
Human Rights
1 Businesses should support and respect the protection of internationally proclaimed human rights,
and
2 make sure that they are not complicit in human rights abuses.
Labour
3 Businesses should uphold the freedom of association and the effective recognition of the right to
collective bargaining,
4 the elimination of all forms of forced and compulsory labour,
5 the effective abolition of child labour, and
6 the elimination of discrimination in respect of employment and occupation.
Environment
7 Businesses should support a precautionary approach to environmental challenges,
8 undertake initiatives to promote greater environmental responsibility, and
9 encourage the development and diffusion of environmentally friendly technologies.
Anti-Corruption
10 Businesses should work against corruption in all its forms, including extortion and bribery.
40 41 APPENDlCES
lNTRODUCTlON
3. Resources
General Reports/Guides for Business
Business and Human Rights: A Compilation of Documents, Edited by Radu Mares, Leiden: 2004
Business and Human Rights: A geography of corporate risk, Amnesty International (UK) and The Prince of Wales Interna-
tional Business Leaders Forum, London: 2002.
Business and Human Rights, Dilemmas and Solutions, Edited by Rory Sullivan, Insight Investment, London: 2003
Business and Human Rights in a time of change, Christopher Avery, Amnesty International (UK), London: 2000
Business as Partners in Development: Creating wealth for countries, companies and communities, Jane Nelson/The
Prince of Wales Business Leaders Forum, in collaboration with The World Bank and The U.N. Development Programme,
London: 1996
Business Leaders Initiative on Human Rights: Report 1: Getting Started, BLIHR, London, New York and Stockholm: 2003
Business Leaders Initiative on Human Rights: Report 2: Work in Progress, BLIHR, London, New York and Stockholm:
2004
Embedding Human Rights in Business Practice, The Global Compact and the Offce of the United Nations High Commis-
sioner for Human Rights, New York and Geneva: 2004.
Human Rights: Is it any of your business?, Amnesty International (UK) and The Prince of Wales International Business
Leaders Forum, London: 2000.
Human Rights: It is your business – the case for corporate engagement, The Prince of Wales International Business
Leaders Forum, London: 2005.
Raising the Bar: Creating Value with the United Nations Global Compact, Edited by Claude Fussler, Aron Cramer and
Sebastian van der Vegt, Greenleaf Publishing Limited: 2004.
The Business of Peace, Jane Nelson, International Alert, Council on Economic Priorities and The Prince of Wales Interna-
tional Business Leaders Forum, London: 2000.
Training
Business and Human Rights in Practice
Over 100 business managers from many industries have attended this training course since 2002. Now run by TwentyFifty
Limited (see www.twentyffty.co.uk ) the course comprises of an on-line module, residential workshop and a workplace project.
Its aim is to help companies to implement their human rights commitments by developing the capacity of key individuals to
manage human rights issues. The course is run twice a year in the UK and by invitation internationally.
Human Rights & Business training
General training on the ‘why, what and how’ of human rights and business and special training for specifc corporations
have been developed and performed by the law frm Lawhouse.dk (www.lawhouse.dk). Since 1999 Lawhouse.dk has
trained more than a thousand business managers and lawyers and conducted specifc training for several members of
the UN Global Compact. Tools, programs and training on particular rights such as non-discrimination, the right to health,
freedom of information and expression, the right to privacy, and the right to participate in technological development
were developed to support individual corporate priorities.
42 43 APPENDlCES
lNTRODUCTlON
4. Organizations
African Institute for Corporate Citizenship
www.aiccafrica.com
Amnesty International Business Groups
www.amnesty.org.uk/business
Business & Human Rights Resource Centre
www.business-humanrights.org
Business for Social Responsibility (BSR)
www.bsr.org
CAFOD
www.cafod.org.uk
Christian Aid
www.christian-aid.org.uk
Ethos Institute
www.ethos.org.br
Friends of the Earth
www.foe.org.uk
Fund for Peace Human Rights and Business Roundtable
www.fundforpeace.org/programs/hrbrt/hrbrt.php
GeSI - Global E-Sustainability Initiative
www.gesi.org
Global Reporting Initiative
www.globalreporting.org
Human Rights Watch
www.hrw.org
International Chamber of Commerce (ICC)
www.iccwbo.org
International Commission of Jurists
www.icj.org
International Committee of the Red Cross
www.icrc.org
International Federation for Human Rights
www.fdh.org
International Financial Corporation
www.ifc.org
International Labour Organization (ILO )
www.ilo. org
Offce of the United Nations High Commissioner
for Human Rights
www.ohchr.org
Organisation for Economic Co-operation and Development
www.oecd.org
Social Accountability International (SAI)
www.sa-intl.org
The Danish Institute for Human Rights
www.humanrights.dk
The International Confederation of Free Trade Unions
www.icftu.org
The Prince of Wales International Business Leaders Forum
www.iblf.org
United Nations Development Programme (UNDP)
www.undp.org
UN Global Compact
www.unglobalcompact.org
Social Venture Network
www.svn.org
World Business Council for Sustainable Development
www.wbcsd.org
World Health Organization (WHO)
www.who.int
42 43 APPENDlCES
lNTRODUCTlON
5. Voluntary Initiatives, Guidelines, Principles and Tools
AccountAbility’s AA1000 Framework and series standards
www.accountability.org.uk/aa1000/default.asp
Amnesty International Human Rights Principles for Companies
www.amnesty.org.uk/business/pubs/hrgc.shtml
The Caux Round Table Principles for Business
www.cauxroundtable.org/index.html
Clean Clothes Campaign: Model code
www.cleanclothes.org/codes/ccccode.htm
Dow Jones Sustainability Index (DJSI)
www.sustainability-index.com/
Ethical Trading Initiative
www.ethicaltrade.org/Z/home/index.shtml
Electronic Industry Code of Conduct
www.hp.com/hpinfo/globalcitizenship/environment/pdf/supcode.pdf
Equator Principles
www.equator-principles.com
Extractive Industries Transparency Initiative – Source book
www.eitransparency.org/keydocuments.htm
Fair Labor Association – Code of conduct
www.fairlabor.org/all/code/index.html
FTSE4Good
www.ftse.com/ftse4good/index.jsp
Global e-Sustainable Initiative (GeSI)
www.gesi.org
Global Reporting Initiative
www.globalreporting.org
The Global Sullivan Principles
www.thesullivanfoundation.org/gsp/default.asp
Human Rights Compliance Assessment Tool (HRCA)
www.humanrightsbusiness.org/
ILO’s Declaration on Fundamental Principles and Rights at Work
www.ilo.org/dyn/declaris/DECLARATIONWEB.INDEXPAGE
ILO’s Tripartite Declaration of Principles Concerning Multinational
Enterprises and Social Policy
www.ilo.org/public/english/employment/multi/overview.htm
ISO Standard on CSR
ww.iso.org/iso/en/ISOOnline.frontpage
Kimberly Process
www.kimberleyprocess.com
The OECD Guidelines for Multinational Enterprises
www.oecd.org/
Social Accountability 8000
www.sa-intl.org
Voluntary Principles on Security and Human Rights
www.voluntaryprinciples.org/
6. Websites of companies mentioned
in this report
ABBFG www.abb.com
BarclaysF www.barclays.com
BPG www.bp.com
CarrefourG www.carrefour.com
CemexG www.cemex.com
CodelcoG www.codelco.com
CopelG www.copel.com
EskomG www.eskom.co.za
Gap Inc.FG www.gapinc.com
Hewlett PackardFG www.hp.com
Li and Fung Trading LimitedG www.lifung.com
MAS Holdings G www.masholdings.com
MTV Networks EuropeF www.mtvne.com
National GridF www.nationalgrid.com
Novartis Foundation for Sustainable DevelopmentFG
www.novartisfoundation.com
Novo NordiskFG www.novonordisk.com
Rio TintoG www.riotinto.com
StatoilFG www.statoil.com
ShellG www.shell.com
Taj HotelsG www.tajhotels.com
Tata EnterprisesG www.tata.com
TelefónicaG www.telefonica.com
The Body Shop InternationalF www.thebodyshop.com
ValeoG www.valeo.com
Fdenotes membership of BLIHR
Gdenotes membership of the United Nations Global Compact
APPENDlCES 44 PB
www.blihr.org www.ohchr.org www.unglobalcompact.org
A Guide for Integrating Human Rights
into Business Management
BUSINESS LEADERS INITIATIVE ON HUMAN RIGHTS
Member companies of the Business Leaders Initiative on Human Rights
National Grid plc
Novartis Foundation for
Sustainable Development
Novo Nordisk A/S
Statoil ASA
The Body Shop International Plc
ABB Ltd
Barclays PLC
Gap Inc.
Hewlett-Packard Company
MTV Networks Europe
www.respecteurope.com www.realizingrights.org
doc_543494821.pdf
Human rights education is the teaching of the history, theory, and law of human rights in schools and educational institutions, as well as outreach to the general public.
A Guide for Integrating Human Rights
into Business Management
BUSINESS LEADERS INITIATIVE ON HUMAN RIGHTS
www.respecteurope.com www.realizingrights.org
2
Business Leaders
Initiative on
Human Rights
United Nations
Global Compact
and
the Offce of the
High Commissioner
for Human Rights
Disclaimer
The views expressed in this publica-
tion do not necessarily represent
the views of the Global Compact
Offce or the Offce of the High
Commissioner for Human Rights or
any of the individual companies
participating in BLIHR or whose
case examples are included. More-
over, the Global Compact Offce
and the OHCHR make no repre-
sentation concerning, and do not
guarantee, the source, originality,
accuracy, completeness or reli-
ability of any statement, informa-
tion, data, fnding, interpretation,
advice or opinion contained within
the publication. The publication is
intended as a learning document.
The inclusion of examples of com-
pany experiences does not in any
way constitute an endorsement of
the individual companies nor their
human rights policies or practices
by the Global Compact Offce and/
or the OHCHR.
photo credits page 4/ from left to right:
all photos © istockphoto.com except for
numbers 1 and 5, © United Nations Capi-
tal Development Fund/Roger Adams
Preface
Introduction
Getting Started
1 Strategy
2 Policy
3 Processes and
Procedures
4 Communications
5 Training
6 Measuring Impact
and Auditing
7 Reporting
Conclusion
Appendices
add photo captions
Contents
3
A growing number of companies are becom-
ing aware of the contribution they can make to
advancing human rights within their spheres of
infuence and the benefts such an approach can
have for their businesses. While human rights
continue to be the primary responsibility of govern-
ments, companies can do a lot within the context
of their own business to support and respect the
observance of human rights. Being proactive on
human rights can make good business sense, as
well as being the right thing to do.
This publication, a joint product of the Business
Leaders Initiative on Human Rights (BLIHR), the
United Nations Global Compact Offce, and the
Offce of the High Commissioner for Human Rights
(OHCHR), offers practical guidance to companies
that want to take a proactive approach to hu-
man rights within their business operations. It is
principally for business leaders and managers in
large and medium-sized enterprises, private and
state-owned, who would like to develop their un-
derstanding of human rights in business practice.
What is the Business Leaders Initiative on
Human Rights?
The Business Leaders Initiative on Human Rights
(BLIHR) is a business-led program that is developing
practical tools and methodologies for applying hu-
man rights principles and standards across a range
of business sectors, issues, and geographical loca-
tions. The ten member companies of BLIHR took the
lead in this Guide’s development, in which they share
some of their experiences and lessons they have
learned. For more information, see www.blihr.org
What is the United Nations Global Compact Offce?
The United Nations (UN) Global Compact is the
UN’s voluntary corporate citizenship initiative based
on ten universal principles in the areas of hu-
man rights, labor standards, the environment and
anti-corruption (see the Appendices). It has been
endorsed by all 191 Heads of State and Govern-
ments of the United Nations and has further been
legitimized through a consensus resolution by the
General Assembly. The frst two principles of the
Global Compact are derived from the Universal Dec-
laration of Human Rights, which is the foundational
framework of the international human rights system.
• Business should support and respect the pro-
tection of international human rights; and
• Business must not be complicit in abuses of
human rights.
The Global Compact Offce works with participants
and other stakeholders to provide support, commu-
nications, governance, and programs related to the
Global Compact initiative and principles. For more
information, see www.unglobalcompact.org
What is the Offce of the High Commissioner
for Human Rights?
The Offce of the High Commissioner for Human
Rights (OHCHR) is an important branch of the UN
human rights structure. The current High Com-
missioner, Louise Arbour, is responsible to the UN
Secretary General for encouraging the international
community and nation states to uphold universal
human rights standards. The Offce seeks to work
with an ever wider range of participants, including
the private sector, to promote respect for and com-
mitment to human rights as widely as possible.
For more information, see www.ohchr.org
Why we chose to produce this Guide
Human rights is one of the most challenging areas
of corporate responsibility for companies to ad-
dress; more human rights tools and guidance are
needed. This Guide is intended to help meet this
need and, in doing so, help companies make hu-
man rights a successful part of their business.
Preface
4 lNTRODUCTlON
Introduction
Human rights are the basic rights of each human
being, independent of race, sex, religion, political
opinion, social status, or any other characteristic.
Through international human rights conventions,
governments commit to respect, protect, promote
and fulfll the human rights of their citizens and
other individuals within and beyond their borders.
A list of the human rights contained in the Universal
Declaration, the International Covenant on Civil and
Political Rights, and the International Covenant on
Economic, Social and Cultural Rights – the three
fundamental United Nations agreements on human
rights – is included in the Appendices to this Guide.
Businesses should also be aware of the core con-
ventions of the International Labour Organisation. In
addition, a specifc body of law applies in situations
of armed conficts: international humanitarian law.
Its rules have two aims: frst, protecting people who
are not or no longer taking part in hostilities and,
secondly, regulating means and methods of warfare.
At this time in history, there are compelling reasons
why businesses should involve human rights in
their policies and practices. Businesses increasingly
need a stable international environment in which
to operate, with sustainable markets and a “level
playing feld” of opportunities. Human rights offer
a common framework for businesses to under-
stand societies’ expectations and deliver value to
stakeholders in a more sustainable way. This Guide
demonstrates that, in a business context, advancing
human rights is as much about realizing new op-
portunities and managing risk as it is about meeting
essential global standards.
For business, human rights provide a universal
benchmark for minimum standards of behavior.
Many national laws and regulations have evolved as
a result of a State’s obligation to implement human
rights standards. Business must, of course, observe
such laws in all countries and jurisdictions in which
they operate.
The debate about the nature and scope of com-
panies’ human rights responsibilities is a relatively
recent one, as is the idea of applying human rights
to business decisions and operations. A number
of international efforts have been undertaken to
elaborate on the content of human rights relevant
to business. One of the most comprehensive efforts
resulted in the “Draft Norms on the Responsibilities
of Transnational Corporations and Other Business
Enterprises with Regard to Human Rights” (Draft
Norms), developed by a United Nations expert
group, the UN Sub-Commission on the Promotion
and Protection of Human Rights. While the Draft
Norms have no formal legal status, the inter-gov-
ernmental UN Commission on Human Rights has
observed that they have useful elements. Many of
the companies that have contributed to this Guide,
especially the companies involved in BLIHR, agree
that the content of the Draft Norms provides a help-
ful framework for human rights in business.
5 lNTRODUCTlON
Vision
Empowerment
Leadership
Resources
Policies
Strategy
Processes
Innovation
Impact on
People
Impact on
Value
Chain Impact
on Society
Reporting
e
n
a
b
l
e
r
s
r
e
s
u
l
t
s
Global Compact
Performance Model
Structure
This Guide is based on a conventional management
system. It follows the Global Compact Performance
Model, which is a map for responsible corporate citi-
zenship. The model allows business to implement the
Global Compact principles without undermining their
other business goals. The Performance Model was
built on practical experience, identifying methods
that actual companies followed to mainstream the
Global Compact principles into their own business
operations and activities. More information about
implementing the Performance Model in practice
is available on the Global Compact website (www.
unglobalcompact.org) and in the publication entitled
Raising the Bar: Creating Value with the United Na-
tions Global Compact, listed in the Appendices.
This Guide is intended to be a technical manual and a
hands-on toolkit to help any company integrate prac-
tices consistent with human rights standards into an
existing management system. It is made up of seven
elements common to most management systems:
Strategy, Policy, Processes and Procedure, Communi-
cations, Training, Measuring Impact and Auditing, and
Reporting. The Getting Started section identifes the
initial steps a company should take to implement the
performance model, and in the Appendices at the end
of the Guide you will fnd tools and resources which
the BLIHR companies have found to be helpful in
bringing human rights into their businesses.
The examples in this Guide illustrate how aspects of
the model have been implemented and are designed
to inspire other businesses. The human rights
processes and procedures included in this Guide are
ongoing projects for the companies concerned.
There is much still to learn. We welcome com-
ments on the content of this Guide as we seek to
constantly improve the business and human rights
tools available to companies.
6
Getting Started
understanding human rights in a business context
Human rights in your business: getting started
1 Develop the business case for human rights
2 Familiarize yourself with the broad content of human rights and the
available resources
3 Understand the implications of the frst two principles of the Global Compact
4 Develop and encourage a rights-aware approach to your business
1. Develop the business
case for human rights
There is a strong moral and ethical case to support
the notion that business entities should integrate
human rights principles into their business practices
within their sphere of infuence. The concept of
businesses as a ‘force for good’ and as a powerful
actor in economic, environmental and social devel-
opment has been strengthened in recent years.
In terms of the ‘business case’ for human rights,
although the precise logic can vary between each
business sector and country of operation, the fol-
lowing main benefts have been identifed:
• Improved stakeholder relations
• Improved employee recruitment,
retention, and motivation
• Improved risk assessment and
management
• Reduced risk of consumer protests
• Enhanced corporate reputation
and brand image
• A more secure license to operate
• Strengthened shareholder confdence
• More sustainable business relationships
with governments, business partners, trade
unions, sub-contractors and suppliers.
Human rights can be a way of identifying new busi-
ness opportunities; sometimes what might be frst
perceived as a risk to a business can be converted
into an asset. The Human Rights Matrix, introduced
in the Strategy section of this report, is a good way
to map both risks and opportunities and the man-
agement approaches that can link the two.
In addition to the business case for human rights,
there are also important strategic reasons for busi-
ness to take a long-term interest in good governance
and a stable social environment in places where
they do business. There are many good resources on
the business and strategic case for human rights; a
selection is listed in the Appendices to this Guide.
GETTlNG STARTED
7
Getting Started
understanding human rights in a business context
2. familiarize yourself with the broaD content of human
rights anD the available resources
Which human rights are relevant to business?
The short answer is: all human rights are relevant.
Businesses should look frst at what is often
referred to as the “International Bill of Human
Rights” made up of three international agreements:
• The Universal Declaration of Human Rights
• The International Covenant on Civil and
Political Rights
• The International Covenant on Economic,
Social and Cultural Rights
A short description of the rights contained in
these documents is included in the Appendices
to this report.
A business should consider the full range of civil,
political, economic, social, and cultural rights
when examining the impact of its operations
(see Sphere of infuence overleaf). In addition, in
situations of armed confict businesses should be
aware of the rules of international humanitarian
law, in particular those contained in the Geneva
Conventions of 1949 and their Additional
Protocols of 1977.
The Business Leaders Initiative on Human Rights
has developed a Human Rights Matrix which
follows the Universal Declaration of Human Rights
and other international agreements. The categories
in the Matrix are those developed in the Draft
Norms; the content covers the following areas:
A General Obligations
B Right to equal opportunity and non-discrimi-
natory treatment
C Right to security in persons
D Rights of workers
E Respect for national sovereignty and human
rights
F Obligations with regard to consumer protec-
tion
G Obligations with regard to environmental
protection
H General provisions of implementation
The full content of the Matrix and explanatory
notes on the Draft Norms are available at www.
blihr.org and www.ohchr.org respectively. A longer
list of resources is included in the Appendices.
GETTlNG STARTED
8
3. unDerstanD the implications of the first two principles
of the global compact The frst two principles of the Global Compact call on businesses
to support and respect the protection of international human rights within their ‘sphere of infuence’ and to
make sure they are not complicit in human rights abuses. The two concepts of ‘sphere of infuence’ and
‘avoiding complicity’ are very useful when trying to decide what your business can do, and what tools are
needed, to ensure human rights consistent policies and practices in a business context.
Sphere of infuence
“ While the concept [of sphere
of infuence] is not defned in
detail by international human
rights standards, it will tend to
include the individuals to whom
the company has a certain
political, contractual, economic
or geographic proximity. Every
company, both large and small,
has a sphere of infuence,
though obviously the larger or
more strategically signifcant
the company, the larger the
company’s sphere of infuence
is likely to be.” (“The Global
Compact and Human Rights: Un-
derstanding Sphere of Infuence
and Complicity: OHCHR Briefng
Paper,” in ‘Embedding Human
Rights in Business Practice’
– listed in the Appendices.)
Understanding a company’s
sphere of infuence can be
accomplished by mapping the
stakeholder groups affected
by a business’ operations. A
key stakeholder group that
will normally lie at the center
of any company’s sphere of
infuence will be employees.
Other groups, such as business
partners, suppliers, trade
unions, local communities, and
customers will follow. The fnal
group will usually be govern-
ment and the wider society.
#OMPANY
#ONTRACTORS #OMMUNITY 3OCIETY
Fig: This diagram is developed from the publication: Business as Partners in Development: Creating wealth
for countries, companies and communities, Jane Nelson/The Prince of Wales International Business Leaders
Forum, in collaboration with The World Bank and The U.N. Development Programme, London: 1996
GETTlNG STARTED
9
Avoiding complicity in human rights abuses
“A company is complicit in hu-
man rights abuses if it autho-
rises, tolerates, or knowingly
ignores human rights abuses
committed by an entity associ-
ated with it, or if the company
knowingly provides practical
assistance or encouragement
that has a substantial effect
on the perpetration of human
rights abuse. The participation
of the company need not actu-
ally cause the abuse. Rather
the company’s assistance or
encouragement has to be to
a degree that, without such
participation, the abuses
most probably would not have
occurred to the same extent
or in the same way.” (“The
Global Compact and Human
Rights: Understanding Sphere
of Infuence and Complicity:
OHCHR Briefng Paper,” in
‘Embedding Human Rights in
Business Practice’ – listed in
the Appendices.)
Avoiding complicity in human
rights abuses is an important
challenge for business. As the
dynamics between govern-
ments, companies, and civil
society organizations change,
so too does the understand-
ing of when and how different
organizations should take on
responsibilities for human
rights issues. Four situations
help to illustrate how the no-
tion of complicity might arise:
1 When the company actively
assists, directly or indirectly,
in human rights violations
committed by others e.g.
where a company provides
information to a government
that it knows will be used to
violate human rights;
2 When the company is in a
partnership with a govern-
ment and knows, or should
have known before agreeing
to the partnership, that the
government is likely to com-
mit abuses in carrying out
its part of the agreement e.g.
forced relocation of peoples;
3 When the company benefts
from human rights violations
even if it does not positively
assist or cause them e.g.
abuses committed by secu-
rity forces, such as the sup-
pression of a peaceful protest
against business activities
or the use of repressive
measures while guarding
company facilities; and
4 When the company is silent
or inactive in the face of sys-
tematic or continuous human
rights violations e.g. inaction
or acceptance by companies
of systematic discrimination
in employment law against
particular groups.
Where an international crime
is involved, complicity may
arise where a company
assisted in the perpetration
of the crime, the assistance
had a substantial effect on
the perpetration of the crime
and the company knew that
its acts would assist the
perpetration of the crime
even if it did not intend for
the crime to be committed.
State-owned enterprises
should be aware that
because they are part of the
state, they may have direct
responsibilities under interna-
tional human rights law.
Business risk assessment and
management tools are needed
to identify the potential for
complicity as it arises and to
develop policies and proce-
dures to ensure non-complicity.
Some of these tools are being
developed and are referred to
in this Guide.
GETTlNG STARTED
4. Develop anD encourage a
rights-aware approach to
your business Understanding the
relationship a business has with human rights
means taking a ‘rights-aware approach’ to business
practices. This allows the business to understand
challenges and dilemmas from the perspective of
other stakeholders and to better manage social risk.
It will also enable the business to choose a globally
recognized strategic framework for the full range of
its economic and social activities – the ways in which
the business can be a ‘force for good.’ Human rights
provide a universal and legitimate framework that is
applicable everywhere and to any stakeholder group.
A human rights analysis can help highlight additional
risks and opportunities for a particular project before
any technical or investment decisions are made. In
this way, a rights-aware approach can enable better-
informed business decisions.
Starting to integrate human rights into business
management requires the support of senior execu-
tives, along with a shared understanding of the
advantages a rights-aware approach offers the
business. This often means some initial invest-
ment to fully understand the nature of the risks and
opportunities that human rights present to the com-
pany. One such investment might be sourcing the
necessary expertise from outside the business or
training in human rights for key members of staff.
Many of the BLIHR companies are able to provide
examples of where such an approach has delivered
business benefts.
The ‘rights aware’ approach
The ‘rights aware’ approach
A ‘rights-aware approach’
means that a business is will-
ing to accept that its stake-
holders have universal rights
and that any decisions made
by the business should strive to
respect these. Clearly, there are
still many dilemmas and also
‘competing rights’ in which the
interests of one stakeholder
group might oppose another. A
human rights-aware approach
would mean that a business
would:
1 Identify the rights at issue,
2 Identify its responsibilities
in terms of international hu-
man rights standards, and
3 Determine the appropriate
action.
10 11 GETTlNG STARTED
11 lNTRODUCTlON
Overview of the management components outlined in this Guide
1. Human rights in STRATEGY
1.1 Find out what you are already doing
1.2 Identify risks and opportunities and then the priorities for action
1.3 Develop a human rights strategy for your business
1.4 Defne and embed appropriate management responsibilities
1.5 Integrate human rights into your company’s activities
1.6 Develop your strategy through a circle of continuous improvement
2. Human rights in POLICIES
2.1 Include human rights in your existing policies
2.2 Develop specifc human rights policies where appropriate
2.3 Develop local policies to meet local situations
2.4 Ensure full implementation of your policies and review their outcomes
3. Human rights in PROCESSES and PROCEDURES
3.1 Consider the full scope of your business activities and functions
3.2 Establish procedures for identifying your human rights-related risks and opportunities
3.3 Establish control systems for managing human rights in your business
3.4 Learn from sector-wide business initiatives
3.5 Expect the unexpected – how to react when procedures are not enough
4. Human rights in COMMUNICATIONS
4.1 Share understanding of why human rights are important to business communications
4.2 Integrate human rights into your internal communications
4.3 Integrate human rights into your external communications
5. Human rights in TRAINING
5.1 Identify target groups in your business to receive human rights training
5.2 Review the different types of training materials available
5.3 Select, organize and evaluate the training program for target groups
6. Human rights in MEASURING IMPACT AND AUDITING
6.1 Set relevant performance indicators for measuring human rights impact across the different
functions of your business
6.2 Undertake human rights based audits
6.3 Analyze the results of audits and use the results to inform the strategic development of your business
7. Human rights in REPORTING
7.1 Decide which human rights impacts are priorities for you to report on
7.2 Consider who your main target audiences are
7.3 Develop an effective reporting format
7.4 Publish this information on its own or as part of a regular business report
7.5 Submit a link/description to the Global Compact website (Global Compact participants)
E
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E
R
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E
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T
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10 11 GETTlNG STARTED
12
Human rights in strategy: key steps for your business
1.1 Find out what you are already doing
1.2 Identify risks and opportunities and then the priorities for action
1.3 Develop a human rights strategy for your business
1.4 Defne and embed appropriate management responsibilities
1.5 Integrate human rights into your company’s activities
1.6 Develop your strategy through a circle of continuous improvement
1.1 finD out what you are alreaDy Doing The debate on the nature and scope of
companies’ responsibilities concerning human rights may be relatively recent, but many related issues are already managed
by business through established procedures and practices. Legal requirements, negotiated agreements and policies on such
issues as data protection, wage fxing, working hours and holidays, non-discrimination, occupational health and safety, and
product safety, are all founded in human rights and form part of a company’s relationship with stakeholders.
1.2 iDentify risks anD opportunities anD then the priorities for action
It is important for a company to map its existing policies and undertake a gap analysis to establish how well human rights issues
are covered and whether additional policies are needed. A crucial part of the gap analysis is to identify human rights risks and
dilemmas facing your business operations. There are many examples of human rights dilemmas faced by businesses around the
world on a daily basis; a few are listed here, but many more are cited in the resources listed in the Appendices to this Guide.
Human rights risks and dilemmas – some examples
• Corruption: how do you operate within international
standards when there are local corrupt fnancial prac-
tices, a lack of laws, and the improper administration of
justice, leading to limited respect for human rights?
• Security: how do you obtain protection for personnel
and plant when the state security forces are known to
use excessive violence and commit other human rights
abuses against the local population?
• Discrimination: how do you reconcile the realities of
traditional work and cultural practices with your own
policies and adherence to international standards? How
do you ensure disabled workers have equal job opportu-
nities within the company?
• Privacy: how do you balance the marketing advan-
tages of registering your customer information with their
legitimate request for protection of their right to privacy?
• Rest, leisure and paid holidays: how do you keep
production costs competitive when you operate in a
country where there is no legal mandate for paid holi-
days, but you wish to follow international standards?
• Housing: do you evaluate the fnancial impact of
upgrading staff quarters to international minimum
requirements when performing a due diligence of a
factory that you plan to take over?
1 Strategy
STRATEGY STRATEGY
13
Desirable
Expected
Essential
Once risks and opportunities are identifed, the next step is
to identify human rights priorities based on these conclu-
sions. The Human Rights Matrix designed by the BLIHR
companies (see diagram overleaf) can be used to allow a
business to map what it sees as its ‘essential’, ‘expected,’
and ‘desirable’ priorities against a broad spectrum of hu-
man rights categories. It allows risks and opportunities to
be shown together and helps to identify the human rights
content of a company’s ‘sphere of infuence.’
• Essential – is the action that must be taken by the
company to follow relevant legal standards, eg interna-
tional human rights law, national laws, and regulations,
including in situations where a government is unwilling
or unable to fulfll its obligations.
• Expected – is the action which should be taken by the
company to meet the expectations of, and accept its
shared responsibilities to, relevant stakeholders. What is
expected may vary according to your business sector.
• Desirable – is the action through which the busi-
ness could demonstrate real leadership. This can take
a number of forms depending on the circumstances,
but could include partnerships with other stakeholders,
philanthropic and charitable donations or the donation of
technical expertise to help the most disadvantaged.
The pyramid (left) shows that any
human rights strategy should align
the essential, expected and
desirable actions of a company.
It makes no sense for
a business to take
desirable actions to address a human rights concern,
such as providing charitable donations, if it is not already
demonstrating its essential and expected action in the
same area.
The Human Rights Matrix is a general version for the pur-
poses of example only. Your business would need to produce
its own version drawing on all the relevant data from your
company’s activities across specifc geographic areas. A
great advantage offered by a rights-aware approach is that
the categories (shown across the column headings of the
Matrix) are universal and therefore global in application, as
are many of the international standards upon which ‘essen-
tial’ actions are based.
Additional risks emerge if dilemmas are not properly managed.
These might include negative impacts on stakeholder relations,
such as with employees, contractors, local communities, local and
national governments, and others. There might also be possible
operational disruption or a negative impact on investor confdence
and share value. There is also a risk of negative publicity, gener-
ated locally and internationally. However, if dilemmas are properly
managed, they can become opportunities for your business.
Turning risk into opportunity is a key component of a strategic
approach to human rights in business. During the initial scoping
phase, a company may also identify other opportunities to promote
human rights in the conduct of their regular business activities.
Human rights opportunities – some examples
• Positive impacts upon stakeholder relations, including with employees, contractors, trade unions, local communities,
non-governmental organizations, local and national governments and others.
• A minimization of operational disruption.
• Better opportunities for positive public relationships with society, the press, and other media
• A positive impact upon investor confdence and share value
• Improving employee morale due to good safety performance
1 Strategy
STRATEGY STRATEGY
14 lNTRODUCTlON
C3. Right to
security of persons
C4. Security
arrangements
D5. Forced or
compulsory labour
D7. Safe and
healthy workplace
D8. Adequate
remuneration
D9. Freedom of
association /
collective
bargaining
E10. Respect for
national governance
practices
E11. Bribery E12. Contribution to
realisation of human
rights
H15.
Internal rules
of operation
H16. Monitoring H17. Reparations
Public statement of
commitment to
human rights
Equal opportunities
policy
Employee self-
protection advice /
training
Criteria in contracts for
for security services
Bribery and
corruption
prevention policy
On-going studies
into the safety of
products and
services
Environment policy Code of conduct 3rd party veri?-
cation of CSR
reporting
Public statements of
commitment to ILO
Core conventions,
UDHR, OECD
guidelines, etc.
Progressive
Maternity, Adoption,
Family leave,
Harassment policies
Supplier screening /
monitoring
Global HSE guide-
lines specifying
standards,
implementation and
compliance process
Pay at least living
wage in all
countries
of operation
Establishment of
Consultative
Committees (e.g.
Health and safety)
Commitment to
political neutrality
Board Committee
with terms of refe-
rence covering
environmental and
social issues including
human rights.
Committee)
Focused diversity
initiatives/
programmes and
leadership structure
Safety management
system
Pension provision
in all countries of
operation
Letter of Assurance
process
Procurement
process assessed
Annual review of
policies
Diversity awareness/
training for
employees
Publication of
performance data
Merit-based pay
and performance
system
Board Audit and
Compliance
Committee
Goals for reduction
of energy
consumption
Support for speci?c
programmes e.g.
black empowerment
in South Africa
Training for
employees and
selected
Third Parties
Wage level
incorporated into
supplier screening
criteria
Transparent public
reporting in Annual
Report
Established risk
management process
Public reporting of
basic performance
metrics
Participation in
industry safety
forums and
initiatives
Certi?cation of
ISO14001
environmental
management
programme(s)
Chairman's award
to promote best
practice
Employee personal
accident insurance
Withdrawal from
countries where
forced labour is
prevalent
Safety working
groups
Enhanced pension
schemes
Trade union
consulted on all
business changes that
impact employees
in relevant areas
Participation in
public good
governance debate
incl. corruption
Training on
compliance /
Grey zones
Matched giving
(support employee's
charitable giving)
Supplier development
programme
Internal audits of
social and environ-
mental performance
Membership of
forums promoting
diversity, gender
balance etc.
Employee Assist
(24 hour
con?dential
help line)
Community safety
education
programmes
Share ownership
schemes
Models to meet
employee needs in
countries with dif?-
cult of?cial policies
Training programs
and work placement
for vulnerable /
excluded groups
Public safety
awareness
campaigns
Targeted products /
services for
disadvantaged
groups
HIV/AIDS awareness
and treatment
programmes
Support to
educational
programmes /
local enterprise
Corporate standards
applied within
business partnerships
and supply chain
Corporate
foundation
giving
H. General provisions of implementation
A1.
General
obligations
D. Rights of workers C.Right to security of persons
F13. Obligations
with regard to
consumer
protection
G14. Obligations
with regard to
environmental
protection
E. Respect for national sovereignty and human rights
Community
Investment strategy,
policy and program-
mes focusing on
human rights issues
Business develop-
ment / due diligence
processes
incorporate human
rights risks
B2.
Right to equal
opportunity and
non-
discriminatory
treatment
E
X
P
E
C
T
E
D
Formal
environmental
management
system(s)
E
S
S
E
N
T
I
A
L
A
R
E
A
D
E
S
I
R
A
B
L
E
Cooperation with
Human Rights
related institutions
Corporate policy
on protection
for whistle-blowing
Internal audits of
human rights
complaints
mechanisms
Offer fair and timely
compensation
A Human Rights Matrix (template version)
Public reporting,
for example
according to GRI
or other reporting
standards
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
T
H
E
S
E
S
T
A
N
D
A
R
D
S
A
R
E
N
O
T
F
I
X
E
D
A
N
D
W
I
L
L
E
V
O
L
V
E
O
V
E
R
T
I
M
E
Do not interfere
with union
activities after
hours and
cooperate with
union and workers
to participate in
union business
during working
hours
Refrain from
exerting any
inappropriate
in?uence that
might jeopardize
the independence
of the union
Avoid actions
which may
undermine the
union’s credibility
with members
D6. Childrens’
rights
Train managers to
ensure they are
able to detect
different forms of
forced labour
Rigorously
inspect work
facilities to
ensure that
premises are free
from all forms of
forced labour
Rigorously
inspect suppliers’
facilities to
ensure that
premises are free
from all forms of
forced labour
Develop
understanding from
standards such as
the Voluntary
Principles on
Security and Human
Rights on how to
best manage
relations with
security staff and
engage in training of
relevant staff on the
protection of human
rights.
Work with the
local police
(public) or security
service providers
(private) in
advance of a
project to develop
a common
understanding and
agreement to
protect human
rights in the event
of a dangerous
situation requiring
intervention.
Carry out a risk
assessment study
of the home and
host countries
and of actors in
the supply chains
in both countries.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Public reporting,
for example
according to GRI or
other reporting
andards.
A Human Rights Matrix
15 lNTRODUCTlON
C3. Right to
security of persons
C4. Security
arrangements
D5. Forced or
compulsory labour
D7. Safe and
healthy workplace
D8. Adequate
remuneration
D9. Freedom of
association /
collective
bargaining
E10. Respect for
national governance
practices
E11. Bribery E12. Contribution to
realisation of human
rights
H15.
Internal rules
of operation
H16. Monitoring H17. Reparations
Public statement of
commitment to
human rights
Equal opportunities
policy
Employee self-
protection advice /
training
Criteria in contracts for
for security services
Bribery and
corruption
prevention policy
On-going studies
into the safety of
products and
services
Environment policy Code of conduct 3rd party veri?-
cation of CSR
reporting
Public statements of
commitment to ILO
Core conventions,
UDHR, OECD
guidelines, etc.
Progressive
Maternity, Adoption,
Family leave,
Harassment policies
Supplier screening /
monitoring
Global HSE guide-
lines specifying
standards,
implementation and
compliance process
Pay at least living
wage in all
countries
of operation
Establishment of
Consultative
Committees (e.g.
Health and safety)
Commitment to
political neutrality
Board Committee
with terms of refe-
rence covering
environmental and
social issues including
human rights.
Committee)
Focused diversity
initiatives/
programmes and
leadership structure
Safety management
system
Pension provision
in all countries of
operation
Letter of Assurance
process
Procurement
process assessed
Annual review of
policies
Diversity awareness/
training for
employees
Publication of
performance data
Merit-based pay
and performance
system
Board Audit and
Compliance
Committee
Goals for reduction
of energy
consumption
Support for speci?c
programmes e.g.
black empowerment
in South Africa
Training for
employees and
selected
Third Parties
Wage level
incorporated into
supplier screening
criteria
Transparent public
reporting in Annual
Report
Established risk
management process
Public reporting of
basic performance
metrics
Participation in
industry safety
forums and
initiatives
Certi?cation of
ISO14001
environmental
management
programme(s)
Chairman's award
to promote best
practice
Employee personal
accident insurance
Withdrawal from
countries where
forced labour is
prevalent
Safety working
groups
Enhanced pension
schemes
Trade union
consulted on all
business changes that
impact employees
in relevant areas
Participation in
public good
governance debate
incl. corruption
Training on
compliance /
Grey zones
Matched giving
(support employee's
charitable giving)
Supplier development
programme
Internal audits of
social and environ-
mental performance
Membership of
forums promoting
diversity, gender
balance etc.
Employee Assist
(24 hour
con?dential
help line)
Community safety
education
programmes
Share ownership
schemes
Models to meet
employee needs in
countries with dif?-
cult of?cial policies
Training programs
and work placement
for vulnerable /
excluded groups
Public safety
awareness
campaigns
Targeted products /
services for
disadvantaged
groups
HIV/AIDS awareness
and treatment
programmes
Support to
educational
programmes /
local enterprise
Corporate standards
applied within
business partnerships
and supply chain
Corporate
foundation
giving
H. General provisions of implementation
A1.
General
obligations
D. Rights of workers C.Right to security of persons
F13. Obligations
with regard to
consumer
protection
G14. Obligations
with regard to
environmental
protection
E. Respect for national sovereignty and human rights
Community
Investment strategy,
policy and program-
mes focusing on
human rights issues
Business develop-
ment / due diligence
processes
incorporate human
rights risks
B2.
Right to equal
opportunity and
non-
discriminatory
treatment
E
X
P
E
C
T
E
D
Formal
environmental
management
system(s)
E
S
S
E
N
T
I
A
L
A
R
E
A
D
E
S
I
R
A
B
L
E
Cooperation with
Human Rights
related institutions
Corporate policy
on protection
for whistle-blowing
Internal audits of
human rights
complaints
mechanisms
Offer fair and timely
compensation
A Human Rights Matrix (template version)
Public reporting,
for example
according to GRI
or other reporting
standards
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
T
H
E
S
E
S
T
A
N
D
A
R
D
S
A
R
E
N
O
T
F
I
X
E
D
A
N
D
W
I
L
L
E
V
O
L
V
E
O
V
E
R
T
I
M
E
Do not interfere
with union
activities after
hours and
cooperate with
union and workers
to participate in
union business
during working
hours
Refrain from
exerting any
inappropriate
in?uence that
might jeopardize
the independence
of the union
Avoid actions
which may
undermine the
union’s credibility
with members
D6. Childrens’
rights
Train managers to
ensure they are
able to detect
different forms of
forced labour
Rigorously
inspect work
facilities to
ensure that
premises are free
from all forms of
forced labour
Rigorously
inspect suppliers’
facilities to
ensure that
premises are free
from all forms of
forced labour
Develop
understanding from
standards such as
the Voluntary
Principles on
Security and Human
Rights on how to
best manage
relations with
security staff and
engage in training of
relevant staff on the
protection of human
rights.
Work with the
local police
(public) or security
service providers
(private) in
advance of a
project to develop
a common
understanding and
agreement to
protect human
rights in the event
of a dangerous
situation requiring
intervention.
Carry out a risk
assessment study
of the home and
host countries
and of actors in
the supply chains
in both countries.
Compliance with the ‘core’ Conventions of the International Labour Organisation
Compliance with national laws and regulations in the countries of operation
Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant on
Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination of
All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women and the Convention on the Rights of the Child.
These commitments are universal and enforced by governments, but also apply in situations where a government is unwilling or unable to enforce these standards.
Public reporting,
for example
according to GRI or
other reporting
andards.
16
Identifying human rights priorities – some examples
Energy Utilities National Grid has produced
a variation of the Human Rights Matrix, which
relates the different human rights areas of the
company’s responsibilities to different stake-
holder groups such as government, business
and domestic customers, local communities,
investors, employees, and suppliers.
Pharmaceutical Sector Novartis has used a
corporate citizenship matrix containing human
rights principles to help defne the sphere of
infuence of the pharmaceutical sector as it
relates to the Access to Medicines policy and the
ethical principles of the Declaration of Helsinki
on clinical trials.
Extractive Sector Statoil has applied the
Human Rights Matrix in detail as a strategic
tool to better understand the total impact of its
activities in Venezuela.
Media and Entertainment Industry MTV
Networks Europe has applied the Human Rights
Matrix to all On-Air and Off-Air operations in the
UK and Ireland and as a result is one of the frst
media companies to develop policies based on
human rights considerations.
For more information on the above examples,
please go to www.blihr.org or visit the company
websites shown in the Appendix to this Guide.
1.4 Define anD embeD appropriate management responsibilities
A strong commitment to human rights from a company’s senior leaders is a prerequisite for embedding
human rights into a company’s operations and activities. Support from senior leaders ensures that human
rights issues are taken seriously and become part of business strategy. A number of companies have found
that having a member of the board of directors or executive management team assume overall responsibil-
ity for human rights-relevant issues has been important in ensuring that these matters receive the required
degree of attention. Clear lines of accountability have also proven to be vital. These companies typically have
a designated senior manager who is responsible for implementing the company’s human rights policies and
driving performance improvement. The senior manager generally reports to the executive level and may be
responsible for one of several possible functions / departments in the company, such as human resources,
procurement, legal affairs, public affairs, or the sustainability department.
1.3 Develop a human rights strategy for your business
Having identifed the human rights risks and opportunities, it is necessary to set out what the organiza-
tion wants to achieve (the vision) and how it intends to achieve it (the strategy). For many companies, this
will entail setting out how they will integrate human rights considerations into their existing management
systems and cover issues such as leadership, planning, defning roles and allocating resources.
STRATEGY
17
Embedding management responsibilities – some examples
Articles of Association Novo Nordisk’s Articles
of Association specify that the company will ‘strive
to conduct its activities in a fnancially, environ-
mentally and socially responsible way.’ The Novo
Nordisk commitment to sustainable development is
anchored in the company’s corporate governance
and its fundamental business principles, called the
“Novo Nordisk Way of Management.” The Novo
Nordisk Way of Management explicitly refers to the
Triple Bottom Line (TBL) — social, environmental
and fnancial responsibility — as the company’s
underlying business principle. Since 1999, the Novo
Nordisk Way of Management has included a com-
mitment to support the United Nations Universal
Declaration of Human Rights and to integrate hu-
man rights considerations into its daily business.
Board-level representation National Grid’s board
subcommittee, the Risk and Responsibility Com-
mittee, is chaired by a Non-executive Director and
has responsibility for reviewing the management
of non-fnancial issues, policies, and standards and
for reviewing the performance of the Group. Where
appropriate, this includes that of its contractors
and suppliers. The Committee’s remit includes
occupational and public safety, occupational health,
environment, inclusion and diversity, human rights,
business ethics, and community involvement.
Executive level representation ABB’s human
rights policy is embedded in its social policy and
is the responsibility of the head of the Sustain-
ability Affairs group. He reports on the economic,
environmental, and social aspects of the group’s
business activities and the human rights poli-
cies and commitments to a member of the group
executive committee who has overall responsibility
for sustainability issues. Environmental and social
policies are monitored and enforced by country
and regional sustainability controllers in the 100
countries where ABB operates.
Ethical Guidance Council Copel, whose vision
statement makes explicit its aim to “become the
best company within the Brazilian power sector
by 2006, striking a balance between the interests
of the community and of its shareholders,” has an
Ethical Guidance Council whose role is to discuss
and guide Copel’s actions, examine submitted
cases, and recommend appropriate sanctions, to
ensure that the Company’s actions are conducted
in accordance with sound principles and to over-
see the dissemination and effective application of
the Copel Code of Conduct across all sectors of
the Company. To ensure its autonomy, the Council
is made up of the Company’s employees, each
representing their respective different professional
categories, and is coordinated by a representative
of civil society.
Mainstreaming Human Rights Novartis has
developed and implemented human rights related
Corporate Citizenship Guidelines and implemented
them through line management.
Direct involvement of the Chief Executive Offcer
The Managing Director of each Tata company is also
its Principal Ethics Offcer who nominates an Ethics
Offcer and a team of Location Ethics Counsellors.
Together this team is responsible for the Management
of Business Ethics (MBE) in the company and for
ensuring compliance of the Tata Code of Conduct – a
written document.
Human Resources In January 2005, the CEO of
Valeo, an automobile company based in France,
decided that the responsibility for implementing
and monitoring the Group’s Human Rights policy
should be an integral part of the Human Resources
function. The Group Human Resources Director is
now responsible for dealing with any human rights
violations, as are the Human Resources Directors
across the Group entities.
STRATEGY
18
1.6 Develop your strategy through a circle of continuous
improvement To help ensure that implementation efforts remain on track, it is a good idea
to adopt a continuous improvement approach from the start. The plan-do-check-act circle may help in the
process of learning and improving along the way.
• Define roles and
responsibilities
• Document
• Impose
operational
control
• Measure results
• Internal audit
• Records of results
• Management
review
• Identify risks and
opportunities
• Set goals
P
L
A
N
D
O
A
C
T
C
H
E
C
K
Fig: The plan-do-check-act circle of continuous improvement with examples of activities to be undertaken in different
steps [First developed by Walter Shewhart, it was popularized by Edwards Deming.]
2 Policy
1.5 integrate human rights into your company’s activities
Particularly in large companies, integration of human rights may be a complex process that involves several
organizational levels and different types of operations in different parts of the world.
To track progress, adequate indicators and goals must be developed for different activities; internal audits can
prove key in tracking progress. The main purpose of audits is to check that the system is working according to
plan, that new issues are captured by the system, and that performance is continually improved.
Often progress on an issue across an entire company is gradual and incremental. In the meantime, imple-
mentation efforts for the company as a whole can be complemented by local strategies and special plans for
certain operations and units. These ‘bottom-up approaches’ can be developed quickly to meet the challenges a
business faces in a particular geographic location or a specifc production process.
STRATEGY
19
2 Policy
2.1 incluDe human rights in your existing policies
A policy statement sets out the direction and gives the overall goals for a company in a certain area of
activity. It should drive the management of the activity in the company and be supported by programs and
objectives throughout the organization, to ensure that the policy and related commitments are implemented
and maintained. More and more companies include human rights either as a policy in itself or as part of
other policies in the governance structure.
Human rights in policies: key steps for your business
2.1 Include human rights in your existing policies
2.2 Develop specifc human rights policies where appropriate
2.3 Develop local policies to meet local situations
2.4 Ensure full implementation of your policies and review their outcomes
Including human rights in existing policies – some examples
Barclays Barclays developed a human rights
framework in 2004 to draw together a wide
range of existing policies relevant to its human
rights impact as an employer, purchaser of goods
and services, and provider of fnancial services
to customers. Policies were mapped using the
Human Rights Matrix to ensure areas of strength
and to identify any “gaps.” The framework was
formally approved by the heads of each business
line and supports the Corporate Responsibility
Board Governance Standard, one of a series of
standards through which the Barclays Board tracks
compliance with desired business objectives and
regulatory requirements. Since adoption of the
framework, work has continued in integrating
human rights considerations into practice. For
example, Sourcing management is strengthening
existing social and environmental supplier
screening/engagement criteria to incorporate
human rights aspects more explicitly into the
assessment of sourcing proposals. While it is
paramount that contracts deliver commercial
beneft, human rights aspects can be a signifcant
factor in decision-making. From a workforce
perspective, Barclays – like many businesses – has
longstanding policies on human rights-relevant
issues including health and safety, equality and
diversity, non-discrimination, and many others. The
human rights impact of lending, however, is the
area where most dilemmas arise, as the impact is
indirect. Here, Barclays’ human rights framework
focuses on risk management and the identifcation
of social and environmental risks in assessing and
sanctioning fnancial propositions.
POLlCY
20 20 21
Checklist for a human rights policy
q Does the policy comply with existing international human rights conventions and norms, such
as the United Nations Universal Declaration of Human Rights, the International Covenant on Civil
and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the
International Labour Organization’s Declaration on Fundamental Principles and Rights at Work?
q Is the policy relevant to your company and its sphere of infuence?
q Does the policy include a commitment to respect, protect and promote human rights and to
avoid complicity in human rights abuses?
q Does the policy extend to all parts of the organization and other existing policies such as
health and safety, procurement, and human resources?
q Does the policy include your company’s expectations of its partners, joint ventures, customers,
and supply chain?
q Has consideration been given to tie in with existing codes and guidelines where appropriate,
such as the Global Compact Principles, the ILO’s Tripartite Declaration of Principles Concerning
Multinational Enterprises and Social Policy, the Organisation for Economic Co-operation and
Development’s Guidelines for Multinational Enterprises, and Social Accountability 8000 (SA
8000)? A more detailed list of existing codes and guidelines is included in the Appendices.
2.2 Develop specific human rights policies where appropriate
A good human rights policy should give consideration to the points in the checklist below:
Including human rights in existing policies – some examples
Hewlett-Packard’s Global Citizenship Policy
states its commitment to the Universal Declaration
of Human Rights and includes specifc policies
on human rights and labor, as well as employee
privacy. HP’s Global Citizenship organization
provides the governance for human rights and the
other key aspects of its commitment to corporate
citizenship.
Human Rights are integral elements of Corporate
Citizenship at Novartis. To put the Novartis
human rights responsibilities in the wider context
of a fair societal division of labor, the Novartis
Corporate Citizenship Guideline on Human Rights
is supported by a commentary.
http://www.novartis.com/corporate_citizenship/
en/guidelines.shtml
POLlCY
Getting started
20 21
Companies that have been recognized for including human rights in policies
The Business and Human Rights Resource Centre
(www.business-humanrights.org) is a valuable
resource for people interested in understanding
different perspectives of business and human
rights. It lists companies that have taken the step
of adopting a formal company policy statement
explicitly referring to human rights.
It also notes which companies are participants in
the Global Compact.
2.3 Develop local policies to meet local situations
It may be benefcial for international businesses to use local policies based on corporate standards and
national requirements. These local policies need to be translated into local languages to facilitate their under-
standing and implementation. However, local policies should not contradict the general corporate standards.
For example, in some cultures it is common practice for bribes to be sought and made, while at the interna-
tional level such practices are unlawful as well as being irreconcilable with a commitment to human rights.
Human rights embedded in local policies –
some examples of tackling national and local discrimination
Equity (South Africa) Eskom has incorporated
issues of human rights - especially those relating
to employment equity and the local social needs
of the country - into its decision-making proc-
esses. In South Africa, Eskom developed employ-
ment equity policies, performance indicators and
reward systems to ensure that the organization is
representative of the country in which it operates.
Affrmative action, gender equity and the rights of
people with disabilities are key elements. Simi-
larly, targets and performance indicators are set
for procurement practices that proactively support
and develop Black Economic Empowerment (BEE)
and, in particular, Black Woman Owned business
and small and medium sized enterprises.
Professionals with disabilities (Mexico)
Through the Mexico-based program Congru-
encia, CEMEX Mexico has developed a policy of
inclusion for workers with disabilities, intended to
enhance their job opportunities and to raise com-
munity awareness on the issue of social equity.
This program is managed through a specialized
website that provides information on vacancies
and human rights. In 2004, the program was
opened to other companies and currently involves
more than 20 public and private institutions,
which promote favorable conditions for social and
labor inclusion.
POLlCY
22 23 22 23
2.4 ensure full implementation of your policies anD
review their outcomes Group and local policies should be the overall responsibility
of identifed individuals within the business who are tasked with ensuring the policies are fully implemented.
These individuals should ensure that there are suffcient resources for implementation, the results are moni-
tored, and the policies are regularly reviewed. Even the most clearly defned policies will require interpretation.
The policy owner should act as a focal point for dealing with human rights issues that arise through imple-
mentation and should have access to both local and international expertise.
3 Processes and
Procedures
Human rights embedded in local policies –
some examples of tackling national and local discrimination
Women’s rights (Sri Lanka) MAS Holdings
(an apparel manufacturer) has a business model
that supports the empowerment of women. With
92 per cent of the total workforce of 34,000
employees in the company being made up of
women, MAS has developed best practices in
its corporate citizenship program to empower
women. The “Go Beyond” program at MAS
recruits economically less affuent, rural women
and teaches them English language skills and
how to use IT-enabled tools to advance their ca-
reers. The female employees are also trained to
manage their fnances, to have an understand-
ing of sexual and reproductive health and to
achieve a better work-life balance. The work-life
balance initiatives recognize and support the
multiple roles played by career women and the
need for a healthy balance between work and
personal life. MAS also rewards high-achievers
in academia, sports, science, commerce, and
arts and culture. Employees are encouraged to
perform better through annual awards such as
the ‘Empowered Woman of the Year Award.”
Community initiatives, especially those that im-
prove educational and healthcare infrastructure
for young women, have been a long standing
tradition at MAS. The company ensures that
its predominantly female workforce has a high
level of confdence and self-esteem. This in turn
has helped the company to grow its business
POLlCY
22 23 22 23
3 Processes and
Procedures
Human rights in processes and procedures:
key steps for your business
3.1 Consider the full scope of your business activities and functions
3.2 Establish procedures for identifying your human rights-related risks
and opportunities
3.3 Establish control systems for managing human rights in your business
3.4 Learn from sector-wide business initiatives
3.5 Expect the unexpected – how to react when procedures are not enough
3.1 consiDer the full scope of your business activities
anD functions As part of human rights policy implementation, it is crucial to defne the pro-
cesses and procedures that will make the policy a reality. The processes and procedures may differ according
to business context within the same company. However, what they will all have in common is that they are
intended to achieve the same result, are documented, and have measurable indicators and outcomes.
The executive management team of the business is responsible for ensuring that roles, responsibilities,
authority, and resources are defned and allocated in a way that enables effcient implementation and main-
tenance of human rights management in the organization.
3.2 establish proceDures for iDentifying your human
rights-relateD risks anD opportunities As already outlined
in the section on Strategy, the key to managing human rights in an organization is to analyze and
understand the risks and opportunities in a company’s operations. Ensuring compliance with legal
requirements and international treaties is essential to this analysis and should be reviewed regularly
as part of the management process.
PROCESSES AND PROCEDURES
Getting started
24 25 24 25
Human rights as an important factor in a country risk assessment – an example
Statoil has formulated country and reputation
risk guidelines to ensure the company has wide-
ranging knowledge and understanding of local
conditions, business culture, and external factors
as early as possible in a business project. The
aim is to minimize Statoil’s country and reputa-
tion risk exposure through the early identifca-
tion, prioritization, and mitigation of risks that
may affect a project or business opportunity.
Risk mitigation alternatives are specifed for
every signifcant risk factor that is identifed; the
level of detail depends on how far the project
or business opportunity has progressed. Risk
mitigation measures refect Statoil’s corporate
social responsibility strategy and its require-
ments for social investment management. Risk
assessments are performed regularly and when
signifcant events occur. The risks are divided
into 19 factors within the following categories:
• Political risk elements
• Country-specifc operational risk elements
• Reputational risk
Human rights and possible violations are impor-
tant factors within the political risk category.
The Human Rights Matrix developed by BLIHR can help companies identify risks and opportunities.
Stakeholder panels may give advice on external concerns regarding a company’s operations and may also
provide input on possible solutions. Mapping a company’s sphere of infuence may also help to identify the
risk of complicity when operating in a country with a poor record on human rights. In addition, calling for
regular checks and updates is advisable if a particular country ranks low on an index of corruption levels
for instance. Finally, input from non-governmental organizations (NGOs) and external country assessments
can provide additional value.
3.3 establish control systems for managing human
rights in your business Once risks and opportunities have been identifed for each
business operation, a company should develop and implement adequate control processes for those op-
erations. Control processes could range from a supplier qualifcation process with a mandatory risk review
of customer projects, to a code of conduct that ensures equal opportunity and minority rights, or a checklist
and instructions for business operations in sensitive areas. Guidelines for suppliers and contractual agree-
ments with customers and suppliers have proven to be powerful tools for ensuring that risks are minimized
or eliminated and opportunities are maximized.
PROCESSES AND PROCEDURES
24 25
Introduction
24 25
Human rights in different types of control systems – some examples
Identifying market opportunities National Grid
does not have extensive operations in countries that
are considered to be ‘of urgent concern’ in relation
to some aspects of human rights. The utility com-
pany has therefore focused on extending its existing
risk management by identifying and understanding
the areas where the Group might be exposed to hu-
man rights risks and opportunities when developing
new business in emerging markets. As a result, it
has revised its business development procedures
to include an analysis of human rights risks when
identifying market opportunities. It has also devel-
oped protocols to enable an analysis of potential
target companies, to assess their approach and
record on human rights issues.
Editorial practices MTV Europe is developing
a Code of Editorial Conduct, which will be one
of the frst in the industry to be based on human
rights values. The Code and its procedures for
application will be based on MTV’s understand-
ing of its spheres of infuence and would provide
internal processes for creative thinking and
decision-making. This in no way will involve
censorship; instead it will enable the company to
take better-informed risks.
Purchasing practices Gap Inc. is working
towards better human rights compliance by im-
proving supply chain operations and embedding
labor standards directly into business practices.
Ultimately, Gap believes garment manufacturers,
most of whom are multinational corporations,
must take responsibility for conditions in the
factories they own and operate. To encourage
them to take that responsibility seriously, Gap is
developing a formal tool that will enable them to
consider a garment manufacturer’s compliance
record – along with criteria such as cost, speed,
quality, and innovation – when deciding where to
place orders. At the same time, Gap recognizes
that its own business practices can have an
impact on compliance, and is actively exploring
better ways to work with its manufacturers. To
avoid contributing to excessive overtime, Gap is
making a greater effort to ensure that garment
manufacturers have accurately assessed their
capacity and capabilities before orders are
placed with them. Gap is also working to reduce
ineffcient purchasing practices such as rush
orders and last-minute changes.
Lending assessments Human rights issues
such as the rights of indigenous peoples, are
included in the Equator Principles which defne
social and environmental criteria that apply to
project fnancial transactions (see the Appendices
for details). Barclays was one of the original group
of banks to adopt the Principles in June 2003
and, while the criteria is specifc to project-related
lending, Barclays extends the “spirit” of the Prin-
ciples when assessing other types of lending.
Performance standards for resettlement The
International Finance Corporation (IFC) is in the
process of adopting a new set of performance
standards that it will require its clients to adhere
to as a condition of lending. One of the perfor-
mance standards addresses involuntary resettle-
ment – a process in which governments move
people to make way for projects in the public
interest such as roads or water treatment plants.
In preparing the new performance standard, IFC
reviewed the human rights protections in the
right to housing and incorporated those aspects
of the right to housing that the private sector can
take action on within a project context.
(continued on next page)
PROCESSES AND PROCEDURES
26 27 26 27
Human rights in different types of control systems – some examples
(continued) For example, anyone moved must
be provided with security of tenure in their new
location, even if they did not have security of
tenure in their previous location. This refects
the right to housing with emphasis on providing
everyone with security of tenure – i.e. protection
against illegal eviction. If an IFC-fnanced project
involves involuntary resettlement, the company
must prepare a detailed plan for resettlement,
including plans for providing informal settlers with
security of tenure in a new location. IFC then
reviews and approves the plan as a condition
of fnancing. As a further condition of fnanc-
ing, the client must implement the plan, monitor
and ensure that the actions taken achieve the
objectives set out in the performance standard
and the resettlement plan. If the resettlement is
suffciently large or diffcult, IFC will require an
independent third party to monitor implementa-
tion of the resettlement activities.
Scheduled and unscheduled inspections Li
& Fung (Trading) Limited, based in Hong Kong, is
a global trading group that manages the supply
chain for high-volume, time-sensitive consumer
goods – particularly garments, furnishings, gifts,
home products, toys, and sporting and travel
goods. From Hong Kong, it co-ordinates the manu-
facture of goods through a network of offces in
almost 40 countries. All suppliers to Li & Fung
are required to commit to the Code of Conduct
to Vendors, which has 14 principles, including no
child labor and non-discrimination principles. A
signed copy must be returned to Li & Fung within
30 days, and failure to give a timely response will
cause it “to review its relationship with [the sup-
plier].” The code is enforced through scheduled
and unscheduled inspections.
Managing Third Party relationships The
objective of Novartis’ Third Party Guidelines is
to provide criteria, tools, and procedures for: (1)
the assessment and approval of Third Parties;
and (2) the continuous management of business
relationships. The standards set forth in this Third
Party Guideline apply to Corporate Functions
and all Novartis Divisions and Business Units. No-
vartis Divisions and Business Units either adopt
these guidelines as is or issue an equivalent
guidance note of their own. http://www.novartis.
com/corporate_citizenship/en/guidelines.shtml
Supply chain management Human rights are a
central focus of Hewlett-Packard’s Supply Chain
Social and Environmental Responsibility (SER) Pro-
gram. One of HP’s biggest challenges is to apply
its Human Rights Policy in its supply chain, where
it does not have direct control. One way HP is
addressing this is through the Electronic Industry
Code of Conduct (EICC), which HP co-developed
with Dell, IBM, and several large contract manu-
facturers in 2004. The Code provides an important
foundation for ongoing supplier audits and other
efforts to ensure compliance with the HP Human
Rights Policy. Most importantly, it makes supplier
performance easier to audit and verify.
Gap Inc. views SA8000 as a premier set of global
labor standards towards which they hope gar-
ment manufacturers will aspire. A few of their
suppliers have already received SA8000 certi-
fcation. As a member of Social Accountability
International’s Corporate Involvement Program,
Gap Inc. recently conducted a gap analysis of
their Code of Vendor Conduct relative to the
SA8000 standard and are examining areas in
which they can bring their policies and program
into closer alignment with SA8000. In addition,
they have asked their entire internal monitoring
team to take the SA8000 auditor course.
PROCESSES AND PROCEDURES
26 27
Getting started
26 27
3.4 learn from sector-wiDe business initiatives Some business sectors already
have an interest in sharing knowledge and experiences about human rights-based processes and procedures. It is
worthwhile researching which sector-specifc groups might be available to you and which might have valuable tools for you to
adapt to your business. Some examples are shown below:
Examples of sector-specifc initiatives with expertise
in human rights codes and procedures
3.5 expect the unexpecteD – how to react when proceDures are
not enough Given the rapidly changing nature of international business, processes and procedures constantly
require adaptation and review. Sometimes unexpected events can provoke human rights issues that had not been anticipated
or prepared for. In such situations, management is best able to deal with the situation if they have the knowledge (see the
section on Training) and resources to act quickly, professionally, and in ways that provide a just solution. Clear lines of ac-
countability within business strategies and policies make such fexibility possible, as does a commitment to transparency.
Reacting when confronted with unforeseen human rights issues
An example of responsiveness to unforeseen human rights
issues is how BP responded to Amnesty International’s
2003 Report on the Baku-Tbilisi-Ceyhan oil and gas
pipeline. The report highlighted a number of human rights
concerns relating to the Host Government Agreement
signed between the consortium of companies and the gov-
ernments of Azerbaijan, Georgia, and Turkey, and the ability
of these governments to uphold future human rights com-
mitments within the region of the pipeline. BP responded
by opening a dialogue with Amnesty International over a
period of several months during 2003. The talks resulted
in a legally binding additional contract designed to protect
the rights of the three host governments to promote and
regulate human rights and environmental issues.
(This case study appears in ‘Embedding Human Rights in
Business Practice’ – listed in the Appendices)
Business Sector Relevant Initiatives
Retail • Ethical Trading Initiative
• Fair Labor Association
• Social Accountability 8000
• Clean Clothes Campaign: Model Code
Mining • The Voluntary Principles on Security and Human Rights
• Kimberley Process (indirect human rights protection)
• The Extractive Industries Transparency Initiative (indirect human rights protection)
Financial Services • The Equator Principles
Oil and Gas companies • The Voluntary Principles on Security and Human Rights
• The Extractive Industries Transparency Initiative (indirect human rights protection)
Information Technology • Electronic Industry Code of Conduct
• Global e-Sustainable Initiative (GeSI)
PROCESSES AND PROCEDURES
28 29 28 29
4.1 share unDerstanDing of why human rights are
important to business communications The act of communicating is
in itself an essential part of a human rights approach; balancing freedom of expression with the protection
of personal or private information and the participation of stakeholders is essential. Your company’s human
rights policy, procedures, and performance should be documented and communicated to employees; for
instance, through codes of business conduct. They should also be made available through the corporate
website, company publications, annual reports, and notice boards – and in local languages, where ap-
propriate. In addition, companies should encourage suppliers to publicize to their employees the obligations
they have undertaken to uphold human rights in their business relations.
4.2 integrate human rights into your internal communications
Internal communication is critical to developing an effective human rights management system. Consistent
and well-presented top-down communication within a company serves to inform about human rights within
the business strategy. Employees should be informed about human rights risks and opportunities that the
company faces in its operations. The performance indicators that are used to monitor and measure the
effciency of the human rights management system should also be communicated to all. It is particularly
important for businesses to communicate to all employees the principal drivers behind human rights based
initiatives and their relevance to the long-term strategy of the company. The latter can prevent the marginaliza-
tion of initiatives and ensure that specialized departments handling human rights issues are fully integrated
into the company. An interactive approach to internal communications may generate greater understanding
and a fow of innovative ideas and proposals on how to improve established practices and procedures.
Effcient lines of communication with employees are also needed to ensure effective non-compliance reporting
and whistle-blowing. This requires clearly defned policies and procedures on the subject and clear contact
points in the organization. Human rights issues should be communicated using simple and straightforward
terminology, translated into relevant languages, and made widely accessible, including to employees with
disabilities. It may be useful to initially address human rights issues using business terminology, since human
rights may appear overly political or legalistic and may create barriers or misunderstanding. It is key that
communications are followed up by encouraging a culture of human rights recognition and respect in the
organization; it may be necessary to develop change management strategies to best facilitate this.
Human rights in communications:
key steps for your business
4.1 Share understanding of why human rights are important to business
communications
4.2 Integrate human rights into your internal communications
4.3 Integrate human rights into your external communications
4 Communications
COMMUNlCATlONS
28 29
Getting started
28 29
Human rights in internal communication – some examples
Communicating human rights within a
company’s code of conduct to employees
Human rights is a key part of Novartis’ code of
conduct. Setting out standards of professionalism
for the day-to-day conduct of associates around
the globe, the code describes how associates
should handle themselves ethically and safely in
a variety of potentially challenging situations. An
on-line e-learning package is being developed to
help managers and associates around the world
understand the real dilemmas that might occur in
the workplace and how the code can be applied.
Any effective human rights communication should
be appealing and attractive enough to awaken
and sustain the necessary level of interest, whilst
accurately presenting key messages. For this reason,
the Novartis Foundation for Sustainable Development
provides a human rights helpdesk for the whole
company and has also developed a ‘roll-out kit’ that
is available to potential users of the code.
Human rights within a ‘balanced scorecard’
used for staff appraisals Novo Nordisk has a
number of systems to ensure that it lives up to
its commitment to corporate responsibility. Each
year, the company defnes a number of corporate
responsibility targets that are contained in the
company’s “balanced scorecard.” Staff apprais-
als and management bonuses are dependent
on performance toward these targets. Facilita-
tors, who are a group of experienced staff with
an international background from the holding
company Novo A/S, make independent assess-
ments of individual departments’ compliance to
the Novo group’s values.
Communicating with staff throughout the
workplace The accomplishments of Taj Hotels (a
prominent member of the Tata Group) in the area
of human rights are largely the result of its em-
phasis on corporate ‘values.’ The company has
different ways of communicating and reinforcing
its values in the workplace, including e-mail foot-
ers, screen savers, posters, quiz programs and
billboards. A Performance Management System is
also used by the company.
A company needs to do more than just report on its human rights approach; it should ensure that human
rights are protected in all of its communications, including data protection, personal privacy, and company
confdentiality. Companies may also be responsible for the actions of their employees while at work, such
as the use of the internet or possible e-mail abuse.
4 Communications
4.3 integrate human rights into your external commu-
nications A company’s human rights record is central to its accountability and can affect its
reputation. To be accountable to stakeholders, a company must be transparent about its policies, ap-
proach and performance. Open and transparent communications on performance and a willingness to act
constructively following external advice are keys to success. The sphere of infuence of some businesses,
such as those involved in the media and communications, may lead them to have a signifcant impact
(positive or negative) on how human rights are viewed and respected in society.
COMMUNlCATlONS
Getting started
30 31 30 31
Human rights in external communication – some examples
Human rights on the high street As a
high street retailer, The Body Shop wants
to use its windows and daily contact with
thousands of customers to raise awareness
on human rights issues. Over the years, The
Body Shop has run numerous campaigns
to support human rights causes around the
world. Currently, the company is focusing
on issues facing customers, employees,
and the communities in which the com-
pany operates with a successful campaign
to Stop Violence in the Home, as well as
raising awareness of HIV/AIDS.
Stakeholder Advisory panel Although
most scientifc evidence states that
electric and magnetic felds do not result
in adverse health impacts, National Grid
recognizes that there is some limited
scientifc evidence suggesting the
opposite, and that parts of society are
concerned about this issue.
In 2003, National Grid took the initiative
to improve the dialogue between parties
with an interest in this issue by creat-
ing a Stakeholder Forum. The Group
engaged an independent body, the UK’s
Environment Council, to set up and
facilitate a workshop to which represen-
tatives from industry, Government, aca-
demia, professional bodies, and interest
groups were invited. This brought people
with differing views to the table for the
frst time. Although there was suspicion
of why National Grid had established the
Forum, involving some of the interest
groups in the planning for the meetings
helped overcome concerns. The partici-
pants in the Forum have now agreed
to establish a more formal Stakeholder
Advisory Group under the sponsorship of
the Department of Health.
Providing the opportunity for stakehold-
ers with opposing views to voice their
concerns has proved to be extremely
benefcial, both for the broader under-
standing of relative positions on the
subject and for the development of
sensible policy in this area.
Consultation with key stakeholders
Telefónica, a global telecommunications
company, has made a name for itself in
fostering equal opportunity and support-
ing the rights of people with disabilities.
Through the “Accessible Telefonica” plan,
the company uses stakeholder dialogue
and engagement to enhance equal op-
portunities and access to its telecommu-
nications services and products.
The plan is coordinated by Telefónica’s
CSR Department and involves a number
of business lines and subsidiaries. It
has been developed through a partner-
ship and framework agreement with the
main platform that represents people
with disabilities in Spain. As part of
the plan, consumers with disabilities
participate in consultation processes,
test products and services, and give
feedback about the degree to which
their needs and expectations are met.
The plan involves a range of projects in-
cluding the development of accessible
services and products, outreach and
awareness-raising with Telefónica’s
stakeholders, labor integration and
employment policies, internal regula-
tions that promote accessibility, and
research and development.
Human rights and on-air program-
ming For MTV Networks Europe, “hu-
man rights in external communications”
is less about communicating its internal
practices to the outside world than about
human rights in action: promoting hu-
man rights on air and on the ground, in
particular to its core youth audience.
The two strongest examples are two
ongoing multi-platform MTV human
rights campaigns: MTV’s Exit Campaign
to End Exploitation and Traffcking, and
the Staying Alive HIV/Aids Campaign. Both
campaigns comprise of MTV program-
ming (MTV specials such as the traffcking
awareness and prevention documentary
“Inhuman Traffc,” hosted by Angelina
Jolie, and the Staying Alive special “Meet-
ing Mandela”), awareness and prevention
events, multi-language websites www.
mtvexit.org and www.staying-alive.org,
and support for NGOs working to fght
traffcking and HIV/AIDS.
By developing and implementing such
campaigns on issues critical to its
core audience, MTV maximizes the
promotion and realization of certain
fundamental human rights within its
key spheres of infuence.
As for internal communications, a company should ensure that
human rights are protected in all of its external communications.
For example, if local communities want to communicate with
the company through protest, the company should respect their
right to freedom of expression and should not seek to repress
demonstrations or ask governments to do so, even if the com-
pany does not agree with the message or the style of communi-
cation. In gathering and retaining information about employees,
customers, or others, companies should follow data protection
rules and respect the right to privacy. This is especially true
where companies hold sensitive health or other private informa-
tion gathered for the company’s human resources fles.
COMMUNlCATlONS
30 31
Introduction
30 31
5 Training
Human rights in training: key steps for your business
5.1 Identify target groups in your business to receive human rights training
5.2 Review the different types of training materials available
5.3 Select, organize and evaluate the training program for target groups
5.1 iDentify target groups in your business to receive
human rights training General employee training needs to provide an understand-
ing of how human rights relate to the business and must raise awareness of human rights risks and
opportunities. A needs analysis of employees at particular business sites or of those who perform specifc
functions can help identify areas which the training should cover. Case studies can support this training.
Key employees throughout the organization should receive function-specifc training; for example, training
about specifc risks in their operations and how to handle them, or training on new procedures and tools.
Target groups for training could include:
• Procurement employees
• Sales and export staff
• Human resources
• Security staff
• All supervisors and managers
The company can also take steps to train key suppliers and contractors. Stakeholders and external partners
can help with training on specifc issues such as political, geographical, and cultural risks. Key staff should
also participate in external training where independent experts challenge others and give specialist insight into
specifc human rights issues.
5.2 review the Different types of training materials available
There are a range of different types of human rights training available: web-based and paper-based or in
person, held either in the workplace or at a special venue outside the business location.
TRAlNlNG
0.0 Xxxxxxxxxxxxxxxxxxxxxxx
Xxxxxxxxxxxxxxxxxxxxx.
Getting started
32 33 32 33
Human rights in different types of training – some examples
E-learning systems Novartis requires every
manager and associate to complete a number of
web-based courses as part of its commitment to
the group’s compliance initiative and its commit-
ment to hold all associates to the highest stan-
dards possible. Ensuring that Novartis employees
across 140 countries understand the company’s
Human Rights Guidelines and the strategy behind
them represents a huge challenge. Therefore, in
2005 all non-US Novartis associates with e-mail
access will complete four out of the following
six courses, each involving human rights as a
key element: Insider trading, Confict of interest,
Corporate citizenship, Sales practices, Marketing
practices, and Financial integrity.
Specifc training for business units National
Grid has over 8,000 active suppliers. The group’s
procurement teams are experienced in assess-
ing suppliers’ environmental, safety, and quality
performance, but not in assessing other human
rights-related performance. During 2005, the
Groups’ UK and US procurement team mem-
bers received human rights awareness training
and were introduced to a practical tool to help
prioritize their human rights assessments. The tool
is being used to assess the human rights risk as-
sociated with each purchased commodity and the
infuence that the purchaser has with suppliers of
each commodity. This analysis is used to identify
the level and priority of human rights-related
engagement with potential suppliers.
Staff induction Every employee at The Body
Shop is required to attend a staff induction that
includes a signifcant section on the company’s
commitment to ethical trade, community trade,
campaigning, environmental protection, and animal
welfare. In addition, in connection with the launch
of the campaign to Stop Violence in the Home, all
stores will be provided with training materials to
ensure that all employees understand the issues
and the importance of the campaign activities.
Management handbooks and primers
The Business and Human Rights Management
Primer produced by Shell in 1998 was one of the
frst of its kind in business. The primer is a key re-
source for human rights training programs within
the company and has been augmented by a series
of real-life management dilemmas for training
purposes. Another good example is the Human
Rights Guidance report developed by Rio Tinto.
Residential Multi-Business Human Rights
Training There is an increasing demand for resi-
dential training, which allows business managers
from a number of companies to gather in a less
formal setting. Some examples are listed in the
Appendices.
5.3 select, organize anD evaluate the training program
for target groups The selection of the appropriate training program is based on factors
such as cost, location, and the technology involved. It is worthwhile to ask other businesses and business as-
sociations which programs they have found the most useful, but remember that no two businesses are alike.
It is likely that stakeholders from the local community or NGOs will have much to contribute to any program
that is to be organized. It is essential in these circumstances that the business and NGO or community group
work together in partnership to clearly defne expectations and develop a productive working relationship.
TRAlNlNG
32 33
Getting started
32 33
6 Measuring
Impact and Auditing
6.1 Set relevant performance indicators for measuring human rights impact
across the different functions of your business
6.2 Undertake human rights-based audits
6.3 Analyze the results of audits and use results to inform strategic
development of your business
6.1 set relevant performance inDicators for measuring
human rights impact across the Different functions of
your business A company should develop quantifable performance indicators to monitor and
measure elements in its operations that have an impact on human rights. Performance indicators should
measure both the direct result of the company’s operations and the effciency of management processes
that infuence performance – such as training and the allocation of resources.
The indicators should be relevant to the company’s sphere of infuence, activities, and industry sector, and
should drive continuous improvement. They should relate to the organizational goals of the business and be
consistent with the risks and opportunities that the company has identifed. Measurements should be made
regularly and be communicated to employees and other interested parties. Since a company’s sphere of
infuence may change over time, performance indicators should be reviewed on a regular basis.
Measuring Impact – The Human Rights Compliance Assessment Tool
The Danish Institute for Human Rights has devel-
oped an interactive database for use by business
in any specifc national market. The web-based
tool contains approximately 350 questions for
business and more than 1,000 corresponding
human rights indicators, developed from the
Universal Declaration of Human Rights and
over 80 other major human rights treaties and
International Labour Organization (ILO) conven-
tions. Over 70 businesses were involved in the
development of the tool, and the database is now
being refned into some sector-specifc versions.
Human Rights in measuring impact and auditing:
key steps for your business
MEASURlNG lMPACT AND AUDlTlNG
34 35 34 35
Measurement of performance – an example
6.2 unDertake human rights-baseD auDits
Human rights-based audit programs should be part of a company’s governance procedures. Audits establish
whether management systems are working as planned; they focus on the causes of problems and the neces-
sary corrective measures. Human rights-based audits by qualifed personnel, preferably verifed by external
human rights experts, should be carried out regularly and made available publicly. Auditing is also a tool for
the Board and Executive Committee of a business to ensure that the strategies, policies, procedures, and
processes outlined in this Guide have been properly implemented across the company.
Human rights-based audits – an example
Building relationships with local NGOs
As part of its long-standing partnership with
Carrefour, the International Federation for Human
Rights (FIDH) set up a system of independent
monitoring of the company’s Charter, which is
based on human rights. By engaging with an
established NGO in this way, Carrefour was able to
ensure the credibility of the monitoring system.
MEASURlNG lMPACT AND AUDlTlNG
As part of its policy to develop a human rights-
aware approach in its business activities, ABB
developed a checklist for managers based on
the Global Reporting Initiative’s (GRI) guidelines
on human rights and the Draft Norms. ABB
established the checklist’s criteria by carrying out
a gap analysis between the Draft Norms and the
GRI guidelines (published in the second BLIHR
report – see the Appendices).
The risk assessment checklist mirrors human
rights categories listed in the Draft Norms – the
rights of workers, occupational health and safety,
non-discriminatory treatment, the rights of local
communities, transparency and business ethics,
and protection of the environment.
Acting on behalf of BLIHR, ABB is testing the
checklist within the parameters of its rural electri-
fcation program – called Access to Electricity – in
Tanzania and sub-Saharan parts of Africa. Initial
results show that while the checklist is suffcient
in some situations and countries, it needs to
include extra questions and be made more coun-
try-specifc for more sensitive nations.
A human rights-aware approach benefts all stake-
holders – villagers, local authorities, suppliers, and
the companies and organizations involved in Ac-
cess to Electricity. For ABB, it also means lowering
business risk through taking a wider approach on
the potential impact of such projects.
Working within the GRI’s internationally ack-
nowledged framework may help make the Draft
Norms easier to accept and implement for a
wider circle of transnational corporations. It would
provide a comparable reporting system built on
auditable performance criteria.
34 35
Getting started
34 35
The use and analysis of human rights in business audits – some examples
Auditing Equal Opportunities and Diversity
Each year, all business areas in Novo Nordisk de-
velop action plans for ensuring that equal oppor-
tunities and diversity (EO&D) are fully embedded
in all relevant business processes spanning the
employment cycle (recruitment, working condi-
tions, remuneration, development, promotion and
termination). EO&D targets are included in the
company’s “balanced scorecard,” the perform-
ance management mechanism used to drive all
key areas of business performance. These tar-
gets require the action plans to be submitted for
evaluation by the human resources function, and
that - as a minimum - 80% of the actions for the
year are achieved. The achievement of the EO&D
targets is directly linked to staff appraisal and
individual bonuses in management. Failure to
meet these targets in any of the business areas
is visible within the company, and initiates a
dialogue process between the human resources
function and the business areas involved.
Assessing risk to determine auditing needs
Every approved supplier to The Body Shop must
sign an agreement committing to meeting The
Body Shop Ethical Trade standards, which are
based on the Ethical Trading Initiative’s Base
Code. First-tier product suppliers are assessed
for potential risk based on their responses to
an initial screening questionnaire and take
into account factors such as their location and
relationship with The Body Shop. Each supplier
is ranked as high, medium, or low risk. High-risk
suppliers are audited by a not-for-proft audit
company or by a third-party agent. A buyer
from The Body Shop or a representative from a
local non-governmental organization will audit
a medium-risk supplier. Low-risk suppliers will
undergo an ethical assessment and is expected
to adopt the Body Shop Code of Conduct.
6.3 analyze the results of auDits anD use results to
inform strategic Development of your business
MEASURlNG lMPACT AND AUDlTlNG
36 37 36 37
7 Reporting
Human rights in reporting: key steps for your business
7.1 Decide which human rights impacts are priorities for you to report on
7.2 Consider who your main target audiences are
7.3 Develop an effective reporting format
7.4 Publish this information on its own or as part of a regular business report
7.5 Submit a link/description to the Global Compact website (Global Compact participants)
7.1 DeciDe which human rights impacts are priorities for you to
report on For the reasons mentioned in the Communications section, reporting on human rights is an essential part
of a business management system. A report is in its own right a business management tool. Many companies already report
on social and environmental performance in addition to their business results, and an increasing number have their reports
independently verifed. For companies over a certain size in some countries, basic reporting on social and environmental perfor-
mance is mandatory.
7.2 consiDer who your main target auDiences are Companies often report on
human rights issues linked to suppliers and employees, but neglect other areas. Good practice is to report on the company’s
full sphere of infuence. This means including issues and opportunities linked to customers and communities where the
company operates. Transparent reporting of successes, failures, and challenges sets an example for others, builds credibility
and trust, and maintains the company’s license to operate.
7.3 Develop an effective reporting format There are several ways to present human
rights data in a company report and it is worth reviewing a selection of those listed on www.business-humanrights.org. Ref-
erence can also be made to the 3rd Generation of reporting guidelines from the Global Reporting Initiative. These guidelines
provide an example of a thorough framework for human rights reporting. One key decision to be made is whether the report
should be purely web-based, paper-based, or both. A rights-aware approach also requires careful attention to accessibility,
particularly in terms of the languages used and meeting the needs of those with visual impairment or without the required
technology to access the report.
7.4 publish this information on its own or as part of a regular
business report Another key decision is whether your company is moving towards an integrated triple bot-
tom line approach to reporting (i.e. fnancial, environmental, and social) or whether the social issues are better served in their
own report or combined with environmental issues in a ‘sustainability report’. Many businesses see human rights as a sub-
set of wider social issues; some companies maintain a distinction between labor rights and human rights. However, as more
companies move towards a more holistic approach to human rights in business, we can expect that an increasing amount of
the ‘social space’ in company reports will be categorized as human rights.
REPORTlNG
36 37
Getting started
36 37
Human Rights in a Social Responsibility Report – an example
Gap Inc.’s 2003 Social Responsibility Report was widely
praised for its honest appraisal of the challenges facing a
company trying to uphold international human rights and
labor rights standards across global supply chains. Greater
transparency has led to newspaper headlines such as “Gap
admits factory abuses,” but this has been more than offset
by positive responses from employees, customers, investors,
and NGOs. Gap’s 2004 report continues transparent report-
ing against the ILO Core Conventions. In its 2004 report, the
company quotes US Supreme Court Justice Louis Brandeis
to capture its philosophy about reporting: “a bright light is the
best disinfectant”. The more open and honest a company can
be about conditions and challenges, the more helpful it can
be in addressing them. Gap’s report also contains construc-
tive criticism and learning from the Public Reporting Working
Group and stakeholder outreach sessions. Gap also presents
its work with the Global Reporting Initiative (GRI) to develop
consistent reporting standards that will make it possible to
compare performance across companies and over time.
Codelco, a successful Chilean mining company, has a
history of reporting on sustainable development issues,
including human rights. The company’s most recent Sus-
tainability Report was prepared by its Senior Vice-President
of Operational Excellence, Promotion, and Sustainability in
accordance with the latest Global Reporting Initiative (GRI)
Guidelines. Codelco’s report highlights its work on human
rights issues ranging from the company’s compliance with
a comprehensive occupational health and safety plan to
its approval of a document of commitments to indigenous
people. In addition, the company took its reporting a step
further and submitted it to an external independent review-
er. The aim of the review was to provide assurance of the
report’s accuracy and its adherence to the GRI Guidelines.
As part of the process, the independent reviewer visited
numerous Codelco facilities as well as the head offce in
Santiago, Chile.
The Global Reporting Initiative
Over 700 businesses now cite the Global Reporting Initiative
as the framework for their social and environmental report-
ing, with human rights included within their social indicators.
The GRI framework is one example of how to report on such
matters. At the time of writing, in early 2006, the Global
Reporting Initiative is involved in developing the 3rd genera-
tion of reporting guidelines. For more information, see www.
globalreporting.org
Communicating progress
7.5 submit a link/Description to the global compact website
(global compact participants) Participants in the Global Compact are expected to communicate,
on an annual basis, with their stakeholders about the progress they are making in implementing all ten Compact principles,
including the two human rights principles. The communication on progress is expected to include a statement of continuing
support by the company’s leadership for the Global Compact, a description of practical actions taken to implement the prin-
ciples, and measurement of outcomes using, as far as possible, standard indicators or metrics such as those elaborated in the
GRI’s Sustainability Reporting Guidelines. Communications on progress can be part of a broader annual or sustainability report
or a stand alone document that is web-based, paper-based or both. A link to or description of the communication on progress
is required to be submitted to the Global Compact website. Guidance materials for how to communicate progress are available
at: www.unglobalcompact.org/communicatingprogress
REPORTlNG
Introduction
The rapid development of ‘business and human rights’ as an area of concern and interest over the last de-
cade seems likely to continue. As it does, an increasing number of businesses around the world will identify
practical ways to integrate human rights into their business practices.
However, there is much work to be done to develop and refne the tools and systems needed for businesses
to manage human rights effectively. This Guide is very much a ‘frst attempt’ at exploring the practical
integration of human rights into business management, and it is hoped that businesses might be inspired by
its advice and examples to develop their own applications of human rights which, in turn, might be shared
more widely.
Conclusion
38 39 CONCLUSlON
lNTRODUCTlON
Appendices
1. International Bill of Human Rights
The International Bill of Human Rights consists of:
• The Universal Declaration of Human Rights (UDHR),
• The International Covenant on Economic, Social and Cultural Rights (ICESCR), and
• The International Covenant on Civil and Political Rights (ICCPR)
The UDHR and the Covenants can be read in their entirety at www.ohchr.org/english/law. Below you will fnd the
headings of the articles in the Covenants (excluding articles concerned with procedural or organizational matters).
International Covenant on Economic, Social and Cultural Rights (ICESCR)
Article 1: The right to self-determination for peoples.
Article 2: Non-discrimination in relation to all rights
Article 6: The right to work, including the right to vocational guidance and training
Article 7: The right to a minimum wage and equal pay, to safe and healthy working conditions, and to
rest, leisure and holidays with pay
Article 8: The right to form trade unions and join a trade union, and the right to strike
Article 9: The right to social security, including social insurance
Article 10: The right to a family life, to maternity leave and prohibition of exploitative child labor
Article 11: The right to adequate food, clothing, housing and fair distribution of food
Article 12: The right to the highest attainable standard of physical and mental health
Article 13-14: The right to education
Article 15: The right to participate in cultural life and the technological development and the right to
protection of moral and materiel interests resulting from one’s inventions
38 39 APPENDlCES
lNTRODUCTlON
Appendices
International Covenant on Civil and Political Rights (ICCPR)
Article 1: The right to self-determination for peoples.
Article 2: Non-discrimination in relation to all rights
Article 6: The right to life
Article 7: Prohibition against torture or cruel, inhumane or degrading treatment or punishment and
against medical or scientifc experimentation without free consent
Article 8: Prohibition against slavery, forced or other compulsory labour
Article 9 - 10: The right to freedom and personal safety (arrest and detention)
Article 11: Prohibition against imprisonment for non-fulfllment of a contractual obligation
Article 12: The right to liberty of movement and freedom to choose residence
Article 13: The right to seek asylum
Article 14-15: The right to a fair trial and prohibition against retroactive punishment
Article 16: The right to recognition as a person before the law
Article 17: The right to privacy
Article 18: Freedom of thought, conscience and religion
Article 19: The right to hold opinions and the right to freedom of information and freedom of expres-
sion
Article 20: Prohibitions against inciting war and against hate speech
Article 21: The right of peaceful assembly
Article 22: Freedom of association, including the right to form and join trade unions
Article 23-24: The right to form a family and the rights of the child
Article 25: The right to take part in public affairs
Article 26: Equality before the law
Article 27: Minority rights to culture, religious practice and language
40 41 APPENDlCES
lNTRODUCTlON
Appendices
2. The Ten Principles of the UN Global Compact
The Global Compact’s ten principles are derived from: the Universal Declaration of Human Rights; the Inter-
national Labour Organization’s Declaration on Fundamental Principles and Rights at Work; the Rio Declara-
tion on Environment and Development; and the United Nations Convention Against Corruption.
The Global Compact asks companies to embrace, support and enact, within their sphere of infuence, a set
of core principles in the areas of human rights, labour standards, the environment, and anti-corruption:
Human Rights
1 Businesses should support and respect the protection of internationally proclaimed human rights,
and
2 make sure that they are not complicit in human rights abuses.
Labour
3 Businesses should uphold the freedom of association and the effective recognition of the right to
collective bargaining,
4 the elimination of all forms of forced and compulsory labour,
5 the effective abolition of child labour, and
6 the elimination of discrimination in respect of employment and occupation.
Environment
7 Businesses should support a precautionary approach to environmental challenges,
8 undertake initiatives to promote greater environmental responsibility, and
9 encourage the development and diffusion of environmentally friendly technologies.
Anti-Corruption
10 Businesses should work against corruption in all its forms, including extortion and bribery.
40 41 APPENDlCES
lNTRODUCTlON
3. Resources
General Reports/Guides for Business
Business and Human Rights: A Compilation of Documents, Edited by Radu Mares, Leiden: 2004
Business and Human Rights: A geography of corporate risk, Amnesty International (UK) and The Prince of Wales Interna-
tional Business Leaders Forum, London: 2002.
Business and Human Rights, Dilemmas and Solutions, Edited by Rory Sullivan, Insight Investment, London: 2003
Business and Human Rights in a time of change, Christopher Avery, Amnesty International (UK), London: 2000
Business as Partners in Development: Creating wealth for countries, companies and communities, Jane Nelson/The
Prince of Wales Business Leaders Forum, in collaboration with The World Bank and The U.N. Development Programme,
London: 1996
Business Leaders Initiative on Human Rights: Report 1: Getting Started, BLIHR, London, New York and Stockholm: 2003
Business Leaders Initiative on Human Rights: Report 2: Work in Progress, BLIHR, London, New York and Stockholm:
2004
Embedding Human Rights in Business Practice, The Global Compact and the Offce of the United Nations High Commis-
sioner for Human Rights, New York and Geneva: 2004.
Human Rights: Is it any of your business?, Amnesty International (UK) and The Prince of Wales International Business
Leaders Forum, London: 2000.
Human Rights: It is your business – the case for corporate engagement, The Prince of Wales International Business
Leaders Forum, London: 2005.
Raising the Bar: Creating Value with the United Nations Global Compact, Edited by Claude Fussler, Aron Cramer and
Sebastian van der Vegt, Greenleaf Publishing Limited: 2004.
The Business of Peace, Jane Nelson, International Alert, Council on Economic Priorities and The Prince of Wales Interna-
tional Business Leaders Forum, London: 2000.
Training
Business and Human Rights in Practice
Over 100 business managers from many industries have attended this training course since 2002. Now run by TwentyFifty
Limited (see www.twentyffty.co.uk ) the course comprises of an on-line module, residential workshop and a workplace project.
Its aim is to help companies to implement their human rights commitments by developing the capacity of key individuals to
manage human rights issues. The course is run twice a year in the UK and by invitation internationally.
Human Rights & Business training
General training on the ‘why, what and how’ of human rights and business and special training for specifc corporations
have been developed and performed by the law frm Lawhouse.dk (www.lawhouse.dk). Since 1999 Lawhouse.dk has
trained more than a thousand business managers and lawyers and conducted specifc training for several members of
the UN Global Compact. Tools, programs and training on particular rights such as non-discrimination, the right to health,
freedom of information and expression, the right to privacy, and the right to participate in technological development
were developed to support individual corporate priorities.
42 43 APPENDlCES
lNTRODUCTlON
4. Organizations
African Institute for Corporate Citizenship
www.aiccafrica.com
Amnesty International Business Groups
www.amnesty.org.uk/business
Business & Human Rights Resource Centre
www.business-humanrights.org
Business for Social Responsibility (BSR)
www.bsr.org
CAFOD
www.cafod.org.uk
Christian Aid
www.christian-aid.org.uk
Ethos Institute
www.ethos.org.br
Friends of the Earth
www.foe.org.uk
Fund for Peace Human Rights and Business Roundtable
www.fundforpeace.org/programs/hrbrt/hrbrt.php
GeSI - Global E-Sustainability Initiative
www.gesi.org
Global Reporting Initiative
www.globalreporting.org
Human Rights Watch
www.hrw.org
International Chamber of Commerce (ICC)
www.iccwbo.org
International Commission of Jurists
www.icj.org
International Committee of the Red Cross
www.icrc.org
International Federation for Human Rights
www.fdh.org
International Financial Corporation
www.ifc.org
International Labour Organization (ILO )
www.ilo. org
Offce of the United Nations High Commissioner
for Human Rights
www.ohchr.org
Organisation for Economic Co-operation and Development
www.oecd.org
Social Accountability International (SAI)
www.sa-intl.org
The Danish Institute for Human Rights
www.humanrights.dk
The International Confederation of Free Trade Unions
www.icftu.org
The Prince of Wales International Business Leaders Forum
www.iblf.org
United Nations Development Programme (UNDP)
www.undp.org
UN Global Compact
www.unglobalcompact.org
Social Venture Network
www.svn.org
World Business Council for Sustainable Development
www.wbcsd.org
World Health Organization (WHO)
www.who.int
42 43 APPENDlCES
lNTRODUCTlON
5. Voluntary Initiatives, Guidelines, Principles and Tools
AccountAbility’s AA1000 Framework and series standards
www.accountability.org.uk/aa1000/default.asp
Amnesty International Human Rights Principles for Companies
www.amnesty.org.uk/business/pubs/hrgc.shtml
The Caux Round Table Principles for Business
www.cauxroundtable.org/index.html
Clean Clothes Campaign: Model code
www.cleanclothes.org/codes/ccccode.htm
Dow Jones Sustainability Index (DJSI)
www.sustainability-index.com/
Ethical Trading Initiative
www.ethicaltrade.org/Z/home/index.shtml
Electronic Industry Code of Conduct
www.hp.com/hpinfo/globalcitizenship/environment/pdf/supcode.pdf
Equator Principles
www.equator-principles.com
Extractive Industries Transparency Initiative – Source book
www.eitransparency.org/keydocuments.htm
Fair Labor Association – Code of conduct
www.fairlabor.org/all/code/index.html
FTSE4Good
www.ftse.com/ftse4good/index.jsp
Global e-Sustainable Initiative (GeSI)
www.gesi.org
Global Reporting Initiative
www.globalreporting.org
The Global Sullivan Principles
www.thesullivanfoundation.org/gsp/default.asp
Human Rights Compliance Assessment Tool (HRCA)
www.humanrightsbusiness.org/
ILO’s Declaration on Fundamental Principles and Rights at Work
www.ilo.org/dyn/declaris/DECLARATIONWEB.INDEXPAGE
ILO’s Tripartite Declaration of Principles Concerning Multinational
Enterprises and Social Policy
www.ilo.org/public/english/employment/multi/overview.htm
ISO Standard on CSR
ww.iso.org/iso/en/ISOOnline.frontpage
Kimberly Process
www.kimberleyprocess.com
The OECD Guidelines for Multinational Enterprises
www.oecd.org/
Social Accountability 8000
www.sa-intl.org
Voluntary Principles on Security and Human Rights
www.voluntaryprinciples.org/
6. Websites of companies mentioned
in this report
ABBFG www.abb.com
BarclaysF www.barclays.com
BPG www.bp.com
CarrefourG www.carrefour.com
CemexG www.cemex.com
CodelcoG www.codelco.com
CopelG www.copel.com
EskomG www.eskom.co.za
Gap Inc.FG www.gapinc.com
Hewlett PackardFG www.hp.com
Li and Fung Trading LimitedG www.lifung.com
MAS Holdings G www.masholdings.com
MTV Networks EuropeF www.mtvne.com
National GridF www.nationalgrid.com
Novartis Foundation for Sustainable DevelopmentFG
www.novartisfoundation.com
Novo NordiskFG www.novonordisk.com
Rio TintoG www.riotinto.com
StatoilFG www.statoil.com
ShellG www.shell.com
Taj HotelsG www.tajhotels.com
Tata EnterprisesG www.tata.com
TelefónicaG www.telefonica.com
The Body Shop InternationalF www.thebodyshop.com
ValeoG www.valeo.com
Fdenotes membership of BLIHR
Gdenotes membership of the United Nations Global Compact
APPENDlCES 44 PB
www.blihr.org www.ohchr.org www.unglobalcompact.org
A Guide for Integrating Human Rights
into Business Management
BUSINESS LEADERS INITIATIVE ON HUMAN RIGHTS
Member companies of the Business Leaders Initiative on Human Rights
National Grid plc
Novartis Foundation for
Sustainable Development
Novo Nordisk A/S
Statoil ASA
The Body Shop International Plc
ABB Ltd
Barclays PLC
Gap Inc.
Hewlett-Packard Company
MTV Networks Europe
www.respecteurope.com www.realizingrights.org
doc_543494821.pdf