Guidance on Responsible
Business in Conflict-Affected
and High-Risk Areas:
A Resource for Companies and Investors
A joint UN Global Compact – PRI publication

“Guidance on Responsible Business in Conflict-Affected and High-risk Areas:
A Resource for Companies and Investors” aims to assist companies in implementing
responsible business practices in conflict-affected and high-risk areas consistent with the Global
Compact Ten Principles. It seeks to provide a common reference point for constructive dialogue
between companies and investors on what constitutes responsible business practices in difficult
operating environments, though it does not provide guidance on investment practices of financial
institutions.
This voluntary guidance aims to complement applicable national and international laws bypromoting international good practice. It does not presume to replace the private sector’s legal
rights and duties to their home and host country governments. Voluntary approaches cannot be
a substitute for government action, but they can reinforce the positive impacts of investment inconflict-affected and high-risk areas.
This guidance is designed to stimulate learning and dialogue and to promote collective action
and innovative partnerships through Global Compact Local Networks and other initiatives. It wasdeveloped by the United Nations Global Compact Office, the Principles for Responsible Investment (PRI) initiative and an expert group comprised of company representatives, investors, civilsociety leaders, UN representatives and others. It was informed by good corporate practices
from around the world, as well as a series of multi-stakeholder events (Istanbul; New York;
Khartoum; Tokyo). Global Compact Board members and Global Compact Local Networks havealso been involved in its development. It is subject to review in the light of new developments and– like all guidance developed by the Global Compact Office – it is voluntary.
For companies of all sizes, operating a business unit in a high-risk area poses a number ofdilemmas with no easy answers. There are challenges, yet a number of difficulties can be defusedwith early proactive measures. It is our hope that this guidance is a useful resource to help reduce
corporate risks and enhance the capacity of companies to make a positive long-lasting contribution to peace and development. We believe there is effectively no contradiction between maximized
long-term financial performance and positive contributions to peace and development.

Project Management: Melissa Powell, Adrienne Gardaz, Dawoon Chung, Meng Liu
Copy-Editor: Tom Zoellner
Designer: Hedie Joulaee
Printer: United Nations, New York

Copyright © 2010
United Nations Global Compact Office
Two United Nations Plaza, New York, NY 10017, USA
Email: globalcompact@un.org

Disclaimer:
The United Nations Global Compact Office makes no representation concerning, and does not guarantee, thesource, originality, accuracy, completeness or reliability of any statement, information, data, finding, interpretation, advice or opinion contained within this publication. The inclusion of company examples does not in
any way constitute an endorsement of these organizations by the United Nations Global Compact Office. The
material in this publication may be quoted and used provided there is proper attribution.
Copyright
The material in this publication is copyrighted. The UN Global Compact encourages the dissemination of thecontent for educational purposes. Content from this publication may be used freely without prior permission, provided that clear attribution is given to UN Global Compact and that content is not used for commercial purposes.

Table of Contents

Introduction

6

Core Business10

Government Relations

16

Local Stakeholder Engagement

20

Strategic Social Investment

24

Summary of Guidance Points

28

Acknowedgements

30

Expert Group Members

32

Annex

36

1. Further resources on specific
Guidance Points

36

2. General sources of information40

4 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas“It is this need to find common solutions
to pressing challenges that drives thecorporate responsibility movement
globally. It makes business a key partner
to the United Nations as we pursue ourgoals for development, peace and security(...). Our mission is an historic one. The
challenge before us is clear: ensuringthat companies apply the principles of theCompact within their own organizations,while enabling them to make common
cause with other companies and otherstakeholders is addressing global
challenges and helping to meet theneeds of the world’s people.”—H.E. Mr. Ban Ki-moon, United Nations Secretary-General

56 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Introduction

1. The following conditions often
prevail in conflict-affected andhigh-risk areas: human rights violations; presence of an illegitimate or
unrepresentative government; lack ofequal economic and social opportunity;
systematic discrimination againstparts of the population; lack of political participation; poor managementof revenues, including from natural
resources; endemic corruption; andchronic poverty with associated heightened risks and responsibilities.
2. As used in this document, the term
“investors” refers to a number of financial agents including asset owners(such as pension funds, government
reserve funds, foundations, endowments, insurance and reinsurancecompanies and depository organizations) and investment managers. This
guidance will also be relevant for
professional service providers engaging with investee companies on behalfof their client financial institutions.
Further information on these terms isavailable on the Principles for Responsible Investment’s website at: www.
unpri.org/faqs/#whocansign.

Companies and their investors are paying
increased attention to the challenges andopportunities of doing business in conflictaffected and high-risk areas. These areas differ significantly from more stable operating
environments and require companies and investors to take into consideration additional
factors.1 Various tools have been developed tohelp companies implement responsible business practices in these sensitive areas, yetthey still face many challenges. Two majordifficulties have been the lack of agreementon what constitutes “responsible” business inconflict-affected and high-risk areas, and thepractical challenges unique to such contexts.

PurposeThe primary purpose of this guidance document is twofold:• To assist companies in implementing responsible business practices by living up
to the Global Compact Ten Principles inconflict-affected and high-risk areas sothey may maximize their long-term financial performance and make positive
contributions to peace and development,
while minimizing risks and negative
impacts to both the business and society.
• To provide a common reference point
for constructive engagement in conflictaffected and high-risk areas, as opposed
to divestment, between companies andinvestors2 (specifically shareholders andpotential shareholders).

Context
The primary responsibility for peace,security and development rests with governments, but the private sector can makea meaningful contribution to stability andsecurity in conflict-affected and high-riskareas. Commercial activities have direct
and indirect positive impacts by creating
job opportunities, generating revenues that
advance economic development and recov-

ery, making sustainable investments in cities
and towns, creating inclusive hiring policies
that build good relations between ethnicities
and communities, developing “bottom of the
pyramid” business strategies and promoting best practices in the areas of humanrights, labour, the environment and anticorruption. Business can also be a powerfulincentive for bringing people together acrossnational and cultural lines, creating relationships based on a shared sense of identityand purpose, overcoming differences that,in the wider society, are more difficult tosurmount. These contributions can be madeby companies of all forms: small and large,
public and private, international and local.
Yet in some cases, companies may negatively impact their own operations and theiractivities may exacerbate conflict or instability – even if their intentions are for the best.
One common pitfall is hiring or consultingwith one group of local stakeholders while
ignoring the rest, unintentionally benefiting one group over another which can foster
grievances between communities. Wellmeaning social investment projects may
undermine a government’s role in providing
basic services. And poorly-trained security
forces might use excessive force aroundcompany assets resulting in human rights
abuses. Such impacts can create reputational, operational, and financial risks forcompanies and investors. Engagement withcompanies operating in conflict-affected andhigh-risk areas can increase investors’ understanding of highly complex situations andaccess to information regarding companies’
activities, promote the development of good
policies and risk mitigation strategies related
to such activities, and encourage companies’
positive contributions to sustainable peaceand development. When companies andinvestors are able to understand and takesteps to address complex issues associatedwith such contexts, they can mitigate therisks and negative impacts posed to and/

7or by corporate activities, ensure long-term
financial performance of business and play
an important role in supporting peace anddevelopment.

Using this document3
This guidance does not offer technicalinstructions. It is not intended to serve
as a blueprint for responsible behavior in
all conflict-affected and high-risk areas. It
complements responsible practices in peaceful and stable contexts, in situations of instability or conflict. This Guidance is offered
to help companies improve their conduct,
and provides a point of reference for engagement between companies and investors. It is
designed to stimulate learning and dialogue
and promote collective action and innovative
partnerships through Global Compact Local
Networks and other initiatives. It is subject
to review in the light of new experiences anddevelopments and, like all guidance developed by the Global Compact Office, is not a
mandatory requirement for participants.
The Guidance categorizes responsible business practices into four areas:• Core Business• Government Relations• Local Stakeholder Engagement• Strategic Social Investment
Each section is structured in a similar fashion and includes:• Definitions of relevant terminology• Opportunities• Challenges4• Guidance points• Explanatory notes• Brief examples illustrating theguidance points
All of the sections are complementary and,given the cross-cutting nature of some
aspects, should be considered in intercon-

THE MEANING OF “CONFLICT-AFFECTED” AND“HIGH-RISK” IN THIS DOCUMENT:
There is no single definition for the terms “conflict-affected” or “highrisk” areas. This Guidance may be relevant for a variety of contexts,
including countries, areas or regions:• That are not currently experiencing high levels of armed violence, butwhere political and social instability prevails, and a number of factors
are present that make a future outbreak of violence more likely (thesefactors are explained further throughout the document).
• In which there are serious concerns about abuses of human rights
and political and civil liberties, but where violent conflict is not currently present.
• That are currently experiencing violent conflict, including civil wars,
armed insurrections, inter-state wars and other types of organizedviolence.
• That are currently in transition from violent conflict to peace (theseare sometimes referred to as ‘post-conflict’; however transition
contexts remain highly volatile and at risk of falling back into violent
conflict).

nection with the other parts of the guidance.
Good practice with regard to one section
should not be considered a substitute foranother. The guidance is complemented byan annex that builds upon existing resourcesin the field and provides a list of tools andinitiatives that can be considered for further
support.
In general, companies are encouraged to:• Develop policies and procedures forengagement with investors and be open
to discussing concerns outlined within
this guidance.
• Make reasonable efforts to disclose
information that will enhance investors’
understanding of business activity in atimely manner and taking account oflegal and commercial considerations.

3. As used in this document, the term“engagement” is to be understood as
an overall description for a two-way
conversation between a company
and its shareholders and/or potential
shareholders for the purpose of communicating views and concerns on
issues that can impact the long-term
performance of the company. Suchdialogue can vary from regular correspondence to resolutions on company
ballots at Annual General Meetings(AGMs), or in-depth meetings over asignificant time period. However, theterm “engagement” is also used torefer to a company’s relations to thegovernment and other stakeholders
as outlined in other sections of this
Guidance.
4. The term “challenge” is used to referto the risks to a company which may result from the impacts of its operations.

8 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas• Refer to this guidance at the earliest
stages of their operations and throughout, especially during their initial consideration of investment.
• Use their annual “Communication on
Progress” to report on the implementation of this guidance and make sure it
receives wide circulation among thestakeholders.
• Ensure the involvement of their Boards
and senior management on these issues
to demonstrate high-level concern forthe challenges of operating in suchcontexts.
• Join a Global Compact Local Network in
an operational area. These are countryspecific, multi-stakeholder platforms
which can have a multiplying effect on
a company’s good intentions. Actions
are often more effective when takencollectively and in a multi-stakeholder
context.
Investors are encouraged to:• Make reasonable efforts to assess all
public information when engaging
companies.
• Make reference to this guidance during
dialogues with investee companies with
operations or interests in conflict-affected or high-risk areas.
• Review the company’s annual Communication on Progress to access relevant
information about a company’s implementation efforts.
• Improve communications between specialist Economic, Social and Governance(ESG) analysts and fund managers in relation to conflict-related issues discussedwith companies.

• Provide constructive feedback to companies on their communications withinvestors.
• Explain how the information provided
by companies will be used in the investment process (selection of sectors andindividual assets, basis for ownershipdecisions, etc).
• Be prepared to act collectively withother investors under appropriate circumstances.
All Global Compact participants are expected
to embrace, support and implement a set ofTen Principles in the areas of human rights,
labour standards, environmental sustainability, and anti-corruption wherever they
do business. There is no doubt that conflictaffected and high-risk areas present a special
challenge to this commitment. Failure to adhere to responsible business practices carries
additional costs and risks in such contexts,
as it can exacerbate tensions and instability.
Yet the potential rewards are correspondingly high. A responsible business sector canmake a marked contribution to the lasting
peace and prosperity of conflict-affected andhigh-risk areas. This document aims to be
a common reference point for this ongoingand vital dialogue.

910 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Core BusinessCore Business refers to corporate activities aimed principally at generating
profits. This includes operations located at the company’s own premises, itsbranches, subsidiaries and/or joint ventures, as well as trading and procurement links with suppliers.
Opportunities

CHALLENGE

Companies may face numerous challenges
to their operations in conflict-affected andhigh-risk areas. Through responsible corebusiness operations, a company can:• Mitigate risk factors posed to and bycorporate activities.
• Reduce operational challenges enhancing its ability to create value.
• Foster stability that would secure longterm benefits for the company.

A company may not adequately address all
risks and impacts present in such contexts,
including its potential to fuel conflictthrough its core business activities. As aresult, the company may be exposed toheightened tensions, and even disruption in
its own operating environment.

While securing its operations, it can also
make important contributions to theeconomic development and/or recovery of regions coming out of conflict. For example by:• Generating tax revenues for host governments that, if managed responsibly, canhelp them recover and provide services
to their citizens after war.
• Creating job opportunities and ensuring
equitable access to jobs through sensitive
human resource policies, such as youth
employment programmes.
• Bringing diverse groups together to work
towards shared and mutually beneficial
economic and social development.
• Creating value locally by ensuring theuse of local products and services in
its supply chains wherever possible,
particularly including vulnerable andconflict-affected parts of the population.
• Creating infrastructure developments
related to company operations which
can benefit local communities.
However, if adequate policies and strategies
are not in place, core business operations
may have unintended consequences andimpacts. The most significant challenges
relating to a company’s core business operations are identified below, with guidance on
how they can be addressed.

Guidance Point #1: Companies are encouraged to take adequate steps to identify
the interaction between their core business
operations and conflict dynamics and ensurethat they do no harm. They are encouraged toadapt existing due diligence measures to thespecific needs of conflict-affected and highrisk contexts.

Explanatory Note
Conflicts can arise from a number of problems that can be inadvertently exacerbatedby private sector investments. Companies areencouraged to take purposeful steps in orderto operate in a manner sensitive to the conflict. This includes three overall dimensions:
1. Understand the risks and conflict dynamics present in the operating environment
and the potential impacts of their own
operations. Examples of these include
fuelling corruption, labour issues, orlack of socioeconomic opportunities for
local populations. Conflicts can also arise
where a company contributes to environmental damage; uses natural resources
unsustainably; or restricts access to natural resources such as land and water.
2. Adapt operations to minimize negative
risks and impacts.
3. Adapt operations to maximize potential
positive contributions through core business operations.

11

Extending core business activities to support peace
Issue – Two Asian companies in the heavy manufacturing sector adapted products fromtheir core earthmoving range to be suitable for anti-personnel mine clearance activities
in post-conflict areas. When using the machines in one village where they operated, theylearned that some villagers were actually opposed to mine-clearing activities as theyfeared that the cleared land would be allocated by the government for commercial agriculture once it had been made safe.
Approach – The example illustrates: first, how a core business activity (heavy manufacturing) can be extended to support peace initiatives (mine clearance). And secondly, thatsuch efforts may have unexpected negative impacts if the specific context is not assessedthoroughly. The company widened the field of stakeholders and included more voices in its
process of gathering information.
Result – The land, once cleared of mines, was put to beneficial use by the villagers.

To achieve this, companies should take up
the following measures, in line with the due
diligence principles outlined in the United
Nations Framework for Business and Human
Rights, developed by the UN Secretary-General’s Special Representative on Business andHuman Rights:
1. Develop policies and integrate them into
management systems to minimize negative risks and impacts and maximize
positive impacts through core business
operations.
2. Clearly communicate these policies
and steps taken to implement them, forexample through a policy statement by
the Board. Organizing internal trainings
can also raise staff awareness.
3. Conduct a “conflict risk and impact assessment” prior to investing and starting
operations. This should complement, andnot replace, human rights, environmental
and social impact assessment processes.

4. Continue to regularly monitor the operating environment based on credible andreliable sources of information from thepre-acquisition phase. This can be in addition to or integrated in other types of
information gathering (such as politicalrisk analysis or security assessments).
5. Work in partnership with reputable
third parties with the relevant local
expertise and skills, such as in conflict
analysis, mediation and arbitration.
Relevant partners can be local andinternational civil society organizations,development agencies, or think tanks
and universities.
6. Explore options for contributing constructively to tackle specific risks andconflict issues identified (see paragraphon opportunities above).
7. Track and report on performance,
including through their annual Communication on Progress.

12 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

CHALLENGE
Grievances and disputes may arise from acompany’s core business operations among
local communities and other stakeholders
and may not be detected early enough to be
dealt with constructively and in a timely
manner. Grievances of those affected may beleft to fester and lead to increasing tensions.
Guidance Point #2: Companies are encouraged to make a commitment to addressing
grievances and disputes constructively andproactively through dialogue and by having
grievances and dispute settlement mechanisms that allow affected parties to raise
problems with the company with a clear
process for discussion and resolution.

Explanatory Note
In conflict-affected and high-risk areas, communities typically experience high levelsof stress and trauma through prevailinginsecurity, violence or displacement. Due tothe preexisting strain on the population andthe volatility of the context, businesses needto pay particular attention to monitoring
and adapting their operations to their en-

vironment. Grievance procedures can serve
as early warning systems and provide thecompany with ongoing information on theirimpacts that can be used to adapt practice,
avoid the escalation of disputes and, where
necessary, inform a process for resolution.
In order to develop a social license to operate, companies are encouraged to:
1. Strive for meaningful and constructive
engagement and dialogue with individuals and communities affected bycore business operations. This is also an
essential element of impact assessments
and monitoring (see also Section 4 on
Stakeholder Engagement).
2. Develop policies and mechanisms according to existing standards to settle
disagreements and grievances.
3. Inform relevant stakeholders about existing company policies and explain how
specific challenges will be addressed.
4. Ensure the broad participation of thecommunity and adopt measures thatthose participating can raise grievances
freely, safely, and in the knowledge that
their concerns are dealt with in a timely
manner.

DEALING WITH Community grievances
Issue – Conflicts between local communities and an oil company in Asia over the impacts of the oil operations threatened to cause delays and financial losses for the company.
Approach – The company employed four main strategies to engage more effectively with communities:
1. Community outreach and interviews with key opinion leaders and decision makers.
2. Information dissemination, education, and communication activities for the wider community.
3. Perception surveys and participatory workshops to introduce the project and validate initial survey results.
4. Participatory involvement in the formulation of environmental management plans.
The cost of this engagement was estimated at approximately US$6 million on a total project cost of US$ 4.5
billion (0.13% of total costs).
Result – The company calculated that by changing its engagement with local communities, it managed to
avoid project delays of approximately 10-15 days, equivalent to an estimated saving of US $50-72 million
through timely completion of construction and avoiding contractual penalties.

13

CHALLENGE

CHALLENGE

Companies may become implicated in abuses
and allegations of complicity in humanrights abuses. Such accusations may be costly
both reputationally and financially for acompany and seriously affect the concerned
communities.

Abusive behavior by security forces engaged
to protect staff and physical plants may expose the company to accusations of complicity in such abuses.

Guidance Point #3: Companies are encouraged to respect emerging international bestpractices, especially where national law setsa lower standard. Policies, strategies andoperational guidance, aligned with the Global
Compact’s Ten Principles, should be adapted
to the specific needs of conflict-affected andhigh-risk contexts.

Explanatory Note
Systematic and large-scale violations of human rights, humanitarian and criminal law
may accompany violent conflict, and can beboth a cause and a consequence of conflictand instability. What may begin as apparently “one off” abuse can escalate. In order
to avoid accusations of complicity, companies are encouraged to:
1. Develop corporate policies and systems
throughout the company to ensure effective respect of, among others, nationallaw, the United Nations Framework for
Business and Human Rights developedby the United Nations Secretary-General’s Special Representative on Businessand Human Rights, United Nations
Security Council resolutions, typicallyon sanctions, international humanitarian law and evolving international bestpractices.
2. Mainstream policies and systems
throughout the company, such as byproviding training to employees anddevelop adequate indicators for compliance.
3. Establish effective systems to monitor
compliance and share experiences withpeers and stakeholders.

Guidance Point #4: Companies are encouraged to apply evolving best practices in the
management of security services provided byprivate contractors as well as, to the extent
possible, public security forces.

Explanatory Note
In conflict-affected and high-risk areas,
companies may hire private security providers or work with public security providers
to protect their operations and personnel. If
security providers use excessive force, it may
amount to a human rights violation, which
can have significant negative consequences
for the company’s reputation and financial
performance. This may be the case even
where the company did not intend or order
the actions. Companies are encouraged to:
1. Build provisions on evolving best practices
into the contract with security providers.
2. Screen potential security providers’ trackrecords, including their human rights
records, and ensure they have requisite
policies and codes of conduct that reflect
good practice in security provision.
3. Consult regularly with host governments and local communities about
the impact of security arrangements on
those communities.
4. Record and report any credible allegations of human rights abuses by security
providers to appropriate host government authorities in a company’s area of
operation.
5. Provide relevant human rights training
to security forces, where possible.
6. Join voluntary initiatives offering guidance, such as the Voluntary Principles
on Security and Human Rights.
For additional guidance, see also Guidance Point 2
in the section on Government Relations.

14 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

dealing with the supply chain
Issue – A large North-American company is producing computers and related hardware products. While
their direct suppliers do not necessarily operate in conflict-affected and high risk areas, they have learned
that critical raw materials used in their products may have come from areas controlled by armed actors.
Approach – The company joined forces with other industry peers to create a certification mechanism oncertain minerals such as tin, coltan and cassiterite coming from conflict-affected and high-risk countries. It
also asked some of its suppliers – those deemed “high risk” -- to complete a self-assessment questionnaire
to identify potential social and environmental responsibility performance risks.
Result – These self-assessments began with an important psychological effect. They helped its suppliers
become more familiar with the company’s expectations of what it means to conform to the supply chain codeof conduct. The company then reviewed the results of the self-assessment and asked some of them to implement an improvement plan. The company has engaged more than 600 suppliers in this process and conducted
over 500 supplier site-audits in the last ten years. The company has made available as much information on
those audits as possible. It has listed the majority of its suppliers in an effort to be more transparent.

CHALLENGE
Companies may inadvertently provide financial or material means that facilitates armed
conflict, causing reputational, legal, operational and financial risks for the company. Thiscan happen more generally through business
relations and transactions with conflicting parties, inadequate supply-chain management or
through extortion payments to armed groups.
Guidance Point #5: Companies are encouraged to carefully monitor their business
relations, transactions as well as flows offunds and resources and to develop a rigorous
supply chain management system to assess
and monitor if and how their suppliers obtain
resources and raw materials in conflict-affected and high-risk areas. In so doing, companies

can help to ensure that they are not providing
funding or support to armed actors who may
benefit from revenues generated by the sale ofsuch goods and resources.

Explanatory Note
Companies should be aware that purchasing
commodities through suppliers and supply
chains which may be connected to armed actors may result in financial or in-kind support
to violent or criminal factions. A thoroughand extensive supply chain management
system is critical to reducing these risks inhigh-risk areas. Companies are encouraged to:
1. Carefully examine and monitor existingand newly established business relations
and transactions to verify that they do
not supply funding or other resources toarmed groups.

15

2. Conduct an extensive mapping exercise
and focus due diligence on their suppliers to verify the origin of products theypurchase, as well as understand the setof risks involved at different levels of the
supply chain.
3. Expand their supply chain due diligenceprocess to sub-tier suppliers which areresponsible for providing goods andservices to companies’ strategic suppliers.
In conflict-affected and high risk areas,
these sub-tier suppliers often provide raw
materials and thus pose the most significant challenge to companies in implementing responsible business practices.
4. Develop a robust mechanism for monitoring business and funding transactions in conflict-affected and high-riskareas and set up procedures for supply
chain engagement and regularly communicate with suppliers about the company’s expectations and standards.
5. Encourage their suppliers and sub-tiersuppliers to develop the capacity to implement responsible business practices.

ery, kickbacks, extortion, protection money, facilitation payments, fraud, money laundering,influence peddling and political and charitable
contributions. When systematic, such practices
often aggravate grievances among populations
and can fuel conflict. Companies are encouraged to:
1. Place particular emphasis on due diligenceagainst corruption, by adopting stringent
anti-corruption measures and regulations
against financial misconduct.
2. Be transparent about the selection process
for awarding contracts.
3. Organize periodic workshops and trainings for employees and contractors on anticorruption measures.
4. Where possible, join voluntary initiatives
promoting revenue transparency such as
the Extractive Industries Transparency
Initiative or the Wolfsberg Anti-Money
Laundering Principles for Private Banking.
For additional guidance on transparency, see also
Guidance Point 3 in the section on government
relations.

CHALLENGE
Vast sums of money and/or the sudden influxof revenues legally generated by companies
may lead to corruption both between private
sector entities and between the private sector
and the public sector. Further, in some situations, there may be a lack of regional andlocal capacity to manage such influx.
Guidance Point #6: Companies are encouraged to develop detailed policies on specificbribery issues and put in place robust management procedures such as risk assessment,
training and whistle-blowing to prevent corruption. Such policies and procedures should
be applied to any third-party (i.e. governments,
local suppliers, joint-venture partners, agentsor community organisations) contracting withthe company.

Explanatory Note
Corruption can take place between private sector entities and between the private sector andthe public sector. It can take the form of brib-

Joint initiative to stem the flow ofconflict-diamonds
Issue – Diamond traders were accused of fueling devastating
civil wars in Africa through the purchase of rough diamonds
from rebel groups.
Approach – The international Kimberley Process Certification
Scheme (KPCS) was set up, supported by leading international
companies. It says that participating states must put in placenational legislation and institutions, establish export, importand internal controls and commit to transparency and theexchange of statistical data.
Participants can only legally trade with other participants
who have also met the minimum requirements of thescheme, and international shipments of rough diamonds
must be accompanied by a certificate guaranteeing that they
are conflict-free.
Result – The flow of conflict diamonds was stemmed andfragile countries saw some stabilization of their economies.

16 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Government Relations
Government Relations refers to interactions between the company and government officials, agencies and organizations. Companies interact with governments at multiple levels, from the local to municipal/provincial up to thecentral government apparatus. At issue may be the granting of licenses, thepayment of taxes, the use of public services and other contractual relationships. Government relations also include legitimate public and private lobbying activities to shape the operating environment for business. For companies
that operate across borders, this includes dealings with both home and hostgovernments.
Opportunities
In conflict-affected and post-conflict areas,
government relations may be complicated by
the absence of a clearly identifiable government or one that is not supported by large
sections of the population. Carefully considered government relations may therefore bean effective means for a company to:• Avoid actual or perceived complicity inhuman rights abuses by government
actors.
• Contribute to successful risk management by reducing the risk of the company becoming a target for community
grievances.
• Protect its reputation.
• Foster constructive relations that may
translate into a competitive advantage.
• Promote strong governance practices
that are a central feature of a stable operating environment for business.
All of these outcomes are in the long-term
interests of companies, and provide a compelling proposition for investors. In addition
to being critical to successful risk management and ensuring that the company does noharm, well-managed government relations
efforts may contribute to peace-building
processes and help encourage sustainable
development by:• Promoting the “peace dividend” of apolitical resolution to a conflict for example through local business or multistakeholder coalitions, such as Global
Compact Local Networks.

• Drawing on political and material resources from outside the context.
• Encouraging the development of institutions, and governance mechanisms
to address or forestall the economic,
political and social grievances that drive
conflict.
• Supporting transparent and accountablemechanisms to govern the allocation,transfer and use of water, land and otherresources.
• Encouraging the development andenforcement of effective labour laws, tax
codes and other business regulations.

CHALLENGE
A company may find it difficult to avoid actualor perceived political involvement in a context
and then may wrongly assume that inaction
or withdrawal are the only available courses ofaction.
Guidance Point #1: Companies are encouraged to explore all opportunities for constructive corporate engagement with government
as well as set good examples in their dealings
with governments in order to support peace.

Explanatory Note
Through their interactions with government,
both local and international business canpromote good governance and support both
political will and government capacity to address, resolve and forestall conflict.

17

Local private sector can contribute to peacebuilding efforts by:
1. Providing material support to peace
negotiations.
2. Adopting hiring and workplace policies
that cut across ethnic or racial divides(e.g. the Sullivan and MacBride Principles).
3. Mobilizing pubic opinion (e.g. a publiccampaign run by a group of trade associations in 2001 encouraged citizens to
speak out on the urgency of peace).
Engaging with governments on conflict-related issues can be more sensitive for international companies, given concerns that theiractions may be considered unwelcome interventions. However, opportunities for engagement may be present during various pointsof a project cycle and may be proactive orreactive to specific events. Based on a rigorous analysis of the situation in economic,
ethical and legal terms, a wide spectrum of

engagement opportunities exist. Companies
may choose to employ any or a combinationof these strategies:
1. Directly engage the government with
their concerns, including for example
by articulating the shared interest of
government and business in peace andstability, in public and/or private forums.
2. Seek to address their concerns indirectly
by engaging with third parties, suchas the Global Compact Local Networks
or convening business roundtables ormulti-stakeholder conferences.
3. Engage in efforts that support governance capacity and support international best practice in resource governance,
where possible, through joining initiatives that provide forums for businessgovernment engagement on transparency and accountability, such as the
CEO Water Mandate or the Extractive
Industries Transparency Initiative.

Responding to Incidents of ViolenceIssue – A community meeting in Southern Africa was bombed amidst tensions overresettlement of the population. A company with major operations in the area was thenfaced with a choice - what to do about it?
Approach – Silence and/or withdrawal from the area was rejected. The company instead
embraced a three-fold strategy:
1. Writing a letter of protest to the government, issuing a public statement condemning
the incident and calling for a full and public inquiry.
2. Re-iterating an offer to train the local authority responsible for resolving re-settlement
issues that were a source of tension.
3. Initiating and co-hosting a multi-stakeholder forum on the most effective means ofcreating the right business climate for investment without the fear of perceived complicity in human rights abuses. This also led to the establishment of a Global Compact
Local Network.
Result – A proactive government relations strategy which sought to (a) generate political
will (i.e. the letter of protest and public statement) and support stronger governance capacity (i.e. the offer of re-settlement training); (b) investigate the immediate incident andits causes; and (c) promote the shared interests of business and government in peace (i.e.
through the multi-stakeholder forum).

18 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

CHALLENGE
Human rights violations by government
actors may expose the company to accusations of complicity in these abuses. Further,perceptions that a company may somehow
benefit from abuses may make it a focus of
local disruption and international attention, negatively impacting its operations andreputation.
Guidance Point #2: Companies are encouraged to take all necessary measures to avoid
complicity in human rights violations by government actors in relation to all aspects of thecompany’s operations.

Explanatory Note
Companies are encouraged to:
1. Include in their risk assessments thepossibilities of being indirectly or directly complicit in human rights abuses,in the illegal use of force and/or in grosshuman rights violations.
2. Develop policies, practices and operational guidance on government relations with regard to the environmental protection and natural-resource
management, the rights of labour andindigenous peoples and the use of public
security forces.
It is important to note that challenges are
greater for companies:• Involved in sectors strategically important to the government or the conflict(i.e. extractive, infrastructure, defense
and telecommunications sectors,
amongst others).
• With significant or sustained interaction
with the government, through jointventure arrangements.
• Which provide large source of tax revenue (i.e. the risk being that the company is seen as implicitly supporting thegovernment, and so becoming a proxytarget).

All companies are exposed to government-related challenges in conflict-affected or highrisk areas, regardless of their size or sector.
Employees may be affected, for example, by
the illegal use of force and/or gross humanrights violations, requiring company engagement with local or national authorities. A
company may usefully develop policies andoperational guidance on such issues identified through risk assessments. In such situations, some companies have provided legal
support to their employees.

CHALLENGE
Companies may expose themselves toreputational risks if they engage in corrupt
practices in their relations with government
officials. Such practices may also undermine
the development and strengthening of accountable governance mechanisms.
Guidance Point #3: Companies are encouraged to develop clear policies and robust
management practices to prevent corrupt
relations with government officials. Within
legal and commercial constraints, companies
are encouraged to promote transparency withhost governments and be as transparent as
possible with other stakeholders about theirrelationships with governments.

Explanatory Note
Lack of transparency may foster the perception of corrupt entanglement with thegovernment. Silence toward government malfeasance may also be a poor communication
strategy, because the company risks being
seen as indifferent and may therefore see its
operations targeted by parties in the conflict.
On the other hand, companies can bringsignificant expertise in financial accounting
mechanisms – expertise that can contributeto strengthening accountability mechanisms. Engagement with government actors
on corruption and transparency, and followup communication with stakeholders, can bemost effective through collective initiatives
such as Global Compact Local Networks.
For additional guidance on anti-corruption, seealso Guidance Point 6 of the Core Business section.

19

CONSTRUCTIVE ENGAGEMENT WITH GOVERNMENT
Issue – Projects that generate large government revenues may exacerbate tensions between conflicting parties, for example between different regions or a region and a central government. The company’s risk of becoming a target increases
if there is a lack of transparency about the terms of a project. Yet, a company’s ability to share information is often restricted by legal and commercial considerations. A company with oil and gas interests in the Middle East was aware of thisdynamic before it went into negotiations with a regional government.
Approach – Prior to entry, the company undertook due diligence and extensive stakeholder engagement, both locally andinternationally, to: a) assess the exact nature of the risks posed by and to the projects, and b) identify strategies to minimize
those risks.
The strategy the company employed included:
1. Requiring the redrawing of the boundaries for one of the projects to lie solely within the area under the recognized control of the regional authority.
2. Negotiating an option for the company to leave the project after a set period, which allowed the regional and central
governments time to resolve outstanding legal and political issues associated with the creation of production-sharing
agreements.
3. Making public the payments made to the regional government to support infrastructure and capacity building projects in
the region.
4. Confirming the mutual commitment of the regional government and the company to transparency in promoting respect
for and compliance with voluntary principles and international best practices such as the Extractive Industries Transparency Initiative or the Voluntary Principles on Security and Human Rights.
Result – A creative strategy developed through extensive stakeholder consultation, and in collaboration with government
actors, reduced risks to the company through (a) clarifying the content and structure of relations between the company
and different government actors, and (b) encouraging transparency and promoting human rights observance.

20 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Local Stakeholder Engagement
Local Stakeholder Engagement refers to consultation and communication
strategies for the purpose of building ongoing relationships with local communities. Local stakeholder engagement can be complementary to global
stakeholder engagement and may take place with relevant local communities
and civil society organizations. It may address a wide array of issues, including company policies, core business operations and social investment.
Opportunities

Explanatory Note

Constructive and regular stakeholder engagement, by the company and its contractors, may
be an effective means for a company to build a
relationship of trust with all concerned parties,
so as to position the company as a predictableentity in a context where there may be distrust
and/or violence. A company may also:• Demonstrate its respect for local actors,
its willingness to listen to local people
and a genuine concern for community
well-being.
• Develop a more predictable and stableworking environment through early andcontinued engagement.
• Bring together parties who may have common needs, fostering positive relationships
between conflicting groups and reducing
the possibility of violent conflict.
• Encourage or support the activities of
reputable independent third parties.
Global Compact Local Networks can also
help to identify suitable and well-motivated civil society organizations which
can assist in this process.

A company’s stakeholder engagement strategy should be made operational throughout
all company departments and company’scontractors. Companies are encouraged to:
1. Ensure proactive and inclusive community consultation, referencing current
international standards on Free Prior
Informed Consultation or Consent.

CHALLENGE
Lack of ongoing and genuine engagement
may increase company costs and resourcestrain. A lack of proactive engagement may
leave stakeholders feeling like they have few
options other than disruptive behavior as away to attract attention. Work stoppages, media coverage and questions by investors canresult in a company spending valuable timeand resources responding to conflict.
Guidance Point #1. Companies are encouraged
to establish strategic and rigorous stakeholder
engagement mechanisms across company andcontractor operations, including establishing key
performance indicators to demonstrate that thecompany is accessible and accountable.

2. Implement formal and transparent
communication procedures, including
publication of meeting minutes and aregistry for commitments made by thecompany.
3. Develop a formal grievance procedure
agreed upon with stakeholders, taking
into account different approaches togrievance-based concerns and criminally-induced violence.
4. Invest in front-line conflict management
capacity and training for staff to professionalize around the issues of conflict
resolution, consensus building andfacilitating community meetings.
5. Support capacity building of local stakeholders in the ability to be a genuine
part of decision-making role, including
the involvement of civil society.
6. Ensure that all policies affecting local
stakeholders (hiring, compensation, security, etc.) are designed in recognitionof the specific operating environment.
7. Utilize conflict analysis tools to understand the impacts of stakeholder engagement activities.
8. Work with independent and trusted
third parties such as those identified
through the Global Compact Local
Networks.

21

22 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

CHALLENGE
Company actions can potentially exacerbateinter- and intra-community tensions andmay increase the likelihood of violence directed against a company. Dealing with only
one party in the conflict can be perceived by
its adversaries as siding with that group andcan make corporate operations a target forviolence. At the same time, conferring legitimacy to those involved with the conflict may
expose the company to the risk of extortion,
reward violence or make the company potentially complicit in human rights abuses.
Guidance Point #2: In the context of existing
inter- and intra-group tensions, companies areencouraged to take a broad and inclusive approach towards stakeholder engagement.

Explanatory Note
Taking a narrow approach to stakeholder
engagement or engaging with the “wrong”
leadership may lead to inter-community conflict, by making people feel that they needto compete for access to company decisionmakers and company benefits. In developing
an inclusive and participatory engagement
strategy related to their activities, companies
are encouraged to identify legitimate representatives of the community and:1. Assess if “official” or elected representatives enjoy broad support among theirconstituency. Propose collective action
in stakeholder engagement.
2. To the extent possible, use multiple
venues for engagement: informal sports
events or festivals, formal meetings with
official representatives, public meetings,
advisory board of informal leaders, etc.
Make sure that some venues are public
so that all people have access to thesame information.
3. Perform stakeholder mappings to understand positions and interests of eachgroup within the context, and to develop
a strategy of engagement for each group.
4. Take a cautious approach to engaging with armed groups. In some cases
talking to aggrieved parties can aid due
diligence processes and help provide
a more accurate understanding of theconflict. However engaging with crimi-

nal or armed groups at a business level
may expose the company to allegationsof bribery, corruption and illegality.
Transparent contractual relationships
are generally difficult in this context.
5. Reference current international laws
and standards for guidance on financialtransactions regarding interactions withgroups listed on international terrorist
lists.
6. Take a broad and inclusive approach toproviding opportunities, such as jobs, inthe community. Be careful that job programmes that integrate ex-combatants
into the local economy do not create unfair competition with local stakeholders
who chose to stay out of the conflict.
7. Use independent and reliable third
parties to analyze and understand local
power structures. Developing or working with Global Compact Local Networks
may contribute to this process.

CHALLENGE
International attention to business activities
in conflict-affected and high-risk areas may
increase a company’s reputational risks. It
can create a space for outsiders (advocacy
groups, politicians, criminal elements) togather popular support against the company,
cause an unstable working environment andgenerate negative international press.
Guidance point #3: Companies are encouraged to engage proactively with relevant
civil society organizations and internationalorganizations.

Explanatory Note
Companies are encouraged to develop an
inclusive and participatory engagement strategy related to their activities with a broad,rather than narrow, representation of local
civil society and to:
1. Take collective action. Work with Local
Global Compact Networks to contributeto local solutions.
2. Engage with independent and informed
third parties to communicate the company’s business principles, values, and commitment to UN Global Compact Principles.

23

CHALLENGE
Insufficient or late engagement with local
communities may heighten security risks
for business activities. Taking an outcomefocused approach towards engagement, rather
than a participatory and inclusive process,may cause people to feel that they have notbeen consulted on matters that affect theirlives. An increase in tensions between thecompany and community may escalate into
obstructive behavior against the company,
and a possible shutdown of business activities.
Guidance Point #4: Companies are encouraged to promote and take action towards constructive and peaceful company-community
engagement.

Explanatory Note
With a view to approaching communities aspartners in preventing and managing con-flict, rather than automatically treating themas a risk factor, companies are encouraged to:
1. Identify constructive leaders who advocate a non-violent approach.
2. Focus on engagement as a transparent,
open and ongoing “consultative” process
aimed at meeting both stakeholders’ andcompany’s needs, instead of viewing it asa “negotiated” process.
3. In partnership with stakeholders, clearly
define goals, desired outcomes, andmutual expectations regarding communication, relationship building, andrespectful engagement.
4. Recognize that the importance of nontangibles like building trust, respect anda sense of neighborliness are as important as material benefits the company
may have to contribute.
5. Work with reliable independent third
parties who can provide disinterested
input.

STAKEHOLDER ENGAGEMENT AND RISK MANAGEMENT
Issue – A company sought a project in Latin America amidst a regional conflict, and somewere calling for a corporate policy of isolation and silence. Minimizing contact with feuding
communities was one possible risk-mitigation strategy.
Approach – Isolation was judged to be the riskiest approach and the company actively
sought ways to maximize contact with local communities to: a) be better informed about
the exact nature of the risks and threats to corporate activities, and b) use the friendly reputation the company had within the community as a means to minimize risk, both throughthe influence communities had over illegal armed groups (both guerilla groups and paramilitary groups), as well as being warned by the community about possible threats. The
community engagement strategies that the company employed included:
1. Gathering knowledge of the political operating environment by employing experienced
community affairs staff and working closely with the communities.
2. Obtaining knowledge and understanding of the direct and indirect impacts of corporate
activities, including security, economic, cultural, and social impacts.
3. Senior management of the company were entirely local, enabling, in this context, an alignment of the personal values of its staff with the business objectives of the company.
Result – Stakeholder-focused management systems and a concerted effort to be “part ofthe community” provided the company with the social capital that has become fundamental to operating successfully in this conflict-affected area.

24 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Strategic Social Investment
Strategic Social Investment refers to the voluntary, and sometimes legally
mandated, financial contributions by companies. They can help local communities and broader societies achieve their development priorities and create
sustainable opportunities in ways that are sustainable and aligned with strategic business objectives. Social investment does not include resources spent oncore business activities such as local hiring, contracting, waste management,or land compensation. Core business activities, however, can be leveraged in asocially beneficial way to complement social investments.
Opportunities
Companies, no matter the size, may havethe opportunity to deliver long-lasting
programmes that benefit local and regional
communities when social investment is strategically aligned with core business activities. Proactive community consultation andstrategic planning may serve as a means tobring conflicting groups together rather thanexacerbate existing tensions and divisions.
It can also help companies to gain politicalsupport among local communities for business activities. Development of new enterprises and of independent and sustainableeconomic activity should be a major goal ofsuch strategic investment.

CHALLENGE
The manner in which benefits are distributed
may create competition for resources inside
the community. Resentments over resource
distribution can potentially create tensions
between communities that may jeopardize
the security of a company’s business activities.
Guidance Point #1: Companies are encouraged to establish strategic social investment
programmes built on existing capacities as acomponent of, not a substitute for, local stakeholder engagement and consultation.

Explanatory Note
With a view to utilizing ongoing stakeholder
engagement as a method to inform designand development of social investment projects in conflict-affected and high-risk areas,
companies are encouraged to:
1. Define “fair benefits distribution”
through stakeholder forums.

2. Ensure, to the extent possible, that benefits are reasonably distributed acrosscommunities, not only to host communities, which can exacerbate tensions orcompetition.
3. Decrease “incentives” for local groups tobehave in a violent manner in obtaining
company resources and projects.

CHALLENGE
Failing to implement a strategic social investment plan may cause a waste of company
resources. Social investment projects thatare not aligned with core business strategy
and competencies may cause the company toundertake activities in which it has limited
expertise and knowledge. This can create
mounting expenditures on social investment
and reduce the likelihood of success.
Guidance Point #2: Companies are encouraged to employ the same rigor in developing social investment strategies as in otheraspects of business operations.

Explanatory Note
Companies are encouraged to execute aplanned (not ad-hoc) social investment strategy that takes into account their social impacts, with clear and measurable indicatorson the likelihood of increasing or decreasing
conflict. With a view to doing so, they areencouraged to:
1. Clearly define objectives that are linked
to the conflict-specific business caseand link the strategy to other company
processes.

25

26 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

2. Take an approach that builds on sharedcommon goals and involves the active
participation and commitment of both
local communities and the government.
3. Avoid providing free social services,thus ensuring that social investment isstrengthening local capacity rather thansubstituting for government.
4. Employ existing standards and guidanceon social investment, such as the Principles for Social Investment (PSI).

CHALLENGE
Failing to achieve long-term sustainable
development may reduce a company’s returnon social investment as well as damage thefinancial bottom line. If communities are not
involved in the identification and developmentof projects or feel no ownership, social investment efforts will have no long-term impacts,
and yield little goodwill for the company. In
a conflict-affected or high-risk area, this may
increase the perception that the company does
not care about the community and could makeit a target for obstructive action.
Guidance Point #3: Companies are encouraged to implement strategic social investment
as an independent activity, separate from thecompany’s obligations to mitigate or compensate for its operations’ impacts.

Explanatory Note
Social investment should be viewed as
a complement to, not a substitute for, aconflict-sensitive approach to company’s
core business operations. In this perspective,
companies are encouraged to:
1. Ensure that their social investment strategy is designed around the specific local
context, taking into account aspects ofthe conflict-affected or high-risk area.
2. Develop risk mitigation strategies andpolicies that specifically address social
investment programmatic impacts.
3. Demonstrate transparency, equity andfairness in decision making processes so
as not to increase perceptions of corruption, favoritism, or competition.

CHALLENGE
Providing basic services may undermine thegovernment’s role. A lack of exit strategy
may also place greater resource demands andexpectations on business. A company-drivensocial investment approach undertaken in
isolation from the government can becomea substitute for government responsibilities,
undermine the government’s legitimacy inthe eyes of its constituencies, and place greater expectations on the company. Unsustainable projects – especially the provision offree services in conflict-affected or high risk
areas – can, over time, become a perceived
entitlement for local stakeholders, creating
recurrent expenditures for the company.
Guidance Point #4: Companies are encouraged to ensure that social investment projects
are sustainable and not replacing services
which should be provided by the government.

Explanatory Note
Companies are encouraged to design all social
investments, no matter the project time frame,with a clear exit strategy, accounting for acommunity hand-over plan, no free service
provision and a blueprint for continued activity without financial input from the company.
In doing so, companies are encouraged to:
1. Take into consideration the long-term impacts of a social investment strategy as amethod to gauge sustainability of projects.
2. Define how social investment projects
will contribute to the company’s strategy of managing its impacts on local
communities and support sustainable
development.
3. Ensure that social investment efforts
build on, rather than replace, existing
capacities.
4. Work directly with the central and local
government to ensure that social investment strategies are in line with regional
and local community development plans.
5. Develop an exit strategy in conjunction with local communities, local civilsociety and local and national government, to ensure that social investment
projects can be successfully handed off
and taken over by other parties including local and national governments.

27

STAKEHOLDER CONSULTATION FOR STRATEGIC SOCIAL INVESTMENT
Issue – A major oil and gas project in Africa was threatening to trigger violence between communities (with the risk ofevolving into a company-community conflict) over employment, contracts and community projects.
Approach – It was widely known that an exclusive focus on the nearby community would lead to further violent conflictinstigated by those who felt left out. Instead, the company brought in an independent mediator to negotiate a benefit
distribution agreement between all communities based on 1) population size, 2) ancestral ownership, and 3) disruption theywould experience during construction due to proximity.
Negotiations took place at three levels: 1) consultation with traditional rulers, 2) establishing principles of negotiations
with three dominant communities, and 3) final negotiations with all stakeholders including all communities, the company,
government representatives and contractors.
Result – The project was implemented without any conflict between communities or with the company. The project wascompleted with zero down days due to community unrest.

28 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Summary of Guidance Points
CORE BUSINESS
Guidance Point #1: Companies are encouraged to take adequate steps to identify the interaction between their core business operations and conflict dynamics and ensure that they do noharm. They are encouraged to adapt existing due diligence measures to the specific needs ofconflict-affected and high-risk contexts.
Guidance Point #2: Companies are encouraged to make a commitment to addressing grievances and disputes constructively and proactively through dialogue and by having grievanceand dispute settlement mechanisms that allow affected parties to raise problems with thecompany with a clear process for discussion and resolution.
Guidance Point #3: Companies are encouraged to respect emerging international best practices, especially where national law sets a lower standard. Policies, strategies and operational
guidance, aligned with the Global Compact’s Ten Principles, should be adapted to the specificneeds of conflict-affected and high-risk areas.
Guidance Point #4: Companies are encouraged to apply evolving best practices in the management of security services provided by private contractors as well as, to the extent possible,
public security forces.
Guidance Point #5: Companies are encouraged to carefully monitor their business relations,transactions as well as flows of funds and resources and to develop a rigorous supply chain
management system to assess and monitor if and how their suppliers obtain resources andraw materials in conflict-affected and high-risk areas. In so doing, companies can help toensure that they are not providing funding or support to armed actors who may benefit fromrevenues generated by the sale of such goods and resources.
Guidance Point #6: Companies are encouraged to develop detailed policies on specific bribery
issues and put in place robust management procedures such as risk assessment, training andwhistle-blowing to prevent corruption. Such policies and procedures should be applied to any
third-party (i.e. governments, local suppliers, joint-venture partners, agents or community
organizations) contracting with the company.

GOVERNMENT RELATIONS
Guidance Point #1: Companies are encouraged to explore all opportunities for constructive
corporate engagement with government as well as set good examples in their dealings withgovernments in order to support peace.
Guidance Point #2: Companies are encouraged to take all necessary measures to avoid
complicity in human rights violations by government actors in relation to all aspects of thecompany’s operations.
Guidance Point #3: Companies are encouraged to develop clear policies and robust management practices to prevent corrupt relations with government officials. Within legal andcommercial constraints, companies are encouraged to promote transparency with host governments and be as transparent as possible with other stakeholders about their relationships
with governments.

29

LOCAL STAKEHOLDER ENGAGEMENT
Guidance Point #1: Companies are encouraged to establish strategic and rigorous stakeholder
engagement mechanisms across company and contractor operations, including establishingkey performance indicators to demonstrate that the company is accessible and accountable.
Guidance Point #2: In the context of existing inter- and intra-group tensions, companies areencouraged to take a broad and inclusive approach towards stakeholder engagement.
Guidance point #3: Companies are encouraged to engage proactively with relevant civil society organizations and international organizations.
Guidance Point #4: Companies are encouraged to promote and take action towards constructive and peaceful company-community engagement.

STRATEGIC SOCIAL INVESTMENT
Guidance Point #1: Companies are encouraged to establish strategic social investment programmes built on existing capacities as a component of, not a substitute for, local stakeholder
engagement and consultation.
Guidance Point #2: Companies are encouraged to employ the same rigor in developing social
investment strategies as in other aspects of business operations.
Guidance Point #3: Companies are encouraged to implement strategic social investment as
an independent activity, separate from the company’s obligations to mitigate or compensate
for its operations’ impacts.
Guidance Point #4: Companies are encouraged to ensure that social investment projects are
sustainable and not replacing services which should be provided by the government.

30 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Acknowledgements
The Global Compact Office would like to express its gratitude to the members of the “Expert
Group on Responsible Investment in Conflict-Affected Areas” for their invaluable advice andsupport throughout the process that led to this publication. A special thank you to the Chairof the group and Vice-Chair of the Global Compact Board, Sir Mark Moody Stuart. His outstanding contribution and involvement was instrumental in the development of this guidance. We are also grateful for the excellent collaboration with the Principles for Responsible
Investment (PRI), especially Ms. Valeria Piani from the PRI Secretariat, for her input andsuggestions throughout the process. Without her efforts this joint Global Compact-PRI
product would not have been possible. A very special thank you is extended to Ms. Karen
Ballentine (Independent Consultant), Ms. Dost Bardouille-Crema (CDA Collaborative Learning Projects – Corporate Engagement Project), Ms. Nicola Black (Research Consultant), Ms.
Canan Gündüz and Ms. Ulrike Joras (International Alert) and Ms. Melany Grout (Conflict Risk
Network) who all went above and beyond in contributing to the development of this guidance.
Their enthusiasm and expertise were invaluable.
We would like to thank the Global Compact Local Networks in China, Colombia, India,
Japan, Sudan and Turkey as well as the Global Compact Inter-Agency team for their input
and suggestions. We wish to thank members of the Global Compact Human Rights Working
Group and the Global Compact Anti-corruption Working Group as well as all Global Compact participants who shared their views and provided valuable contributions. We are also
thankful to those who participated in the events in Istanbul, New York, Khartoum and Tokyo(participanys’ lists are available from http://www.unglobalcompact.org/Issues/conflict_prevention/
meetings_and_workshops.html).
Finally, the Global Compact Office would like to extend a special thank you to the Swiss
Government, Swiss Agency for Development and Cooperation, who made the publicationof this guidance possible.

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32 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

List of Expert Group Members
Chair
UN Global Compact Board

Sir Mark Moody-Stuart, Vice Chair

Company Representatives
ABB Ltd.
Mr. Ron Popper, Head of Corporate Responsibility
AngloGold Ashanti
Ms. Jessica van Onselen, Senior Officer, Sustainability
Alstom
Mr. Dominique Jaoul, Corporate Responsibility Director
ArcelorMittal
Ms. Charlotte Wolff, Corporate Responsibility Manager
BP International Ltd
Ms. Elisabeth Wild, Social Performance Adviser
China Development Bank
Mr. Xuchen Sun, Deputy Director
China Development Bank
Ms. Xia Wang, Project Manager
China Development Bank
Ms. Yuan Wang, Director General
China Development Bank
Ms. Hong Zhou, Project Manager
China National Offshore Oil
Mr. Tian Xu Duan, Overseas Manager
Corporation (CNOOC)
China National Offshore Oil
Ms. Bing Ma, Public Relations Coordinator
Corporation (CNOOC)
China National Offshore Oil
Ms. Xue Fei Ren, Corporate Social Responsiblity
Corporation (CNOOC)		 Coordinator
China National Offshore Oil
Mr. Bo Xue, Chief, Health, Safety and Environment
Corporation (CNOOC)
China National Petroleum
Mr. Weijiang Liu, Director of International Department
Corporation (CNPC)			
China National Petroleum
Ms. Wang Wei, Senior Representative
Corporatation (CNPC)
China National Textile and
Mr. Liang Xiaohui, Chief Researcher
Apparel Council
CNPC International (Nile) Limited
Mr. Qifeng Han, General Office Manager
CNPC International (Nile) Limited
Mr. Anjiang Qin, Vice President of Great Nile
			 Company Ltd
Holcim Ltd
Ms. Barbara Dubach, Head, Corporate
			 Social Responsibility
Oil and Natural Gas Corporation, Ltd.
Mr. Arbindoo Kumaria, Advisor to the Chairman and			 Managing Director
Pacific Rubiales
Mr. Jorge Alfredo Rodriguez, CSR Manager
PricewaterhouseCoppers
Ms. Shannon Schuyler, Corporate Responsibility Manager
Royal Dutch Shell plc.
Mr. Richard Dion, Policy and External Relations Adviser
Royal Dutch Shell plc.
Mr. Andrew Vickers, Head, Policy and External Relations
Schlumberger
Ms. Johana Dunlop, Global Citizenship Affairs Manager
Siemens
Mr. Daniel Kronen, Senior Manager, Corporate 					 Responsibility
Sinopec
Mr. Jack Fang, Investor Relation Representative
Sinopec
Mr. Huang Wensheng, Director-General and Spokesman
Sumitomo Chemical Company
Mr. Hisaka Netsu, Manager, Corporate Social
			 Responsibility Team
Sri Lanka Institute of Nanotechnology
Mr. Ravi Fernando, Chief Executive Officer
Standard Chartered Bank
Ms. Marianne Mwaniki, Senior Sustainability Manager

33

Talisman Energy Inc.
Mr. Reg Manhas, Vice President
Total
Ms. Laure Armandon, Legal Counsel
Total
Ms. Marie Capitaine, Compliance and Corporate
			 Social Responsiblity
Total
Mr. Bernard Claude, Chairman, The Ethics Committee
The Coca-Cola Company
Mr. Afzaal Malik, Vice President, International
			 Government Relations
The Coca-Cola Company
Ms. Marika McCauley Sine, Corporate
			 Responsibility Manager
Veolia Environnement
Ms. Pauline Danel, Special Advisor
Veolia Environnement
Mr. Dominique Heron, Vice President, Partnerships

Investors 		
Albright Stonebridge GroupMs. Brandon Berkeley, Director
APG All Pensions GroupMs. Anna Pot, Senior Sustainability Specialist, Global
			 Real Estate Asset Management
ATP-The Danish Labour Market
Ms. Susanne Birgitte Pedersen, Analysis, Strategy andSupplementary Pension		 Social Responsibility Investment
AVIVA
Mr. Neil Brown, Social Responsible Investment Analyst
Batirente
Mr. Francois Meloche, Extrafinancial Risk Manager
BC Investment Management
Ms. Susan Enefer, Manager, Shareholder Engagement
Corporation (bcIMC)
CalSTRS
Ms. Janice Hester Amey, Portfolio Manager
CalSTRS
Mr. Philip Larrieu, Investment Officer,
			 Corporate Governance
CalPERSMr. Bill McGrew, Portfolio Manager,
			 Corporate Governance
CalvertMr. Bennett Freeman, Senior Vice President,
			 Social Research and Policy
Ethix SRI Advisors
Ms. Anna Massarsch, Research Coordinator
Ethix SRI Advisors
Ms. Reinhilde Weidacher, Research Coordinator
Experts in Responsible Investment
Ms. Nadia Laine, Senior Client Relationship Manager
Solutions (EIRIS)ES Global Solutions
Mr. Marc de Sousa-Shields, Managing Partner
F&C Asset Management
Ms. Anna Krutikov, Director, Governance &			 Sustainable Investment
GES Investment Services
Ms. Hanna Roberts, Research Manager
Hermes Fund Management, Ltd
Mr. June Choi, Hermes Fund Managers, Hermes Equity
			 Ownership Service
Hermes Fund Management, Ltd
Ms. Mais Hayek, Assistant Manager, Hermes Equity
			 Ownership Service
Hermes Fund Management, Ltd
Ms. Naheeda Rashid, Manager, Hermes Equity
			 Ownership Service
Interfaith Center on Corporate
Mr. Gary Browse, Director
Responsibility (ICCR)JMR Portfolio Intelligence
Mr. John Richardson, Chief Executive Officer

34 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Mn Services
Mr. Kris Douma, Head of Responsible Investment
			 & Active Ownership
Norwegian Government Pension Fund
Ms. Pia Rudolfsson Goyer, Senior Advisor
Norwegian Government Pension Fund
Ms. Valborg Lie, Senior Advisor
Norwegian Government Pension Fund
Ms. Trude Myklebust, Senior Advisor
Northwest & Ethical Investments
Ms. Jennifer Coulson, Manager, Shareholder
			 Action Program
New Zealand Superannuation Fund
Ms. Anne-Maree O’Connor, Head of Responsible
			 Investment
PGGM
Ms. Saskia van den Dool, Responsible Investment Advisor
RobecoMs. Lara Yacob, Senior Engagement Specialist
Sustainalytics
Ms. Andrea Van Dijk, Sustainability Analyst
Sustainalytics
Mr. Darragh Gallant, Director, US Operations
Standard Life Investments
Ms. Julie McDowell, Head of Social Responsibility
			 Investment
TIAA-CREF
Mr. John Wilson, Director, Corporate Governance
TrucostMr. Cary Krosinsky, Vice President

Experts, Civil Society Representatives, and International Organizations
Beijing Rongzhi Corporate Social
Ms. Ying Chen, Director
Responsibility Research InstituteBeijing Rongzhi Corporate Social
Mr. Xiaoguang Wang, Deputy General Manager
Responsibility Research InstituteBusiness for Social Responsibility
Mr. Doug Bannerman, Senior Manager,
			 Advisory Services
Business for Social Responsibility
Mr. Michael Oxman, Director, Energy & Extractives
CDA Collaborative Learning Projects
Ms. Dost Bardouille-Crema, Project Director,
			 Corporate Engagement Project
CDA Collaborative Learning Projects
Mr. Luc Zandvliet, Advisor, Corporate Engagement Project
Conflict Risk Network
Ms. Melany Grout, Director
Conflict Risk Network
Mr. Adebiyi Odegbile, Analyst
Control Risks
Mr. John Bray, Director
Danish Institute for Human Rights
Mr. Mike Baab, Analyst
Extractive Industries Transparency
Mr. Jonas Moberg, Director
Initiative (EITI)Friends of the Earth
Ms. Adina Matisoff, China Sustainable			 Finance Campaigner
FAFO
Ms. Marion Marmorat, Researcher
FAFO
Ms. Anne Lene D. Sandsten, Managing Director,
			 FAFO AIS
Federal Department of Foreign
Ms. Segolene Adam, Adviser, Post-Conflict Transition,
Affairs (FDFA), Swiss Agency for 		 Recovery and Peace-Building, Global Institutions
Development and Cooperation (SDC)		 Divisions
Federal Department of Foreign
Mr. Markus Eggenberger, Programme Manager
Affairs (FDFA), Swiss Agency for
Development and Cooperation (SDC)
Global Compact Local Network Sudan
Ms. Lena Mahgoub, Advisor
Global Compact Local Network Sudan
Ms. Malak Abubakr, Advisor

35

Global Compact Local Network Colombia
Ms. Diana Chávez, Director
Global Witness
Ms. Seema Joshi, Legal Advisor, Ending Impunity
Independent Consultant
Ms. Karen Ballentine
Institute for Economics and Peace
Mr. Steve Killelea, FounderInstitute for Economics and Peace
Ms. Camilla Schippa, Director
International Alert
Ms. Canan Gündüz, Senior Programme Officer
International Alert
Ms. Ulrike Joras, Senior Programme Officer
International Business Leaders
Ms. Désirée Abrahams, Programme Manager
Forum (IBLF)
International Business Leaders
Mr. Graham Baxter, Acting CEO
Forum (IBLF)		
International Business Leaders
Mr. Steve Kenzie, Senior Programme Coordinator
Forum (IBLF)
International Council on
Ms. Kathryn McPhail, Senior Programme Director
Mining & Metals (ICMM)International Committee of the
Mr. Claude Voillat, Economic Advisor
Red Cross (ICRC)
Institute for Human Rights and Business
Mr. Salil Tripathi, Policy Director
International Finance Corporation (IFC)
Mr. James Emery, Principal Strategy Officer,
			 Sub-Saharan Africa
International Finance Corporation (IFC)
Ms. Debra Sequeira, Senior Development Specialist
International Petroleum Industry
Ms. Hannah Buckley, Senior Project Manager
Environment Conservation
Association (IPIECA)
Keiai University
Ms. Mariko Shoji, Professor of International Studies
Mitsubishi Research Institute, Inc.
Mr. Shinichi Mizuta, Senior Policy Analyst
Organisation for Economic
Ms. Lahra Liberti, Advisor on International
Co-operation and Development (OECD)		 Investment Law
Osaka University
Mr. Toshiya Hosino, Professor
Permanent Mission of Switzerland
Mr. Marco Rossi, Counselor
to the United Nations
Principles for Responsible Investment
Ms. Valeria Piani, Clearinghouse Manager
Research Consultant
Ms. Nicola Black
Scottish Human Rights Commission
Mr. Alan Miller, Chair
Stanford University
Mr. Chip Pitts, Professor
Taylor McKellar
Mr. Nicholas Taylor, Principal
TRACE International, Inc.
Ms. Alexandra Wrage, President
UN Development Programme, Bureau
Mr. Bartholomew Armah, Senior Policy Advisor,
for Crisis Prevention and Recovery 		 Central Strategy and Policy Cluster
UN Development Programme,
Mr. Henry Jackelen, Director
Private Sector Division
UN Development Programme,
Mr. Casper Sonessen, Policy Advisor
Private Sector Division
UN SRSG on Human Rights and
Mr. Gerald Pachoud, Special Advisor
Transnational Corporations
and Other Business Enterprises
University of Hong Kong
Mr. Ian Holliday, Dean of Social Sciences
University of Maryland
Ms. Virginia Haufler, Professor, Department
			 of Governments
University of Tokyo
Mr. Kasunobu Sato, Professor
United Nations University
Mr. Tatsuro Kunugi, Visiting Professor

36 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

Annex
1. Further resources on specific Guidance Points
CORE BUSINESS
Guidance Point #1:• “Business Guide for Conflict Impact Assessment & Risk Management,” UN Global Compact, available at http://www.unglobalcompact.org/docs/issues_doc/Peace_and_Business/BusinessGuide.pdf• “Risk Awareness Tool for Multinational Enterprises in Weak Governance Zones,” the Organisation for Economic Co-operation and Development, available at http://www.oecd.org/
dataoecd/26/21/36885821.pdf• “Guide to Operating in Areas of Conflict for the Oil & Gas Industry,” International Petroleum Industry Environmental and Conservation Association, available at http://www.ipieca.
org/activities/social/social_publications.php#4• “Guide to Human Rights Impact Assessment and Management,” UN Global Compact, with
the International Finance Corporation and International Business Leaders Forum, available at http://www.guidetohria.org• “Conflict-Sensitive-Business Practice: Guidance for Extractive Industries,” International
Alert, available at http://www.international-alert.org/pdf/conflict_sensitive_business_practice_section_1.pdf• The UN Global Compact’s Principles 7, 8 and 9 provide further guidance on environmental issues: http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/environment.html• “Protect, Respect and Remedy: a UN Framework for Business and Human Rights” A/
HRC/8/5, 2008 and “Business and Human Rights: Further steps toward the operationalization of the “protect, respect and remedy ”framework””, A/HRC/14/27 2010: reports of the
UN Special Representative of the Secretary-General on the issue of human rights andtransnational corporations and other business enterprises, John Ruggie, available at http://
www.business-humanrights.org/SpecialRepPortal/Home
Guidance Point #2:• “Good Practice Note: Addressing Grievances from Project-Affected Communities,” International Finance Corporation, available at http://www.ifc.org/ifcext/sustainability.nsf/Content/
Publications_GPN_Grievances• The website of the IFC’s Compliance Advisor Ombudsman: http://www.cao-ombundsman.org• “Handling and Resolving Local-Level Concerns and Grievances,” International Council
on Mining and Minerals, available at http://www.icmm.com/page/15822/icmm-presents-newguidance-note-on-handling-and-resolving-local-level-concerns-and-grievances• “Grievance Mechanisms for Business and Human Rights Strengths, Weaknesses andGaps,” John F. Kennedy School of Government, Harvard University, available at http://www.
hks.harvard.edu/m-rcbg/CSRI/publications/workingpaper_40_Strengths_Weaknesses_Gaps.pdf• Rights Compatible Grievance Mechanisms – A Guidance Tool for Companies and Their
Stakeholders,” John F. Kennedy School of Government, Harvard University, available at
http://www.hks.harvard.edu/m-rcbg/CSRI/publications/Workingpaper_41_Rights-Compatible%20
Grievance%20Mechanisms_May2008FNL.pdf• “Embedding Rights-Compatible Grievance Procedures for External Stakeholders Within
Business Culture,” John F. Kennedy School of Government, Harvard University, available
at http://www.hks.harvard.edu/m-rcbg/CSRI/publications/report_36_sherman_grievance.pdf• “Protect, Respect and Remedy: a UN Framework for Business and Human Rights” A/
HRC/8/5, 2008 and “Business and Human Rights: Further steps toward the operationalization of the “protect, respect and remedy ”framework””, A/HRC/14/27 2010: reports of the
UN Special Representative of the Secretary-General on the issue of human rights andtransnational corporations and other business enterprises, John Ruggie, available at http://
www.business-humanrights.org/SpecialRepPortal/Home

37

Guidance Point #3:• The UN Global Compact’s Principles 1 and 2 provide further guidance: http://www.unglobalcompact.org/Issues/human_rights/Tools_and_Guidance_Materials.html• “The Labour Principles of the United Nations Global Compact: A Guide for Business,” UN
Global Compact, available at http://www.unglobalcompact.org/issues/Labour/Tools_Guidance_Materials.html• “Business and International Humanitarian Law: An Introduction to the Rights and Obligations of Business Enterprises under International Humanitarian Law,” International Committee of the Red Cross, available at http://www.icrc.org/web/eng/siteeng0.nsf/html/p0882• “Guide for Integrating Human Rights into Business Management,” Business Leaders Initiative on Human Rights, UN Global Compact and Office of the United Nations High Commission for Human Rights, available from http://www.integrating-humanrights.org/• The Swiss Initiative on Private Military and Security Companies, which aims to promotea ‘Global Code of Conduct for Respect of Human Rights and International Law’ in the
global security industry, available at http://www.dcaf.ch/privatisation-security/PSC_PMC-CoC_
Draft_11.01.2010.pdf
Guidance Point #4:• “The Voluntary Principles on Security and Human Rights” available at http://www.voluntaryprinciples.org• “Voluntary Principles Performance Indicators,” International Alert available from http://
www.international-alert.org/pdf/Voluntary_Principles_on_Security_and_Human_Rights.pdf.
• The “Red Flags”, especially explanation and case examples under “Engaging Abusive Security Forces”: at http://www.redflags.info.
• The World Bank, Multilateral Investment Guarantee Agency and Anvil Mining toolkit,
available at http://www.miga.org/documents/VPSHR_Toolkit_v3.pdf
Guidance Point #5:• “Supply Chain Sustainability. A Practical Guide to Continuously Improving Upstream
Impacts by Applying the UN Global Compact Principles”, Global Compact – Business forSocial Responsibility, available at http://www.unglobalcompact.org/Issues/supply_chain/index.html• “The Kimberley Process”, further information available at www.kimberleyprocess.com.
• “The OECD Financial Action Task Force”, further information available at http://www.fatfgafi.org.
• “Conflict-Sensitive-Business Practice: Guidance for Extractive Industries, Flashpoint Issue on dealing with armed groups”, International Alert, available at http://www.iisd.org/
pdf/2005/security_conflict_sensitive_business.pdf• The “Red Flags”, explanation and case examples of “financing international crimes”: http://
www.redflags.info.
Guidance Point #6:• The UN Global Compact’s 10th Principle, provides further guidance available at http://
www.unglobalcompact.org/Issues/transparency_anticorruption/index.html• “The UN Global Compact Reporting Guidance on the 10th Principle” (2009) available at http://
www.unglobalcompact.org/docs/issues_doc/Anti-Corruption/UNGC_AntiCorruptionReporting.pdf• “Anti-Corruption Instruments and the OECD Guidelines for Multi-National Enterprises,”
OECD, available at http://www.oecd.org/dataoecd/0/33/2638728.pdf• The Extractive Industry Transparency Initiative (EITI): http://eitransparency.org/• “Transparency International Integrity Pact”: http://www.transparency.org/global_priorities/
public_contracting/integrity_pacts• “The Wolfsberg Anti-Money Laundering Principles for Private Banking”, available at http://
www.wolfsberg-principles.com/privat-banking.html• “IMF Draft Guide on Resource Revenue Transparency”, available at http://www.imf.org/external/np/fad/2004/grrt/eng/guide.pdf

38 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

GOVERNMENT RELATIONS
Guidance Point #1:• “The Role of Local Business in Peacebuilding”, the Berghof Research Centre for Constructive Conflict Management, available at http://www.berghof-handbook.net/documents/publications/killick_etal_handbook.pdf• “How Business Can Encourage Governments to Fulfil their Human Rights Obligations”, a Good Practice Note by the UN Global Compact’s Human Rights Working
Group, available at http://www.unglobalcompact.org/docs/issues_doc/human_rights/Resources/
Governments&HumanRights_Good_Practice_Note.pdf• “Local Business, Local Peace”, International Alert, available at http://www.international-alert.
org/peace_and_economy/index.php
Guidance Point #2:• The UN Global Compact’s 2nd Principle provides further guidance: http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/Principle2.html• The “Final Report of the ICJ Expert Legal Panel on Corporate Complicity in International
Crime”, available at http://www.business-humanrights.org/Updates/Archive/ICJPaneloncomplicity
Guidance Point #3:• The UN Global Compact’s 10th Principle provides further guidance: http://www.unglobalcompact.org/Issues/transparency_anticorruption/index.html• The “UN Global Compact Reporting Guidance on the 10th Principle”, (2009) available at
http://www.unglobalcompact.org/docs/issues_doc/Anti-Corruption/UNGC_AntiCorruptionReporting.
pdf• “Anti-Corruption Instruments and the OECD Guidelines for Multi-National Enterprises,”
OECD, available at http://www.oecd.org/dataoecd/0/33/2638728.pdf• The Extractive Industry Transparency Initiative (EITI): http://eitransparency.org/

LOCAL STAKEHOLDER ENGAGEMENT
Guidance Point #1:• “Performance Standards on Social and Environmental Sustainability,” International
Finance Corporation, available at http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvSocStandards• “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in
Emerging Markets,” Overseas Development Initiative, available at http://www.odi.org.uk/
resources/download/1436.pdf• “Getting it Right: Making Corporate-Community Relations Work”, Anderson, Mary B. and
Luc Zandvliet, Sheffield, UK: Greenleaf Publishing, 2009.
• “Setting Up a Multi-Stakeholder Panel as a Tool for Effective Stakeholder Dialogue,” UN
Global Compact Human Rights Working Group, available at http://www.unglobalcompact.org/
docs/issues_doc/human_rights/Resources/Stakeholder_Panels_Good_Practice_Note.pdf
Guidance Point #2:• “Conflict-Sensitive Business Practice: Guidance for Extractive Industries,” International
Alert, especially “Flashpoint 6: Dealing with Armed Groups,” available at http://www.
international-alert.org/pdf/conflict_sensitive_business_practice_section_1.pdf• “Stakeholder Engagement: A Good Practice Handbook for Companies: Doing Business in
Emerging Markets,” International Finance Corporation, available at http://www.odi.org.uk/
resources/download/1436.pdf• “Stakeholder Consultation Issue Paper,” CDA Collaborative Learning Project – Corporate
Engagement Project, available at http://www.cdainc.com/cdawww/pdf/issue/issue_paper_stakeholder_consultation_november_2004_Pdf.pdf

39

Guidance Point #3:• “Proactive Stakeholder Engagement: A Practical Guide for Companies and Stakeholders,”
CRS Europe, available at http://www.csreurope.org/data/files/toolbox/Stakeholder_engagement.pdf• “Guide to Engaging with NGOs,” Business for Social Responsibility, available from http://
commdev.org/files/1922_ file_BSR_Guide_to_Engaging_NGOs.pdf
Guidance Point #4• “Getting it Right: Making Corporate-Community Relations Work”, Anderson, Mary B. and
Luc Zandvliet, (Sheffield, UK: Greenleaf Publishing, 2009)

STRATEGIC SOCIAL INVESTMENT
Guidance Point #1, #2, #3, #4:• “Guide to Successful, Sustainable Social Investment for the Oil & Gas Industry”, 2008
International Petroleum Industry Environmental and Conservation Association, available
at http://www.ipieca.org/activities/social/downloads/publications/SocialInvestmentGuide.pdf• “Strategic Community Investment Quick Guide”, International Finance Corporation available at http://www.ifc.org/ifcext/advisoryservices.nsf/Content/70040EB805511D33852576D600517C
21?OpenDocument• “Sustainable Business and Peace: A Resource Pack on Corporate Responsibility for Smalland Medium Enterprises,” UN Global Compact, available at http://www.unglobalcompact.org/
docs/issues_doc/Peace_and_Business/Sustaining_Business_and_Peace.pdf• “Guide to Successful, Sustainable Social Investment for the Oil & Gas Industry”, 2008,
IPIECA, available at http://www.ipieca.org/activities/social/downloads/publications/SocialInvestmentGuide.pdf

40 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

2. General sources of information
AccountAbility
http://accountabilityaa1000wiki.net/
See, especially:• “From Words to Action: The Stakeholder Engagement Manual”: http://www.accountability21.
net/publications.aspx?id=904• “AA1000 Stakeholder Engagement Standard”: http://www.accountability.org/aa1000ses
AlertNet (Thomson Reuters Foundation)
http://www.alertnet.org/
Humanitarian news network based around a website, aiming to keep relief professionals andthe wider public up-to-date on humanitarian crises around the globe. The website is organized geographically as well as according to topic.
Berghof Research Centre for Constructive Conflict Management
http://www.berghof-center.org/std_page.php?LANG=e&id=13
See, especially:• “The Role of Local Business in Peacebuilding”: http://www.berghof-handbook.net/documents/
publications/killick_etal_handbook.pdf
Business Leaders Initiative on Human Rights
http://www.integrating-humanrights.org/
See especially:• “Guide for Integrating Human Rights into Business Management” Business Leaders Initiative on Human Rights, UN Global Compact and Office of the United Nations High Commission for Human Rights.
Business for Social Responsibility (BSR)
http://www.bsr.org/
See, especially:• “Guide to Engaging with NGOs”: http://commdev.org/files/1922_ file_BSR_Guide_to_Engaging_NGOs.pdf
CDA, Collaborative Learning Projects
http://www.cdainc.com/cdawww/publication.php
See especially:• “Getting it Right: Making Corporate-Community Relations Work”, Anderson, Mary B. and
Luc Zandvliet, (Sheffield, UK: Greenleaf Publishing, 2009)• “Corporate Engagement Project. Stakeholder Consultation Issue Paper”: http://www.cdainc.
com/cdawww/pdf/issue/issue_paper_stakeholder_consultation_november_2004_Pdf.pdf• “Corporate Engagement Project Framework”: http://www.youtube.com/watch?v=G0eBMpX9wIA• “Do No Harm: How AID Can Support Peace – Or War”: http://www.cdainc.com/cdawww/publication.php
CSR Europe
http://www.csreurope.org/
See, especially:• “Proactive Stakeholder Engagement: A Practical Guide for Companies and Stakeholders”:
http://www.csreurope.org/data/files/toolbox/Stakeholder_engagement.pdf
Danish Institute for Human Rights
http://www.humanrights.dk/
See, especially:• “Country Risk Assessment Reports”: http://humanrightsbusiness.org/?f=country_risk• “Doing Business in High-Risk Human Rights Environments”: http://www.humanrightsbusiness.org/files/11111/file/doing_business_in_highrisk_human_rights_environments__180210.pdf

41Engineers Against Poverty
http://www.engineersagainstpoverty.org/
See, especially:• “A Systemic Approach to Project Social Risk Management”: http://www.engineersagainstpoverty.org/_db/_documents/social_risk_management_briefing_note.pdf
Extractive Industry Transparency Initiative
http://eitransparency.org/
Voluntary multi-stakeholder initiative bringing together companies, government, investors
and civil society to improve transparency and accountability in the extractive sector with the
purpose of reducing poverty, conflict and corruption frequently associated with the conceptof the resource curse.
Global Network Initiative
http://www.globalnetworkinitiative.org/
Initiative formed by a multi-stakeholder group of companies, civil society organizations,investors and academics that aimed at negotiating and creating a collaborative approach toprotect and advance freedom of expression and privacy in the ICT sector.
Heidelberg Institute on International Conflict Researchwww.hiik.de/en/index_e.htm
Publishes a “Conflict Barometer” annually, which describes recent trends in conflict development, escalations, and settlements.
International Alert
http://www.international-alert.org/peace_and_economy
International Alert’s work offers detailed policy and operational guidance, research, advisory
and training services to companies operating in conflict-affected areas. See, especially:• “Conflict-Sensitive-Business Practice: Guidance for Extractive Industries”: http://www.
international-alert.org/pdf/conflict_sensitive_business_practice_section_1.pdf• “Local Business, Local Peace”: http://www.international-alert.org/peace_and_economy/index.php• “Conflict-Sensitive Business Practice: Engineering Contractors and their Clients”: http://
www.international-alert.org/pdf/CSBP_Engineering_contrators_clients.pdf• “Conflict Sensitive Project Funding: Better Lending Practices in Conflict Prone States”:
http://www.international-alert.org/pdf/CSBP_Finance_Lending_Conflict.pdf• “Voluntary Principles Performance Indicators”: http://www.international-alert.org/pdf/Voluntary_Principles_on_Security_and_Human_Rights.pdf
International Commission of Jurists
http://www.icj.org/
See, especially:• The “Final Report of the ICJ Expert Legal Panel on Corporate Complicity in International
Crime”, available at http://www.business-humanrights.org/Updates/Archive/ICJPaneloncomplicity
International Council on Mining and Minerals
http://www.icmm.com/
See, especially:• “Handling and Resolving Local-Level Concerns and Grievances”: http://www.icmm.com/
page/15822/icmm-presents-new-guidance-note-on-handling-and-resolving-local-level-concerns-andgrievances• “Community Development Toolkit”: http://www.icmm.com/page/629/community-developmenttoolkit• “Mining: Partnership for Development”: http://www.unglobalcompact.org/docs/issues_doc/Financial_markets/Zurich_Report_WhoCaresWins.pdf

42 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas

International Crisis Group
http://www.crisisgroup.org/home/index.cfm
NGO providing regular reports and briefing papers on conflict affected and conflict prone
countries.
Institute for Economics and Peace
http://www.economicsandpeace.org
Non-profit research institute dedicated to developing the inter-relationships between business,peace and economic development. Products include the ground-breaking Global Peace Index.
International Finance Corporation
http://www.ifc.org/
See, especially:• “Performance Standards on Social and Environmental Sustainability”: http://www.ifc.org/
ifcext/sustainability.nsf/Content/EnvSocStandards• “Stakeholder Engagement: A Good Practice Handbook for Companies: Doing Business in
Emerging Markets,”: http://www.odi.org.uk/resources/download/1436.pdf• “Good Practice Note: Addressing Grievances from Project-Affected Communities”:
http://www.ifc.org/ifcext/sustainability.nsf/Content/Publications_GPN_Grievances• “Strategic Community Investment Quick Guide”: http://www.ifc.org/ifcext/advisoryservices.nsf/
Content/70040EB805511D33852576D600517C21?OpenDocument• The website of the IFC’s Compliance Advisor Ombudsman: http://www.cao-ombundsman.org
International Labour Organization
http://www.ilo.org
See, especially:• “The Labour Principles of the United Nations Global Compact. A Guide for Business”:
http://www.ilo.org/public/libdoc/ilo/2008/108B09_260_engl.pdf• “Business and Decent Work in Conflict zones: A “Why?” and “How?” Guide”: http://www.ilo.
org/wcmsp5/groups/public/---ed_emp/---emp_ent/---ifp_crisis/documents/publication/wcms_116628.pdf
International Red Cross and Red Crescentwww.icrc.org
See, especially:• “Business and International Humanitarian Law: An Introduction to the Rights and Obligations of Business Enterprises under International Humanitarian Law”: http://www.icrc.
org/web/eng/siteeng0.nsf/html/p0882
International Petroleum Industry Environment Conservation Association (IPIECA)
http://www.ipieca.org/
See, especially:• “Guide to Operating in Areas of Conflict for the Oil & Gas Industry”: http://www.ipieca.org/
activities/social/social_publications.php#4• “Guide to Successful, Sustainable Social Investment for the Oil & Gas Industry”:
http://www.ipieca.org/activities/social/downloads/publications/SocialInvestmentGuide.pdf
John F. Kennedy School of Government, Harvard University
http://www.hks.harvard.edu/
See, especially:• “Grievance Mechanisms for Business and Human Rights Strengths, Weaknesses and Gaps”:
http://www.hks.harvard.edu/m-rcbg/CSRI/publications/workingpaper_40_Strengths_Weaknesses_Gaps.pdf• “Rights Compatible Grievance Mechanisms – A Guidance Tool for Companies and Their
Stakeholders”: http://www.hks.harvard.edu/m-rcbg/CSRI/publications/Workingpaper_41_RightsCompatible%20Grievance%20Mechanisms_May2008FNL.pdf• “Embedding Rights-Compatible Grievance Procedures for External Stakeholders Within Business Culture”: http://www.hks.harvard.edu/m-rcbg/CSRI/publications/report_36_sherman_grievance.pdf

43Kimberly Process
http://www.kimberleyprocess.com/
Joint governments, industry and civil society initiative to stem the flow of rough diamonds
used by rebel movements to finance wars against legitimate governments.
Organisation for Economic Co-operation and Development (OECD)
http://www.oecd.org/
See, especially:• “Risk Awareness Tool for Multinational Enterprises in Weak Governance Zones”:
http://www.oecd.org/dataoecd/26/21/36885821.pdf• “The OECD Financial Action Task Force”: http://www.fatf-gafi.org• “Anti-Corruption Instruments and the OECD Guidelines for Multi-National Enterprises”:
http://www.oecd.org/dataoecd/0/33/2638728.pdf• “Due Diligence for responsible supply chain management of minerals from conflictaffected and high-risk areas”: http://www.oecd.org/document/36/0,3343,en_2649_34889_44307
940_1_1_1_1,00.html
Red Flags
http://www.redflags.info/
Lists business practices which may result in legal liabilities for a company that operates inhigh-risk zones, including in conflict affected areas.
ReliefWeb
http://www.reliefweb.int/rw/dbc.nsf/doc100?OpenForm
Website providing timely information on humanitarian emergencies and natural disasters
and run by the United Nations Office for the Coordination of Humanitarian Affairs (OCHA).
Swiss Initiative on the Global Code of conduct for Private Security Companies
and Private Military Companies
http://www.dcaf.ch/privatisation-security/PSC_PMC-CoC_Draft_11.01.2010.pdf
Code of conduct resulting from an active collaboration of members of the private security
industry, the Swiss Department of Foreign Affairs, the Geneva Centre for the Democratic
Control of Armed Forces (DCAF) and the Geneva Academy of International Humanitarian Law
and Human Rights (ADH). It lays down international industry norms and standards for theprovision of private security services.
United Nations Global Compact
http://www.unglobalcompact.org/
See, especially:• The UN Global Compact Ten Principles in the areas of human rights, labour, the environment and anti-corruption: http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html• “Business Guide for Conflict Impact Assessment & Risk Management” http://www.unglobalcompact.org/docs/issues_doc/Peace_and_Business/BusinessGuide.pdf• “Guide to Human Rights Impact Assessment and Management” UN Global Compact,with the International Finance Corporation and International Business Leaders Forum,
http://www.guidetohria.org• “The Labour Principles of the United Nations Global Compact: A Guide for Business”:
http://www.unglobalcompact.org/issues/Labour/Tools_Guidance_Materials.html• “Supply Chain Sustainability. A Practical Guide to Continuously Improving Upstream
Impacts by Applying the UN Global Compact Principles”, Global Compact – Business forSocial Responsibility: http://www.unglobalcompact.org/Issues/supply_chain/index.html• “The UN Global Compact Reporting Guidance on the 10th Principle” 2009 available at http://
www.unglobalcompact.org/docs/issues_doc/Anti-Corruption/UNGC_AntiCorruptionReporting.pdf

44 Guidance on Responsible Business in Conflict-Affected and High-Risk Areas• “How Business Can Encourage Governments to Fulfil their Human Rights Obligations”,
a Good Practice Note by the UN Global Compact’s Human Rights Working Group: http://
www.unglobalcompact.org/docs/issues_doc/human_rights/Resources/Governments&HumanRights_
Good_Practice_Note.pdf• “Setting Up a Multi-Stakeholder Panel as a Tool for Effective Stakeholder Dialogue,” UN
Global Compact Human Rights Working Group: http://www.unglobalcompact.org/docs/issues_
doc/human_rights/Resources/Stakeholder_Panels_Good_Practice_Note.pdf• “Sustainable Business and Peace: A Resource Pack on Corporate Responsibility for Smalland Medium Enterprises,” UN Global Compact, available at http://www.unglobalcompact.org/
docs/issues_doc/Peace_and_Business/Sustaining_Business_and_Peace.pdf• “Who Cares Wins”: http://www.unglobalcompact.org/docs/issues_doc/Financial_markets/Zurich_
Report_WhoCaresWins.pdf• The CEO Water Mandate: http://www.unglobalcompact.org/Issues/Environment/CEO_Water_Mandate/
UN Secretary-General’ Special Representative on the issue of human rights andtransnational corporations and other business enterprises:
http://www.business-humanrights.org/SpecialRepPortal/Home
See especially:• “Protect, Respect and Remedy: a UN Framework for Business and Human Rights”
A/HRC/8/5, 2008
• “Business and Human Rights: Further steps toward the operationalization of the “protect,respect and remedy ”framework””, A/HRC/14/27 2010
Voluntary Principles on Security and Human Rights
http://www.voluntaryprinciples.org/
Guidance to companies operating in zones of conflict or fragile states so that they can ensurethat security forces – public or private – protecting the companies’ facilities operate in a waythat protects the company’s assets while respecting human rights and fundamental freedoms.
The World Bank
http://www.worldbank.org/
See, especially:• World Bank MIGA and Anvil Mining: http://www.miga.org/documents/VPSHR_Toolkit_v3.pdf
World Resources Institutehttp://www.wri.org/projects
See, especially:• ‘Development Without Conflict – the Business Case for Community Consent’:
http://www.wri.org/publication/development-without-conflict

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PHOTO CREDITS
Cover © The World Bank/Tomas Sennett,
			 The World Bank/Scott Wallace
Page 5 © UN Photo/Mark Garten
Page 9 © The World Bank/Yosef Hadar,			 UN Photo/Logan Abassi
Page 11 © Komatsu Ltd./Atsushi Nagira
Page 14 © The World Bank/Curt Carnemark
Page 19 © The World Bank/Bill Lyons
Page 21 © UN Photo/Fred Noy
Page 25 © The World Bank/Julio Etchart,		
provided by Microsoft
Page 29 © The World Bank/Eric Miller
Page 30 © UN Global Compact Office
Page 31 © UN Global Compact Office
Page 39 © Manoocher Deghati/IRIN
Page 45 © IRIN

The Ten Principles of theUnited Nations Global Compact
Human rights
Principle 1
Principle 2

Businesses should support and respect the protection ofinternationally proclaimed human rights; andmake sure that they are not complicit in human rights abuses.
LabourPrinciple 3
Principle 4
Principle 5
Principle 6

Businesses should uphold the freedom of association and theeffective recognition of the right to collective bargaining;
the elimination of all forms of forced and compulsory labour;
the effective abolition of child labour; andthe elimination of discrimination in respect of employment
and occupation.
Environment

Principle 7
Principle 8
Principle 9

Businesses are asked to support a precautionary approach toenvironmental challenges;
undertake initiatives to promote greater environmental
responsibility; andencourage the development and diffusion ofenvironmentally friendly technologies.
Anti-corruption

Principle 10

Businesses should work against corruption in all its forms,
including extortion and bribery.

Published by the UN Global Compact Office
Contact: unglobalcompact@un.org
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