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Ensuring that what should happen, does happen

Many people across the business will play a role in enabling the company to identify and manage its human rights risks - including senior leaders and representatives of relevant business units, functions and teams.

To support these groups to perform their roles effectively, it is important to clarify who needs to do what and to establish channels for communication and coordination. The company will also need to allocate responsibility and oversight for ensuring it meets its human rights commitments and responsibilities – and to decide who will lead on the day-to-day implementation of its human rights programme. A cross-functional committee or working group can facilitate communication and coordination across the business. And an internal reporting process will be needed to enable progress and issues to be discussed by practitioners and at the most senior levels of the business.

Governance frameworks and coordination mechanisms should create a strong foundation to advance respect for human rights across the company - and to ensure stakeholders' expectations and the requirements of emerging legislative requirements are met. A company's approach will likely evolve over time, and should reflect its structure, culture and business.


What does governance and coordination look like in practice?

Ways to approach human rights governance:

  • Allocate responsibility for human rights commitments to a specific senior leader or Board member.
  • Establish a human rights team or specialist to lead the company's day-to-day human rights work.
  • Decide what roles and responsibilities will be allocated to relevant teams, functions or business units.

Ways to strengthen coordination on human rights:

  • Establish a cross-functional committee or working group to strengthen coordination across the business.
  • Ensure formal reporting and escalation processes are in place.
  • Disseminate the company's human rights policies and responsibilities internally in accessible language. 
     

Four questions to consider when establishing human rights governance


What do the UN Guiding Principles say about governance and coordination?

The UN Guiding Principles on Business and Human Rights, or UNGPs, expect companies to embed human rights commitments throughout the entire business, with clearly established systems of accountability.

Key guidance relevant to governance and coordination includes:

  • Human rights commitments should be embedded throughout the entire business and within all relevant business functions.
  • Companies should strive for coherence between policy statements and procedures that govern their business activities and relationships.
  • Lines and systems of accountability for a company’s human rights policy commitment and related policies and procedures should be communicated clearly internally.
  • Responsibility for addressing adverse impacts should be assigned to the appropriate level and function within the company.
  • Internal decision-making, budget allocation and oversight processes should enable effective responses to human rights impacts.

See Guiding Principles 16 and 19 for more.


Insights from business practice

  • Strong leadership commitment is key

    Support from senior leaders in the company is essential to ensure the success of governance frameworks and internal coordination, and that human rights becomes part of the corporate culture.

    Ideally, human rights performance should be a standing item in enterprise risk management reviews and management meeting agendas.

    If a company’s leadership has strong commitment and takes responsibility for ensuring the company meets its human rights responsibilities, efforts to drive respect for human rights across the company will be more effective. Ultimately, managing human rights issues effectively should become core to how business is conducted, with all relevant business units, functions and teams taking a role in making this happen.   

    Practitioners emphasise the need to articulate why human rights is important for the company and its business – and to do so clearly and in language that resonates across the business. Discuss the UNGPs with senior leaders and other colleagues to help build their familiarity with the company’s responsibilities and stakeholders’ expectations, and the way in which human rights can impact the business. Human rights risk mapping and other due diligence processes can also provide a good foundation for discussions about the company’s priorities and focus areas.

  • Communication should be clear and address human rights priorities

    Effective governance and coordination require buy-in from colleagues in different business units, functions and teams – and their continued support. This is especially important where the company is working to embed ownership and accountability for human rights at ‘ground level’ across the business.

    Keep communication with colleagues concise, use practical language and link ‘asks’ directly to colleagues’ roles and priorities. Some practitioners start by articulating why human rights (or a specific human rights issue) is important for the company, before discussing two or three targeted issues or requests relevant to the colleague or team they are speaking with.

    Importantly, practitioners emphasise the need to provide ongoing support to ensure actions are implemented effectively over time. The provision of ongoing support also creates opportunities for continued two-way discussions about human rights.

  • There are different ways to approach governance – and these will likely evolve over time

    Formal governance frameworks tend to operate at two distinct levels – senior leadership and practitioner level – and may be centralised or decentralised. Overall responsibility and accountability should lie at the top of the company, with an assigned Board or Executive Committee member in charge of human rights. 

    At a senior management level, responsibility for the management of human rights issues and policies may be allocated to a senior manager, such as the Chief Compliance Officer or Chief Sustainability Officer. 

    At a practitioner level, many companies find it helpful to designate a particular individual or team to lead on implementation of respect for human rights across the company. This human rights manager or team may sit within corporate responsibility, legal, risk and compliance, procurement, human resources or corporate affairs, depending on what makes sense within the company. As human rights-related regulatory requirements emerge, some companies have found it helpful to move their human rights team to the risk or legal and compliance function.   

    Some companies also see value in decentralising responsibility for human rights to all relevant business units and functions to embed respect for human rights in the company’s day-to-day activities. In practice, this requires a level of know-how and maturity across the company, and centralised coordination will likely still be needed.

  • Establish clear communication channels and accountability frameworks across the company

    Companies need to establish clear horizontal and vertical communication channels or make use of those already in existence. These channels or internal reporting mechanisms should reach the highest possible levels of seniority – but communication also needs to be facilitated at operational levels and between business units, functions and different teams.

    There are different ways to support internal communication on human rights issues. One common approach is to establish a cross-functional working group or committee that enables representatives of relevant business units and functions to share information and coordinate efforts on human rights. Some companies establish formal reporting frameworks and issue escalation guidelines. A centralised reporting process will improve consistency and access to information. Other companies have more informal approaches to communication – arranging regular calls with different colleagues and joining meetings convened by relevant functions or teams. 

    Ensure communication channels and accountability frameworks extend across the business. It’s not enough to have robust governance and coordination in place at corporate level – these also need to be embedded throughout the business. In addition, implementation of communication channels and accountability frameworks can provide a valuable opportunity to engage colleagues and leaders at a local level.

  • Provide training and support to key colleagues and teams

    Embedding human rights responsibility across all business functions requires that ownership be given to relevant leaders, functions and parts of the business. Accountability can be improved by providing senior leaders and key teams with training and support to effectively oversee the implementation of human rights commitments.

    Some initial awareness-raising, sensitisation and capability building is often needed to strengthen buy-in to establishing a cross-functional human rights committee and to support human rights leaders in different parts of the business. Analysis of training and reporting data can be a useful first step to identify gaps and target areas within the business where more human rights attention and a trained human rights colleague may be needed.

    Some practitioners emphasise the importance of building the ‘muscle memory’ of governance committees – for example, by working through past or current company cases and hypothetical scenarios. This can also be a valuable way to strength-test the company’s human rights governance and processes and identify opportunities for improvement.

    For more, see: Raising awareness, training and capacity building


Looking forward: Strengthening human rights governance

We see a number of opportunities to enhance human rights governance and coordination. These include:

  1. Mainstreaming human rights in business: A key challenge for business practitioners is building colleagues’ familiarity with the company’s human rights risks and responsibilities. And their awareness that the company has human rights responsibilities that stakeholders expect it to meet. Such familiarity and awareness will be needed if human rights governance is to be effective. Individual practitioners can do a lot to raise awareness and build commitment internally. But if we can find ways to mainstream awareness within companies of the link between business and human rights, more and faster progress can be made.

  2. Getting – and keeping – human rights at the table: Good human rights governance and coordination requires senior leaders and other relevant business units, teams and functions to see human rights as a priority for the business. This may be prompted when things go wrong and an urgent situation needs attention. But there will frequently be times when many issues are competing for time and attention, particularly at a senior leadership level. It’s important that business practitioners find effective ways to articulate the case for sustained oversight and momentum on human rights.