Human rights saliency assessment in metals and mining
Human Rights & Modern Slavery | read time: 3 min
Mining is recognised as a high-risk sector for adverse human rights impacts. To help one of the world’s leading mining and metal processing companies uphold its commitment to the United Nations Guiding Principles, GoodCorporation was asked to conduct a human rights saliency assessment to identify the most severe and most likely human rights impacts linked to the company’s activities.
Understanding a company’s salient human rights risks is the starting point for developing an effective human rights strategy that effectively tackles the company’s most likely and most severe human rights impacts.
With over 100,000 employees worldwide and operations on most continents, for its first human rights risk assessment the company wanted to understand its human rights risks at the Group-level, before carrying out more specific saliency assessments across the different entities within the Group.
An effective human rights saliency assessment must take account of any actual and potential impacts across all stakeholder groups, including end-users, consumers, employees, subcontractors, suppliers (across the whole supply chain), the environment, and the communities in which it operates. It is a key exercise for the company to understand its human rights risk universe and to gain insights into where to focus its resources.
Our approach to human rights saliency assessments
There are three key strands to GoodCorporation’s human rights saliency assessments: –
- Stakeholder engagement: through internal and external interviews, internal surveys and a workshop
- Document review and background research
- Analysis and reporting
We conducted Interviews at the Group-level with a cross-section of managers of key functions with oversight over the Group’s risks regarding health and safety, environment, security, communities, diversity and inclusion, discrimination and harassment, living wage etc. as well as with stakeholders from some of the companies’ higher-risk subsidiaries, and external stakeholders such as trade unions and clients. Stakeholders were selected by GoodCorporation to ensure objective perspectives were incorporated. Findings from the interviews were analysed against the results of an internal survey completed by staff from a cross-section of functions within the head office.
Supply chain research
To add context, GoodCorporation carried out background research into the different industries and countries in which the company operates, the type of work they do, the nature of the supply chain and any media reports of human rights issues in these areas to identify risk factors.
The company’s own policies and procedures were also evaluated to identify any existing mitigating measures and highlight best practice.
Once the research and stakeholder engagement stage was completed a workshop was held to discuss the risks identified and validate the findings. This produced a clear list of actual and potential negative human rights impacts.
Risk rating and analysis
Taking stakeholder feedback into account, GoodCorporation then graded each of the risks according to likelihood and severity using the UNGPs definition of scale, scope and irremediability, and determined whether the impacts were potential or actual. The saliency of each issue was also graded as were the mitigation measures in place. The saliency levels and mitigation measures were then used to determine the level of priority of the actions that the company needed to take regarding each of the issues.
This resulted in a clear and prioritised human rights risk map for the company as well as recommendations on how to mitigate the salient issues identified. Recommendations encompassed those per issue topic as well as overall strategic ones. The company then used the recommendations to inform the development of its 5-year human rights strategy.
The company was also able to use this human rights risk analysis as part of its double materiality assessment conducted to comply with the EU Corporate Sustainability Reporting Directive.
Having completed this assessment at the Group level, GoodCorporation then developed a set of tools, templates and a Guidance Manual for the company to use across its subsidiaries globally to carry out more localised, targeted human rights saliency assessments.
The GoodCorporation View
Human rights saliency assessments are iterative processes, they need to be repeated every couple or few years and done both at the Group level and in the specific geographies of the business. They are an essential starting point for any human rights programme, enabling companies to focus their resources on the areas where the most severe impacts on people are most likely to occur. This helps companies comply with the growing raft of human rights legislation and be sure they are following internationally recognised best practice.
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