C1

Specific Policies

Overarching question

To inform the reader of any specific policies the reporting company has in place – in addition to its overarching public human rights commitment – that are particularly relevant to the salient issues identified. By outlining, or referring the reader to, key elements of the policy, the reporting company can help the reader understand the foundation for how the company approaches the management of each salient issue.

Section A1 of this Reporting Framework is about a company’s public statement(s) of commitment to respect human rights at a general level. This section is about specific policies or policy provisions that address the salient human rights issues identified in Section B. These policies may or may not be public. They may overlap with the company’s public commitment, for example, where that commitment includes specific provisions related to a salient issue. Where that is the case, it would be helpful to make this clear in response to this question.

In some instances, a specific policy may relate solely to the salient issue on which the company is reporting. For example, the reporting company may have a policy on non-discrimination, on security and human rights or on data privacy that would be relevant for reporting on those issues.

In other instances, a salient issue may be addressed through a single provision or section within a broader document. For instance, a general human resources policy may include provisions on the right to freedom of association and collective bargaining in relation to its own employees. A supply chain code of conduct may include provisions on the right to freedom of association and collective bargaining in relation to the employees of suppliers.

Specific policies may be articulated at the corporate level or at the level of particular business units or regional or country operations, or both, depending on the size and structure of the company and how far a policy is, or needs to be, tailored to different areas of the business.

Some reporting companies may not have specific policies that address salient issues beyond their general public commitment to respect human rights, in which case they can make that clear. Other reporting companies may be planning or developing such policies, and this would also be relevant information to include.

Relevant information for the company’s answer could include:

  • The focus and purpose of the specific policy/policies;
  • The content of the policy/policies (in summary and/or through a link or cross-reference to another publicly available document);
  • Any internal or external consultative processes that informed the development of the policy/policies;
  • Whether, and if so how, senior management and/or the Board were involved in the development of the specific policy;
  • Clarification of who is expected to implement the policy/policies (e.g., employees, contractors, suppliers);
  • Clarification of whose human rights the policy/policies relate to (e.g., employees, contract workers, communities, consumers);
  • Which position or function has operational responsibility for the policy’s day-to-day implementation;
  • Which position has ultimate accountability for the policy’s implementation (if different from operational responsibility);
  • The level (Board, senior management, or other) at which the specific policy was approved;
  • Any changes in the specific policy within the reporting period;
  • Any plans to update the specific policy within the next reporting period.

The robustness of the reporting company’s response to this question will be improved to the extent 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: …

(e) Is reflected in operational policies and procedures necessary to embed it throughout the business enterprise.”

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

*D. Performance: Company Human Rights Practices: D.1.5, D.1.8, D.2.4.a, D.2.4.b, D.2.5, D.2.6, D.2.7.a, D.2.7.b, D.2.8, D.3.4.b, D.3.5.b, D.3.6.a, D.3.6.b, D.3.6.c, D.3.6.d, D.3.7.a, D.3.7.b, D.3.8.a, D.3.8.b, D.3.10.a, D.3.10.b, E.1.2

*Section D of the CHRB refers to sector-specific key human rights risks identified by the CHRB.

DJSI

For specific salient human rights issues identified:
Criterion: Supply Chain Management
Question: Risk Management Measures
Data-point: Standard/Policy Code of Conduct for suppliers
Data-point: Contract Clauses

FTSE ESG

For specific salient human rights issues identified, Strategy & Practice and Quantitative, Sector Specific and Performance elements related to policy commitments under the following Themes:
Labour Standards, Health & Safety, Human Rights & Community Indicators, Social Supply Chain, Customer Responsibility

GNI

Where freedom of expression and/or privacy are salient human rights issues:
Implementation Guidelines: 2. Responsible Company Decision Making – Integration into Business Operations; 3. Freedom of Expression; 4. Privacy

GRI

For specific salient human rights issues identified: G4-DMAb (Policies and Commitments)

ICMM

For specific salient human rights issues identified:
Principle 1: Key Management Actions Required (non-mandatory examples from ICMM’s Assurance Procedure):
– Develop and implement company statements of ethical business principles and practices that management is committed to enforcing.

Where this relates to policies on specific salient human rights issues identified: Principle 3

IR

KTC

Where forced labour and human trafficking are salient human rights issues:

1.3 Management and Accountability

1.4 Training

3.0 Purchasing Practices

4.0 Recruitment

5.0 Worker Voice

6.0 Monitoring

7.0 Remedy

OECD

Where supply or use of minerals from conflict-affected and high-risk areas is a salient human rights issue:
OECD-1 and OECD-3

UNGC

For specific salient human rights issues identified: 
Criterion 3, Criterion 6 and specifically:
– Reference to principles of relevant international labour standards (ILO Conventions) and other normative international instruments in company policies

VPSHR

Where security and human rights is a salient human rights issue:
2. Relevant policies, procedures, and/or guidelines (or any changes thereof from the previous reporting year) to implement the Voluntary Principles.

Supporting questions

To explain how specific policies aimed at managing the salient human rights issues are communicated to those who need to implement them, such that they understand why their implementation matters, and what they need to do to help put them into practice.

Those with a role in the implementation of the policies might include employees, contract workers, suppliers, business customers, joint venture partners or others. The communication of a policy might vary depending on the intended audience and how the policy relates to their particular responsibilities. For example, a policy related to the right to non-discrimination has different implications for someone who recruits employees, someone who allocates contracts to local suppliers in an ethnically diverse region, and someone who handles disciplinary matters.

Relevant information for the company’s answer could include:

  • How the policy is disseminated to those who need to implement it (e.g., in writing, in meetings, on a website);
  • How the policy is made understandable to those who need to implement it (e.g., through translation into different languages, or guidance on implementation related to their specific roles and responsibilities);
  • How the significance of the policy as part of the wider business strategy is conveyed to those who need to implement it (e.g., through communication from top management, sharing information on successes or failures of implementation);
  • Any training provided to support its implementation, including any training that is tailored to participants’ particular roles and responsibilities;
  • Any incentives for individuals or business partners to pay attention to the implementation of the policy in their work (e.g., periodic assessments of the policy’s implementation, rewards and penalties linked to the success or failure of implementation, or other forms of accountability).

The commentary to UN Guiding Principle 16 provides that:

“[i]nternal communication of the statement [of policy commitment] 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

DJSI

For specific salient human rights issues identified:
Criterion: Codes of Conduct/Compliance/Corruption & Bribery
Question: Codes of Conduct: Systems/Procedure
Question: Codes of Conduct/Anti-Corruption & Bribery: Business Relationships

FTSE ESG

For specific salient human rights issues identified:
Social Supply Chain: Strategy & Practice
– Policy integrated into buyer training and purchasing

GNI

Where freedom of expression and/or privacy are salient human rights issues:
Implementation Guidelines: 2. Responsible Company Decision Making – Integration into Business Operations

GRI

Where security and human rights is a salient human rights issue: G4-HR7 (a,b)

ICMM

IR

KTC

Where forced labour and human trafficking are salient human rights issues:

1.4 Training

3.1 Purchasing Practices

3.3 Integration into Supplier Contracts

3.4 Cascading Standards through the Supply Chain

7.1 Corrective Action Plans

OECD

Where supply or use of minerals from conflict-affected and high-risk areas is a salient human rights issue:
OECD-1A, OECD-1B, OECD-1D, OECD-3C

UNGC

For specific salient human rights issues identified:
Criterion 4 and specifically:
– Internal awareness-raising and training on human rights for management and employees

VPSHR

Where security and human rights is a salient human rights issue:
12. Examples of supporting outreach, education, and/or training of (i) relevant personnel, (ii) private security, (iii) public security, and/or (iv) civil society (e.g., local NGOs, community groups).

7. Examples of promoting awareness of the Voluntary Principles throughout the organization or government.