"The intent of integration is to make respecting human rights part of the parameters within which business is conducted – like ethical behaviour, compliance should ensure leadership from the top to embed respect for human rights, include human rights in relevant training, and develop the capacity to respond to unforeseen situations in a manner that respects human rights.”*

Human rights are the basic rights of each human being, independent of race, sex, religion, political opinion, social status or any other characteristic.

At this time in history, there are compelling reasons why businesses should involve human rights in their policies and practices. Businesses increasingly need a stable international environment in which to operate, with sustainable markets and a “level playing field” of opportunities. Human rights offer a common framework for businesses to understand societies’ expectations and deliver value to stakeholders in a more sustainable way.

For business, human rights provide a universal benchmark for minimum standards of behaviour.  Many national laws and regulations have evolved as a result of a state’s obligation to implement human rights standards. Business must, of course, observe such laws in all countries and jurisdictions in which they operate.

Companies are using sustainability and integrated reports to publicly report on their human rights practices. In particular, reporting frameworks (such as the GRI G4 Guidelines) provide specific indicators to report human rights practices against. However, in order to report, companies first require human rights policies, strategies, management plans and programmes as well as indicators to measure human right practices against.

Above all, effective human rights strategies are to be integrated and embedded across operations in order to report.

Based on research conducted on more than 100 sustainability reports, across industries and across geographies, Next Generation has come to understand the following challenges.

• Human rights commitments are only partly understood, implemented and managed
• No coherent, systematic human rights approach exists: In general, human rights are included in the context of labour or social compliance and “by accident” happen to also fulfil the criteria for human rights compliance.

Based on our work specifically in the mining and resources sectors in Africa, we identified the following factors that could aid more effective human rights management practices.

• Internal commitment on all levels, particularly that of middle management
• Creating an enabling environment, i.e. resources and ownership across functions and divisions.
• Developing a common language for human rights management throughout the organisation.
• Making human rights as specific and contextual as possible, i.e. geographic.
• Other success factors depend on the industry: For some, industry collaboration has been a key to success, for others that may not be a possibility.

1. Define your company’s ambition level. Link this process clearly to your business strategy. Clearly define who you are as a business and why it is relevant for your organisation to manage human rights. Be ambitious but pragmatic. Set a concrete, business-minded goal for your company’s human rights approach. This way you speak the language of business from the very start while making the direction clear for everyone.
   
2. Map out what you are already doing. Collect all human rights-related commitments, resources, systems and key contacts into a description of the status quo. This way you will ensure you are not rebuilding something that already exists.
   
3. Conduct a gap analysis. For this, the UNGP and UN Global Compact’s instruments offer excellent starting points, but it is also important to integrate your ambition level and specific business-minded goals in the framework against which the gap analysis is conducted.
   
4. Develop an action plan and a roadmap. Here, several findings from the gap analysis can be used to guide actions:

1. Integrate, integrate, integrate. Look at existing processes and think which are relevant for the chosen human rights approach. And then – integrate.
2. Make human rights as specific as possible. The more concrete the issues and actions are, the easier it is to understand the business relevance of human rights and thus to get the necessary business buy-in.
3. Invest in middle management’s commitment.  Our research shows that, when moving from commitment to implementation, human rights management lives and dies with the commitment of middle management to the issue. Actions speak louder than words – and this is where you need middle management close to the operational level of the business and its human rights risks.
4. Build a training-focused audit/due diligence programme. Combine human rights audits/due diligence with training wherever possible and relevant. This is the best way to get the most out of audits and taps into the current trend by pioneering companies. This helps build long-term commitment with suppliers, which may bring down operational costs as well.
   

5. Communicate transparently but carefully, keeping different stakeholders/rightsholders and their interests in mind. Communicating about human rights issues is not easy, due to their vastness and political nature. So make it concrete and contextual but also understand what fuels the different stakeholder groups. Transparency is the talk of the day and the best policy here, but choose your battles well and keep your backyard in order. White-washing is out of fashion for good.

There are several methods and instruments that companies employ to implement the human rights policy and accelerate integration:

• Include criteria related to human rights commitments in human resources processeslike recruitment, hiring and performance appraisals.
  
• Train employees on business principles and codes of conduct, including sharing dilemmas on human rights and understanding impact of certain business decisions.
  
• Develop long-term incentives, including non-financial appraisals and bonuses (e.g. making bonuses dependent on lowering the number of complaints over time or improving employee engagement scores).
  
• Install strong disincentives for conduct that is out of line with the human rights policy– i.e. impose disciplinary measures when someone is responsible for a human rights abuse.
  
• Organise capacity to cope with human rights dilemmas and improve performance, such as training for specific employees, corporate risk and responsibility committee, ethics committee.
  
• Make human right part of governance systems, including supporting policies, procedures, monitoring and other oversight mechanisms.
  
• Include human rights principles in contracts with business partners(e.g. suppliers, joint venture partners, contractors) and train and monitor the company’s own buyers in these relationships.

 Key points to consider when moving towards implementation of a human rights policy:

 Assessing impacts

• Undertaking a human rights baseline study for the business, including country-risk analyses.
• Undertaking a human rights impact assessment at the pre-feasibility stage of any major project with the potential to negatively impact human rights, for new operations, and on an ongoing basis, as human rights risks may change over time. Some operating contexts, such as conflict-affected areas, will require additional attention. As part of their human rights approach, companies need to consult potentially affected groups and other stakeholders/rightsholders in a meaningful way.

Integrating human rights throughout the company

• Integrating and acting on the findings of the impact assessment.
• Engaging in ongoing stakeholder consultation to build relationships across the company and with external groups.
• Reviewing company training to include human rights criteria as appropriate and identifying target groups that may need additional learning support.
• Embedding human rights into management systems, including responsibilities in job descriptions and performance appraisals.
• Integrating human rights into the company’s internal and external communications (such as intranet) to ensure relevant stakeholders understand the policy and business implications of not adhering to it or failing to act on impact assessment findings.

 Tracking performance

• Identifying indicators for measuring human rights performance, developing and implementing systems for acquiring qualitative and quantitative data, drawing on both internal and external feedback, including from affected stakeholders, and reviewing the findings to inform future strategy.

 Communicating on how impacts are addressed

• Communicating on commitments, targets and performance (through the Global Compact Communication on Progress for United Nations Global Compact participants). The communication should be of a form and frequency that reflects the enterprise’s human rights impacts and that is accessible to its intended audiences.
• The communication should provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact.
• Reporting on progress with regard to implementing and assessing human rights strategies, policies and programmes in company reports i.e. sustainability and integrated reports.

Remediation

• If a company finds that it has caused or contributed to negative human rights impacts, it is expected that it engages actively in remediation.
• The company should provide for or cooperate in the remediation of such impacts through legitimate mechanisms. Establishing or participating in operational-level grievance mechanisms can be an effective means of providing access to remedy for individuals and communities that may be adversely impacted by the company’s activities if these mechanisms meet certain criteria.

*Source: Special Representative online forum: www.srsgconsultation.org (“Integration”)