Integrate respect for human rights into company policies and governance, assign clear responsibilities, and ensure internal alignment. It is important to set clear commitments. Develop a human rights policy that clearly outlines how your organisation identifies and manages human rights risks. Ensure that responsibilities are linked to governance by establishing board-level accountability and integration into ESG or impact frameworks.

Tip Use international human rights treaties as a guide when drawing up a code of conduct. The 2011 UN Guiding Principles on Business and Human Rights is a good example. This document outlines the obligations public authorities have to protect human rights, the responsibilities of businesses to respect human rights, and the rights of victims of human rights violations to access judicial remedy. These principles are based on the Universal Declaration of Human Rights adopted by the United Nations General Assembly in 1948.

Map actual and potential human rights impacts across operations, value chains, and investments, and then prioritise the most severe risks. Use structured assessment tools to identify and evaluate risks across sectors and assets.

“Effective human rights due diligence starts with understanding real-world risks. That requires going beyond desk research – engaging local expertise, listening to affected stakeholders, and being willing to ask difficult questions throughout the supply chain.”

- Eva Smulders, Human Rights and Business Due Diligence Expert

Tip Some key resources for this risk assessment include:

• OECD Due Diligence Guidance for Responsible Business Conduct. Human rights are part of the OECD Guidelines for Multinational Enterprises on responsible business conduct. They are fundamental rights that apply to everyone. Key examples include the right to life, freedom and security; equal treatment; freedom of expression; the right to education; and protection against discrimination.

• UN Guiding Principles on Business and Human Rights (UNGP) This sets out three core expectations: 1) Governments have a duty to protect human rights; 2) Companies have a responsibility to respect human rights; and 3) Victims must have access to remedy in case of violations.

• EU due diligence related legislation. Many companies may need to comply with legislation such as the Corporate Sustainability Reporting Directive (CSRD), the Due Diligence Directive (CSDDD), the EU Battery Regulation (EUBR), the Forced Labour Regulation (FLR), the EU Deforestation Regulation (EUDR), or the Conflict Minerals Regulation (CMR).

• Practical tools (available on Dutch government business support website) can help you identify which human rights issues your business should consider. For example, the Human rights impact assessment and guidance toolbox gives you insights into these issues. Doing business with respect for human rights – a guidance tool for companies, is a manual with practical tools, advice, insights, and experiences relating to business and human rights. It also provides information on implementing the UN Guiding Principles.

Take action to stop or reduce negative human rights impacts and use leverage to influence suppliers, partners, or portfolio companies. Use your influence as an investor to encourage companies to strengthen their human rights policies, grievance mechanisms, and disclosure. It is also important to collaborate with peers and industry initiatives to amplify expectations and share knowledge. And, of course, track progress using consistent metrics – not only of policy adoption but also tangible evidence of change on the ground.

Monitor the effectiveness of actions taken and use data, indicators, and stakeholder feedback to improve performance. Ensure there are channels for affected stakeholders to raise concerns and seek remedy. Use findings from assessments and incidents to refine future due diligence processes and improve decision-making. And integrate lessons learned into investment frameworks to prevent recurrence and build systemic awareness.

Be transparent about policies, risks, and actions, and report to stakeholders in a clear and accessible way. Monitoring and communicating are essential to ensure that human rights commitments translate into real-world impact. Companies are expected to track the effectiveness of their actions over time using relevant indicators and feedback from stakeholders to understand whether risks are being properly addressed. Equally important is transparent communication: organisations should regularly report on their policies, identified risks, and the steps taken to mitigate them. This not only supports accountability but also builds trust with investors, employees, and affected stakeholders, while enabling continuous improvement across the due diligence process.

Enable access to remedy where harm has occurred and establish or participate in grievance mechanisms. Put in place accessible and trusted channels through which affected stakeholders can voice concerns and seek resolution. Draw on insights from risk assessments and past incidents to strengthen future due diligence and inform better decision-making. Incorporate these learnings into investment processes to help prevent similar issues from arising and to build a more proactive, system-wide understanding of human rights risks.