For those reporting companies that adopt a geographical focus in their reporting, to explain the basis for that decision and the principles underlying the selection of the specific chosen geographies.

Selecting specific geographies as a focus for reporting will not be necessary for every reporting company. It is an option that some companies – particularly large companies with multiple business units and/or operating contexts – may choose in order to ensure reporting is focused and relevant.

Focal geographies should be selected with a primary focus on risk to human rights, and, therefore, favour geographies where the salient issues being reported are significant. This significance may be due to:

a. a local context of conflict or other weaknesses in the rule of law, placing the particular human rights at heightened risk;

b. the particular vulnerability of certain groups in that location to impacts on the human rights in question, for instance, due to discriminatory laws or social practices;

c. corruption or other factors that place the human rights in question at heightened risk from the actions of suppliers or other business partners.

Explaining the selection of geographies in terms of risk to human rights may, on occasion, raise sensitivities, for instance, if it might be seen to imply a critique of a particular government. In this case, the reporting company may find it useful to reference third-party sources as a basis for its selection, for example, by pointing to stakeholders’ (including local stakeholders’) interest in how the one or more of the salient human rights issues are respected in that country or region; or by reference to public assessments by an industry association, government or international organization of the human rights context.

A reporting company may choose the same focal geographies across all the salient human rights issues on which it is reporting. Alternatively, it may identify different geographies in relation to different issues.

Some companies may prefer not to focus all their reporting about a salient human rights issue on specific geographies, but to draw examples from multiple settings. The principle guiding which examples to select should be the same: examples should be drawn from settings where there are real challenges in preference to those where the issue is a limited problem or easy to address. It is in the challenging contexts that the company can best demonstrate that its efforts to ensure respect for the human right are meaningful and effective. If a company uses an example from a less challenging setting it should highlight the reason for the selection, for example, if it demonstrates an important innovation or an approach that the company will be rolling out to other geographies.

Essential information for companies focusing their reporting on specific geographies includes:

• Which geographies form the focus for reporting in regard to which salient human rights issues;

• The reasons for the selection of those geographies, with due attention to the significance of risks to human rights.

Additional relevant information for the company’s answer could include:

• Key aspects of the process through which the specific geographies were selected;

• If and how inputs from stakeholders were taken into account in the identification of the selected geographies, in particular, inputs from potentially affected stakeholders;

• Any role of senior management and the Board in identifying and/or agreeing on the specific geographies.

UN Guiding Principle 21 states that:

“Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them.”

Please note:

1. Assurance provided at the higher tiers should include indicators from lower tiers.
2. These indicators are supported by further notes in the Microsoft Excel version of the indicators. For all support materials on assurance of human rights performance and reporting, please see our website section on assurance.

TIER ONE ASSURANCE

• If the company focuses its efforts to address human rights risks on a limited number of geographies, these are geographies where those risks are particularly significant.

[Relevant for the assurance of human rights reporting]

• If the company selected one or more focal geographies for its human rights reporting:
  • the company conducted a clear process to arrive at its selection based on the time frame addressed in its reporting
  • senior management and the Board signed off on this selection

• Where focal geographies are not those where the issue(s) being reported are particularly significant, this is made clear and there is a credible alternative explanation for their selection.

TIER TWO ASSURANCE

[Relevant for the assurance of human rights reporting]

• If the company selected one or more focal geographies for its human rights reporting:
  • the company drew on internal expertise and experience from all relevant parts of the company, and any necessary external expertise, in making this selection

TIER THREE ASSURANCE

[Relevant for the assurance of human rights reporting]

• There is evidence that informed external stakeholders find the company’s selection of focal geographies for reporting:
  • to be reasonable as a reflection of locations where the company’s salient human rights issues are particularly significant
  • to be otherwise justified based on an explanation provided