C1 Specific Policies Overarching question C1 — Does the company have any specific policies that address its salient human rights issues and, if so, what are they? Objective × 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. Supporting guidance × 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 × 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. The UN Guiding Principles × 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.” Reference points in other initiatives × 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. Assurance indicators × Please note: Assurance provided at the higher tiers should include indicators from lower tiers. 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 Any specific company policies related to a salient human rights issue: are aligned with the relevant international human rights standard(s) do not limit the company’s recognition of human rights to the terms of national law or wider industry practice where these are weaker than the international standards make clear whose human rights they refer to do not lead to certain potentially affected groups being implicitly or explicitly excluded from a company’s commitment to respect a certain human right make it clear who is expected to implement them make it clear who has oversight of their implementation TIER TWO ASSURANCE no additional indicators TIER THREE ASSURANCE no additional indicators Supporting questions C1.1 — How does the company make clear the relevance and significance of such policies to those who need to implement them? Objective × 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. Supporting guidance × 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 × 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 UN Guiding Principles × 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.” Reference points in other initiatives × 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. Assurance indicators × Please note: Assurance provided at the higher tiers should include indicators from lower tiers. 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 Any specific policies related to a salient human rights issue: are available in the languages spoken by those people who need to implement them Specific policies related to a salient human rights issue are supported by training, procedural guidance or other appropriate tools for employees or contract workers who need to implement them. TIER TWO ASSURANCE Any specific policies related to a salient human rights issue: are brought to the attention of those people who need to implement them with sufficient regularity to maintain their awareness There is evidence that those individuals inside the company who need to implement a specific policy: are aware of the policy understand the policy understand why the policy matters for the company know how to implement the policy in their own work TIER THREE ASSURANCE There is evidence that those individuals inside the company who need to implement a specific policy: have the necessary skills and capacity to implement the policy have the necessary resources to implement the policy Specific policies related to a salient human rights issue are supported by any capacity-building necessary for business partners (such as suppliers) to implement them. There is evidence that individuals or groups outside the company who need to implement the specific policy: are aware of the policy understand the policy understand why the policy matters for the company know how to implement the policy in their own work have the necessary skills and capacity to implement the policy have the necessary resources to implement the policy
