A1

Policy Commitment

Overarching question

To explain how the reporting company understands its responsibility to respect human rights, and how it articulates its resulting expectations of its workforce, business partners and businesses or other entities directly linked to its operations, products or services.

A policy commitment refers to any one or more publicly available statements of the company’s responsibilities, commitments or expectations with regard to respect for human rights across its activities and business relationships.

The key for addressing this question is to focus on:

  1. public commitments, and not policies that are only internal;
  2. commitments that relate to respect for human rights across the company’s own activities and business relationships, and not philanthropic or other activities that support or promote human rights more generally.

The commitment may take the form of a single, stand-alone public policy regarding respect for human rights, or be included in a broader document, such as a code of ethics or business principles.

Alternatively, different aspects of the company’s commitment may be reflected in different documents, for example, policies on non-discrimination, freedom of association, respect for communities’ cultural rights, a supply chain labour rights code of conduct, and so forth. While commitments set out in different documents usually don’t cover all internationally recognized human rights, they can nevertheless provide the basis for responding to this question by showing the current scope of the company’s public commitments. If there are plans to expand on these, then it will also be useful to reflect that in response to this question.

Relevant information for the company’s answer could include:

  • A summary or restatement of the company’s public human rights policy commitment, or a web link to where it can be found;
  • What written form the public commitment takes (e.g., a stand-alone human rights policy, part of the company’s code of business ethics or code of conduct, a statement on the company’s website, or multiple different documents);
  • The human rights included within the public commitment and whether it highlights particular human rights for attention (e.g., whether the commitment is limited to a particular set of rights, encompasses all internationally recognized human rights, or encompasses all internationally recognized human rights but highlights some as needing particular attention);
  • Whether the commitment relates solely to the company’s own activities or includes the company’s expectations of other organizations with which it has business relationships (e.g., first-tier suppliers, suppliers beyond the first tier, contractors, entities in the downstream value chain, joint venture partners, governments or government agencies).

The robustness of the reporting company’s response to this question will be improved to the extent that it is able to answer the supporting questions that follow.

UN Guiding Principle 16 provides that:

“As the basis for embedding their responsibility to respect human rights, business enterprises should express their commitment to meet this responsibility through a statement of policy that:

(a) Is approved at the most senior level of the business enterprise;

(b) Is informed by relevant internal and/or external expertise;

(c) Stipulates the enterprise’s human rights expectations of personnel, business partners and other parties directly linked to its operations, products or services;

(d) Is publicly available and communicated internally and externally to all personnel, business partners and other relevant parties; …”

The Commentary to UN Guiding Principle 16 states that:

“The term ‘statement’ is used generically, to describe whatever means an enterprise employs to set out publicly its responsibilities, commitments, and expectations.

The level of expertise required to ensure that the policy statement is adequately informed will vary according to the complexity of the business enterprise’s operations. Expertise can be drawn from various sources, ranging from credible online or written resources to consultation with recognized experts.

The statement of commitment should be publicly available. It should be communicated actively to entities with which the enterprise has contractual relationships; others directly linked to its operations, which may include State security forces; investors; and, in the case of operations with significant human rights risks, to the potentially affected stakeholders.

Internal communication of the statement and of related policies and procedures should make clear what the lines and systems of accountability will be, and should be supported by any necessary training for personnel in relevant business functions.”

These references are intended to help users identify which provisions from other initiatives would be relevant as part of the answer to this question. They are not a substitute for the guidance above.
See the cross-references to other initiatives page for a key to the initiatives referenced.
Initiative Reference point
CHRB

A. Governance and Policy Commitments: A.1.1, A.1.2, A.1.5
E. Performance: Responses to Serious Allegations: E.1.2

DJSI

Criterion: Labor Practice Indicators and Human Rights
Question: Public Commitment to Human Rights

Criterion: Codes of Conduct/Compliance/Corruption & Bribery, where there are relevant publicly available commitments related to Discrimination, Environment, Health and Safety or Whistleblowing.

FTSE ESG

Strategy & Practice elements related to policy commitments under the following Themes:
Labour Standards, Health & Safety, Human Rights & Community Indicators, Social Supply Chain, Risk Management, Customer Responsibility

GNI

Governance Charter: 4B. Responsibilities of Participating Companies; 7E. Company Reporting to the Public

GRI

G4-DMAb (Policies and Commitments)

ICMM

Subject Matter 1: The alignment of the member company’s sustainability policies to ICMM’s 10 SD principles and any mandatory requirements set out in ICMM position statements.

Specifically, those SD principles most relevant to human rights: Principle 1, Principle 2, Principle 3.

IR

KTC

1.1 Awareness and Commitment

OECD

OECD-1

UNGC

Mandatory question: Does your COP contain a statement by the CEO (or equivalent) expressing continued support for the Global Compact and renewing your company’s ongoing commitment to the initiative and its principles?

Criterion 3
Criterion 6 and specifically:
– Written company policy to obey national labour law, respect principles of the relevant international labour standards in company operations worldwide , and engage in dialogue with representative organization of the workers (international, sectoral, national).

VPSHR

1. Statement of commitment or endorsement of the Voluntary Principles.

Supporting questions

To explain the various factors that have informed the content of the reporting company’s public commitment, including the internal or external stakeholders and experts who have had a role in its development.

A public human rights commitment, whilst not static, provides a somewhat constant reference point over time for individuals within and outside the company. It may not have changed within the reporting period. Therefore, this question will be particularly relevant for reporting companies that are reporting for the first time, that have made changes to their policy in the reporting year, or that are planning any changes to the policy. If this is not the case, companies may choose to respond to this question by referring the reader to where the process of development has been described in a prior report, making that information as accessible as possible.

Relevant information for the company’s answer could include:

  • Any internal and/or external consultative processes that contributed to the development of the public commitment;
  • How external inputs are reflected in the policy;
  • Whether, and if so how, senior management and/or the Board were involved in the development of the commitment;
  • The level (Board, senior management, or other) at which the public commitment was approved;
  • Any changes in the public commitment within the reporting period;
  • Any plans to update the public commitment within the next reporting period.

UN Guiding Principle 16 states that:

“As the basis for embedding their responsibility to respect human rights, business enterprises should express their commitment to meet this responsibility through a statement of policy that:

(a) Is approved at the most senior level of the business enterprise;

(b) Is informed by relevant internal and/or external expertise; …”

The commentary to Guiding Principle 16 further states that:

“The level of expertise required to ensure that the policy statement is adequately informed will vary according to the complexity of the business enterprise’s operations. Expertise can be drawn from various sources, ranging from credible online or written resources to consultation with recognized experts.”

These references are intended to help users identify which provisions from other initiatives would be relevant as part of the answer to this question. They are not a substitute for the guidance above.
See the cross-references to other initiatives page for a key to acronyms.
Initiative Reference point
CHRB

A. Governance and Policy Commitments: A.1.4, A.2.1

DJSI

FTSE ESG

GNI

GRI

ICMM

IR

KTC

1.2 Supply Chain Standards
(element 4: reviewed and updated regularly)

OECD

OECD-1A

UNGC

Criterion 3 and specifically:

– Integrated or stand-alone statement of policy expressing commitment to respect and support human rights approved at the most senior level of the company (BRE 1 + BRE5 + ARE 1 + ARE 5)

VPSHR

To give more information about the specific groups that the reporting company’s public commitment to respect human rights aims to address, in order to place the remainder of the company’s reporting in context.

In some instances, it may be explicit that the public commitment covers any and all individuals and groups who may be affected by the company’s activities or through its business relationships, or that it focuses on certain groups, such as employees. In other instances, the scope of its application may be implicit and understood within the company but not set out in the relevant public documents.

It is particularly relevant to explain whether the public commitment includes individuals who perform work for the company under temporary contracts as well as its employees. The reporting company may also wish to highlight other groups that it deems particularly relevant for its own efforts to ensure respect for human rights, such as indigenous communities, smallholder farmers, or women working in its supply chain.

Relevant information for the company’s answer could include:

  • Whether the public commitment covers all individuals and groups who may be impacted by the company’s activities or through its business relationships, or whether it relates to certain, specific groups and, if so, which ones and why;
  • Any groups to which the company pays particular attention, and why;
  • Any plans to change the scope of individuals or groups covered by the policy commitment, and why.

UN Guiding Principle 12 provides that:

“The responsibility of business enterprises to respect human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.”

The commentary to UN Guiding Principle 12 states that:

“Because business enterprises can have an impact on virtually the entire spectrum of internationally recognized human rights, their responsibility to respect applies to all such rights. In practice, some human rights may be at greater risk than others in particular industries or contexts, and therefore will be the focus of heightened attention. However, situations may change, so all human rights should be the subject of periodic review.

An authoritative list of the core internationally recognized human rights is contained in the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights and the main instruments through which it has been codified: the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), coupled with the principles concerning fundamental rights in the eight ILO core conventions as set out in the Declaration on Fundamental Principles and Rights at Work.

These are the benchmarks against which other social actors assess the human rights impacts of business enterprises. The responsibility of business enterprises to respect human rights is distinct from issues of legal liability and enforcement, which remain defined largely by national law provisions in relevant jurisdictions.

Depending on circumstances, business enterprises may need to consider additional standards. For instance, enterprises should respect the human rights of individuals belonging to specific groups or populations that require particular attention, where they may have adverse human rights impacts on them. In this connection, United Nations instruments have elaborated further on the rights of indigenous peoples; women; national or ethnic, religious and linguistic minorities; children; persons with disabilities; and migrant workers and their families. Moreover, in situations of armed conflict enterprises should respect the standards of international humanitarian law.”

These references are intended to help users identify which provisions from other initiatives would be relevant as part of the answer to this question. They are not a substitute for the guidance above.
See the cross-references to other initiatives page for a key to acronyms.
Initiative Reference point
CHRB

A. Governance and Policy Commitments: A.1.3, A.1.8

DJSI

FTSE ESG

Strategy & Practice elements related to policy commitments under the following Themes:
Labour Standards, Health & Safety, Human Rights & Community Indicators, Social Supply Chain, Risk Management, Customer Responsibility

GNI

GRI

ICMM

IR

KTC

1.2 Supply Chain Standards
(element 1: requires suppliers to uphold workers’ fundamental rights and freedoms)

OECD

OECD-1A

UNGC

Criterion 3 and specifically:

– Commitment to comply with all applicable laws and respect internationally recognized human rights, wherever the company operates (e.g., the Universal Declaration of Human Rights, Guiding Principles on Human Rights) (BRE1 + ARE1)

Criterion 6 and specifically:

– Reference to principles of relevant international labour standards (ILO Conventions) and other normative international instruments in company policies

VPSHR

To explain how the reporting company’s public commitment is shared with those for whom it is relevant, whether because they are expected to implement it (for example, the company’s contractors and suppliers), because they have a direct interest in its implementation (for example, potentially affected communities, investors, consumers, and civil society organizations), or both (for example employees and contract workers).

Dissemination can include relatively simple steps such as posting the public commitment on the company’s website or intranet, inserting references to it into contracts with third parties, or engaging in conversations internally and externally to raise awareness of the policy.

One key consideration for how to disseminate the policy commitment is also its accessibility to its target audiences. For example, some individuals may regularly access a website or company intranet; others may not have Internet access but be able to read documents; others may be illiterate. In response to this question, it will be relevant to reflect the extent to which the company tailors the way the policy commitment is disseminated according to the particular audience.

Relevant information for the company’s answer could include:

  • Whether and how the public commitment is communicated to employees and other individuals who work for the company (e.g., through a company intranet, in induction training, in other training, in meetings, in presentations by senior management, in written guidance);
  • Whether and how the public commitment is communicated to the company’s business partners or others in the company’s value chain (e.g., through pre-business conversations, contract negotiations, contractual terms, in training, in written guidance);
  • Whether and how the public commitment is disseminated in an accessible form to external stakeholders, in particular potentially affected stakeholders, (e.g., workers in the company’s value chain, trade unions representing value chain workers, communities or end users/customers who may be negatively impacted, NGOs or others who work with or advocate for potentially affected stakeholders);
  • Any limitations on the dissemination of the commitment, either internally or externally, and any plans to overcome those limitations.

UN Guiding Principle 12 provides that:

“As the basis for embedding their responsibility to respect human rights, business enterprises should express their commitment to meet this responsibility through a statement of policy that: …

(d) Is publicly available and communicated internally and externally to all personnel, business partners and other relevant parties; …”

The commentary to UN Guiding Principle 16 states that:

“The statement of commitment should be publicly available. It should be communicated actively to entities with which the enterprise has contractual relationships; others directly linked to its operations, which may include State security forces; investors; and, in the case of operations with significant human rights risks, to the potentially affected stakeholders.

Internal communication of the statement and of related policies and procedures should make clear what the lines and systems of accountability will be, and should be supported by any necessary training for personnel in relevant business functions.”

These references are intended to help users identify which provisions from other initiatives would be relevant as part of the answer to this question. They are not a substitute for the guidance above.
See the cross-references to other initiatives page for a key to acronyms.
Initiative Reference point
CHRB

B. Embedding Respect and Human Rights Due Diligence: B.1.4.a, B.1.4.b

DJSI

Criterion: Labor Practice Indicators and Human Rights
Question: Public Commitment to Human Rights

Criterion: Codes of Conduct/Compliance/Corruption & Bribery, where there are relevant publicly available commitments related to Discrimination, Environment, Health and Safety or Whistleblowing.

FTSE ESG

Labour Standards: Strategy & Practice
– Policy translated and communicated

Social Supply Chain: Strategy & Practice
– Policy translated and communicated

GNI

Where this relates to dissemination of a public commitment on human rights: Principle 10.

GRI

ICMM

Where this relates to dissemination of a public commitment on human rights: Governance Charter: 7E. Company Reporting to the Public

IR

KTC

1.2 Supply Chain Standards (element 3: is easily accessible on the company’s website)

1.4 Training (element 1 + 2: internal and supplier training on policies and standards related to human trafficking and forced labor)

5.1 Communication of Policies (element 1: to supply chain workers)

OECD

Where this relates to dissemination of a public commitment on human rights: OECD-1B (in supplements on Tin, Tantalum and Tungsten and on Gold), OECD-1D, OECD-5

UNGC

Criterion 3 and specifically:

– Statement of policy publicly available and communicated internally and externally to all personnel, business partners and other relevant parties (BRE 1 + BRE 5 + ARE 1 + ARE 5)

VPSHR