From policies to progress: Our observations from our human rights campaign

What is our human rights campaign?

AIM: Following the release of our inaugural human rights policy last year, we launched our human rights engagement campaign in 2024. Recognising the multi-faceted nature of human rights, the campaign aims to initiate two-way dialogue to raise awareness with our investee companies, and, in return, strengthen our understandings of such intricate issues. 

Following receipt of responses, we will isolate companies for direct individual engagement to move from the ‘research and outreach’ stage as part of seeking change over the longer term.

SCOPE: Over 400 top-market cap companies in 43 countries across six priority sectors. We also included eight companies listed as UNGC violators.

METHOD: We structured a far-reaching email campaign to share our human rights policy and expectations, and, equally importantly, to invite responses from companies through a survey so that we can learn more about their approaches to human rights and the challenges they face in meeting our minimum expectations. 

We acknowledge the complexity of human rights issues. Therefore, our engagement campaign aims to communicate both the ‘what’ of our published expectations and the ‘how’ of demonstrating the effectiveness of companies’ human rights risk management beyond commitments, aspiring for continuous improvement. 

Furthermore, as set out above, we plan to track progress of a small group of companies through direct interactions in 2025 and beyond, while we continue our engagements on this agenda. These companies will be selected from survey respondents, accounting for sector and geographical spread. 

 

Responses so far

Companies that responded to our survey inquiries have been receptive to engaging on human rights. Through our engagement so far, we have seen some confirmation of a disconnect in many cases between a company’s policy commitments and the efficacy of their human rights risk management. Companies that demonstrated the most comprehensive human rights management showed a holistic understanding of their operation and supply chain risks, taking a granular, often bottom up, approach to addressing these risks.

Mind the gap: From oversight to corporate governance and business strategy?

Our survey results showed that 95%[1] of respondents reported strong awareness of human rights issues demonstrated through published policies and board oversight. We recognise that this percentage of companies in the broader universe may be lower in practice. However, it is worthwhile noting that the top motivations conveyed by companies revealed that they see value in managing human rights, primarily as these efforts:

-          Align with company values

-          Support business strategy

-          Ensure long-term sustainability

-          Comply with regulations

-          Manage reputational risks

-          Maintain social license to operate

Our view is that human rights integration within corporate governance principles is essential for long-term business success. Our campaign indicates that companies demonstrating stronger credentials in human rights management often have human rights considerations included in their business strategies and operations, beyond ‘top-down’ board oversight and policy commitments. Companies shared that it is imperative that robust human rights governance is integrated at various levels of company operations to strengthen risk management. 

While the majority of respondents shared that they have human rights risk identification process in place, such as human rights due diligence to ensure sound human rights management, it was more notable that companies demonstrating a more robust due diligence programme often appear to be people-centric and forward-looking, to identify, prevent, mitigate and account for how they address their impacts on human rights.

European regulations, like the German Supply Chain Due Diligence Act or the French Duty of Vigilance Law[2], and standards bodies and industry coalitions – like the Initiative for Responsible Mining Assurance (IRMA)[3] and the Responsible Business Alliance (RBA)[4] – provide companies with strong imperatives to adhere to robust frameworks. To this end, we observed companies that participated in influencing these best practices also displayed much more stringent management, particularly within the EU and the ones in higher-risk extractive industries.

We also noticed, however, that most respondents are currently unable to meaningfully articulate the holistic process they have taken to identify their salient human rights risks. This includes laying out the considerations taken throughout this process across their operations and value chain and linking to designing human rights performance measurement. The firms that stood out in taking holistic approaches have been leveraging best practices from geographies where they operate, contextualising specific location-based considerations into their management framework while implementing a corporate level programme beyond regulatory frameworks. 

Strength through partnership: Mapping, disclosing and managing supply-chain risk

When asked to demonstrate effective human rights management beyond policy commitments through risk identification, remedy access, and preventive actions, 4 out of 5 companies that claimed they have strong awareness of human rights issues acknowledged those measures to be in place. Respondents pointed to the following challenges in implementation: 

• Navigating complex and evolving business operations as global organisations
• Gaining transparency across complex supply chains
• Ensuring effective implementation
• Ensuring consistent awareness across organisations
• Tracking current and emerging compliance standards
   

This includes navigating complex operating models as global organisations. Certain Asian companies highlighted the difficulty of managing cultural differences. One company noted that operating globally involves diverse cultural norms and legal frameworks regarding human rights. With operations spanning multiple regional markets, implementing site-based human rights management aligned with corporate policies can be challenging.

Managing supply chain complexities is a core and difficult aspect of mitigating risk, especially for companies with extensive supply chains. Beyond the defined parameters of Codes of Conduct, procurement contracts and audits, our engagements revealed that companies that demonstrate confidence in managing human rights risks put deliberate actions in place beyond policy commitments. 

The art of the possible

A North American mining company with a significant footprint in emerging markets stood out in articulating how it implemented different types of measures in human rights risks in its operations, navigating complex and evolving business operations globally. It was able to clearly distinguish between human rights due diligence – such as impact assessments for salient risks identification purposes – and audits by standards bodies and industry coalitions to assure management controls for meeting commitments, securing market access or meeting customer requirements.

Another exemplary company demonstrated that, by focusing on identifying high-risk raw materials violations through its risk assessment system, it could assess salient supply-chain risks from the bottom up and implement corresponding risk management measures. Through partnership with suppliers in high-risk areas, the company was able to effectively consider workers’ voices as part of binding measures. This further indicates a company’s willingness to account for remedy if its suppliers fail to deliver on their contractual obligations. This demonstrates a commitment to meaningful remedy measures and preserving the integrity of their relationships within the supply chain, in our view. 

Companies using technology and data to proactively monitor potential risks in complex supply chains, such as public sentiment, were better able to evidence robust systems of human rights management. It is critical, in our view, that companies dedicate resources to responding to human rights incidents, not just preventing them.

In our next instalment, we’ll be covering what we’ve learned in our campaign so far about companies’ approaches to human rights in the context of climate change, and what we expect from human rights disclosures.   

 
[1] Percentages reflect only the views of companies responding to the survey, and not all companies contacted. The survey received a response rate of 15%. 
[2] The German Supply Chain Due Diligence Act: Lieferkettensorgfaltspflichtengesetz; the French Duty of Vigilance Law: Loi de vigilance
[3] https://responsiblemining.net/ 
[4] https://www.responsiblebusiness.org/