THE CORPORATEHUMAN RIGHTSBENCHMARK
Draft List of Indicators
for Public Consultation
Deadline for Comments: 2nd October 2015
This document sets out the draft list of indicators for Methodology 1.0 of the Corporate
Human Rights Benchmark (CHRB). This document is complemented by the Framework
Paper for Multi-Stakeholder Consultations which sets out the overview, framework andprocess in the development of the CHRB. These two documents inform the draft CHRB
Methodology 1.0.
The draft Methodology 1.0. will be revised in light of public input and finalised in advance ofthe first pilot Benchmark, which will be undertaken using the revised CHRB Methodology
1.0. and published in March 2016.

Note: The final version of the Methodology 1.0 will contain cross-references torelevant reporting frameworks and benchmarks.
© Copyright CHRB. The copyright in this consultation material is owned jointly by one or more of the six founding organisations
according to agreements between them. Any commercial use of this material or any part of it by third parties will require alicence and any comments or responses made to this consultation may be freely used by the project and the foundingorganisations to enhance the methodology created and their work in relation to business and human rights.

July 2015

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A GLOBAL BENCHMARK WITH SECTOR-SPECIFIC ELEMENTS
The majority of the draft indicators apply to all companies, regardless of sector. However,some sector specific ‘locks’ or additional requirements have been added to an indicatoradding sector specific elements to certain scores where necessary and relevant. The figure
below describes the structure of an indicator that uses these sector locks.

How to read an indicator:

Sector specific locks are required for companies within the specific sector of concern, forexample the extractives (EX) or apparel (AP) sector. However, a diversified company withinvolvment in one or more of these sectors may be required to fulfill the additional sectorspecific requirements. For example, a media company with a large apparel supply chain may
be required to fulfill AP sector locks.

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Table of contents
GENERAL COMMENTS ..................................................................................................................... 6
KEY SYMBOLS ................................................................................................................................ 6
KEY TERMINOLOGY ...................................................................................................................... 6
ACRONYMS ..................................................................................................................................... 7A.

LEADERSHIP ............................................................................................................................... 8
A.1.1. Raising human rights concerns with governments (D) ............................................... 8
A.2.1. Raising human rights concerns with industry peers (D) ............................................. 8
A.3.1. Activities within Multistakeholder Initiatives (MSIs) (D) ............................................... 8
A.4.1. Support for building local human rights capacity (D)................................................... 9

B.

GOVERNANCE .......................................................................................................................... 10
B.1. POLICY COMMITMENTS .................................................................................................... 10
B.1.1. Commitment to respecting human rights (E) .............................................................. 10
B.1.2. Commitment to respecting the core and/or additional ILO conventions (E) .......... 10
B.1.3. Commitment to specifically respecting the rights of human rights of individuals
belonging to specific groups or populations that require particular attention (E) ............. 11
B.1.4. Commitment to respecting additional human rights of or relevant to of local
communities (D) ......................................................................................................................... 12
B.1.5. Commitment to incorporating human rights into Business Relationships (E) ....... 13
B.1.6. Commitment to engage with stakeholders (E) ........................................................... 13
B.1.7. Commitment to remedy (D) ........................................................................................... 14
B.2. BOARD LEVEL ACCOUNTABILITY ................................................................................... 15
B.2.1. Leadership from the top (D) .......................................................................................... 15
B.2.2. Senior responsibility for human rights (E) ................................................................... 15
B.2.3. Board skills and expertise (E) ....................................................................................... 15
B.2.4. Board agenda (E) ........................................................................................................... 16
B.2.5. Performance incentives (D) ........................................................................................... 16
B.2.6. Relationship to corporate strategy (D) ......................................................................... 16

C.

MANAGEMENT SYSTEMS ..................................................................................................... 17
GENERAL ‘CONDITION’ FOR MANAGEMENT SYSTEMS ................................................... 17
C.1. EMBEDDING POLICY .......................................................................................................... 17
C.1.1. Responsibility and resources for day-to-day human rights function (E) ................ 17
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C.1.2. Alignment of other internal policies and processes with the human rights policy(E) ................................................................................................................................................. 17
C.1.3. Integration with enterprise risk monitoring generally (E) .......................................... 18
C.1.4. Incentives and performance management (D)........................................................... 18
C.1.5. Communication / dissemination of policy commitment (E) ...................................... 18
C.1.6. Communication / dissemination of policy commitment to business relationships(E) ................................................................................................................................................. 19
C.1.7. Training on human rights (E) ........................................................................................ 19
C.1.8. Regular review of human rights policy (D) .................................................................. 20
C.1.9. Monitoring and corrective actions (E) .......................................................................... 20
C.1.10. Engaging business relationships (D) ......................................................................... 20
C.1.11. Framework for stakeholder engagement (E) ........................................................... 21
C.1.12. Health and safety management (E) ........................................................................... 21
C.2. HUMAN RIGHTS DUE DILIGENCE ................................................................................... 22
C.2.1. Existence and triggers for identifying human rights risks and impacts (E) ............ 22
C.2.2. Assessment of risks and impacts identified (salient risks and key sector risks) (E)...................................................................................................................................................... 22
C.2.3. Identification and consultation with stakeholders on salient human rights issues(E) ................................................................................................................................................. 23
C.2.4. Acting on outcomes of the assessment (D) ................................................................ 23
C.2.5. Tracking the implementation of actions to respond to the assessments (D) ........ 24
C.3. REMEDIES AND GRIEVANCE MECHANISMS ............................................................... 25
C.3.1. Channel(s)/mechanism(s) to receive human rights complaints or concerns (E) .. 25
C.3.2. Effectiveness of channel(s)/mechanism(s) (E) .......................................................... 25
C.3.3. Oversight and review of the channel(s)/mechanism(s) (E) ...................................... 26
C.3.4. Process for incorporating lessons learnt (D) .............................................................. 26
C.3.5. Remedying any impacts identified (D) ........................................................................ 26
D.

PERFORMANCE ....................................................................................................................... 28
D.1. KPIs & GOOD PRACTICES................................................................................................. 28
GENERAL QUESTIONS/ISSUES ............................................................................................... 28
D.1.1. Forced labour: bonded labour and other unacceptable financial costs [AP, AG] . 28
D.1.2. Forced labour: Restrictions on workers [AP, AG] ...................................................... 28
D.1.3. Direct employment [AP, AG] ......................................................................................... 29
D.1.4. Child labour: Age verification and corrective actions [AP, AG, EX] ........................ 29
D.1.5. Child labour: Hazardous work [AP, AG, EX] ............................................................. 30
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D.1.6. Non-discrimination: Workforce composition [AP, AG, EX] ....................................... 30
D.1.7. Non-discrimination: Board composition [AP, AG, EX] .............................................. 30
D.1.8. Freedom of association [AP, AG, EX] ......................................................................... 30
D.1.9. Workers covered by collective bargaining agreements [AP, AG, EX] .................... 31
D.1.10. Health and Safety: fatalities, lost days, injury rates [AP, AG, EX] ........................ 31
D.1.11. Working hours [AP, AG] .............................................................................................. 32
D.1.12. Living wage [AP, AG, EX] ........................................................................................... 33
D.1.13. Land use and acquisition [AG, EX] ............................................................................ 33
D.1.14. Land use and acquisition: Resettlement [AG, EX] .................................................. 34
FOOTNOTE .................................................................................................................................... 34
D.2. ADVERSE EVENTS .............................................................................................................. 35
D.2.1. HIGH SEVERITY - There are allegations of severe breaches of ILO standards or
the right to security of persons against the Company or the Company’s supply chain(data provided by EIRIS) ........................................................................................................... 35
D.2.2. MEDIUM SEVERITY – The Company faces criticism or negative news stories
related to Labour and Human Rights (data provided by RepRisk and Business & Human
Rights Resource Centre)........................................................................................................... 36
E.

REPORTING / TRANSPARENCY........................................................................................... 37
E.1.1. Public policy available .................................................................................................... 37
E.1.2. Reporting on human rights training .............................................................................. 37
E.1.3. Reporting on the implementation of human rights management system ............... 37
E.1.4. Disclosure of human rights risk/impact assessments ............................................... 38
E.1.5. Detailed reporting on stakeholder engagement on human rights issues, including
salient human rights issues ...................................................................................................... 39
E.1.6. Human rights screening / investments or contracts including human rights
clauses ......................................................................................................................................... 39
E.1.7. Reporting on some ILO standards ............................................................................... 39
E.1.8. Number of human rights related incidents and corrective actions .......................... 40
E.1.9. Number of grievances .................................................................................................... 40
E.1.10. Reporting is verified and informed - Stakeholder verification and input ............... 41

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GENERAL COMMENTS
KEY SYMBOLS(E) for ESSENTIAL: Essential Indicators are indicators that companies are expected to fulfil
either in part or in full and are given additional weight in the scoring.
(D) for DESIRABLE: Desirable indicators are indicators that companies are expected to work
towards. These indicators signal the pathway towards improved human rights performancein a range of areas.
The ESSENTIAL and DESIRABLE separation will also be used in the scoring. I.e. if
ESSENTIAL indicators are not fulfilled, a company will not be able to get past a certain scoreeven if it demonstrates some of the DESIRABLE indicators. The sections on performanceand reporting do not make this distinction between Essential and Desirable indicators.
Sector locks will be applied to companies with activities in sectors exposed to particular
human rights risks, which can be identified by the following colour coding:
AG stands for AGRICULTURE
AP stands for APPAREL
EX stands for EXTRACTIVESKEY TERMINOLOGY
Adverse events - An event reported in the public domain involving the alleged adverse
impact by a company on an individual’s or group of individuals’ human rights.
Business relationships – Those relationships a business enterprise has with its business
partners, entities in its value chain and any other non-State or State entity directly linked toits business operations, products or services. They include indirect business relationships inits value chain, beyond the first tier, and minority as well as majority shareholding positions
in joint ventures.
Human Rights Due diligence – An ongoing management process that a reasonable andprudent enterprise needs to undertake in order to meet its responsibility to respect humanrights. It includes assessing actual and potential human rights impacts, integrating andacting on assessment findings, tracking responses and communicating about how impacts
are addressed.
Key sector risks – The risks regularly regarded as potentially severe and/or likely within the
sector and that companies are expected to demonstrate, through a process of human rights
due diligence, how they are preventing them or why they are not relevant. Therefore, whilethese risks are anticipated to be relevant given the company’s sector, they may notnecessarily be the individual company’s most salient human rights issues (see salient
human rights issues below).

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Remedy – Remediation and remedy refer to both the processes of providing remedy for anadverse human rights impact and the substantive outcomes that can counteract, or makegood, the negative impact. These outcomes may take a range of forms, such as apologies,
restitution, rehabilitation, financial or non-financial compensation, and punitive sanctions(whether criminal or administrative, such as fines), as well as the prevention of harmthrough, for example, injunctions or guarantees of non-repetition.
Salient human rights issues - Those human rights that are at risk of the most severe
negative impacts through a company’s activities or business relationships. They therefore
vary from company to company.
Stakeholder - Any individual who may affect or be affected by an organization’s activities.
Affected stakeholder - An affected stakeholder refers specifically to an individual whose
human rights have been or may be affected by an enterprise’s operations, products orservices.
Stakeholder engagement/consultation – An ongoing process of interaction and dialogue
between an enterprise and its potentially affected stakeholders that enables the enterprise tohear, understand and respond to their interests and concerns, including throughcollaborative approaches.
Workers - Refers to employees, temporary or contracted workers, migrant workers in bothof those categories and the same set of workers in business relationships.

ACRONYMS
CEDAW

The Convention on the Elimination of All Forms of Discrimination Against
Women

EITI

Extractive Industries Transparency Initiative

ETI

Ethical Trading Initiative

FLA

Fair Labor Association

FPIC

Free, prior and informed consent

GRI

Global Reporting Initiative G4 Sustainability Reporting Guidelines

ICOC

International Code of Conduct for Private Security Companies

ILO

International Labour Organisation

UDHR

Universal Declaration of Human Rights

UNGP

United Nations Guiding Principles

UNGPRF

United Nations Guiding Principles’ Reporting Framework

VGGT

UN Voluntary Guidelines on the Responsible Governance of Tenure of Land

VPs

Voluntary Principles on Security and Human Rights
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A. LEADERSHIP
Under this topic, indicators are aiming to advance human rights agenda throughworking with third parties (peers, governments etc.).

A.1.1. Raising human rights concerns with governments (D)The Company commits to promoting the protection of human rights by governments, and/or
takes public policy positions in favour of legislation that aims to prevent human rights abuses
or strengthens protection in a specific context or specific sector or to strengthen access toremedy.
Score 1

Commitment in principle to advocate for human rights with government or local
authorities in a case where human rights are at risk around its operations, or inconnection with the production of its products or services. Or the Company gives
specific examples of seeking to promote the protection of human rights orlobbying for legislation to prevent the denial of rights or to provide remedy (forexample access to judicial and non-judicial remedy)

Score 2

Commitment is backed with specific example(s).

A.2.1. Raising human rights concerns with industry peers (D)The Company commits to publicly differentiating its own position when it has a stronger
stance on a human rights issue than a trade association or other industry or geographic
industry bodies of which it is a member, or to seeks to positively influence trade bodies onhuman rights concerns or to leaving a trade body when its human rights positions conflicts
strongly with the Company’s position. This commitment is backed with specific examples.
Score 1

Commitment in principle to advocate for human rights with trade associations
and other industry or geographic industry bodies. Or the Company gives specificexamples of seeking to positively influence such bodies. Or the Company gives
specific examples leaving such bodies.

Score 2

Commitment is backed with specific example(s).

A.3.1. Activities within Multi-stakeholder Initiatives (MSIs) (D)The Company is a member and actively participates in (a) Multi-stakeholder Initiatives(MSIs) which aim to promote respect for human rights and sustainable business practices.
Score 1

Membership of (a) relevant MSIs

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Score 2

Plays a leadership role within the initiatives or helps to create such initiatives
where none exists.

AG

A score 2 depends upon the belonging to at least one MSI that covers human rights
issues in the sector

AP

A score 2 depends upon the belonging to at least one MSI related to labour
standards in the supply chain such as Ethical Trading Initiative (ETI) or Fair Labor
Association (FLA)EX

For score, the Company needs to be either signatory to the Voluntary Principles on
Security and Human Rights (VPs) or Extractive Industries Transparency Initiative(EITI) and a score of 2 requires both VPs and EITI membership.

A.4.1. Support for building local human rights capacity (D)The Company supports capacity building of local communities, civil society or government tounderstand and promote respect for human rights and gives examples.
Score 1

Commitment in principle to capacity building of local communities, civil society or
government to understand and promote respect for human rights. Or theCompany gives specific examples.

Score 2

Commitment is backed with specific example(s).

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B. GOVERNANCE
This topic aims to assess the extent to which a Company acknowledges its
responsibility to respect human rights, and how it formally incorporates its resulting
expectations of its workforce and business relationships in to policy commitments.
Under governance, indicators seek to assess how these expectations are part of theBoard’s role and responsibility as well as whether they are integrated into theCompany’s strategy.

B.1. POLICY COMMITMENTS
B.1.1. Commitment to respecting human rights (E)The Company publicly commits to respecting human rights. The commitment must relate torespecting human rights across the Company’s activities and business relationships. It must
be clear the commitment relates to human rights more generally, rather than to only or more
selected human rights issues, for example, non-discrimination. This is not about
philanthropic activities.
Score 1The Company has a public statement of policy in which it commits to respecting
human rights.

Score 2The Company has a public statement of policy in which it explicitly commits torespecting human rights and either or all of the following: the UN Guiding
Principles, International Bill of Rights or proxies including the Universal
Declaration of Human Rights (UDHRs), OECD Guidelines for Multinational
Enterprises.

EX

For a score of 2, the Company has a public statement of policy committing torespecting human rights in maintaining the safety and security of operations (basedon relevant UN instruments or is a signatory to the Voluntary Principles on Security
and Human Rights (VPSHRs) or to using security providers who are signatories tothe International Code of Conduct of Private Security Providers).

B.1.2. Commitment to respecting the core and/or additional ILO conventions (E)The Company publicly commits to respecting the principles concerning fundamental rights
set out in the ILO’s Declaration on Fundamental and Rights at Work. The Declaration
covers four core labour standard areas: (i) child labour, (ii) forced labour, (iii) nondiscrimination, (iv) freedom of association and collective bargaining.
Score 1The Company has a public statement of policy in which it explicitly commits torespecting at least two ILO core labour areas.

Score 2The Company has a public statement of policy in which it explicitly commits torespecting all four ILO core labour areas (including an explicit reference to both
freedom of association and collective bargaining).
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AG

In addition, for score 1, it must include a commitment to health and safety of workers.
And for a score of 2, the Company must include a commitment to additional ILO
standards around health & safety and working hours (in addition to the ILO corelabour standards). The commitment to collective bargaining includes a commitment
not to impede the right of farmers to associate and bargain collectively.

AP

For score 1, it must include a commitment to health and safety of workers. And for ascore of 2, the Company must include a commitment to additional ILO around health& safety and working hours (in addition to the ILO core labour standards).

EX

For score 1, it must include a commitment to health and safety of workers in which
the Company either commits to protecting the health and safety of employees, tocomply with the requirements of the health and safety laws applicable in the
countries in which it operates or to ‘zero harm’. For sore 2, the Company either
commits to exceed the requirements of the health and safety laws applicable in the
countries in which it operates or to obtain OHSAS 18001 certification for 100% of its
operations.
The ILO Declaration on Fundamental Principles and Rights at Work covers thefollowing four fundamental principles and rights at work:

Freedom of association and the effective recognition of the right to collective
bargaining
Elimination of all forms of forced or compulsory labour
Effective abolition of child labour
Elimination of discrimination in respect of employment and occupation

B.1.3. Commitment to specifically respecting the rights of human rights of individuals
belonging to specific groups or populations that require particular attention (E)The Company publicly commits to respecting specific human rights of human rights ofindividuals belonging to specific groups or populations that require particular attention, and
who are often vulnerable or marginalised groups which may be impacted by the Company’s
activities.
Score 1The Company has a public statement of policy in which it explicitly commits torespecting the internationally recognised human rights of human rights ofindividuals belonging to specific groups or populations that require particularattention (for example, women, children, indigenous peoples, minorities, persons
with disabilities, and/or migrant workers and their families).

Score 2The Company has a public statement of policy in which it explicitly references
one or more key international human rights instruments applying to these groups
or populations.

EX

For score 1, the Company has a public statement in which it explicitly commits torespecting indigenous peoples rights (and/or to applying ILO Convention 169 or
UNDRIP) and this may include specific recognition of indigenous peoples rights toown, use, develop and control lands and resources under traditional ownership or
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use. For score 2, the Company commits to applying free, prior and informed consent(FPIC) in line with international standards on indigenous peoples and/or publicly
acknowledges that it may not proceed with a project notwithstanding legal permission
and potential profitability where communities do not consent.
AG

For score 1, the Company has a public statement of policy in which it explicitly
commits to respecting women’s rights or refers to CEDAW or the Women’s
Empowerment Principles or to respecting children’s rights or refers to the CRC or theChildren’s Rights and Business Principles.

AP

For score 1, the Company has a public statement of policy in which it explicitly
commits to respecting women’s rights or refers to CEDAW or the Women’s
Empowerment Principles or to respecting children’s rights or refers to the CRC or theChildren’s Rights and Business Principles.
Key International Human Rights Instruments Applying to Potentially Vulnerable
or Marginalised Groups








The Convention on the Elimination of All Forms of Racial Discrimination
The Convention on the Elimination of All Forms of Discrimination Against
Women
The Convention on the Rights of the ChildThe Convention on the Rights of Persons with Disabilities
The Convention on the Protection of the Rights of All Migrant Workers andMembers of their Families
The Declaration on the Rights of Indigenous Peoples / or UNDRIP / orParticipation in UN Permanent Forum on Indigenous Issues (UNPFII)The Declaration on the Rights of Persons Belonging to National or Ethnic,
Religious and Linguistic Minorities

B.1.4. Commitment to respecting additional human rights of or relevant to of local
communities (D)The Company publicly commits to respecting human rights that are relevant to community
health, safety, security and use and/or ownership of land and resources.
Score 1The Company has a public statement of policy committing it to minimising its
impacts on local communities, which may include specific references to impacts
on their rights to health, food, water, livelihoods, safety and land.

Score 2The Company has a public statement of policy committing it to minimising its
impacts on local communities by minimising its impact on the environment,
including a commitment to reducing the use of natural resources and / or waterwhere operating in water constrained environments.

AP

Must include specific commitments around water use, wastewater and waste
management.

AG

For Score 1, the Company has a public statement of policy committing to recognition
and respect of existing use of and ownership rights to land or resources, formal and
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customary, (even if the government claims that land is unoccupied and available forsale or lease) or to FPIC for land transactions or to a zero tolerance for land
grabbing. For score 2, the Company commits to all of these elements.
.
EX

For score 1, the Company also has a public statement of policy committing torecognition and respect of existing use of and ownership rights to land or resources,
formal and customary, (even if the government claims that land is unoccupied andavailable for sale or lease). (with respect to indigenous peoples, see B3 above). For
score 2, the Company has a public statement of policy committing to the health,safety and security of local communities surrounding its operations, including in theuse of any security forces.

B.1.5. Commitment to incorporating human rights into Business Relationships (E)The Company publicly commits to applying its human rights policy in its business
relationships and it has a ‘comprehensive’ policy applying to business relationship.
Score 1The Company has a public statement of policy that specifically commits it to
applying its human rights policy to its business relationships (including partners,
suppliers, franchisees, contractors, etc.). This human rights policy covers at least
two of the ILO conventions on core labour standards.

Score 2The Company has a policy applying to business relationships which includes acommitment to respecting the principles laid out in the ILO’s Declaration on
Fundamental and Rights at Work.

AP

Relevant business relationships must include suppliers. For score 2, the Company
must require its suppliers to respect the ILO conventions on core labour standards
and on health and safety and working hours.

AG

Relevant business relationships must include suppliers. For score 2, the Company
must require its suppliers to respect the ILO conventions on core labour standards
and on health and safety and working hours.

EX

Relevant business relationships must include contractors and joint venture oroperating partners. For score 2, the Company must require its contractors and joint
venture or operating partners to commit to respecting indigenous rights and theprinciples contained in the VPSHRs.

B.1.6. Commitment to engage with stakeholders (E)The Company publicly commits to engage with its stakeholders.
Score 1The Company has a public statement of policy that specifically commits it toengaging with its stakeholders.

Score 2The Company has a public statement of policy that specifically commits it toengaging with stakeholders in the development and monitoring of its human13

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rights approach and to publish (in summary) the views of stakeholders and theCompany’s response.
EX

At either level, the commitment must include engagement with communities whereextraction takes place.

B.1.7. Commitment to remedy (D)The Company publicly commits to enable access to remedy for stakeholders who may be
adversely affected by the Company’s operations.
Score 1

Commitment to remedying adverse impacts caused or contributed to by any acts
or omissions of the Company or collaborating in initiatives that provide access toremedy and to not blocking access to remedy.

Score 2

Commitment to working with business relationships to remedy adverse impacts
which are directly linked to its operations, through the business relationship’s
own mechanisms or through collaborating on the development of third party
UNGP compliant non-judicial remedies available to workers, communities,
customers/consumers.

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B.2. BOARD LEVEL ACCOUNTABILITY
B.2.1. Leadership from the top (D)The Company’s human rights policies are approved by senior management or the board.
Score 1

Human rights policies and positions are attributed to board or the CEO by name.
Or speeches, presentations or other communication setting out the Company’s
stance on human rights or discussing its business importance by board members
and/or the CEO

Score 2The Company does both of the above.

B.2.2. Senior responsibility for human rights (E)The Company identifies the most senior level of responsibility for human rights within the
Company. A board member or Board committee or senior manager is responsible for humanrights.
Score 1The Company identifies the most senior level of responsibility for human rights
within the Company (i.e. responsibility for human rights has been assigned to asenior manager).

Score 2

Responsibility for human rights has been assigned to a main board member or asenior manager who reports directly to the CEO.

AP

In addition, for the scores to be granted at each of the above levels, the Company
needs to also have outlined most senior responsibility for the human rights policy insupply chains.

AG

In addition, for the scores to be granted at each of the above levels, the Company
needs to also have outlined most senior responsibility for the human rights policy insupply chains.

B.2.3. Board skills and expertise (E)The Company details the board’s human rights expertise and organisation.
Score 1The Board is able to describe the relevant experience of one of more Board
members in the field of human rights. Or the board is trained on human rights
issues.

Score 2

Both of the above.

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B.2.4. Board agenda (E)Particular human rights issues or concerns are discussed by senior management or theboard. The Company also has a process in place to address human rights issues atmanagement or board level and /or regularly reviews salient human rights issues (orprovides an example of what was discussed).
Score 1

Human rights is a board agenda item at least annually

Score 2

Board discussion includes review of salient risks and human rights issues andperformance

B.2.5. Performance incentives (D)The Company provides incentives to senior management or the Board linked to the humanrights policy or targets related to the policy and its implementation.
Score 1

At least one Board member has an incentive scheme linked to aspects of humanrights policy.

Score 2

Criteria linking Board and senior managers’ remuneration to human rights
performance are made public and the Company discloses information on theoutcome.

B.2.6. Relationship to corporate strategy (D)The Company considers the importance of human rights issues in the formulation of its
corporate strategy.
Score 1

Acknowledgement of importance of human rights issues in formulating wider
corporate strategy. Or Speeches, presentations or other communication settingout the Company’s stance on human rights or discussing its business importanceby board members and/or the CEO.

Score 2

Clear explanation of relationship between human rights policy and wider
corporate strategy (for example through integrated reporting approach)

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C. MANAGEMENT SYSTEMSThis theme includes three sub-topics: embedding policy, human rights due diligenceand remedies and grievances mechanisms. It first seeks to assess how policies arecommunicated and put into practice in day-to-day management within owned
operations and business partnerships. And secondly, it focuses on how a Company
might adjust to a changing context or mew issues arising. Hence, ‘Embedding policy’(Section C.1.) relates to the on-going management of human rights issues. The
spotting of new risks is focussed in the ‘Due Diligence’ section (section C.2.). Finally,
indicators in the remedy and grievance mechanisms look into the existence ofchannels to receive complaints or concerns, their effectiveness and management andwhether grievances or impacts are remedied.

GENERAL ‘CONDITION’ FOR MANAGEMENT SYSTEMS
Limited policy: Any policy reaching the total score of 3 points or less on indicators
B.1.1, B.1.2 and B.1.3 is considered a “limited” policy.
Scoring of limited policies under section C. Management Systems: With a ‘limited’
policy, a Company will never reach a Score 2 for any indicator in sections C.1. andC.2.

C.1. EMBEDDING POLICY
C.1.1. Responsibility and resources for day-to-day human rights function (E)The Company has outlined the organisation of the day-to-day responsibility for human rights
across relevant internal functions.
Score 1

Day to day responsibility for human rights policy statement implementation isclearly allocated across relevant internal functions.

Score 2

Responsibility, resources and decision making process is clearly allocatedacross the range of relevant functions of the Company.

AP

In addition, for score 2, the Company needs to have also outlined and assigned dayto-day responsibility for human rights policy in supply chains to senior management.

AG

In addition, for score 2, the Company needs to have also outlined and assigned dayto-day responsibility for human rights policy in supply chains to senior management.

C.1.2. Alignment of other internal policies and processes with the human rights policy(E)
The Company aligns internally to the human rights policy statement or describes how
internal policies and processes will embed the human rights policy statement into daily
company management.
Score 1

Commitment to alignment in principle across all relevant policies and processes
and alignment in practice with the most important functions.
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Score 2

Evidence produced of regular review of ongoing alignment is taking place acrossall relevant functions including personnel, procurement and legal functions(including contract approval) with explanation of the frequency of review

APFor score 1, the policy must clearly be part of procurement process(es), for example
reference is made to how buying teams take policy into account when making
decisions on who to use as a supplier.

AG

For score 1, the policy must clearly be part of procurement process(es), for example
reference is made to how buying teams take policy into account when making
decisions on who to use as a supplier.

C.1.3. Integration with enterprise risk monitoring generally (E)The Company has integrated attention to human rights risks into its enterprise risk
management system.
Score 1

Attention to human rights risks are part of its more general enterprise risk
management systems.

Score 2The Company shows evidence that the Audit Committee of the board reviews or
makes an independent assessment of the adequacy of the enterprise risk
management systems.

C.1.4. Incentives and performance management (D)The Company provides incentives to senior management linked to the human rights policy ortargets related to the policy(ies) and implementation.
Score 1The Company has an incentive or performance management scheme linked to
aspects of human rights policy for some employees.

Score 2

Criteria linking remuneration to human rights performance are made public.

EX

Must include relevant managers (site managers and community engagement
managers).

AP

Must include procurement managers and officers.

AG

Must include site managers and procurement managers and officers.

C.1.5. Communication / dissemination of policy commitment (E)The Company communicates its human rights policy publicly and internally to employees
and other workers.
Score 1The Company’s human rights policies are publicly available.

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Score 2

The Company’s human rights policies are accessible (including in local
languages and clearly available from one place) and a communications plan
exists to reach all staff.

C.1.6. Communication / dissemination of policy commitment to business relationships(E)
The Company communicates its human rights policy or business relationship policy (thatincludes human rights) to its business relationships. In addition, it establishes this in practicewithin the terms of its contracts (or other equivalent, binding arrangements) with business
relationships.
Score 1The Company communicates its policy to some major business relationships
including through the incorporation of its human rights policy in contracts (orother equivalent documents) with major business relationships.

Score 2The Company extends the communication of its human rights to business
relationships globally.

AP

A score 2 must cover major suppliers and sub-contractors.

AG

A score 2 must cover major suppliers and sub-contractors.

C.1.7. Training on human rights (E)The Company trains its workers on its human rights policy.
Score 1

Training on one or more aspect of human rights policy at least covering
managers and all relevant workers so they understand their rights, their
responsibilities vis-à-vis company policy and more broadly their responsibility torespect human rights.

Score 2All workers trained broadly and on a continuing basis on human rights (which
policy includes at least two ILO Conventions) and training extends to relevant
workers amongst business relationships.

AP

For score 1, relevant workers include procurement & audit teams. For score 2,
relevant business relationships include suppliers and their relevant workers, including
at least their management.

AG

For score 1, relevant workers include procurement & audit teams. For score 2,
relevant business relationships include suppliers and the relevant workers, including
at least their management.

EX

For score 1, relevant business relationships include contractors and joint venture oroperating partners. A score of 2 requires training for all security personnel (employed
or contracted) and those responsible for community relations policies.

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C.1.8. Regular review of human rights policy (D)The Company is committed to and shows evidence of reviewing its human rights policy
regularly.
Score 1The Company is committed to regularly review its human rights policy.

Score 2The Company provides evidence that the review of its human rights policy
occurs at least once every 3 years.

C.1.9. Monitoring and corrective actions (E)The Company has a system to monitor the implementation of its human rights policy acrossits operations and follow up on corrective actions and necessary changes to policy orprocesses.
Score 1

Statement that monitoring and corrective action systems are part of the
management system.

Score 2

Description and details of monitoring approach which covers company globallyand relevant business relationships and details provided of corrective actions
process with numbers or examples.

AP

Score 1 requires auditing and monitoring of suppliers and score 2 requires extensive
auditing and monitoring of suppliers (more than two-thirds every year) and some useof external monitors (companies or NGOs).

AG

Score 1 requires auditing and monitoring of suppliers and score 2 requires extensive
auditing and monitoring of suppliers (more than two-thirds every year) and some useof external monitors (companies or NGOs).

C.1.10. Engaging business relationships (D)The Company includes human rights considerations within decisions to engage (orterminate) business relationships.
Score 1

Statement that human rights performance can affect decisions to work withbusiness relationships

Score 2

Clear explanation on how the human rights performance of business
relationships interacts with decisions to enter, renew, expand or terminate
business relationships

AP

Score 1 requires that explanation to include suppliers, Score 2 includes an
explanation of working with major or critical suppliers to improve human rights
performance.

AG

Score 1 requires that explanation to include suppliers. Score 2 includes an
explanation of working with major or critical suppliers to improve human rights
performance.

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EX

Score 1 requires that explanation to include contractors and joint venture or operating
partners, Score 2 includes an explanation of working with major or critical contractors
to improve human rights performance

C.1.11. Framework for stakeholder engagement (E)The Company has a process to identify its stakeholders and engages in regular dialogue
with potentially affected stakeholders.
Score 1

Statement of approach(es) governing stakeholder engagement; Or explanationof how stakeholders are identified and the frequency, mechanisms and triggers
for engagement by type and by stakeholder group (including whether any focus
on groups at risk/vulnerable groups);

Score 2A statement of practices governing stakeholder engagement including clarity
about how stakeholders are identified and the frequency and triggers forengagement by type and by stakeholder group (including whether any focus ongroups at risk/vulnerable groups). In addition, the Company makes clear theengagement is a two way process (ie. Includes a feedback mechanism) and thatstakeholders can initiate engagement.

EX

For score 2, the Company also conducts joint assessments and/or monitoring withlocal communities on agreed issues, including human rights and publicly discloses
results.

C.1.12. Health and safety management (E)The Company provides a safe and healthy working environment, with steps taken to prevent
occupational illnesses, injuries or fatalities arising in the course of work, led by a senior
management for health and safety, and providing workers regular health and safety
information and training.
Score 1The Company has at least two of: health and safety management system, senior
responsibility or training.

Score 2The Company has all of: health and safety management system senior
responsibility and training.

EX

Score 2 must include health and safety of communities surrounding operations.

AG

Score 2 must include health and safety of communities surrounding operations.

AP

Score 2 must include fire safety management and training

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C.2. HUMAN RIGHTS DUE DILIGENCE
C.2.1. Existence and triggers for identifying human rights risks and impacts (E)The Company has processes in place to identify human rights risks on an on-going basis as
well as when these are triggered by key moments of the Company’s operations or activities(e.g. policy change, market entry, new project, etc.).
Score 1The Company has a process(es) to identify human rights risks

Score 2The Company has global systems in place to assess human rights risks on aregular basis which is also triggered by new country operations, new business
partnerships or changes in the human rights context in particular locations. This
includes risks with which the company may be involved through relevantbusiness relationships.

AP

For score 1, the description needs to include assessing human rights risks amongst
suppliers.

AG

For score 1, the description needs to include assessing human rights risks amongst
suppliers.

EX

For score 1, the description of process includes an explanation of when HRIAs or
ESIAs including human rights will be carried out.

C.2.2. Assessment of risks and impacts identified (salient risks and key sector risks)(E)
The Company has a process in place to assess and prioritise actual and potential humanrights impacts and risks.
Score 1

Process(es) for assessing the salience of risks is described.

Score 2

Process is described and results made public including details of key sector risks
that might be anticipated for the sector (see the list below), but which wereconsidered but judged not salient. Explains when not including a key sector risk
why the risk was not considered salient. Prioritisation for assessing and acting isbased on most potentially severe impacts.

KEY CONCEPTS
Key Sector risks - The risks regularly regarded as potentially severe and/or likely within the
sector and that companies are expected to demonstrate, through a process of human rights
due diligence, how they are preventing them or why they are not relevant. Therefore, whilethese risks are anticipated to be relevant given the company’s sector, they may notnecessarily be the individual company’s most salient human rights issues.
Salient human rights issues - Those human rights that are at risk of the most severe
negative impacts through a company’s activities or business relationships. They therefore
vary from company to company.

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EX

Key risks anticipated for the sector: indigenous peoples rights, land rights andresettlement, security, environmental protection (may include water and natural
resource use), health and safetyAG

Key risks that might be anticipated for the sector, land rights, food security,
indigenous peoples rights, women and children, smallholder farmers, environmental
protection (may include water and natural resource use), labour relations.

AP

Key risks that might be anticipated for the sector: labour relations, including working
conditions, human trafficking and forced labour, women and children, fire safety
hazard, environmental protection.

C.2.3. Identification and consultation with stakeholders on salient human rights
issues (E)The Company has a process in place to identify and consult stakeholders on salient humanrights issues.
Score 1

Details of systems to identify stakeholders or engagement with stakeholders on
salient human rights issues.

Score 2

Both of the above and transparency (at least at summary level) of the input/views
given by the stakeholders.

EX

For score 1 this must include local communities who are provided with free, publicaccess to full, accurate and meaningful information in accessible formats andlanguage. For score 2, evidence that this is ongoing and that stakeholders
engagement happens with all affected communities (including indigenous people
where relevant).

AP

For score 2, the Company facilitates dialogue with stakeholders by providing relevant
information about its supply chain and its exposure to human trafficking and forced
labour. This includes public disclosure of: its process to assess risk in its supply
chain, including an indication of any third-party involvement in the process / The
names and locations of its first-tier suppliers / Public disclosure of the risks identified.

C.2.4. Acting on outcomes of the assessment (D)The Company has a process to act upon the results of its risks/impact assessments. It also
provides details related to the results of its risks/impact assessment.
Score 1The Company provides a clear description of its process to act upon the resultsof assessments to prevent or mitigate potential impacts and remediate existing
impacts identified in the assessments.

Score 2The Company publicly shares and communicates the specific conclusions
reached and actions taken or to be taken as a result of assessment processes(while accepting that some conclusions or actions may be need to be
confidential).
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Lock: if no salient risk identified – no score 2 (see list of risks under E2).
EX

For score 1, public disclosure of the management plans resulting from theassessments in an understandable format and language for selected operations. For
score 2, public disclosure of management plans in an understandable format andlanguage for a majority of operations.

C.2.5. Tracking the implementation of actions to respond to the assessments (D)The Company has a process to track and communicate its assessment of theimplementation of the human rights policies or targets or the effectiveness of theimplementation of actions in response to the assessments and to integrate that information
into improving actions and systems.
Score 1The Company describes its system for tracking the response(s) to the specificassessments. In other words, the Company has a system for tracking theimplementation of actions in response to assessments and for evaluating if theactions have been effective or has missed key issues or not produced thedesired results.

Score 2The Company has a system for feeding back lessons learned into its companywide systems for managing human rights. Or, the Company provides examplesof lessons fed back as a result of the due diligence process.

Lock: if no salient risk identified – no score 2 on tracking (see list of risks under E2).

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C.3. REMEDIES AND GRIEVANCE MECHANISMS
C.3.1. Channel(s)/mechanism(s) to receive human rights complaints or concerns (E)The Company has a formal or informal channel(s) or mechanism(s) (owned, third party or
shared) through which at least some individuals or groups can raise complaints or concerns
in relation to human rights issues.
Score 1The Company has a channel/mechanism or participates in a shared mechanism
accessible to either workers, affected community stakeholders or the public toalert the company to complaints or concerns about human rights.

Score 2The mechanism is available to all potentially affected stakeholders, as well as
the wider public concerning the company’s operations.

AP

For score 2 and in addition to the above, the Company promotes and supports their
suppliers to facilitate complaints / develop their own channel(s) / mechanism(s) toraise human rights complaints or concerns for workers. Alternatively, the Company
provides a ‘fall-back channel’ for workers or suppliers or contractors.

AG

For score 2 and in addition to the above, the Company promotes and supports their
suppliers to facilitate complaints / develop their own channel(s)/mechanism(s) toraise human rights complaints or concerns for workers. Alternatively, the Company
provides a ‘fall-back channel’ for workers or suppliers or contractors.

EX

For score 2 and in addition to the above, the Company promotes and supports theirjoint venture partners and contractors to facilitate complaints / develop their own
channel(s) / mechanism(s) to raise human rights complaints or concerns for workers
and communities. Alternatively, the Company provides a ‘fall-back channel’ forworkers or suppliers or contractors or communities.

C.3.2. Effectiveness of channel(s)/mechanism(s) (E)The channel/mechanism is effective, organised and is aligned with at least the mostmeasurable aspects of the UNGPs effectiveness criteria such as those on accessibility andpredictability.
Score 1

A clear accessible statement of how complaints or concerns are accepted,
processed and addressed (including timescales for responses) with a clear
commitment to "no retribution” for raising concerns.

Score 2The Company ensures the grievance or complaints mechanism is accessible(known to all relevant stakeholders), and predictable (provides a clear accessible
statement of how complaints are processed and addressed (including timescale
for responses, etc.) and of how complaints or grievances may be escalated), andovercomes other barriers to access. In addition, the Company can provide data
about the practical operation of the mechanism.

AP

For each score, this should also apply to a channel/mechanism covering workers(and all potentially affected stakeholders) in the supply chain.

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AG

For each score, this should also apply to a channel/mechanism covering workers
farmers, cooperatives, smallholders (and all potentially affected stakeholders) in the
supply chain.

EX

For each score 2, this should also apply to a channel/mechanism covering workers of
joint venture partners and contractors and communities potentially affected by theiractivities.

C.3.3. Oversight and review of the channel(s)/mechanism(s) (E)
The Company has allocated responsibility for the management of thechannel(s)/mechanism(s), the concerns/complaints process, for handling the complaints andfor reviewing the process. In addition, stakeholders are included in the design or review ofthe process.
Score 1The Company has allocated clear responsibility for handling concerns/complaints
and for overseeing and reviewing the process.

Score 2The Company provides clear evidence it has robust means of assessing how
effective its channel/ mechanism is in including involving stakeholders in thedesign or review of the performance of the channel/mechanism, assessing levelsof satisfaction with it and commissioning independent reviews of the process.

C.3.4. Process for incorporating lessons learnt (D)The Company seeks to gain insights from the complaints raised through its grievancechannel/mechanism. It also explains whether or how these insights might have informed anychanges to the Company’s own processes and practices.
Score 1

Some description of the process to analyse the frequency, patterns, trends andcauses of concerns and complaints (numerical indicators + support with
explanatory information to interpret the data).

Score 2

In addition to the above, reporting on changes made to policies and processes
based on learning from concerns or complaints.

C.3.5. Remedying any impacts identified (D)Where the Company has identified negative impacts that have occurred and which it hascaused or contributed to, it provides or enables remedies and learns from the experience.
Score 1The Company describes the approach it has taken to provide or enable remedy
for any negative impacts which it has identified (by category or by example)
which it has caused or contributed to or (if it has not identified any), the approach
it would take if impacts were to be identified

Score 2

As well as describing the immediate remediation, the Company is able todescribe changes to systems and procedures or new processes and practices
adopted which are designed to prevent a recurrence in relation to impacts thathave arisen, or (if it has not yet identified any impacts) the Company is able to26

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describe the approach it would take to remediation and learning from key
impacts (*) should they arise in the future.
(*) We need suggestions for one or more key impacts designed to make score 2 reflect a
commitment to particularly thorough remediation and learning in the case where theCompany is seeking to qualify for score 2 without giving examples. Guidance on this will besought during the consultation.

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D. PERFORMANCEThis theme focuses on specific human rights related practices. In a first sub-topic, it
focuses on good practices to prevent or reduce negative impacts. The second
however, focuses on adverse events or severe negative impacts a Company may bealleged or reported to be responsible for by a third party. It also seeks to understandwhether a Company has remedied and learnt from such adverse events.

D.1. KPIs & GOOD PRACTICESGENERAL QUESTIONS/ISSUESPLEASE NOTE THAT THE BELOW INDICATORS WILL ONLY APPLY IF RELEVANT TO
THE ACTIVIITES AND OPERATIONS OF A COMPANY. SECTORS TO WHICH EACH
INDICATOR APPLIES ARE INDICATED IN [..].

D.1.1. Forced labour: bonded labour and other unacceptable financial costs [AP, AG,EX]
The Company refrains from imposing financial costs on workers that may indicate or involve
forced labour – such as debt bondage, requiring deposits, salary advances or loans,including paying for work-related expenses that should be covered by the Company,
withheld wage payments, excessive overtime, or require workers to pay relocation
expenses.
Score 1The Company pays workers regularly and does not require workers to pay
deposits or other similar work-related fees or costs.

Score 2

Evidence of the processes in place to implement and check this practice in any
relevant (*) parts of its own operations and in its business relationships,
particularly with employment agencies and recruitment intermediaries.

AP

For each score, the above applies to supply chainAG

For each score, the above applies to supply chain

EX

For each score, the above applies to contractors & joint ventures or operating
partners

D.1.2. Forced labour: Restrictions on workers [AP, AG, EX]
The Company refrains from restricting workers through the retention of identity cards,
passports, training certificates, ATM cards, bankbooks and other important personal
documents, restricting freedom of movement outside of working hours or throughcompulsory use of accommodation provided by the employer or violence or intimidation.
Score 1The Company does not to retain the workers’ personal documents not deny themaccess to personal documents or provides a secure safeguarding operation that28

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allows workers free and easy access to their documents. In addition the
Company does not restrict workers freedom of movement outside of worker
hours, and does not require workers to stay at and pay for accommodation by
the Company.
Score 2

Evidence of the processes in place to implement and check this practice in any
relevant (*) parts of its own operations and in its business relationships,
particularly with employment agencies /labour brokers / recruitment
intermediaries.

AP

For each score, the above applies to supply chainAG

For each score, the above applies to supply chain

EX

For each score, the above applies to contractors & JVs

D.1.3. Direct employment [AP, AG]
The Company favours the use of direct employment relationships, and does not avoid labourand social security obligations by using certain labour types, such as labour-only contracting,excessive use of consecutive short-term or fixed-term contracts of employment, precarious
sub-contracting arrangements, piecework contracts, or false apprenticeship schemes, andcan report on reduction in number of temporary/contracted workers.
Score 1The Company discloses workforce composition related to temporary workers (i.e.
It provides enough information to calculate the percentage of temporary
workers). In addition, the Company explains the results.

Score 2The Company can report on use of a diminishing percentage of temporary
workers except in justified circumstances such as using temporary workers for
temporary or seasonal work.

D.1.4. Child labour: Age verification and corrective actions [AP, AG, EX]
The Company has processes in place to verify the age of job applicants and workers. In
addition, if the Company learns that it has child workers or school age employees, it ensuresthat the children are enrolled in a remediation/education programme, rather than simply
dismissing them from employment.
Score 1The Company has processes in place to verify the age of job applicants andworkers.

Score 2

If and when child labour is found in operations, the Company has a policy todevelop, participate in or contribute to programmes for transition from
employment to education, enabling them to attend and remain in education.

AP

Companies with large supply chains must ensure their suppliers do the above (with a
special focus on avoiding child labour in fields or workshops)

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AG

Score 1, Companies with large supply chains must ensure their suppliers do theabove (with a special focus on avoiding child labour in fields or workshops). For
Score 2, for hazardous agricultural occupations the Company verifies that children
between the minimum age for work and age 18 are not engaged in tasks that arelikely to harm their health, safety or morals.

EX

Companies must ensure contractors and JVs do apply the above (with a particularfocus on avoiding child labour in mines)

D.1.5. Child labour: Hazardous work [AP, AG, EX]
Young workers, working both directly for the Company or for its relevant business
relationships, are not employed at night or in hazardous conditions which compromise theirhealth, safety, moral integrity, physical, mental, spiritual, moral or social development.
Score 1The Company commits to the issues in policies or documents

Score 2

Evidence that the company has processes in place to implement and check thispractice in any relevant (*) parts of its own operations and in its business
relationships

D.1.6. Non-discrimination: Workforce composition [AP, AG, EX]
The Company reports on the breakdown of employees per employee category according togender, age group, minority group membership and other indicators of diversity.
Score 1The Company has a system for monitoring equal opportunities and is able toprovide supporting data on workforce composition. It discloses the breakdown of
employees per employee category according to gender, age group, minority
group membership and other indicators of diversity (at least 2 sets of data are
required to get score 2). The Company provides an explanation of the figures
provided.

Score 2The Company describes the resulting actions (such as training, encouraging
actions from under-represented groups) and related targets if relevant.

D.1.7. Non-discrimination: Board composition [AP, AG, EX]
The Company reports on the composition of governance bodies according to gender.
Score 1

Percentage of women within the organisation’s governance bodies is equal to orless than 40%, but increasing over time

Score 2

Percentage of women within the organisation’s governance bodies is greaterthan 40%

D.1.8. Freedom of association [AP, AG, EX]
Relevant trade unions are granted access to workers and to carry out trade union functionsin the workplace. Where the right is restricted by law, the employer facilitates a parallel
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means of engagement. In addition, the Company effectively prohibit intimidation,harassment, retaliation and violence against union members and union representatives.
Score 1The Company discloses the percentage of operations (or plants, factories,
subsidiaries, as relevant) with a representative union. It also provides an
explanation for the results and indicates, where access to independent union
might be restricted, that it has provided employees with an alternative for
dialogue.

Score 2The Company effectively prohibits intimidation, harassment, retaliation andviolence against union members and union representatives and is able to give
examples of processes and procedures to implement this commitment. For
example, it has a safe and effective grievance mechanism for reportingharassment or intimidation in the workplace or a zero tolerance policy against
intimidation, harassment and violence against workers and union
representatives, particularly during collective bargaining negotiations and strikes.

D.1.9. Workers covered by collective bargaining agreements [AP, AG, EX]
Percentage of total workers covered by collective bargaining agreements (or equivalent) thatstem from negotiations between the Company and independent and freely elected workers
representatives and/or trade unions.
Score 1The Company discloses the percentage of total workers covered by collective
bargaining agreements. In addition, it provides qualitative explanation for thepercentage.

Score 2The Company remains neutral as regards employees' membership in any
particular trade union and allows trade unions to operate independently. In
particular, the Company does not provide financial support to or have a financial
interest in any trade union nor does it interfere with union voting processes andinternal union business.

D.1.10. Health and Safety: fatalities, lost days, injury rates [AP, AG, EX]
The Company discloses the types of injury and rates of injury, occupational diseases, lostdays, and absenteeism, and total number of work related fatalities.
Score 1The Company discloses quantitative information on health and safety. In
addition, it provides the related explanation of the figures provided.

Score 2The Company sets targets related to injury and rates of injury, occupational
diseases, lost days, fatalities and absenteeism. In addition, it provides an
explanation of the figures provided and briefly describes the resulting corrective
actions or action plans. Alternatively, if the Company had already sets targets
related to the reporting period, it either has met the targets or provides an
explanation of why these were not met.

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EX

For score 1, the Company must disclose at least 3 sets of information (amongst:
fatalities, injury rates, lost days). In addition, the data has to cover contractors and/or
Joint Venture employees.

D.1.11. Working hours [AP, AG]
The Company follows applicable international standards and national laws and regulations
concerning maximum working hours and minimum breaks and rest periods, ensuring that
overtime is limited, infrequent, voluntary and compensated at a premium rate. The
Company assesses the ability of workers to comply with the requirement on working hours
when allocating work or setting targets.
Score 1The Company allocates work or sets targets based on a realistic assessment of
the tasks and resources available. For example, it ensures overtime is used only
infrequently and is not used as a regular solution to meeting production demands
that are predictable. In addition, managers do not pressure, encourage, or allow
employees to give up their minimum holiday requirement or violate overtime
provisions.

Score 2The Company monitors trends in overtime throughout its activities andoperations. Or, the Company provides examples of how it makes sure workers
are not required to work overtime on a frequent basis or involuntarily. Or
compliance is regularly monitored as part of ongoing evaluation (through selfassessment, visits, and/or audits).

AG

For score 1, the Company has a requirement to ensure respect for maximum working
hours and overtime restrictions is included in the Company’s terms of contract with
suppliers and sub-contractors. For score 2, the Company assesses the ability ofsuppliers/sub-contractors to comply with the requirement during qualification andselection of new suppliers and sub-contractors or compliance by suppliers/subcontractors is regularly monitored as part of ongoing evaluation of suppliers and subcontractors through self-assessment, site-visits, and/or audits.

AP

For score 1, the Company has a requirement to ensure respect for maximum working
hours and overtime restrictions is included in the Company’s terms of contract with
suppliers and sub-contractors. For score 2, the Company assesses the ability ofsuppliers/sub-contractors to comply with the requirement during qualification andselection of new suppliers and sub-contractors or compliance by suppliers/subcontractors is regularly monitored as part of ongoing evaluation of suppliers and subcontractors through self-assessment, site-visits, and/or audits.

EX

For score 1, the Company has a requirement to ensure respect for maximum working
hours and overtime restrictions is included in the Company’s terms of contract with
contractors and/or joint ventures. For score 2, the Company assesses the ability ofcontractors/joint ventures to comply with the requirement during qualification andselection of new suppliers and contractors or compliance by contractors/joint
ventures is regularly monitored as part of ongoing evaluation of contractors/joint
ventures through self-assessment, site-visits, and/or audits.
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D.1.12. Living wage [AP, AG, EX]
The Company provides all workers with a wage that is sufficient to cover food and housing
expenses and all other basic needs for themselves and their entitled official dependents(clothing, transport, education, health care, unemployment insurance, pension, etc.) andprovide discretionary income. This is verified by an independent third party.
Score 1The Company provides evidence that it has calculated living wages in the
countries where it operates and commits to paying no less. The Company
discloses the proportion of its operations and /or workers this covers.

Score 2This is verified by an independent third party.

AG

For score 1, where the Company does not employ farmers as labour but instead hassome form of contractual relationship, payment is at a level that would provide aliving income to support an adequate standard of living. For score 2, this is verified
by an independent third party.

D.1.13. Land use and acquisition [AG, EX]
When acquiring, leasing or making other arrangements to use (or restrict the use of) land,
the Company recognises the rights of formal and customary land and resource owners andusers.
Score 1The Company identifies formal and customary land and resources owners
and users through its assessment process. It negotiates directly with them
about compensation (or other contractual arrangements) on a voluntarybasis, which means that it has obtained the consent of the relevant
individuals or communities (this may be expressed as free, prior and informed
consent (FPIC) or a commitment to zero tolerance for land grabs).

Score 2The Company provides fair compensation for land acquired or used (or where
it restricts existing use of land) where land markets are not functioning,(covering direct financial costs of land affected and economic and social
impacts resulting from projects that effect land or natural resource use or
rights or structures compensation to provide longer-term income streams for
those with land based livelihoods (ex: land-based compensation orcompensation-in-kind in lieu of cash compensation where feasible, leasearrangements or other benefit sharing)).

AG

For Score 2, compensation arrangements with farmers for use of land are structured
to share risks with farmers with a view to respecting the right to an adequate
standard of living (ex, offer stable and long-term sourcing relationships to farmers
and particularly to small-scale farmers, help them gain access to resources,
knowledge, inputs, technologies or insurance that increase their resilience against
external shocks).

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EX

For score 1, there is an explicit commitment to obtain FPIC for lands and resourcesof indigenous peoples. For score 2, the Company reports on the sites where
involuntary resettlement took place, the number of households resettled in each andhow their livelihoods were affected in the process. Or the Company reports on thenumber and description of significant disputes relating to land use, customary right oflocal communities and indigenous peoples. (Source: GRI G4 – Mining and Oil & Gas
Sector Disclosures)

D.1.14. Land use and acquisition: Resettlement [AG, EX]
If the Company is involved in resettlement, it conducts or participates in resettlement that isaligned with international standards and discloses related information. Resettlement is
considered involuntary when affected persons or communities do not have the right to refuse
land acquisition or restrictions on land use that result in physical or economic displacement.
(Source: GRI G4 – Mining and Oil & Gas Sector Disclosures, IFC Performance Standard 5)
Score 1The Company has practices in place to guarantee that, where resettlement iscarried out, it is voluntary, with a documented resettlement plan developed withthose to be resettled that focuses on livelihood restoration, providing land based
compensation as first priority and covers both physical and economic
displacement, with appropriate measures to mitigate adverse impacts on
displaced persons and host communities. Or commits to applying international
standards

Score 2The Company commits not to be involved in or benefit from concessions or othercontractual or permitting arrangements that involve forced evictions or actions
characterised as involuntary resettlement that do not meet international
standards (IFC Performance Standard 5 or the OHCHR Guidelines on
Development Induced Displacement).

AG

For score 2, this includes a specific commitment around farmland or land used by
local communities for livelihoods.

EX

For score 1, there is an explicit commitment not to be involved in involuntary
resettlement of indigenous peoples without FPIC.

FOOTNOTE(*) Relevant parts of the Company’s operations include: supply chain for those with
agriculture or apparel supply chains; and subcontractors, joint ventures and arrangements
around the use of migrant labour in the case of extractives.

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D.2. ADVERSE EVENTSAdverse events under this sector stem from a multitude of sources including the globalpress, multilateral organisations, trade unions and relevant NGOs.
D.2.1. HIGH SEVERITY - There are allegations of severe breaches of ILO standards or
the right to security of persons against the Company or the Company’s supply chain(Identified, quantified and analysed by EIRIS)
The allegations covered under this indicator relate to: Child Labour/ Forced Labour/
Discrimination/ Freedom of association and Collective Bargaining / Working Hours/ Healthand Safety/ Right to security of persons / Right to human health /freedom from torture,inhumane or degrading treatment
In order to appear under this indicator, there has to be enough details to substantiate andlink the Company or its Business Relationships to the allegations. In addition, it has toinclude a mix of the following indicators: severity (see below for each area), theLegal/regulatory framework, sources from main newspapers (high profile case), systemic
and prior warning.
Examples related severity: Non-discrimination: degrading discriminatory treatment (verbal or physical abuse) or
harassment or forced pregnancy testing or other forced medical tests OR any
allegations that also include allegations of violence against those affected or serious,
substantial threats of violence such as death threats Forced Labour: allegations of coercion against those affected Child labour: allegations that involve hazardous work or children under the age of 12
or children working excessive hours or that result in the death of a child FoA and CB: allegations involving a clear indication that the Company actively andsystematically opposes employees or other workers from forming or joining unions,or threatens those who do join; refusal to recognise or bargain with a union, unlessfor reasons recognised as reasonable ; interferes in the union's activities oradministration; repeated refusal to recognise a union over a period of time (twoyears) in one location or allegations that it has refused to recognise a union in
multiple locations (ie. allegations that a company has refused to recognise or bargain
with a union or interfered in a union’s activities if it is only one instance occurring overa short period of time are not covered).
 Working hours: allegations that involve forced overtime (the allegations must
explicitly detail the forced overtime) OR allegations that result in the death of aworker Health and Safety: Accidents involving 5 or more deaths or serious injuries of
employees or contractors or other persons outside the workforce where there areallegations that the Company failed to apply health & safety principles (in the
Company). In the Company’s supply chain, the threshold is 10+ deaths or serious
injuries. Major accidents that do not result in this level of deaths or serious injuries if
on the basis of the information available it seems likely to EIRIS that such deaths or
injuries were only avoided by chance.
 right to security of persons (violations by security forces linked to companies,
violence used in forced relocations): minimum threshold implies that violence has
resulted in at least one fatality.
 Right to human health: serious allegations of pollution to air, water or land whichhave serious negative impact on human health35

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Scores will be based on the number of severe allegations the Company faces and on a
combination sub-indicators related to 1) acknowledgment of the issue, 2) learning from theevent and improving processes to prevent the recurrence of such an event in future, and 3)
providing satisfactory remedy(ies) in relation to those affected.

D.2.2. MEDIUM SEVERITY – The Company faces criticism or negative news stories
related to Labour and Human Rights (Identified, quantified and analysed by RepRisk
and Business & Human Rights Resource Centre)
This indicator is based on negative news stories from independent third party sources suchas print media, NGOs, news sites, governmental agencies, blog and social media. The
negative news covers the negative human rights related news on company activity. It seeks
to assess whether the Company disclosed any response related to the negative news.

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E. REPORTING / TRANSPARENCY
This topic focuses on how the Company reports on its human rights policies,
practices and performance as well as impacts. When this involves quantitative details,
it is balanced with qualitative explanations of the results to keep in sight that humanrights may not be easily reported in a quantitative format.

E.1.1. Public policy available
The Company is made publicly available and it reports on whether and how the public
human rights commitment is communicated in an accessible form to external stakeholders,in particular potentially affected stakeholders.
Score 1The Company’s human rights policy is publicly available or indexed in a central
location.

Score 2The policy is communicated to other external stakeholders (i.e. Other thanemployees or business relationships which are dealt with in the next indicator).

AG

In addition, for each score, the Company this must also be the case for the supplier’s
policy.

AP

In addition, for each score, the Company this must also be the case for the supplier’s
policy.

E.1.2. Reporting on human rights training
The Company reports details on training workers on human rights issues (who, how, when,etc.). It also reports the total number of employees trained and the amount of training on
Human Rights they receive.
Score 1

Any details on training (training procurement, or internal auditors trained on
HRs, etc. Or absolute figure of employees trained).

Score 2The Company reports on training and also discloses the total hours of employee
training on policies and procedures concerning aspects of human rights that are
relevant to operations, including the percentage of employees trained.

EX

In addition, for score 1, the Company also reports on training security personnel. For
score 2, it reports the percentage of security personnel trained in the organization’s
policies or procedures concerning aspects of human rights that are relevant tooperations.

E.1.3. Reporting on the implementation of human rights management system
The Company reports details on implementing its human rights management systems. It
also informs about the percentage of operations subject to the organization’s human rights
management processes during the last reporting year.
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Score 1

The Company provides details on monitoring the implementation of its humanrights management system in its operations.

Score 2

Total number and percentage of operations that have been subject to humanrights reviews and/or impact assessments by country.

AP

For score 1, the Company also reports on supplier facilities monitored/audited. For
score 2, the Company reports on the proportion of supply chain monitored/audited(for example percentage of workers in the supply chain, or of suppliers factories, of
supplied goods, etc.).

AG

For score 1, the Company also reports on supplier facilities monitored/audited. For
score 2, the Company reports on the proportion of supply chain monitored/audited(for example percentage of workers in the supply chain, or of suppliers factories, of
supplied goods, etc.).

E.1.4. Disclosure of human rights risk/impact assessments
The Company reports on the outcomes of the risk/impact assessments it has carried out toidentify human rights issues and also identifies where those assessments have been publicly
disclosed.
Score 1The Company provides an overview of salient human rights risks and impacts
identified at an aggregate level and/or provides information on where to find the
publicly disclosed versions of the risk/impact assessment reports.

Score 2The Company provides an overview of its management/responses to the salientissues identified and/or provides information on where to find the publicly
disclosed versions of the management /response plans or reports.

AP

For score 1, the Company reports on targeting monitoring through risk assessment.
For score 2, the Company reports on supply chain performance: e.g. Provides
examples of the non-compliances found with its policy Or reports on the amount of
non-compliances found with its policy Or Provides data on supplier performance – forexample the numbers of suppliers which are of a poor/good standard or the numbersof suppliers which it has stopped using because of persistent non-compliance with its
policy or suppliers it is working with on rectifying non-compliance.

AG

For score 1, the Company reports on targeting monitoring through risk assessment.
For score 2, the Company reports on supply chain performance: e.g. Provides
examples of the non-compliances found with its policy Or reports on the amount of
non-compliances found with its policy Or Provides data on supplier performance – forexample the numbers of suppliers which are of a poor/good standard or the numbersof suppliers which it has stopped using because of persistent non-compliance with its
policy or suppliers it is working with on rectifying non-compliance. Also reports onland rights assessments carried out by the Company or in its supply chain.

EX

For score 1, it must include the publication of at least the summary of key company
human rights related responses to it (unless none conducted and good explanation
given). Or the results of monitoring of implementation of management plan (or other38

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HRs impacts not anticipated in management plan) in an understandable format andlanguage for selected operations. For score 2, public disclosure of ESIA/HRIA andmanagement plans (or other HRs impacts not anticipated in management plan) in anunderstandable format and language for a majority of operations.

E.1.5. Detailed reporting on stakeholder engagement on human rights issues,
including salient human rights issues
The Company provides details of stakeholder engagement on human rights issues.
Score 1The Company provides details of stakeholder dialogue/engagement (providing
actual examples). Or the Company reports the percentage of operations with
implemented local community engagement.

Score 2The Company reports on corrective actions taken / improvements made /lessons learnt from stakeholder engagement.

EXMust include indigenous peoples where relevant and reports on joint assessments
and/or monitoring with local communities.

AP

Must include details of stakeholder engagement carried out in the supply chain.

AG

Must include details of stakeholder engagement carried out in the supply chain.

E.1.6. Human rights screening / investments or contracts including human rights
clausesThis Indicator is one measure of the extent to which human rights considerations areintegrated in an organization’s economic decisions.
Score 1

Total number of significant investment agreements and contracts that include
clauses incorporating human rights concerns, or that have undergone humanrights screening.

Score 2

Percentage and total number of significant investment agreements and contracts
that include clauses incorporating human rights concerns, or that haveundergone human rights screening.

E.1.7. Reporting on some ILO standards
The Company provides quantitative data related to ILO standards on collective bargaining,
non-discrimination and health and safety.
Score 1

Some of: Reports the percentage of total employees covered by collective
bargaining agreements. Reports the total number of permanent employees by
employment type (manager / non-manager) and gender. Reports absenteeism,
injury rate, fatality rate and lost day rate.

Score 2All of.
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EX

For Score 1, H&S data must be include injury rate, fatality rate and lost day rate andmust cover Group and contractor employees. For score 2, data must include thepercentage of workers (or of group companies) that are being offered regular medical
check-ups.

E.1.8. Number of human rights related incidents and corrective actions
Number of ILO or human rights related incidents in the Company’s owned operations or in its
supply chain if relevant. These are incidents related to child labour, forced labour, nondiscrimination, freedom of association and collective bargaining or indigenous rights forcompanies exposed to this type of risks.
Score 1

Total number of incidents related to at least one of the following ILO conventions:child labour, forced labour non-discrimination, freedom of association andcollective bargaining or indigenous rights for companies exposed to this type ofrisks

Score 2

Reports on the corrective actions taken.

EX

For score 1 - The total number of incidents of violations involving rights of indigenous
people is required. For score 2, corrective actions taken in the event of incidents
involving rights of Indigenous Peoples are required.

AP

For score 1 - Reports the number of suppliers identified as having significant actualand potential negative human rights impacts. Or Reports the significant actual andpotential negative human rights impacts identified in the supply chain. For score 2 Reports the percentage of suppliers identified as having significant actual andpotential negative human rights impacts with which improvements were agreed upon
as a result of assessment. Or Reports the percentage of suppliers identified ashaving significant actual and potential negative human rights impacts with which
relationships were terminated as a result of assessment after failure to correct, and
why.

AG

For score 1 - Reports the number of suppliers identified as having significant actualand potential negative human rights impacts. Or Reports the significant actual andpotential negative human rights impacts identified in the supply chain. For score 2 Reports the percentage of suppliers identified as having significant actual andpotential negative human rights impacts with which improvements were agreed upon
as a result of assessment. Or Reports the percentage of suppliers identified ashaving significant actual and potential negative human rights impacts with which
relationships were terminated as a result of assessment after failure to correct, andwhy.

E.1.9. Number of grievances
The Company reports the number of grievances about human rights adverse impacts that it
had to deal with during the previous reporting year. It reports the number of grievances filed,40

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addressed, and resolved through its channel(s)/mechanism(s) to raise with human rights
complaints and concerns.
Score 1The Company discloses details related to monitoring its
channel(s)/mechanism(s) to raise human rights complaints and concerns(outcomes, improvements made, feedback given by users/stakeholders/NGOs
disclosed). Or the Company discloses the number of grievances related tohuman rights filed, addressed, and resolved through its channel(s)/mechanism(s)to deal with human rights complaints and concerns.

Score 2The Company discloses information on both monitoring its
channel(s)/mechanism(s) to raise human rights complaints and concerns and thenumber of grievances. In addition, it includes trends in number of concerns,
types, location and satisfaction of concerns (including the interpretation of it).

EX

In addition to the above, for score 2, companies have to report the number ofgrievances about indigenous rights and security guards filed, addressed andresolved through its channel/mechanism(s) during the reporting period.

AP

In addition to the above, for score 2, companies have to report the number ofgrievances about labour practices in their supply chains filed, addressed andresolved through its channel/mechanism(s) during the reporting period.

AG

In addition to the above, for score 2, companies have to report the number ofgrievances about labour practices in their supply chains filed, addressed andresolved through its channel/mechanism(s) during the reporting period.

E.1.10. Reporting is verified and informed - Stakeholder verification and input
The narrative as well as the quantitative data related to human rights has been
independently verified by a third party. In addition, stakeholder engagement has informed
report writing.
Score 1

Independent verification of report by an independent third party or bystakeholders.

Score 2

Stakeholder verification of report and evidence that stakeholder engagement has
informed report writing.

AP

For score 1, data on supply chain has also been verified by an independent third
party. For score 2, stakeholder engagement related to the supply chain has also
informed report writing.

AG

For score 1, data on supply chain has also been verified by an independent third
party. For score 2, stakeholder engagement related to the supply chain has also
informed report writing.

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