STEP 4: Integrate human rights into the ongoing management of a project or operation for the duration of its lifespan and act on findings as appropriate

Processes and procedures need to be developed to ensure that human rights issues identified in Steps One, Two and Three are adequately managed during the duration of project lifespan. Control processes could range from a supplier qualification process with a mandatory risk review of customer projects, to a code of conduct that ensures equal opportunity and minority rights, or a checklist and instructions for business operations in countries with a poor record on human rights. 

Guidelines for suppliers and contractual agreements with customers and suppliers have proven to be powerful tools for ensuring that risks are minimised, managed or eliminated, and opportunities are maximised. It is essential to repeat the process of identifying risks periodically, especially in sensitive countries. Additionally, standardised processes should be set up to drive action to address the identified risk. Such processes will need to be more detailed or more specific in certain cases. 
 
Human rights control processes are likely to contain:

 

  • Tasks, duties and responsibilities relating to specific individuals to adequately manage human rights risks;
  • Ongoing stakeholder engagement, especially with local communities directly affected by the project;
  • As much transparency as possible, including the publication of a summary of the actions agreed as a consequence of the Human Rights Impact Assessment;
  • Grievance and accountability mechanisms that are available to all and conform the rights-based principles outlined by the United Nations Secretary General’s Special Representative on Business and Human Rights;
  • Reporting on progress and ongoing impact against human rights indicators (see Tracking Performance Section of this Guide). 
 
Once processes and procedures are developed and incorporated into your existing compliance routines, it is critical to establish regular reporting.  This will serve as a control on your processes and assure they are adequately addressing the human rights issues confronted.  There must be regular and constant feedback relating to the human rights issues that have been identified, the compliance processes that address them, and the review process that assures the processes are adequate to control the underlying human rights issues.

Even if a business follows this path of good governance, events may nevertheless unfold where it becomes no longer sustainable to continue to do business in a country.  To manage such an eventuality in a responsible way, the business should attempt to minimise the negative impact its exit may cause to stakeholders including employees, contractors, customers, local communities and the broader society. For example, this consideration needs to be factored in to the ways in which a business supports humanitarian or community projects. Promoting capacity building through training, education, empowerment and sustainability will stand the business in better stead if it needs to exit a country or region.