Additional Severe Impacts

To enable companies to report on how they have addressed any severe impacts that are unrelated to their salient human rights issues, and which are therefore distinct from any severe impacts related to the salient human right issues on which it will be reporting under Section C of this Framework.

This provision enables the reporting company to explain how it is addressing any severe impacts with which the company has been involved:

• that occurred during the reporting period but are unrelated to the salient human rights issues on which the company is reporting under Section C;

• that occurred prior to the reporting period and are still being addressed, but are unrelated to the salient human rights issues on which the company is reporting under Section C.

If neither of these is the case, the reporting company need not address this section of the Framework. Questions C3.2, C4.3 and C6.5 enable the company to report on severe impacts that are related to its salient human rights issues.

In exceptional circumstances, it may not be possible for a company to disclose certain information necessary to respond accurately to this provision of the Framework. In such cases, the company should indicate the nature of the information it has omitted and explain its reasons for the omission: for example, risk to the human rights of stakeholders, specific and legitimate legal prohibitions or confidentiality constraints, or the unavailability of reliable information. Where the company is prevented from disclosing information in specific or explicit form, it should, wherever possible, provide it in aggregated or anonymized form in order to avoid significant gaps in its disclosure.

For a company that identifies additional severe impacts under this provision, it may choose to use relevant questions under Part C to explain the impact and how it was addressed, or it may choose to provide a separate explanation. If a separate explanation is provided, relevant information to include would be:

  • How the company was involved with the impact;
  • The immediate response to the impact, once identified;
  • Steps to provide or support the provision of remedy to those impacted (if the impact was caused or contributed to by the reporting company);
  • Efforts to ensure that the impact could not continue or recur.

If the company has already issued an explanation of its response to the impact in a separate and earlier public document, it might provide a short summary and a link or reference to that document, provided it is readily accessible.

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. In all instances, communications should:

(a) Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;

(b) Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;

(c) In turn not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality.”

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







Content Element 4H: Basis of preparation and presentation
Guiding Principle 3D: Materiality
Content Element 4C: Business model – outcomes
Content Element 4F: Performance – outcomes (see here for relationship between <IR> materiality and salient human rights issues)