C2 Stakeholder Engagement Overarching question C2 — What is the company's approach to engagement with stakeholders in relation to each salient human rights issue? Objective × To explain to the reader how the reporting company learns about the views of stakeholders who have insight into the salient issues on which it is reporting, and how it takes these perspectives into account in its decisions and actions. Supporting guidance × Stakeholders are typically defined as those individuals or organizations that can affect, or be affected by, a company’s actions and decisions. In the context of the responsibility to respect human rights, a key purpose of engagement with stakeholders is to ensure a full understanding of how the company’s actions and decisions can affect individuals and groups. The focus is therefore on stakeholders whose human rights can be negatively impacted, referred to in the UN Guiding Principles as, ‘affected stakeholders’ or ‘potentially affected stakeholders’, and the legitimate representatives of these individuals or groups. Potentially affected stakeholders include internal stakeholders (e.g., employees and contract workers), as well as external stakeholders (e.g., supply chain workers, communities, consumers and end users of products). Particular attention should be paid to stakeholders who may be disadvantaged, marginalized or excluded from society and, therefore, particularly vulnerable to impacts on their human rights, such as children, women, indigenous peoples, people belonging to ethnic or other minorities, or persons with disabilities. Stakeholders also include civil society groups who engage actively on human rights issues related to the company’s operations or value chain and others with expertise in human rights that they can contribute to the company’s understanding of its actual and potential human rights impacts. They also include shareholders, whether socially responsible investors who engage actively on human rights issues, or others whose financial returns can be affected when a company does not manage effectively risks to human rights. Some companies may engage with the same external stakeholders about many or all of the salient issues being reported. In this case, the reporting company should make this clear and describe those processes in response to questions C2.1 or C2.2. If there are different engagement processes with different stakeholder groups or for different salient issues, the reporting company should also make this clear. It could provide an explanation of the company’s overarching approach to engagement and provide further detail or examples in response to question C2.2. Relevant information × Relevant information for the company’s answer could include: The company’s view of the role and relevance of engagement with stakeholders for its efforts to meet its responsibility to respect human rights; Any policies governing engagement with internal and/or external stakeholders; The company’s typical (representative) practices for engaging with stakeholders (insofar as these are not more fully described in responses to questions 2.1, 2.2 and 2.3); Any particular (representative) practices for engaging with stakeholders whose human rights may be directly affected through the company’s activities or business relationships (insofar as these are not more fully described in responses to questions 2.1, 2.2 and 2.3); Any Global Framework Agreements the company has in place with global union federations, or other formal arrangements for engaging with unions representing employees or contract workers in relation to salient issues; Any other permanent arrangements the company has in place at the corporate or operational levels for engaging with stakeholders in relation to the salient issues identified (e.g., dialogue tables, stakeholder advisory councils, consultative groups); Any changes in stakeholder engagement processes within the reporting period (e.g., to include new forms of engagement, new topics for engagement, new groups with which the company is engaging); Any training or capacity-building the company provides to help staff engage appropriately and productively with different stakeholders; Any external processes in which the company takes part that provide a form of stakeholder engagement (e.g., national or international multi-stakeholder initiatives or local industry–union or industry–community dialogues). The robustness of the reporting company’s response to this question will be improved to the extent that it is able to answer the supporting questions that follow. The UN Guiding Principles × UN Guiding Principle 18 provides that: “In order to gauge human rights risks, business enterprises should identify and assess any actual or potential adverse human rights impacts with which they may be involved either through their own activities or as a result of their business relationships. This process should: (b) Involve meaningful consultation with potentially affected groups and other relevant stakeholders, as appropriate to the size of the business enterprise and the nature and context of the operation.” The commentary to UN Guiding Principle 18 states that: “To enable business enterprises to assess their human rights impacts accurately, they should seek to understand the concerns of potentially affected stakeholders by consulting them directly in a manner that takes into account language and other potential barriers to effective engagement. In situations where such consultation is not possible, business enterprises should consider reasonable alternatives such as consulting credible, independent expert resources, including human rights defenders and others from civil society.” 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 B. Embedding Respect and Human Rights Due Diligence: B.1.8, B.2.5 *D. Performance: Company Human Rights Practices: D.1.1, D.1.3, D.1.4, D.1.8, D.2.1, D.2.3, D.2.7.a, D.2.7.b, D.3.1.a, D.3.1.b, D.3.4.a, D.3.8.a *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: Stakeholder Engagement Question: Governance FTSE ESG For specific salient human rights issues identified: Labour Standards: Strategy & Practice – Employee involvement in improvements Human Rights & Community Indicators: Strategy & Practice – Stakeholder engagement consultations and reports GNI Where freedom of expression and/or privacy are salient human rights issues: Implementation Guidelines: 5. Multi-stakeholder Collaboration – Internal Advisory Forum; External Multistakeholder Learning Forums GRI For specific salient human rights issues identified: G4-26 ICMM For specific salient human rights issues identified: Principle 4: Key Management Actions Required (non-mandatory examples from ICMM’s Assurance Procedure): – Consult with interested and affected parties in the identification, assessment and management of all significant social, health, safety, environmental and economic impacts associated with our activities. – Inform potentially affected parties of significant risks from mining, minerals and metals operations and of the measures that will be taken to manage the potential risks effectively. – Develop, maintain and test effective emergency response procedures in collaboration with potentially affected parties. Principle 9: Key Management Actions Required (non-mandatory examples from ICMM’s Assurance Procedure): – Engage at the earliest practical stage with likely affected parties to discuss and respond to issues and conflicts concerning the management of social impacts. – Ensure that appropriate systems are in place for ongoing interaction with affected parties, making sure that minorities and other marginalized groups have equitable and culturally appropriate means of engagement. Principle 10: Key Management Actions Required (non-mandatory examples from ICMM’s Assurance Procedure): – Engage with and respond to stakeholders through open consultation processes. IR Guiding Principle C3: Stakeholder Relationships KTC Where forced labour and human trafficking are salient human rights issues: 1.5 Stakeholder Engagement 5.2 Worker Voice OECD Where supply or use of minerals from conflict-affected and high-risk areas is a salient human rights issue: OECD-1A, OECD-2 and OECD-3 UNGC For specific salient human rights issues identified: Criterion 21 and specifically: – Consult stakeholders in dealing with implementation dilemmas and challenges and invite them to take active part in reviewing performance, for specific salient human rights issues identified Criterion 6 and specifically: – Structural engagement with a global union, possibly via a Global Framework Agreement, regarding specific salient human rights issues identified Criterion 7 and specifically: – Dialogue mechanism with trade unions to regularly discuss and review company progress in addressing labour standards VPSHR — 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 policies, procedural guidance and/or practices governing engagement with stakeholders are aligned with international good practice. There is evidence that any policies, procedural guidance and/or practices governing engagement with stakeholders are: known to those who need to implement them understood by those who need to implement them Senior management and the Board can articulate: the role and relevance of stakeholder engagement for the company the stakeholders (at least, by category) that the company has prioritized for engagement in relation to human rights issues, and why the principal views about the company’s human rights performance held by stakeholders who follow human rights issues There is evidence that any permanent or ad hoc stakeholder advisory groups the company has established, whose remit includes human rights-related issues, include a proportionate number of individuals with recognized human rights expertise, including expertise in the company’s salient human rights issues. There is evidence that any permanent or ad hoc stakeholder advisory groups the company has established, whose remit includes human rights-related issues: have discussed human rights issues in practice TIER TWO ASSURANCE There is evidence that any policies, procedural guidance and/or practices governing engagement with stakeholders are: put into practice by those who need to implement them There is evidence that any permanent or ad hoc stakeholder advisory groups the company has established, whose remit includes human rights-related issues: have provided insights to the company relevant to understanding and addressing human rights risks and impacts TIER THREE ASSURANCE There is evidence that employees or contract workers whose jobs include engagement on human rights-related issues with stakeholders, and in particular with potentially affected stakeholders and/or their legitimate representatives: have the skills necessary to conduct these engagements in a culturally appropriate and respectful manner have the skills necessary to achieve the objectives set for these engagements to the extent that they may lack the necessary skills, receive appropriate training to address those gaps There is evidence that any permanent or ad hoc stakeholder advisory groups the company has established, whose remit includes human rights-related issues: have had an impact on the company’s human rights due diligence practices or outcomes Supporting questions C2.1 — How does the company identify which stakeholders to engage with in relation to each salient issue, and when and how to do so? Objective × To convey to the reader the principles underlying the company’s decisions with regard to stakeholder engagement in relation to each salient issue. Supporting guidance × Responses to this question may address engagement with different kinds of stakeholder (see guidance to C2), insofar as the engagement relates to understanding or addressing the salient issues on which the company is reporting. It will be particularly relevant to include information on any engagement with (potentially) affected stakeholders and/or their legitimate representatives in relation to these issues. Relevant information × Relevant information for the company’s answer could include: How the reporting company identifies stakeholders, including potentially impacted stakeholders (e.g., through a mapping process, based on internal or external guidance); On what occasions/at what times/how often the reporting company engages with stakeholders in relation to the salient issues (e.g., whether at certain points in a project or business process, on a regular basis (for example, through an advisory group, management–union dialogue or community dialogue table), in response to legal or other requirements, in response to stakeholder requests); Whether and how stakeholders or stakeholder groups, including potentially affected stakeholders or their legitimate representatives, can themselves initiate engagement with the reporting company in relation to any or all of the salient issues; What goals are set for engagement processes (e.g., to convey information, to hear views, to work in collaboration, to reach agreements). The UN Guiding Principles × The commentary to UN Guiding Principle 18 states that: “To enable business enterprises to assess their human rights impacts accurately, they should seek to understand the concerns of potentially affected stakeholders by consulting them directly in a manner that takes into account language and other potential barriers to effective engagement. In situations where such consultation is not possible, business enterprises should consider reasonable alternatives such as consulting credible, independent expert resources, including human rights defenders and others from civil society.“ 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 B. Embedding Respect and Human Rights Due Diligence: B.1.8 *D. Performance: Company Human Rights Practices: D.1.3, D.1.4, D.2.3, D.3.3 *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: Stakeholder Engagement Question: Implementation; Data-point: Stakeholder Profiles, Engagement Process FTSE ESG — GNI — GRI For specific salient human rights issues identified: G4-25 ICMM — IR — KTC 2.1 Traceability Where forced labour and human trafficking are salient human rights issues: 1.5 Stakeholder Engagement 5.0: Worker Voice OECD Where supply or use of minerals from conflict-affected and high-risk areas is a salient human rights issue: OECD-2A and B UNGC — VPSHR — 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 The basis (policy, procedure or general practice) upon which the company identifies which stakeholders to engage with: is designed to ensure that representatives of affected stakeholders speak with legitimacy for the individuals or groups concerned does not exclude any stakeholder group that may be affected through the company’s operations or value chain provides for the inclusion of stakeholders who are critical of the company The basis (policy, procedure or general practice) upon which the company decides when to engage with potentially affected stakeholders: is not constrained to times when the company is required by a third party (e.g., a government or financier) to engage with these stakeholders is not constrained to times when the company itself is interested in engagement for other reasons The basis (policy, procedure or general practice) upon which the company engages with stakeholders in relation to human rights issues: reflects sensitivity as to who would be the most appropriate representatives of the company to engage with reflects awareness of the need to adapt engagement to the language needs and cultural sensitivities of those being engaged shows clarity regarding the nature and purpose of an engagement requires that those engaged are informed about how the engagement has been taken into account in the company’s decisions and actions TIER TWO ASSURANCE no additional indicators TIER THREE ASSURANCE There is evidence that stakeholders with which the company has engaged during the period under assessment consider that the company: is sincere in its wish to engage with them is responsive when they wish to initiate some engagement engages with them in a way they find respectful covers relevant issues and is open to their views and any concerns they raise is responsive to their views and any concerns they raise C2.2 — During the reporting period, which stakeholders has the company engaged with regarding each salient issue, and why? Objective × To provide concrete examples of the reporting company’s engagement with stakeholders in relation to each salient issue and their reasons for engaging. Supporting guidance × The supporting guidance to question C2 sets out different kinds of stakeholders that are relevant to a company’s human rights performance. It will be particularly relevant to include information or examples related to engagement with potentially affected stakeholders. It will sometimes be inappropriate to name specific individuals or groups with which the company has engaged, if this may pose risks to those involved. Where this is the case, information about the types of stakeholders engaged and for what general purposes may be more appropriate. Examples should be drawn from settings where there are real challenges in preference to those where the salient issue is a limited problem and/or easy to address. If a company uses an example from a less challenging setting, it should highlight the reason for the selection, for example, if it demonstrates an important innovation or an approach that the company will be rolling out to other geographies. Taken together, examples should be balanced and broadly representative of the company’s performance; if they are not, the company should explain why. Relevant information × Relevant information for the company’s answer could include: Specific organizations, groups or types of stakeholder engaged in particular operating contexts in relation to one or more salient issues, with particular attention paid to potentially affected stakeholders; The general rationale for the engagements; The particular purposes of different engagements and the extent to which those purposes were achieved or advanced; If the engagements were single events or are part of an ongoing engagement process; Any information about how these engagement processes reflect the company’s general approach to stakeholder engagement as described in response to question C2.1. The UN Guiding Principles × The commentary to UN Guiding Principle 18 states that: “To enable business enterprises to assess their human rights impacts accurately, they should seek to understand the concerns of potentially affected stakeholders by consulting them directly in a manner that takes into account language and other potential barriers to effective engagement. In situations where such consultation is not possible, business enterprises should consider reasonable alternatives such as consulting credible, independent expert resources, including human rights defenders and others from civil society.” 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 *D. Performance: Company Human Rights Practices: D.1.3, D.1.4, D.3.4.a E. Performance: Responses to Serious Allegations: E1.3, E2.1 *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: Stakeholder Engagement Question: Implementation; Data-point: Examples of key stakeholders FTSE ESG — GNI — GRI For specific salient human rights issues identified: G4-24 ICMM — IR — KTC Where forced labour and human trafficking are salient human rights issues: 1.5 Stakeholder Engagement 5.2 Worker Voice OECD Where supply or use of minerals from conflict-affected and high-risk areas is a salient human rights issue: OECD-2B, OECD-3B, C UNGC — VPSHR Where security and human rights is a salient human rights issue: 10. Engagements with stakeholders on country implementation. 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 There is evidence that the company has engaged with key relevant stakeholders during the period under assessment: in relation to risks to human rights associated with its business with particular emphasis on its salient human rights issues TIER TWO ASSURANCE Where the company has not engaged during the period under assessment with key stakeholders known to be critical of the company’s human rights performance: there is evidence that the decision is reasonable TIER THREE ASSURANCE Where the company has not engaged during the period under assessment with key stakeholders known to be critical of the company’s human rights performance: there is no evidence that the decision undermines the company’s understanding of its actual or potential human rights impacts C2.3 — During the reporting period, how have the views of stakeholders influenced the company's understanding of each salient issue and/or its approach to addressing it? Objective × To demonstrate, through concrete examples, the extent to which the reporting company’s engagement with stakeholders serves the intended purpose of informing and improving its ability to respect human rights across its activities and business relationships. Supporting guidance × The focus in addressing this question is on specific examples from within the reporting period of whether and how engagement with stakeholders has influenced how the company understands or addresses each salient issue. It will be particularly relevant to report on examples involving engagement with (potentially) affected stakeholders. Relevant information × Relevant information for the company’s answer could include: The views and specific inputs of stakeholders on the different salient issues; Company decisions or actions regarding any of the salient issues that have been informed by stakeholder inputs (e.g., engagement with a business partner to mitigate a risk of impacts in light of feedback from employees; a decision not to proceed with a project based on inputs from communities and relevant experts; a change in labour practices based on a negotiation with workers or trade unions); Reasons for a decision not to make changes in response to a significant point of stakeholder feedback related to a salient issue; If and how stakeholders were informed of the decisions, actions or other changes that resulted from their inputs. The UN Guiding Principles × The commentary to UN Guiding Principle 18 states that: “To enable business enterprises to assess their human rights impacts accurately, they should seek to understand the concerns of potentially affected stakeholders by consulting them directly in a manner that takes into account language and other potential barriers to effective engagement.” UN Guiding Principle 20 provides that: “In order to verify whether adverse human rights impacts are being addressed, business enterprises should track the effectiveness of their response. Tracking should: … (b) Draw on feedback from both internal and external sources, including affected stakeholders.” UN Guiding Principle 21 provides that: “In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders.” The commentary to UN Guiding Principle 31 states that: “For an operational-level grievance mechanism, engaging with affected stakeholder groups about its design and performance can help to ensure that it meets their needs, that they will use it in practice, and that there is a shared interest in ensuring its success.” 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 *D. Performance: Company Human Rights Practices: D.1.4 *Section D of the CHRB refers to sector-specific key human rights risks identified by the CHRB. DJSI — FTSE ESG — GNI — GRI For specific salient human rights issues identified: G4-27 ICMM — IR — KTC — OECD Where supply or use of minerals from conflict-affected and high-risk areas is a salient human rights issue: OECD-3B, C and D UNGC For specific salient human rights issues identified: Criterion 21 and specifically: – Define sustainability strategies, goals and policies in consultation with key stakeholders Criterion 5 and specifically: – Monitoring drawn from internal and external feedback, including affected stakeholders – Process to deal with incidents the company has caused or contributed to for internal and external stakeholders (BRE 4 + ARE 4) VPSHR — 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 There is evidence that the company has informed stakeholders with which it has engaged during the period under assessment about whether and how their views have influenced the company’s decisions or actions. TIER TWO ASSURANCE There is evidence that the views of stakeholders have been fed into the company’s internal discussions and decision-making processes. Where stakeholder feedback on significant human rights risks or impacts has not affected company decisions or actions: the company can articulate a clear reason why this was the case TIER THREE ASSURANCE Where stakeholder feedback on significant human rights risks or impacts has not affected company decisions or actions: the company’s explanation is reasonable and compatible with respect for human rights There is evidence that stakeholders with which the company has engaged during the period under assessment: have confidence that their feedback was fed into internal discussions and decision-making processes know if their feedback influenced the company’s decisions or actions believe it would be worthwhile to engage with the company in the future
