A. SETTING HUMAN RIGHTS REPORTING IN THE BUSINESS CONTEXT

Readers of a company’s human rights disclosure should understand the broader context of what the company does. Relevant information includes the company’s business model, organizational structure, governance, strategy and operations. If the company’s human rights reporting is included in its annual report, integrated report, sustainability report or similar, the company may already be providing this information. If it uses this Reporting Framework for stand-alone reporting on human rights, it should include such information or clearly indicate where it can be found easily. It may look to the Integrated Reporting Framework or the GRI G4 Framework for guidance on the general information to be included.

B. MEETING A MINIMUM THRESHOLD OF INFORMATION

Any company claiming to use this Framework should at a minimum:

• Provide a substantive response to the two overarching questions in Part A;
• Meet the four informational requirements under Part B;
• Provide a substantive response to the six overarching questions in Part C.

This threshold is designed to be attainable by any company that has begun to address human rights within its business. Reporting companies should then work towards answering the supporting questions and improving the quality of their responses to all questions over time.

C. DEMONSTRATING ONGOING IMPROVEMENT

Implementing the necessary policies and processes to meet the responsibility to respect human rights takes time. Moreover, human rights risks evolve as a company’s activities, operating contexts and business relationships change. Putting the Guiding Principles into practice is, therefore, an ongoing process requiring continuous improvement. It is not a finite process that can be reported as complete. The Reporting Framework enables companies to start reporting, whatever their size or stage of progress in implementing the Guiding Principles, and to highlight progress over time. In using the Reporting Framework, companies should endeavour to show how they have progressed in their implementation of the Guiding Principles and how they intend to continue to improve.

D. FOCUSING ON RESPECT FOR HUMAN RIGHTS

The Reporting Framework focuses on respect for human rights: the baseline expectation that all companies “should avoid infringing on the human rights of others and should address adverse human rights impacts with which they are involved” (UN Guiding Principle 11). The Framework does not, therefore, address any social investment or philanthropic activities to support or promote human rights, except where these form part of a deliberate strategy to address a risk to human rights related to the company’s salient human rights issues. A company may wish to report on initiatives that support or promote human rights but which are unrelated to the management of salient human rights issues; if so, it should ensure that this does not obscure or detract from the responses it provides to the questions in this Reporting Framework.

E. ADDRESSING THE MOST SEVERE IMPACTS ON HUMAN RIGHTS

Companies should focus their human rights disclosure on the most severe actual and potential impacts on human rights associated with their activities and business relationships. The starting point for disclosure is, therefore, risk to human rights rather than risk to business, while recognizing that where impacts on human rights are most severe, they converge strongly with risk to the business as well.

F. PROVIDING BALANCED EXAMPLES FROM RELEVANT GEOGRAPHIES

Companies should ground their responses to the questions in the Reporting Framework as far as possible in specific information, including examples of how impacts related to their salient human rights issues have occurred and been prevented, mitigated or remedied during the reporting period. Where this requires the selection of examples from different operating contexts, companies should prioritize those contexts where the salient human rights issues are most significant. Taken together, examples should be balanced and broadly representative of the company’s performance; if they are not, the company should explain why.

G. EXPLAINING ANY OMISSION OF IMPORTANT INFORMATION

In exceptional circumstances, it may not be possible for a company to disclose certain information that is required either to meet the basic threshold for reporting under this Framework, or to respond accurately to a supporting question that the company has chosen to address. 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.