How did companies in the human rights and extractives engagement embed human rights into corporate practice?

High-level trends

Governance and oversight

Companies have made continuous progress in terms of governance and oversight – in particular there are now twice the number of companies from emerging markets and smaller sized companies that disclose how their board and senior management oversees the human rights policy and due diligence process.

Embedding policy

Disclosure in embedding policy has not significantly improved. Nevertheless, over the period 2015-2017, more than half of the companies have strengthened their commitment to human rights by better integrating them into risk management systems and strategies and across relevant functions of the company.

Training - employees

Overall, disclosure around human rights training of employees has improved. Nonetheless, there are some important discrepancies amongst companies. Mining companies have done significantly better than oil and gas companies and emerging markets’ companies are lagging behind their developed markets counterparts.

Training - security personnel

Progress in disclosure around the training of security personnel has been twofold. The number of companies reporting increased, and a number of the companies has also strengthened their reporting and practices by formally joining the Voluntary Principles or by aligning with them.

Training effectiveness

While companies have made substantial progress in reporting on the human rights training conducted for both employees and security personnel, the number of companies reporting on this specific indicator is still very low. Tracking training effectiveness should be the next logical step to ensure that it is implemented properly across all operations.

Good practice - governance and oversight

At Total, the lead responsibility for human rights is with the Ethics Committee. The Human Rights Coordination Committee, led by the chairman of the Ethics Committee spells out the group’s human rights position and initiatives during its quarterly meetings. The meetings bring together representatives of the corporate and business departments most likely to be affected by human rights issues – legal affairs, human resources, public affairs, security, purchasing and sustainable development.

What should investors look out for

What should investors look out for?

Governance and oversight

No member of the board or senior management is responsible for or oversees the human rights policy.
There is no clear line of reporting on human rights risks or incidents.
It is unclear whether senior management is briefed regularly on human rights issues and whether the company leadership actively supports human rights.

Embedding

Despite stating a commitment to human rights, the company does not integrate them into internal policies and processes.
The company does not disclose how the commitment is implemented in practice through impact assessments and due diligence processes.
Lack of information on how the company will advance its efforts to respect human rights.
Human rights issues are not considered in risk management.

Good practice - embedding

Newmont takes a cross-functional approach to human rights integration to support a company-wide understanding, accountability and ownership with the topic. In addition to having a cross-functional human rights working group at the corporate level, the company requires all sites to have ongoing processes to identify human rights risks. The president and CEO, as well as members of the board, often visit sites to ensure policies and standards are being implemented. The company has also incorporated human rights requirements into pre-existing robust assessment and risk management processes and grievance mechanisms rather than create new ones.

Training - employees

Absence of human rights specific training, even for staff working in high-risk locations – rather the company provides training on the business code of conduct/ ethics.
No disclosure around hours of training conducted or share of employees that have received training.

Good practice - training of employees

Vedanta provides human rights training to both permanent and contract employees. The company discloses the number of hours of training provided and has also rolled out the Indigenous Peoples/Vulnerable Tribal Groups Standard with an international consultancy to implement train-the-trainer training for key staff members. All new staff are also trained on human rights as part of their induction process.

Training - security personnel

No training is provided to security personnel – not even to those located in high-risk locations.
The company is not a signatory to the VPs – or does not align with them.
Training is provided only to the company’s personnel – not to contractors or public forces.
Training is not tailored for specific situations (on use of force, for example).

Good practice - training of security personnel

Barrick Gold conducts heightened vetting and due diligence of its security personnel. All of them are required to be trained on human rights policies and procedures. In 2016, all employees and contractors received human rights training. Over 850 security personnel (100% of security employees) received dedicated, in-person human rights training including on the use of force, and comprising more than 3,000 hours of total instruction. The company plans to extend the focus of their security training content to children’s rights and the rights of other vulnerable populations.

Training effectiveness

No adequate system is put in place to verify that employees, security personnel and business partners understand the material.
No survey is conducted pre-training – to assess gaps in employees’ understanding – and post training – to measure effectiveness of training.

Good practice - training effectiveness

Goldcorp conducts pre and post online training surveys to assess training effectiveness. With regards to the online training course Respecting Rights, Level I, rolled out in 2016, the workforce’s average score improved by 12% – from a pre-course score of 60% to a post-course score of 72%. Goldcorp also conducted an in-depth participatory workshop at the end of which they evaluated employees on their capacity to identify human rights risks related to their operations/identify prevention, mitigation and remediation measures for high-risk human rights issues/ explain reporting mechanisms and course of action to take when becoming aware of a human rights risk or violation. The workshop was a pilot they plan to roll out for all operations.