Human Rights Policy

We subscribe to the UN’s "Guiding Principles on Business and Human
Rights", key portions of which are copied below.

Foundational principles

11. Business enterprises should respect human rights. This means that
they should avoid infringing on the human rights of others and should
address adverse human rights impacts with which they are involved.

12. The responsibility of business enterprises to respect human rights refers
to internationally recognized human rights – understood, at a minimum,
as those expressed in the International Bill of Human Rights and the
principles concerning fundamental rights set out in the International
Labour Organization’s Declaration on Fundamental Principles and
Rights at Work.

13.
The responsibility to respect human rights requires that business
enterprises:

(a)
Avoid causing or contributing to adverse human rights impacts
through their own activities, and address such impacts when they
occur;

(b) Seek to prevent or mitigate adverse human rights impacts that are
directly linked to their operations, products or services by their
business relationships, even if they have not contributed to those
impacts.

14. The responsibility of business enterprises to respect human rights
applies to all enterprises regardless of their size, sector,
operational context, ownership and structure. Nevertheless, the scale
and complexity of the means through which enterprises meet that
responsibility may vary according to these factors and with the
severity of the enterprise’s adverse human rights impacts.

15. In order to meet their responsibility to respect human rights,
business enterprises should have in place policies and processes
appropriate to their size and circumstances, including:

(a) A policy commitment to meet their responsibility to respect human
rights;

(b) A human rights due diligence process to identify, prevent,
mitigate and account for how they address their impacts on human
rights;

(c) Processes to enable the remediation of any adverse human rights
impacts they cause or to which they contribute.

OPERATIONAL PRINCIPLES

Policy commitment

16. As the basis for embedding their responsibility to respect human rights,
business enterprises should express their commitment to meet this
responsibility through a statement of policy that:

(a) Is approved at the most senior level of the business enterprise;

(b) Is informed by relevant internal and/or external expertise;

(c) Stipulates the enterprise’s human rights expectations of personnel,
business partners and other parties directly linked to its operations,
products or services;

(d) Is publicly available and communicated internally and externally
to all personnel, business partners and other relevant parties;

(e) Is reflected in operational policies and procedures necessary to
embed it throughout the business enterprise.

Human rights due diligence

17. In order to identify, prevent, mitigate and account for how they address
their adverse human rights impacts, business enterprises should carry
out human rights due diligence. The process should include assessing
actual and potential human rights impacts, integrating and acting upon
the findings, tracking responses, and communicating how impacts are
addressed. Human rights due diligence:

(a)
Should cover adverse human rights impacts that the business
enterprise may cause or contribute to through its own activities, or
which may be directly linked to its operations, products or services
by its business relationships;

(b) Will vary in complexity with the size of the business enterprise, the
risk of severe human rights impacts, and the nature and context of
its operations;

(c) Should be ongoing, recognizing that the human rights risks may
change over time as the business enterprise’s operations and
operating context evolve.

18. In order to gauge human rights risks, business enterprises should identify
and assess any actual or potential adverse human rights impacts with
which they may be involved either through their own activities or as a
result of their business relationships. This process should:

(a)
Draw on internal and/or independent external human rights
expertise;

(b) Involve meaningful consultation with potentially affected groups
and other relevant stakeholders, as appropriate to the size of the
business enterprise and the nature and context of the operation.

19. In order to prevent and mitigate adverse human rights impacts, business
enterprises should integrate the findings from their impact assessments
across relevant internal functions and processes, and take appropriate
action.

(a) Effective integration requires that:

(i) Responsibility for addressing such impacts is assigned to the
appropriate level and function within the business enterprise;

(ii)
Internal decision-making, budget allocations and oversight
processes enable effective responses to such impacts.

(b) Appropriate action will vary according to:

(i) Whether the business enterprise causes or contributes to an
adverse impact, or whether it is involved solely because the
impact is directly linked to its operations, products or services
by a business relationship;

(ii) The extent of its leverage in addressing the adverse impact.

20. In order to verify whether adverse human rights impacts are being
addressed, business enterprises should track the effectiveness of their
response. Tracking should:

(a) Be based on appropriate qualitative and quantitative indicators;

(b)
Draw on feedback from both internal and external sources,
including affected stakeholders.

21. In order to account for how they address their human rights impacts,
business enterprises should be prepared to communicate this externally,
particularly when concerns are raised by or on behalf of affected
stakeholders. Business enterprises whose operations or operating
contexts pose risks of severe human rights impacts should report
formally on how they address them. In all instances, communications
should:

(a) Be of a form and frequency that reflect an enterprise’s human
rights impacts and that are accessible to its intended audiences;

(b) Provide information that is sufficient to evaluate the adequacy of
an enterprise’s response to the particular human rights impact
involved;

(c) In turn not pose risks to affected stakeholders, personnel or to
legitimate requirements of commercial confidentiality.

Remediation

22.
Where business enterprises identify that they have caused or
contributed to adverse impacts, they should provide for or cooperate
in their remediation through legitimate processes.

Issues of context

23. In all contexts, business enterprises should:

(a) Comply with all applicable laws and respect internationally
recognized human rights, wherever they operate;

(b) Seek ways to honour the principles of internationally recognized
human rights when faced with conflicting requirements;

(c) Treat the risk of causing or contributing to gross human rights
abuses as a legal compliance issue wherever they operate.

24.  Where it is necessary to prioritize actions to address actual and
potential adverse human rights impacts, business enterprises should
first seek to prevent and mitigate those that are most severe or where
delayed response would make them irremediable.