business leaders initiative on human rights

8/14/2019 Business Leaders Initiative on Human Rights

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A Guide for Integrating Human Rightsinto Business Management

BUSINESS LEADERSINITIATIVE ON HUMAN RIGHTS

O fce o the United NationsHigh Commissioner

or Human Rights


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Business LeadersInitiative onHuman Rights

United NationsGlobal Compact

andthe Of ce of theUnited NationsHigh Commissionerfor Human Rights

DisclaimerThe views expressed in this publica-tion do not necessarily representthe views of the Global CompactOf ce or the Of ce of the UnitedNations High Commissioner for Hu-man Rights or any of the individualcompanies participating in BLIHR orwhose case examples are included.Moreover, the Global CompactOf ce and the OHCHR make no rep -resentation concerning, and do notguarantee, the source, originality,accuracy, completeness or reli-ability of any statement, informa-tion, data, nding, interpretation,advice or opinion contained withinthe publication. The publication isintended as a learning document.The inclusion of examples of com-pany experiences does not in anyway constitute an endorsement of the individual companies nor theirhuman rights policies or practicesby the Global Compact Of ce and/or the OHCHR.

photo credits page 4/ from left to right:all photos istockphoto.com except fornumbers 1 and 5, United Nations Capi-

tal Development Fund/Roger Adams

Preface

Introduction

Getting Started

1 Strategy

2 Policy

3 Processes andProcedures

4 Communications

5 Training

6 Measuring Impactand Auditing

7 Reporting

Conclusion

Appendices

add photo captions

Contents


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A growing number o companies are becom-ing aware o the contribution they can make toadvancing human rights within their spheres oinfuence and the bene ts such an approach canhave or their businesses. While human rightscontinue to be the primary responsibility o govern-ments, companies can do a lot within the contexto their own business to support and respect theobservance o human rights. Being proactive onhuman rights can make good business sense, aswell as being the right thing to do.

This publication, a joint product o the Business Lead-ers Initiative on Human Rights (BLIHR), the UnitedNations Global Compact O ce, and the O ce o theUnited Nations High Commissioner or Human Rights

(OHCHR), o ers practical guidance to companies thatwant to take a proactive approach to human rightswithin their business operations. It is principally orbusiness leaders and managers in large and me-dium-sized enterprises, private and state-owned, whowould like to develop their understanding o humanrights in business practice.

What is the Business Leaders Initiative onHuman Rights?The Business Leaders Initiative on Human Rights(BLIHR) is a business-led program that is developingpractical tools and methodologies or applying hu-man rights principles and standards across a rangeo business sectors, issues, and geographical loca-tions. The ten member companies o BLIHR took thelead in this Guides development, in which they sharesome o their experiences and lessons they havelearned. For more in ormation, see www.blihr.org

What is the United Nations Global Compact O fce? The United Nations (UN) Global Compact is theUNs voluntary corporate citizenship initiative basedon ten universal principles in the areas o hu-man rights, labor standards, the environment and

anti-corruption (see the Appendices ). It has beenendorsed by all 191 Heads o State and Govern-ments o the United Nations and has urther beenlegitimized through a consensus resolution by theGeneral Assembly. The rst two principles o theGlobal Compact are derived rom the Universal Dec-laration o Human Rights, which is the oundational

ramework o the international human rights system.

Business should support and respect the pro-tection o international human rights; and

Business must not be complicit in abuses ohuman rights.

The Global Compact O ce works with participantsand other stakeholders to provide support, commu-

nications, governance, and programs related to theGlobal Compact initiative and principles. For morein ormation, see www.unglobalcompact.org

What is the O fce o the United Nations HighCommissioner or Human Rights?The O ce o the United Nations High Commissioner

or Human Rights (OHCHR) is an important brancho the UN human rights structure. The current HighCommissioner, Louise Arbour, is responsible to theUN Secretary General or encouraging the inter-national community and nation states to upholduniversal human rights standards. The O ce seeksto work with an ever wider range o participants,including the private sector, to promote respect orand commitment to human rights as widely as pos-sible. For more in ormation, see www.ohchr.org

Why we chose to produce this GuideHuman rights is one o the most challenging areaso corporate responsibility or companies to ad-dress; more human rights tools and guidance areneeded. This Guide is intended to help meet thisneed and, in doing so, help companies make hu-man rights a success ul part o their business.

Preface


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introduction

IntroductionHuman rights are the basic rights o each humanbeing, independent o race, sex, religion, politicalopinion, social status, or any other characteristic.Through international human rights conventions,governments commit to respect, protect, promoteand ul ll the human rights o their citizens andother individuals within and beyond their borders.

A list o the human rights contained in the UniversalDeclaration, the International Covenant on Civil andPolitical Rights, and the International Covenant onEconomic, Social and Cultural Rights the three

undamental United Nations agreements on humanrights is included in the Appendices to this Guide.Businesses should also be aware o the core con-ventions o the International Labour Organisation. Inaddition, a speci c body o law applies in situations

o armed conficts: international humanitarian law.Its rules have two aims: rst, protecting people whoare not or no longer taking part in hostilities and,secondly, regulating means and methods o war are.

At this time in history, there are compelling reasonswhy businesses should involve human rights intheir policies and practices. Businesses increasinglyneed a stable international environment in whichto operate, with sustainable markets and a levelplaying eld o opportunities. Human rights o era common ramework or businesses to under-stand societies expectations and deliver value tostakeholders in a more sustainable way. This Guidedemonstrates that, in a business context, advancinghuman rights is as much about realizing new op-portunities and managing risk as it is about meetingessential global standards.

For business, human rights provide a universalbenchmark or minimum standards o behavior.Many national laws and regulations have evolved asa result o a States obligation to implement humanrights standards. Business must, o course, observesuch laws in all countries and jurisdictions in whichthey operate.

The debate about the nature and scope o com-panies human rights responsibilities is a relativelyrecent one, as is the idea o applying human rightsto business decisions and operations. A numbero international e orts have been undertaken toelaborate on the content o human rights relevantto business. One o the most comprehensive e ortsresulted in the Dra t Norms on the Responsibilities

o Transnational Corporations and Other BusinessEnterprises with Regard to Human Rights (Dra tNorms), developed by a United Nations expertgroup, the UN Sub-Commission on the Promotionand Protection o Human Rights. While the Dra tNorms have no ormal legal status, the inter-gov-ernmental UN Commission on Human Rights hasobserved that they have use ul elements. Many othe companies that have contributed to this Guide,especially the companies involved in BLIHR, agreethat the content o the Dra t Norms provides a help-

ul ramework or human rights in business.


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introduction

Vision

Empowerment

Leadership

ResourcesPoliciesStrategy

ProcessesInnovation

Impact onPeople

Impact on ValueChainImpact

on Society

Reporting

e n a

b l e r s

r e s u

l t s

Global CompactPerformance Model

StructureThis Guide is based on a conventional managementsystem. It ollows the Global Compact Per ormanceModel, which is a map or responsible corporate citi-zenship. The model allows business to implement theGlobal Compact principles without undermining theirother business goals. The Per ormance Model wasbuilt on practical experience, identi ying methodsthat actual companies ollowed to mainstream theGlobal Compact principles into their own businessoperations and activities. More in ormation aboutimplementing the Per ormance Model in practiceis available on the Global Compact website (www.unglobalcompact.org) and in the publication entitledRaising 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 ahands-on toolkit to help any company integrate prac-tices consistent with human rights standards into anexisting management system. It is made up o sevenelements common to most management systems:Strategy, Policy, Processes and Procedure, Communi-cations, Training, Measuring Impact and Auditing, andReporting. TheGetting Started section identi es theinitial steps a company should take to implement theper ormance model, and in the Appendices at the endo the Guide you will nd tools and resources whichthe BLIHR companies have ound to be help ul inbringing human rights into their businesses.

The examples in this Guide illustrate how aspects othe model have been implemented and are designedto inspire other businesses. The human rightsprocesses and procedures included in this Guide areongoing projects or the companies concerned.

There is much still to learn. We welcome com-ments on the content o this Guide as we seek to

constantly improve the business and human rightstools available to companies.


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Getting Startedunderstanding human rights in a business context

Human rights in your business: getting started

1Develop the business case or human rights

2 Familiarize yoursel with the broad content o human rights and theavailable resources

3 Understand the implications o the frst two principles o the Global Compact4 Develop and encourage a rights-aware approach to your business

1. Develop the businesscase for human rightsThere is a strong moral and ethical case to support

the notion that business entities should integratehuman rights principles into their business practiceswithin their sphere o infuence. The concept obusinesses as a orce or good and as a power ulactor in economic, environmental and social devel-opment has been strengthened in recent years.

In terms o the business case or human rights,although the precise logic can vary between eachbusiness sector and country o operation, the ol-lowing main bene ts have been identi ed:

Improved stakeholder relations

Improved employee recruitment,retention, and motivation

Improved risk assessment andmanagement

Reduced risk o consumer protests

Enhanced corporate reputationand brand image

A more secure license to operate

Strengthened shareholder con dence More sustainable business relationships

with governments, business partners, tradeunions, sub-contractors and suppliers.

Human rights can be a way o identi ying new busi-ness opportunities; sometimes what might be rstperceived as a risk to a business can be convertedinto an asset. The Human Rights Matrix, introducedin the Strategy section o this report, is a good wayto map both risks and opportunities and the man-agement approaches that can link the two.

In addition to the business case or human rights,there are also important strategic reasons or busi-ness to take a long-term interest in good governanceand a stable social environment in places wherethey do business. There are many good resources onthe business and strategic case or human rights; aselection is listed in the Appendices to this Guide.

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2. familiarize yourself with the broaD content of humanrights anD the available resources

Which human rights are relevant to business?

The short answer is: all human rights are relevant.

Businesses should look rst at what is o tenre erred to as the International Bill o HumanRights made up o three international agreements:

The Universal Declaration o Human Rights The International Covenant on Civil and

Political Rights The International Covenant on Economic,

Social and Cultural Rights

A short description o the rights contained inthese documents is included in the Appendices to this report.

A business should consider the ull range o civil,political, economic, social, and cultural rightswhen examining the impact o its operations(see Sphere o infuence overlea ). In addition, insituations o armed confict businesses should beaware o the rules o international humanitarian

law, in particular those contained in the GenevaConventions o 1949 and their AdditionalProtocols o 1977.

The Business Leaders Initiative on Human Rightshas developed a Human Rights Matrix which

ollows the Universal Declaration o Human Rightsand other international agreements. The categoriesin the Matrix are those developed in the Dra tNorms; the content covers the ollowing areas:

A General ObligationsB Right to equal opportunity and non-discrimi-

natory treatmentC Right to security in personsD Rights o workersE Respect or national sovereignty and human

rightsF Obligations with regard to consumer protec-

tionG Obligations with regard to environmental

protectionH General provisions o implementation

The ull content o the Matrix and explanatory

notes on the Dra t Norms are available at www.blihr.org and www.ohchr.org respectively. A longerlist o resources is included in the Appendices .

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3. unDerstanD the implications of the first two principlesof the global compact The rst two principles o the Global Compact call on businessesto support and respect the protection o international human rights within their sphere o infuence and tomake sure they are not complicit in human rights abuses. The two concepts o sphere o infuence and

avoiding complicity are very use ul when trying to decide what your business can do, and what tools areneeded, to ensure human rights consistent policies and practices in a business context.

Sphere o infuence

While the concept [o sphereo infuence] is not de ned indetail by international humanrights standards, it will tend toinclude the individuals to whom

the company has a certainpolitical, contractual, economicor geographic proximity. Everycompany, both large and small,has a sphere o infuence,though obviously the larger ormore strategically signi cantthe company, the larger the

companys sphere o infuenceis likely to be. (The Global Compact and Human Rights: Un- derstanding Sphere o In uence and Complicity: OHCHR Briefng

Paper, in Embedding Human Rights in Business Practice

listed in the Appendices .)

Understanding a companyssphere o infuence can beaccomplished by mapping thestakeholder groups a ected

by a business operations. A key stakeholder group thatwill normally lie at the centero any companys sphere oinfuence will be employees.

Other groups, such as businesspartners, suppliers, tradeunions, local communities, andcustomers will ollow. The nalgroup will usually be govern-ment and the wider society.

Fig: This diagram is developed rom the publication: Business as Partners in Development: Creating wealth or countries, companies and communities, Jane Nelson/The Prince o Wales International Business Leaders

Forum, in collaboration with The World Bank and The U.N. Development Programme, London: 1996

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Avoiding complicity in human rights abuses

A company is complicit in hu-man rights abuses i it autho-rises, tolerates, or knowinglyignores human rights abusescommitted by an entity associ-ated with it, or i the companyknowingly provides practicalassistance or encouragementthat has a substantial e ecton the perpetration o humanrights abuse. The participationo the company need not actu-ally cause the abuse. Ratherthe companys assistance or

encouragement has to be toa degree that, without suchparticipation, the abusesmost probably would not haveoccurred to the same extentor in the same way. (The Global Compact and Human Rights: Understanding Sphere o In uence and Complicity: OHCHR Briefng Paper, in

Embedding Human Rights in Business Practice listed inthe Appendices .)

Avoiding complicity in humanrights abuses is an importantchallenge or business. As thedynamics between govern-ments, companies, and civilsociety organizations change,so too does the understand-ing o when and how di erentorganizations should take onresponsibilities or human

rights issues. Four situationshelp to illustrate how the no-tion o complicity might arise:

1 When the company activelyassists, directly or indirectly,in human rights violationscommitted by others e.g.where a company providesin ormation to a governmentthat it knows will be used toviolate human rights;

2 When the company is in a

partnership with a govern-ment and knows, or shouldhave known be ore agreeingto the partnership, that thegovernment is likely to com-mit abuses in carrying outits part o the agreement e.g.

orced relocation o peoples;

3 When the company bene tsrom human rights violations

even i it does not positivelyassist or cause them e.g.abuses committed by secu-rity orces, such as the sup-pression o a peace ul protestagainst business activitiesor the use o repressivemeasures while guardingcompany acilities; and

4 When the company is silentor inactive in the ace o sys-tematic or continuous humanrights violations e.g. inactionor acceptance by companieso systematic discriminationin employment law againstparticular groups.

Where an international crimeis involved, complicity mayarise where a companyassisted in the perpetrationo the crime, the assistance

had a substantial e ect onthe perpetration o the crimeand the company knew thatits acts would assist theperpetration o the crimeeven i it did not intend orthe crime to be committed.

State-owned enterprisesshould be aware thatbecause they are part o thestate, they may have directresponsibilities under interna-tional human rights law.

Business risk assessment andmanagement tools are neededto identi y the potential orcomplicity as it arises and todevelop policies and proce-dures to ensure non-complicity.Some o these tools are beingdeveloped and are re erred toin this Guide.

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4. Develop anD encourage arights-aware approach toyour business Understanding therelationship a business has with human rights

means taking a rights-aware approach to businesspractices. This allows the business to understandchallenges and dilemmas rom the perspective oother stakeholders and to better manage social risk.It will also enable the business to choose a globallyrecognized strategic ramework or the ull range oits economic and social activities the ways in whichthe business can be a orce or good. Human rightsprovide a universal and legitimate ramework that isapplicable everywhere and to any stakeholder group.

A human rights analysis can help highlight additional

risks and opportunities or a particular project be ore

any technical or investment decisions are made. Inthis way, a rights-aware approach can enable better-in ormed business decisions.

Starting to integrate human rights into businessmanagement requires the support o senior execu-tives, along with a shared understanding o theadvantages a rights-aware approach o ers thebusiness. This o ten means some initial invest-ment to ully understand the nature o the risks andopportunities that human rights present to the com-pany. One such investment might be sourcing thenecessary expertise rom outside the business ortraining in human rights or key members o sta .Many o the BLIHR companies are able to provideexamples o where such an approach has delivered

business bene ts.

The rights aware approachThe rights aware approach

A rights-aware approachmeans that a business is will-ing to accept that its stake-holders have universal rightsand that any decisions madeby the business should strive to

respect these. Clearly, there are

still many dilemmas and alsocompeting rights in which theinterests o one stakeholdergroup might oppose another. A human rights-aware approachwould mean that a business

would:

1 Identi y the rights at issue,2 Identi y its responsibilities

in terms o international hu-man rights standards, and

3 Determine the appropriateaction.

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introduction

Overview o the management components outlined in this Guide

1. Human rights in STRATEGY1.1 Find out what you are already doing1.2 Identi y risks and opportunities and then the priorities or action1.3 Develop a human rights strategy or your business

1.4 Defne and embed appropriate management responsibilities1.5 Integrate human rights into your companys activities1.6 Develop your strategy through a circle o continuous improvement

2. Human rights in POLICIES2.1 Include human rights in your existing policies2.2 Develop specifc human rights policies where appropriate2.3 Develop local policies to meet local situations2.4 Ensure ull implementation o your policies and review their outcomes

3. Human rights in PROCESSES and PROCEDURES3.1 Consider the ull scope o your business activities and unctions3.2 Establish procedures or identi ying your human rights-related risks and opportunities3.3 Establish control systems or managing human rights in your business3.4 Learn rom sector-wide business initiatives3.5 Expect the unexpected how to react when procedures are not enough

4. Human rights in COMMUNICATIONS

4.1 Share understanding o why human rights are important to business communications4.2 Integrate human rights into your internal communications4.3 Integrate human rights into your external communications

5. Human rights in TRAINING 5.1 Identi y target groups in your business to receive human rights training5.2 Review the di erent types o training materials available5.3 Select, organize and evaluate the training program or target groups

6. Human rights in MEASURING IMPACT AND AUDITING6.1 Set relevant per ormance indicators or measuring human rights impact across the di erent

unctions o your business6.2 Undertake human rights based audits6.3 Analyze the results o audits and use the results to in orm the strategic development o your business

7. Human rights in REPORTING7.1 Decide which human rights impacts are priorities or you to report on7.2 Consider who your main target audiences are

7.3 Develop an e ective reporting ormat7.4 Publish this in ormation on its own or as part o a regular business report7.5 Submit a link/description to the Global Compact website (Global Compact participants)

EN

ABLERS

RESULT

S

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Human rights in strategy: key steps or your business

1.1Find out what you are already doing

1.2 Identi y risks and opportunities and then the priorities or action1.3 Develop a human rights strategy or your business1.4 Defne and embed appropriate management responsibilities1.5 Integrate human rights into your companys activities1.6 Develop your strategy through a circle o continuous improvement

1.1 finD out what you are alreaDy Doing The debate on the nature and scope ocompanies responsibilities concerning human rights may be relatively recent, but many related issues are already managedby business through established procedures and practices. Legal requirements, negotiated agreements and policies on suchissues as data protection, wage xing, working hours and holidays, non-discrimination, occupational health and sa ety, andproduct sa ety, are all ounded in human rights and orm part o a companys relationship with stakeholders.

1.2 iDentify risks anD opportunities anD then the priorities for actionIt is important or a company to map its existing policies and undertake a gap analysis to establish how well human rights issuesare covered and whether additional policies are needed. A crucial part o the gap analysis is to identi y human rights risks anddilemmas acing your business operations. There are many examples o human rights dilemmas aced by businesses around theworld on a daily basis; a ew 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 internationalstandards when there are local corrupt nancial prac-tices, a lack o laws, and the improper administration o justice, leading to limited respect or human rights?

Security: how do you obtain protection or personneland plant when the state security orces are known touse excessive violence and commit other human rightsabuses against the local population?

Discrimination: how do you reconcile the realities otraditional work and cultural practices with your ownpolicies and adherence to international standards? Howdo you ensure disabled workers have equal job opportu-nities within the company?

Privacy: how do you balance the marketing advan-tages o registering your customer in ormation with theirlegitimate request or protection o their right to privacy?

Rest, leisure and paid holidays: how do you keepproduction costs competitive when you operate in acountry where there is no legal mandate or paid holi-days, but you wish to ollow international standards?

Housing: do you evaluate the nancial impact oupgrading sta quarters to international minimumrequirements when per orming a due diligence o a

actory that you plan to take over?

1 Strategy

StrAtEGy


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Desirable

Expected

Essential

Once risks and opportunities are identi ed, the next step isto identi y human rights priorities based on these conclu-sions. The Human Rights Matrix designed by the BLIHRcompanies (see diagram overlea ) can be used to allow abusiness to map what it sees as its essential, expected,and desirable priorities against a broad spectrum o hu-man rights categories. It allows risks and opportunities tobe shown together and helps to identi y the human rightscontent o a companys sphere o infuence.

Essential is the action thatmust be taken by thecompany to ollow relevant legal standards, eg interna-tional human rights law, national laws, and regulations,including in situations where a government is unwillingor unable to ul ll its obligations.

Expected is the action whichshould be taken by thecompany to meet the expectations o , and accept itsshared responsibilities to, relevant stakeholders. What isexpected may vary according to your business sector.

Desirable is the action through which the busi-ness could demonstrate real leadership. This can takea number o orms depending on the circumstances,but could include partnerships with other stakeholders,

philanthropic and charitable donations or the donation otechnical expertise to help the most disadvantaged.

The pyramid (le t) shows that anyhuman rights strategy should align

the essential, expected anddesirable actions o a company.

It makes no sense ora business to take

desirable actions to address a human rights concern,such as providing charitable donations, i it is not alreadydemonstrating its essential and expected action in thesame area.

The Human Rights Matrix is a general version or the pur-poses o example only. Your business would need to produceits own version drawing on all the relevant data rom yourcompanys activities across speci c geographic areas. Agreat advantage o ered by a rights-aware approach is thatthe categories (shown across the column headings o theMatrix) are universal and there ore global in application, asare many o the international standards upon which essen-tial actions are based.

Additional risks emerge i dilemmas are not properly managed.These might include negative impacts on stakeholder relations,such as with employees, contractors, local communities, local andnational governments, and others. There might also be possibleoperational disruption or a negative impact on investor con denceand share value. There is also a risk o negative publicity, gener-

ated locally and internationally. However, i dilemmas are properlymanaged, they can become opportunities or your business.Turning risk into opportunity is a key component o a strategicapproach to human rights in business. During the initial scopingphase, a company may also identi y other opportunities to promotehuman rights in the conduct o 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 o operational disruption. Better opportunities or positive public relationships with society, the press, and other media A positive impact upon investor con dence and share value

Improving employee morale due to good sa ety per ormance

StrAtEGy


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introduction

C3. Right tosecurity of persons

C4. Securityarrangements

D5. Forced orcompulsory labour

D7. Safe andhealthy workplace

D8. Adequateremuneration

Public statement ofcommitment tohuman rights

Equal opportunitiespolicy

Employee self-protection advice / training

Criteria in contracts ffor security services

Public statements ofcommitment to ILOCore conventions,UDHR, OECDguidelines, etc.

ProgressiveMaternity, Adoption,Family leave,Harassment policies

Supplier screening / monitoring

Global HSE guide-lines specifyingstandards,implementation andcompliance process

Pay at least livingwage in allcountriesof operation

Focused diversityinitiatives/ programmes andleadership structure

Safety managementsystem

Pension provisionin all countries ofoperation

Diversity awareness/ training foremployees

Publication ofperformance data

Merit-based payand performancesystem

Support for specicprogrammes e.g.black empowermentin South Africa

Training foremployees andselectedThird Parties

Wage levelincorporated intosupplier screeningcriteria

Public reporting ofbasic performancemetrics

Participation inindustry safetyforums andinitiatives

Chairman's awardto promote bestpractice

Employee personalaccident insurance

Withdrawal fromcountries whereforced labour isprevalent

Safety workinggroups

Enhanced pensionschemes

Membership offorums promotingdiversity, genderbalance etc.

Employee Assist(24 hourcondentialhelp line)

Community safetyeducationprogrammes

Share ownershipschemes

Training programsand work placementfor vulnerable / excluded groups

Public safetyawarenesscampaigns

Targeted products / services fordisadvantagedgroups

HIV/AIDS awarenessand treatmentprogrammes

Corporate standardsapplied withinbusiness partnershipsand supply chain

A1.Generalobligations

D. Rights of workersC.Right to security of personsB2.Right to equalopportunity andnon-discriminatorytreatment

EXPECTED

ESSENTIAL

AREA

DESIRABLE

Cooperation withHuman Rightsrelated institutions

Essential requirements in compliance with international human rights standards, including: The Universal Declaration of Human Rights, the International Covenant onCivil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination ofAll 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

D6. Childrensrights

Train managers toensure they areable to detectdifferent forms offorced labour

Rigorouslyinspect workfacilities toensure thatpremises are freefrom all forms offorced labour

Rigorouslyinspect suppliersfacilities toensure thatpremises are freefrom all forms offorced labour

Develop

understanding fromstandards such asthe VoluntaryPrinciples onSecurity and HumanRights on how tobest managerelations withsecurity staff andengage in training ofrelevant staff on theprotection of humanrights.

Work with thelocal police(public) or securityservice providers(private) inadvance of aproject to developa commonunderstanding andagreement toprotect humanrights in the eventof a dangeroussituation requiringintervention.

A Human Rights Matrix


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introduction

D9. Freedom ofassociation / collectivebargaining

E10. Respect fornational governancepractices

E11. Bribery E12. Contribution torealisation of humanrights

H15.Internal rulesof operation

H16. Monitoring H17. Reparations

Bribery andcorruptionprevention policy

On-going studiesinto the safety ofproducts andservices

Environment policy Code of conduct 3rd party veri-cation of CSRreporting

Establishment ofConsultative

Committees (e.g.Health and safety)

Commitment topolitical neutrality

Board Committeewith terms of refe-rence coveringenvironmental andsocial issues includinghuman rights.

Letter of Assuranceprocess

Procurementprocess assessed

Annual review ofpolicies

Board Audit andComplianceCommittee

Goals for reductionof energyconsumption

Transparent publicreporting in AnnualReport

Established riskmanagement process

Certication ofISO14001environmentalmanagementprogramme(s)

Trade unionconsulted on allbusiness changes thatmpact employeesn relevant areas

Participation inpublic goodgovernance debateincl. corruption

Training oncompliance / Grey zones

Matched giving(support employee'scharitable giving)

Supplier developmentprogramme

Internal audits ofsocial and environ-mental performance

Models to meetemployee needs incountries with dif-cult ofcial policies

Support toeducationalprogrammes / local enterprise

Corporatefoundationgiving

H. General provisions of implementationF13. Obligationswith regard toconsumerprotection

G14. Obligationswith regard toenvironmentalprotection

E. Respect for national sovereignty and human rights

CommunityInvestment strategy,policy and program-mes focusing onhuman rights issues

Business develop-ment / due diligenceprocessesincorporate humanrights risks

Formalenvironmentalmanagementsystem(s)

Corporate policyon protectionfor whistle-blowing

Internal audits ofhuman rightscomplaintsmechanisms

Offer fair and timelycompensation

Public reporting,for exampleaccording to GRIor other reportingstandards

Do not interferewith unionactivities afterhours andcooperate withunion and workersto participate inunion businessduring workinghours

Refrain fromexerting anyinappropriateinuence thatmight jeopardizethe independenceof the union

Avoid actionswhich mayundermine theunions credibilitywith members

Carry out a riskassessment studyof the home andhost countriesand of actors inthe supply chainsin 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 onCivil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the Convention against Torture, the Convention on the Elimination ofAll 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 exampleaccording to GRI orother reportingandards.


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Identi ying human rights priorities some examples

Energy Utilities National Grid has produceda variation o the Human Rights Matrix, whichrelates the di erent human rights areas o thecompanys responsibilities to di erent stake-holder groups such as government, businessand domestic customers, local communities,investors, employees, and suppliers.

Pharmaceutical Sector Novartis has used acorporate citizenship matrix containing humanrights principles to help de ne the sphere oinfuence o the pharmaceutical sector as itrelates to the Access to Medicines policy and theethical principles o the Declaration o Helsinki

on clinical trials.

Extractive Sector Statoil has applied theHuman Rights Matrix in detail as a strategictool to better understand the total impact o itsactivities in Venezuela.

Media and Entertainment Industry MTVNetworks Europe has applied the Human RightsMatrix to all On-Air and O -Air operations in theUK and Ireland and as a result is one o the rstmedia companies to develop policies based onhuman rights considerations.

For more in ormation 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 rom a companys senior leaders is a prerequisite or embeddinghuman rights into a companys operations and activities. Support rom senior leaders ensures that humanrights issues are taken seriously and become part o business strategy. A number o companies have oundthat having a member o the board o directors or executive management team assume overall responsibil-ity or human rights-relevant issues has been important in ensuring that these matters receive the requireddegree o attention. Clear lines o accountability have also proven to be vital. These companies typically havea designated senior manager who is responsible or implementing the companys human rights policies anddriving per ormance improvement. The senior manager generally reports to the executive level and may beresponsible or one o several possible unctions / departments in the company, such as human resources,procurement, legal a airs, public a airs, or the sustainability department.

1.3 Develop a human rights strategy for your businessHaving identi ed 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, thiswill entail setting out how they will integrate human rights considerations into their existing managementsystems and cover issues such as leadership, planning, de ning roles and allocating resources.

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Embedding management responsibilities some examples

Articles o Association Novo Nordisks Articleso Association speci y that the company will striveto conduct its activities in a nancially, environ-mentally and socially responsible way. The NovoNordisk commitment to sustainable development isanchored in the companys corporate governanceand its undamental business principles, called theNovo Nordisk Way o Management. The NovoNordisk Way o Management explicitly re ers to theTriple Bottom Line (TBL) social, environmentaland nancial responsibility as the companysunderlying business principle. Since 1999, the NovoNordisk Way o Management has included a com-mitment to support the United Nations Universal

Declaration o Human Rights and to integrate hu-man rights considerations into its daily business. Board-level representation National Grids boardsubcommittee, the Risk and Responsibility Com-mittee, is chaired by a Non-executive Director andhas responsibility or reviewing the managemento non- nancial issues, policies, and standards and

or reviewing the per ormance o the Group. Whereappropriate, this includes that o its contractorsand suppliers. The Committees remit includesoccupational and public sa ety, occupational health,environment, inclusion and diversity, human rights,business ethics, and community involvement.

Executive level representation ABBs humanrights policy is embedded in its social policy andis the responsibility o the head o the Sustain-ability A airs group. He reports on the economic,environmental, and social aspects o the groupsbusiness activities and the human rights poli-cies and commitments to a member o the groupexecutive committee who has overall responsibility

or sustainability issues. Environmental and socialpolicies are monitored and en orced by countryand regional sustainability controllers in the 100countries where ABB operates.

Ethical Guidance Council Copel, whose visionstatement makes explicit its aim to become thebest company within the Brazilian power sectorby 2006, striking a balance between the interestso the community and o its shareholders, has anEthical Guidance Council whose role is to discussand guide Copels actions, examine submittedcases, and recommend appropriate sanctions, toensure that the Companys actions are conductedin accordance with sound principles and to over-see the dissemination and e ective application othe Copel Code o Conduct across all sectors othe Company. To ensure its autonomy, the Councilis made up o the Companys employees, each

representing their respective di erent pro essionalcategories, and is coordinated by a representativeo civil society.

Mainstreaming Human Rights Novartis hasdeveloped and implemented human rights relatedCorporate Citizenship Guidelines and implementedthem through line management.

Direct involvement o the Chie Executive O fcerThe Managing Director o each Tata company is alsoits Principal Ethics O cer who nominates an EthicsO cer and a team o Location Ethics Counsellors.

Together this team is responsible or the Managemento Business Ethics (MBE) in the company and orensuring compliance o the Tata Code o Conduct awritten document.

Human Resources In January 2005, the CEO o Valeo, an automobile company based in France,an automobile company based in France,,decided that the responsibility or implementingand monitoring the Groups Human Rights policyshould be an integral part o the Human Resources

unction. The Group Human Resources Director isnow responsible or dealing with any human rightsviolations, as are the Human Resources Directorsacross the Group entities.

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1.6 Develop your strategy through a circle of continuousimprovement To help ensure that implementation e orts remain on track, it is a good idea

to adopt a continuous improvement approach rom the start. The plan-do-check-act circle may help in theprocess o learning and improving along the way.

Define roles andresponsibilities

Document Impose

operationalcontrol

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 o continuous improvement with examples o activities to be undertaken in di erent steps [First developed by Walter Shewhart, it was popularized by Edwards Deming.]

1.5 integrate human rights into your companys activities Particularly in large companies, integration o human rights may be a complex process that involves severalorganizational levels and di erent types o operations in di erent parts o the world.

To track progress, adequate indicators and goals must be developed or di erent activities; internal audits canprove key in tracking progress. The main purpose o audits is to check that the system is working according toplan, that new issues are captured by the system, and that per ormance is continually improved.

O ten progress on an issue across an entire company is gradual and incremental. In the meantime, imple-mentation e orts or the company as a whole can be complemented by local strategies and special plans orcertain operations and units. These bottom-up approaches can be developed quickly to meet the challenges abusiness aces in a particular geographic location or a speci c production process.

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2 Policy

2.1 incluDe human rights in your existing policies A policy statement sets out the direction and gives the overall goals or a company in a certain area oactivity. It should drive the management o the activity in the company and be supported by programs andobjectives 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 itsel or as part oother policies in the governance structure.

Human rights in policies: key steps or your business

2.1 Include human rights in your existing policies2.2 Develop specifc human rights policies where appropriate2.3 Develop local policies to meet local situations2.4 Ensure ull implementation o your policies and review their outcomes

Including human rights in existing policies some examples

Barclays Barclays developed a human rightsramework in 2004 to draw together a wide

range o existing policies relevant to its humanrights impact as an employer, purchaser o goodsand services, and provider o nancial servicesto customers. Policies were mapped using theHuman Rights Matrix to ensure areas o strengthand to identi y any gaps. The ramework was

ormally approved by the heads o each businessline and supports the Corporate ResponsibilityBoard Governance Standard, one o a series ostandards through which the Barclays Board trackscompliance with desired business objectives andregulatory requirements. Since adoption o the

ramework, work has continued in integratinghuman rights considerations into practice. Forexample, Sourcing management is strengthening

existing social and environmental supplierscreening/engagement criteria to incorporatehuman rights aspects more explicitly into theassessment o sourcing proposals. While it isparamount that contracts deliver commercialbene t, human rights aspects can be a signi cant

actor in decision-making. From a work orceperspective, Barclays like many businesses haslongstanding policies on human rights-relevantissues including health and sa ety, equality anddiversity, non-discrimination, and many others. Thehuman rights impact o lending, however, is thearea where most dilemmas arise, as the impact isindirect. Here, Barclays human rights ramework

ocuses on risk management and the identi cationo social and environmental risks in assessing andsanctioning nancial propositions.

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00

Checklist or a human rights policy

q Does the policy comply with existing international human rights conventions and norms, suchas the United Nations Universal Declaration o Human Rights, the International Covenant on Civiland Political Rights, the International Covenant on Economic, Social and Cultural Rights, and theInternational Labour Organizations Declaration on Fundamental Principles and Rights at Work?

q Is the policy relevant to your company and its sphere o infuence?

q Does the policy include a commitment to respect, protect and promote human rights and toavoid complicity in human rights abuses?

q Does the policy extend to all parts o the organization and other existing policies such ashealth and sa ety, procurement, and human resources?

q Does the policy include your companys expectations o 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 ILOs Tripartite Declaration o Principles ConcerningMultinational Enterprises and Social Policy, the Organisation or Economic Co-operation and

Developments Guidelines or Multinational Enterprises, and Social Accountability 8000 (SA8000)? A more detailed list o 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-Packards Global Citizenship Policystates its commitment to the Universal Declarationo Human Rights and includes speci c policieson human rights and labor, as well as employeeprivacy. HPs Global Citizenship organizationprovides the governance or human rights and theother key aspects o its commitment to corporatecitizenship.

Human Rights are integral elements o CorporateCitizenship atNovartis . To put the Novartishuman rights responsibilities in the wider contexto a air societal division o labor, the NovartisCorporate Citizenship Guideline on Human Rightsis supported by a commentary.http://www.novartis.com/corporate_citizenship/ en/guidelines.shtml

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Getting started

Companies that have been recognized or including human rights in policies

The Business and Human Rights Resource Centre(www.business-humanrights.org) is a valuableresource or people interested in understandingdi erent perspectives o business and humanrights. It lists companies that have taken the step

o adopting a ormal company policy statementexplicitly re erring to human rights.It also notes which companies are participants inthe Global Compact.

2.3 Develop local policies to meet local situations It may be bene cial or international businesses to use local policies based on corporate standards andnational requirements. These local policies need to be translated into local languages to acilitate their under-standing and implementation. However, local policies should not contradict the general corporate standards.For example, in some cultures it is common practice or bribes to be sought and made, while at the interna-

tional level such practices are unlaw ul as well as being irreconcilable with a commitment to human rights.

Human rights embedded in local policies some examples o tackling national and local discrimination

Equity (South A rica) Eskom has incorporatedEskom has incorporatedissues o human rights - especially those relatingto employment equity and the local social needso the country - into its decision-making proc-esses. In South A rica, Eskom developed employ-ment equity policies, per ormance indicators andreward systems to ensure that the organization isrepresentative o the country in which it operates.

A rmative action, gender equity and the rights opeople with disabilities are key elements. Simi-larly, targets and per ormance indicators are set

or procurement practices that proactively supportand develop Black Economic Empowerment (BEE)and, in particular, Black Woman Owned businessand small and medium sized enterprises.

Pro essionals with disabilities (Mexico) Through the Mexico-based program Congru-encia, CEMEX Mexico has developed a policy oinclusion or workers with disabilities, intended toenhance their job opportunities and to raise com-munity awareness on the issue o social equity.This program is managed through a specializedwebsite that provides in ormation on vacanciesand human rights. In 2004, the program wasopened to other companies and currently involvesmore than 20 public and private institutions,which promote avorable conditions or social andlabor inclusion.

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2.4 ensure full implementation of your policies anDreview their outcomes Group and local policies should be the overall responsibilityo identi ed individuals within the business who are tasked with ensuring the policies are ully implemented.These individuals should ensure that there are su cient resources or implementation, the results are moni-tored, and the policies are regularly reviewed. Even the most clearly de ned policies will require interpretation.The policy owner should act as a ocal point or dealing with human rights issues that arise through imple-mentation and should have access to both local and international expertise.

Human rights embedded in local policies some examples o tackling national and local discrimination

Womens rights (Sri Lanka) MAS Holdings(an apparel manu acturer) has a business modelthat supports the empowerment o women. With92 per cent o the total work orce o 34,000employees in the company being made up owomen, MAS has developed best practices inits corporate citizenship program to empowerwomen. The Go Beyond program at MASrecruits economically less a fuent, rural womenand teaches them English language skills andhow to use IT-enabled tools to advance their ca-reers. The emale employees are also trained tomanage their nances, to have an understand-

ing o sexual and reproductive health and toachieve a better work-li e balance. The work-li e

balance initiatives recognize and support themultiple roles played by career women and theneed or a healthy balance between work andpersonal li e. MAS also rewards high-achieversin academia, sports, science, commerce, andarts and culture. Employees are encouraged toper orm better through annual awards such asthe Empowered Woman o the Year Award.Community initiatives, especially those that im-prove educational and healthcare in rastructure

or young women, have been a long standingtradition at MAS. The company ensures thatits predominantly emale work orce has a high

level o con dence and sel -esteem. This in turnhas helped the company to grow its business

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3 Processes and

ProceduresHuman rights in processes and procedures:key steps or your business

3.1 Consider the ull scope o your business activities and unctions3.2 Establish procedures or identi ying your human rights-related risks

and opportunities3.3 Establish control systems or managing human rights in your business3.4 Learn rom sector-wide business initiatives3.5 Expect the unexpected how to react when procedures are not enough

3.1 consiDer the full scope of your business activitiesanD functions As part o human rights policy implementation, it is crucial to de ne the pro-cesses and procedures that will make the policy a reality. The processes and procedures may di er accordingto business context within the same company. However, what they will all have in common is that they areintended to achieve the same result, are documented, and have measurable indicators and outcomes.

The executive management team o the business is responsible or ensuring that roles, responsibilities,authority, and resources are de ned and allocated in a way that enables e cient implementation and main-tenance o human rights management in the organization.

3.2 establish proceDures for iDentifying your humanrights-relateD risks anD opportunities As already outlinedin the section onStrategy , the key to managing human rights in an organization is to analyze andunderstand the risks and opportunities in a companys operations. Ensuring compliance with legalrequirements and international treaties is essential to this analysis and should be reviewed regularlyas part o the management process.

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Human rights as an important actor in a country risk assessment an example

Statoil has ormulated country and reputationrisk guidelines to ensure the company has wide-ranging knowledge and understanding o localconditions, business culture, and external actorsas early as possible in a business project. Theaim is to minimize Statoils country and reputa-tion risk exposure through the early identi ca-tion, prioritization, and mitigation o risks thatmay a ect a project or business opportunity.Risk mitigation alternatives are speci ed orevery signi cant risk actor that is identi ed; thelevel o detail depends on how ar the projector business opportunity has progressed. Risk

mitigation measures refect Statoils corporatesocial responsibility strategy and its require-ments or social investment management. Risk assessments are per ormed regularly and whensigni cant events occur. The risks are dividedinto 19 actors within the ollowing categories:

Political risk elements

Country-speci c operational risk elements

Reputational risk

Human rights and possible violations are impor-tant actors within thepolitical risk category.

The Human Rights Matrix developed by BLIHR can help companies identi y risks and opportunities.Stakeholder panels may give advice on external concerns regarding a companys operations and may alsoprovide input on possible solutions. Mapping a companys sphere o infuence may also help to identi y therisk o complicity when operating in a country with a poor record on human rights. In addition, calling orregular checks and updates is advisable i a particular country ranks low on an index o corruption levels

or instance. Finally, input rom non-governmental organizations (NGOs) and external country assessmentscan provide additional value.

3.3 establish control systems for managing human

rights in your business Once risks and opportunities have been identi ed or eachbusiness operation, a company should develop and implement adequate control processes or those op-erations. Control processes could range rom a supplier quali cation process with a mandatory risk reviewo customer projects, to a code o conduct that ensures equal opportunity and minority rights, or a checklistand instructions or business operations in sensitive areas. Guidelines or suppliers and contractual agree-ments with customers and suppliers have proven to be power ul tools or ensuring that risks are minimizedor eliminated and opportunities are maximized.



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IntroductionHuman rights in di erent types o control systems some examples

Identi ying market opportunities National Griddoes not have extensive operations in countries thatare considered to be o urgent concern in relationto some aspects o human rights. The utility com-pany has there ore ocused on extending its existingrisk management by identi ying and understandingthe areas where the Group might be exposed to hu-man rights risks and opportunities when developingnew business in emerging markets. As a result, ithas revised its business development proceduresto include an analysis o human rights risks whenidenti ying market opportunities. It has also devel-oped protocols to enable an analysis o potential

target companies, to assess their approach andrecord on human rights issues.

Editorial practices MTV Europe is developinga Code o Editorial Conduct, which will be oneo the rst in the industry to be based on humanrights values. The Code and its procedures orapplication will be based on MTVs understand-ing o its spheres o infuence and would provideinternal processes or creative thinking anddecision-making. This in no way will involvecensorship; instead it will enable the company totake better-in ormed risks.

Purchasing practices Gap Inc. is workingGap Inc. is workingtowards better human rights compliance by im-proving supply chain operations and embeddinglabor standards directly into business practices.Ultimately, Gap believes garment manu acturers,most o whom are multinational corporations,must take responsibility or conditions in the

actories they own and operate. To encouragethem to take that responsibility seriously, Gap isdeveloping a ormal tool that will enable them toconsider a garment manu acturers compliancerecord along with criteria such as cost, speed,

quality, and innovation when deciding where toplace orders. At the same time, Gap recognizesthat its own business practices can have animpact on compliance, and is actively exploringbetter ways to work with its manu acturers. Toavoid contributing to excessive overtime, Gap ismaking a greater e ort to ensure that garmentmanu acturers have accurately assessed theircapacity and capabilities be ore orders areplaced with them. Gap is also working to reduceine cient purchasing practices such as rushorders and last-minute changes.

Lending assessments Human rights issuessuch as the rights o indigenous peoples, areincluded in the Equator Principles which de nesocial and environmental criteria that apply toproject nancial transactions (see the Appendices

or details). Barclays was one o the original groupo banks to adopt the Principles in June 2003and, while the criteria is speci c to project-relatedlending, Barclays extends the spirit o the Prin-ciples when assessing other types o lending.

Per ormance standards or resettlement TheInternational Finance Corporation (IFC) is in theprocess o adopting a new set o per ormancestandards that it will require its clients to adhereto as a condition o lending. One o the per or-mance standards addresses involuntary resettle-ment a process in which governments movepeople to make way or projects in the publicinterest such as roads or water treatment plants.In preparing the new per ormance standard, IFCreviewed the human rights protections in theright to housing and incorporated those aspectso the right to housing that the private sector cantake action on within a project context.

(continued on next page )



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Human rights in di erent types o control systems some examples

(continued) For example, anyone moved mustbe provided with security o tenure in their newlocation, even i they did not have security otenure in their previous location. This refectsthe right to housing with emphasis on providingeveryone with security o tenure i.e. protectionagainst illegal eviction. I an IFC- nanced projectinvolves involuntary resettlement, the companymust prepare a detailed plan or resettlement,including plans or providing in ormal settlers withsecurity o tenure in a new location. IFC thenreviews and approves the plan as a conditiono nancing. As a urther condition o nanc-ing, the client must implement the plan, monitorand ensure that the actions taken achieve theobjectives set out in the per ormance standardand the resettlement plan. I the resettlement issu ciently large or di cult, IFC will require anindependent third party to monitor implementa-tion o the resettlement activities.

Scheduled and unscheduled inspections Li& Fung (Trading) Limited, based in Hong Kong, isa global trading group that manages the supplychain or high-volume, time-sensitive consumergoods particularly garments, urnishings, gi ts,home products, toys, and sporting and travel

goods. From Hong Kong, it co-ordinates the manu-acture o goods through a network o o ces in

almost 40 countries. All suppliers to Li & Fungare required to commit to the Code o Conductto Vendors, which has 14 principles, including nochild labor and non-discrimination principles. A signed copy must be returned to Li & Fung within30 days, and ailure to give a timely response willcause it to review its relationship with [the sup-plier]. The code is en orced through scheduledand unscheduled inspections.

Managing Third Party relationships Theobjective o Novartis Third Party Guidelines isto provide criteria, tools, and procedures or: (1)the assessment and approval o Third Parties;and (2) the continuous management o businessrelationships. The standards set orth in this ThirdParty Guideline apply to Corporate Functionsand all Novartis Divisions and Business Units. No-vartis Divisions and Business Units either adoptthese guidelines as is or issue an equivalentguidance note o their own. http://www.novartis.com/corporate_citizenship/en/guidelines.shtml

Supply chain management Human rights are acentral ocus o Hewlett-Packards Supply ChainSocial and Environmental Responsibility (SER) Pro-gram. One o HPs biggest challenges is to applyits Human Rights Policy in its supply chain, whereit does not have direct control. One way HP isaddressing this is through the Electronic IndustryCode o Conduct (EICC), which HP co-developedwith Dell, IBM, and several large contract manu-

acturers in 2004. The Code provides an importantoundation or ongoing supplier audits and other

e orts to ensure compliance with the HP HumanRights Policy. Most importantly, it makes supplierper ormance easier to audit and veri y.

Gap Inc. views SA8000 as a premier set o globallabor standards towards which they hope gar-ment manu acturers will aspire. A ew o theirsuppliers have already received SA8000 certi-

cation. As a member o Social AccountabilityInternationals Corporate Involvement Program,Gap Inc. recently conducted a gap analysis otheir Code o Vendor Conduct relative to theSA8000 standard and are examining areas inwhich they can bring their policies and programinto closer alignment with SA8000. In addition,they have asked their entire internal monitoringteam to take the SA8000 auditor course.



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Getting started

3.4 learn from sector-wiDe business initiatives Some business sectors alreadyhave an interest in sharing knowledge and experiences about human rights-based processes and procedures. It isworthwhile researching which sector-speci c groups might be available to you and which might have valuable tools or you toadapt to your business. Some examples are shown below:

Examples o sector-speci c initiatives with expertisein human rights codes and procedures

3.5 expect the unexpecteD how to react when proceDures arenot enough Given the rapidly changing nature o international business, processes and procedures constantlyrequire adaptation and review. Sometimes unexpected events can provoke human rights issues that had not been anticipatedor prepared or. In such situations, management is best able to deal with the situation i they have the knowledge (see thesection onTraining ) and resources to act quickly, pro essionally, and in ways that provide a just solution. Clear lines o ac-countability within business strategies and policies make such fexibility possible, as does a commitment to transparency.

Reacting when con ronted with un oreseen human rights issues

An example o responsiveness to un oreseen human rightsissues is how BP responded to Amnesty Internationals2003 Report on the Baku-Tbilisi-Ceyhan oil and gaspipeline. The report highlighted a number o human rightsconcerns relating to the Host Government Agreementsigned between the consortium o companies and the gov-ernments o Azerbaijan, Georgia, and Turkey, and the abilityo these governments to uphold uture human rights com-

mitments within the region o the pipeline. BP respondedby opening a dialogue with Amnesty International over aperiod o several months during 2003. The talks resultedin a legally binding additional contract designed to protectthe rights o the three host governments to promote andregulate 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)

In ormation Technology Electronic Industry Code o Conduct Global e-Sustainable Initiative (GeSI)



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4.1 share unDerstanDing of why human rights areimportant to business communications The act o communicating isin itsel an essential part o a human rights approach; balancing reedom o expression with the protectiono personal or private in ormation and the participation o stakeholders is essential. Your companys humanrights policy, procedures, and per ormance should be documented and communicated to employees; orinstance, through codes o business conduct. They should also be made available through the corporatewebsite, 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 obligationsthey have undertaken to uphold human rights in their business relations.

4.2 integrate human rights into your internal communicationsInternal communication is critical to developing an e ective human rights management system. Consistentand well-presented top-down communication within a company serves to in orm about human rights withinthe business strategy. Employees should be in ormed about human rights risks and opportunities that thecompany aces in its operations. The per ormance indicators that are used to monitor and measure thee ciency o the human rights management system should also be communicated to all. It is particularlyimportant or businesses to communicate to all employees the principal drivers behind human rights basedinitiatives and their relevance to the long-term strategy o the company. The latter can prevent the marginaliza-tion o initiatives and ensure that specialized departments handling human rights issues are ully integratedinto the company. An interactive approach to internal communications may generate greater understandingand a fow o innovative ideas and proposals on how to improve established practices and procedures.

E cient lines o communication with employees are also needed to ensure e ective non-compliance reportingand whistle-blowing. This requires clearly de ned policies and procedures on the subject and clear contactpoints in the organization. Human rights issues should be communicated using simple and straight orwardterminology, translated into relevant languages, and made widely accessible, including to employees with

disabilities. It may be use ul to initially address human rights issues using business terminology, since humanrights may appear overly political or legalistic and may create barriers or misunderstanding. It is key thatcommunications are ollowed up by encouraging a culture o human rights recognition and respect in theorganization; it may be necessary to develop change management strategies to best acilitate this.

Human rights in communications:key steps or your business

4.1 Share understanding o why human rights are important to businesscommunications

4.2 Integrate human rights into your internal communications4.3 Integrate human rights into your external communications

4Communications

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Getting started

Human rights in internal communication some examples

Communicating human rights within acompanys code o conduct to employeesHuman rights is a key part o Novartis code oconduct. Setting out standards o pro essionalism

or the day-to-day conduct o associates aroundthe globe, the code describes how associatesshould handle themselves ethically and sa ely ina variety o potentially challenging situations. Anon-line e-learning package is being developed tohelp managers and associates around the worldunderstand the real dilemmas that might occur inthe workplace and how the code can be applied. Any e ective human rights communication shouldbe appealing and attractive enough to awaken

and sustain the necessary level o interest, whilstaccurately presenting key messages. For this reason,the Novartis Foundation or Sustainable Developmentprovides a human rights helpdesk or the wholecompany and has also developed a roll-out kit thatis available to potential users o the code.

Human rights within a balanced scorecardused or sta appraisals Novo Nordisk has a

number o systems to ensure that it lives up toits commitment to corporate responsibility. Eachyear, the company de nes a number o corporateresponsibility targets that are contained in thecompanys balanced scorecard. Sta apprais-als and management bonuses are dependenton per ormance toward these targets. Facilita-tors, who are a group o experienced sta withan international background rom the holdingcompany Novo A/S, make independent assess-ments o individual departments compliance tothe Novo groups values.

Communicating with sta throughout theworkplace The accomplishments o Taj Hotels (aprominent member o the Tata Group) in the areao human rights are largely the result o its em-phasis on corporate values. The company hasdi erent ways o communicating and rein orcingits values in the workplace, including e-mail oot-ers, screen savers, posters, quiz programs andbillboards. A Per ormance Management System isalso 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 o its communications, including data protection, personal privacy, and companycon dentiality. Companies may also be responsible or the actions o their employees while at work, suchas the use o the internet or possible e-mail abuse.

4.3 integrate human rights into your external commu-nications A companys human rights record is central to its accountability and can a ect itsreputation. To be accountable to stakeholders, a company must be transparent about its policies, ap-proach and per ormance. Open and transparent communications on per ormance and a willingness to actconstructively ollowing external advice are keys to success. The sphere o infuence o some businesses,such as those involved in the media and communications, may lead them to have a signi cant impact(positive or negative) on how human rights are viewed and respected in society.

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Getting started

00

Human rights in external communication some examples

Human rights on the high street As ahigh street retailer, The Body Shop wantsto use its windows and daily contact withthousands o customers to raise awarenesson human rights issues. Over the years, TheBody Shop has run numerous campaigns

to support human rights causes around theworld. Currently, the company is ocusingon issues acing customers, employees,and the communities in which the com-pany operates with a success ul campaignto Stop Violence in the Home, as well asraising awareness o HIV/AIDS.

Stakeholder Advisory panel Althoughmost scienti c evidence states thatelectric and magnetic elds do not resultin adverse health impacts, National Gridrecognizes that there is some limitedscienti c evidence suggesting theopposite, and that parts o society areconcerned about this issue.

In 2003, National Grid took the initiativeto improve the dialogue between partieswith an interest in this issue by creat-ing a Stakeholder Forum. The Groupengaged an independent body, the UKsEnvironment Council, to set up and

acilitate a workshop to which represen-tatives rom industry, Government, aca-demia, pro essional bodies, and interestgroups were invited. This brought people

with di ering views to the table or therst time. Although there was suspicion

o why National Grid had established theForum, involving some o the interestgroups in the planning or the meetings

helped overcome concerns. The partici-pants in the Forum have now agreedto establish a more ormal Stakeholder Advisory Group under the sponsorship othe Department o Health.

Providing the opportunity or stakehold-ers with opposing views to voice theirconcerns has proved to be extremelybene cial, both or the broader under-standing o relative positions on thesubject and or the development osensible policy in this area.

Consultation with key stakeholders Tele nica, a global telecommunicationscompany, has made a name or itsel in

ostering equal opportunity and support-ing the rights o people with disabilities.Through the Accessible Tele onica plan,the company uses stakeholder dialogueand engagement to enhance equal op-portunities and access to its telecommu-nications services and products.

The plan is coordinated by Tele nicasCSR Department and involves a numbero business lines and subsidiaries. Ithas been developed through a partner-ship and ramework agreement with themain plat orm that represents peoplewith disabilities in Spain. As part othe plan, consumers with disabilities

participate in consultation processes,test products and services, and give

eedback about the degree to whichtheir needs and expectations are met.The plan involves a range o projects in-

cluding the development o accessibleservices and products, outreach andawareness-raising with Tele nicasstakeholders, labor integration andemployment 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 communicationsis less about communicating its internalpractices to the outside world than abouthuman rights in action: promoting hu-man rights on air and on the ground, inparticular to its core youth audience.

The two strongest examples are twoongoing multi-plat orm MTV humanrights campaigns: MTVs Exit Campaign

to End Exploitation and Tra cking, andthe Staying Alive HIV/Aids Campaign. Bothcampaigns comprise o MTV program-ming (MTV specials such as the tra ckingawareness and prevention documentaryInhuman Tra c, hosted by AngelinaJolie, and the Staying Alive special Meet-ing Mandela), awareness and preventionevents, multi-language websites www.mtvexit.org and www.staying-alive.org,and support or NGOs working to ghttra cking and HIV/AIDS.

By developing and implementing such

campaigns on issues critical to itscore audience, MTV maximizes thepromotion and realization o certain

undamental human rights within itskey spheres o infuence.

As or internal communications, a company should ensure thathuman rights are protected in all o its external communications.For example, i local communities want to communicate withthe company through protest, the company should respect theirright to reedom o expression and should not seek to repressdemonstrations or ask governments to do so, even i the com-

pany does not agree with the message or the style o communi-cation. In gathering and retaining in ormation about employees,customers, or others, companies should ollow data protectionrules and respect the right to privacy. This is especially truewhere companies hold sensitive health or other private in orma-tion gathered or the companys human resources les.

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Introduction5 TrainingHuman rights in training: key steps or your business

5.1Identi y target groups in your business to receive human rights training

5.2 Review the di erent types o training materials available5.3 Select, organize and evaluate the training program or target groups

5.1 iDentify target groups in your business to receivehuman rights training General employee training needs to provide an understand-ing o how human rights relate to the business and must raise awareness o human rights risks andopportunities. A needs analysis o employees at particular business sites or o those who per orm speci c

unctions can help identi y areas which the training should cover. Case studies can support this training.Key employees throughout the organization should receive unction-speci c training; or example, trainingabout speci c risks in their operations and how to handle them, or training on new procedures and tools.Target groups or training could include:

Procurement employees Sales and export sta Human resources Security sta All supervisors and managers

The company can also take steps to train key suppliers and contractors. Stakeholders and external partnerscan help with training on speci c issues such as political, geographical, and cultural risks. Key sta should

also participate in external training where independent experts challenge others and give specialist insight intospeci c human rights issues.

5.2 review the Different types of training materials availableThere are a range o di erent types o human rights training available: web-based and paper-based or inperson, held either in the workplace or at a special venue outside the business location.

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Getting started

Human rights in di erent types o training some examples

E-learning systems Novartis requires everymanager and associate to complete a number oweb-based courses as part o its commitment tothe groups compliance initiative and its commit-ment to hold all associates to the highest stan-dards possible. Ensuring that Novartis employeesacross 140 countries understand the companysHuman Rights Guidelines and the strategy behindthem represents a huge challenge. There ore, in2005 all non-US Novartis associates with e-mailaccess will complete our out o the ollowingsix courses, each involving human rights as akey element: Insider trading, Confict o interest,Corporate citizenship, Sales practices, Marketing

practices, and Financial integrity.

Specifc training or business units NationalGrid has over 8,000 active suppliers. The groupsprocurement teams are experienced in assess-ing suppliers environmental, sa ety, and qualityper ormance, but not in assessing other humanrights-related per ormance. During 2005, theGroups UK and US procurement team mem-bers received human rights awareness trainingand were introduced to a practical tool to helpprioritize their human rights assessments. The toolis being used to assess the human rights risk as-sociated with each purchased commodity and theinfuence that the purchaser has with suppliers oeach commodity. This analysis is used to identi y

the level and priority o human rights-relatedengagement with potential suppliers.

Sta induction Every employee at The BodyShop is required to attend a sta induction thatincludes a signi cant section on the companyscommitment to ethical trade, community trade,campaigning, environmental protection, and animalwel are. In addition, in connection with the launcho the campaign to Stop Violence in the Home, allstores will be provided with training materials toensure that all employees understand the issuesand the importance o the campaign activities.

Management handbooks and primers The Business and Human Rights ManagementPrimer produced by Shell in 1998 was one o the

rst o its kind in business. The primer is a key re-source or human rights training programs withinthe company and has been augmented by a serieso real-li e management dilemmas or trainingpurposes. Another good example is the HumanRights Guidance report developed by Rio Tinto.

Residential Multi-Business Human RightsTraining There is an increasing demand or resi-dential training, which allows business managers

rom a number o companies to gather in a lessormal setting. Some examples are listed in the

Appendices.

5.3 select, organize anD evaluate the training programfor target groups The selection o the appropriate training program is based on actorssuch as cost, location, and the technology involved. It is worthwhile to ask other businesses and business as-sociations which programs they have ound the most use ul, but remember that no two businesses are alike.It is likely that stakeholders rom the local community or NGOs will have much to contribute to any programthat is to be organized. It is essential in these circumstances that the business and NGO or community groupwork together in partnership to clearly de ne expectations and develop a productive working relationship.

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Getting started6 Measuring

Impact and Auditing

6.1 Set relevant per ormance indicators or measuring human rights impactacross the di erent unctions o your business

6.2 Undertake human rights-based audits

6.3 Analyze the results o audits and use results to in orm strategicdevelopment o your business

6.1 set relevant performance inDicators for measuringhuman rights impact across the Different functions ofyour business A company should develop quanti able per ormance indicators to monitor andmeasure elements in its operations that have an impact on human rights. Per ormance indicators shouldmeasure both the direct result o the companys operations and the e ciency o management processesthat infuence per ormance such as training and the allocation o resources.

The indicators should be relevant to the companys sphere o infuenc

business leaders initiative on human rights

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