Public Consultation on Reporting Framework’s Assurance Guidance

This consultation is now closed. 

13 September 2016 — The Human Rights Reporting and Assurance Frameworks Initiative (RAFI), a joint initiative of Shift and Mazars, launched in early 2013. The goal of RAFI has been to advance understanding of what good human rights reporting looks like and what good assurance of human rights reporting involves. The project team has advanced this work through a process of extensive research and global consultations to which hundreds of individuals and organizations have contributed.

The first product of this process was the UNGP Reporting Framework launched in February 2015. The Reporting Framework has enjoyed strong uptake by companies and extensive support from all stakeholder groups in the months since its publication.

The second phase of RAFI has involved the development of guidance for practitioners of human rights assurance, for both internal and external purposes. Following the development of an initial vision paper, two practitioner roundtables were held in June 2015 in London and New York. These resulted in a number of key take-aways that informed the first draft of the proposed guidance.

This draft was then the subject of multi-stakeholder consultations in Jakarta, London and New York in autumn 2015, from which the take-aways were again published online.

In the first half of 2016, the RAFI project team continued to revise and refine the draft guidance document and solicited further inputs and feedback from a range of experts from different areas of assurance as well as civil society.

Consultation drafts

These various consultations have informed the consultation draft, which includes two parts:

  1. Narrative guidance for assurance practitioners
  2. A set of indicators of appropriateness and effectiveness

The RAFI project team would warmly welcome feedback on this draft from all interested parties. The public consultation period will run from Wednesday 14 September to Monday 31 October 2016. Comments should be sent to info[at]

Key structural changes to the draft guidance

The following sets out the main ways in which we have revised the draft guidance since its first version as well as some priority questions on which we would welcome feedback.

Consultations over the last year have led to a number of changes to the draft guidance on human rights assurance. The primary structural changes are as follows:

  1. We have framed the document more clearly as subject matter guidance that fits with, and, from a human rights perspective, builds upon the regulatory and other frameworks that guide the general practice of assurance.
  1. We have explicitly broadened the guidance to address three distinct types of practitioners:
  • Internal auditors providing an independent evaluation (for management) of their company’s performance in relation to its responsibility to respect human rights, as well as external service providers contracted to perform this function;
  • External expert assessors reviewing and assessing (for management) a company’s performance in relation to its specific human rights commitments and/or its general responsibility to respect human rights;
  • External assurance providers providing assurance (to management and publicly) on a company’s reporting in relation to its responsibility to respect human rights.
  1. We have streamlined the indicators for assessing the appropriateness and effectiveness of human rights policies and processes and put them into a spreadsheet format to make them a more practical tool for practitioners. The indicators follow the logic of the questions in the UNGP Reporting Framework and comments (marked by red corners in spreadsheet cells) provide further guidance and cross-references for users.

Priority questions for feedback

The following are specific questions on which the RAFI project team would particularly welcome feedback, along with any other points that those commenting would like to raise.

  1. Are there any other factors of heightened importance for human rights assurance that have not been included? If so, what are they and why are they relevant?
  2. Are there any further competencies, beyond those highlighted, that should be included within an Assurance Engagement team?
  3. Are there ways in which the Assurance Guidance could be made an even more helpful tool to companies trying to improve their internal management systems?
  4. Does this Assurance Guidance dovetail sufficiently with existing standards and frameworks? If not, please identify the gaps.
  5. Should the indicators be broken into two tiers (basic/advanced, for example), and if so, which indicators should be included in the ‘basic’ category?