Human Rights Reporting and Assurance Frameworks Initiative - RAFI
1. Recent updates
Draft Guiding Principles Reporting Framework for Companies Now Available
Following 15 months of research and consultation led by Shift and Mazars for the Human Rights Reporting and Assurance Frameworks Initiative (RAFI), the draft UN Guiding Principles Reporting Framework is now available for review and feedback leading up to its launch in 2015. The Framework is the first comprehensive guidance for companies to report on how they meet their responsibility to respect human rights in line with the United Nations Guiding Principles on Business and Human Rights. The draft framework is available here and its corresponding implementation guide is available here.
Unilever and Shift Collaboration
Unilever and Shift are pleased to announce a collaboration in support of the Human Rights Reporting and Assurance Frameworks Initiative (RAFI). Unilever will work with Shift to conduct the first pilot of the draft reporting framework in 2014-2015. This framework will inform how Unilever reports on its on-going efforts to implement the corporate responsibility to respect human rights. Unilever’s experience with the framework will, in turn, inform the framework’s further development, prior to its finalization at the end of 2015. The press release with further details on the collaboration is available here. For further coverage of the collaboration, see here.
Today, there are a growing number of regulatory and other requirements for companies to report on their human rights performance. Many of these cite the UN Guiding Principles as a key reference point for reporting. At the same time, more and more investors and other stakeholders are seeking transparency from companies on how they are implementing the UN Guiding Principles. Furthermore, companies are increasingly taking their own initiative to explore how they can better demonstrate their alignment with the Guiding Principles. The accelerating trend in requirements and requests for reporting on human rights is clear. Moreover, the beginnings of a similar dynamic can be seen with regard to assurance of human rights reports.
As these dynamics develop, the question arises as to what good reporting on company alignment with the UN Guiding Principles – and good assurance of such reports – should involve. RAFI aims to help answer this question.
The proposed reporting and assurance frameworks will be public, meaning that they will be non-proprietary and publicly available to all companies and assurance providers to use in their work. They are intended to be relevant to, and viable for, all companies and auditors/assurance providers in any region, and to dovetail with existing reporting initiatives.
3. Project Structure, Timeline and Process
The RAFI process is facilitated by Shift and Mazars in liaison with the Human Rights Resource Centre (the “project team”). Mazars is a global provider of audit, accountancy, tax, legal and advisory services. The Human Rights Resource Centre is a non-profit academic centre working on human rights issues in the Association of South East Asian Nations (“ASEAN”).
The project team will conduct research, liaise with all interested stakeholders, facilitate consultations, produce public reports from those consultations – including key issues and emerging ideas or proposals – and help advance the process of drafting the proposed frameworks.
A 2014-2015 tentative calendar for RAFI, which will be further driven by the needs of the consultative process, can be found here: 2014-2015 RAFI Calendar.
An outline of the project’s next steps for the first half of 2014, including consultation plans, are available here: RAFI Feb 2014 Next Steps Summary.
Note to stakeholders: Mazars Indonesia - with Mazars UK and US - was a founding member of the Reporting and Assurance Frameworks Initiative (RAFI), together with the non-profit business and human rights center, Shift. In May 2014, the Indonesia firm became independent of Mazars and now operates under the name Moores Rowland. Due to differences in its approach to business and human rights from those followed by RAFI, it will no longer participate in the initiative.
Eminent Persons Group
RAFI is overseen and steered by an Eminent Persons Group (“EPG”) which consists of leaders from a broad range of stakeholder backgrounds, globally and in ASEAN. The EPG provides strategic oversight of the project’s process and substance and advice on its overall direction. The 16 members of the EPG are:
1. Helen Brand, Chief Executive Officer of the Association of Chartered Certified Accountants
2. Marzuki Darusman, Executive Director of the Human Rights Resource Centre for ASEAN, UN Special Rapporteur on human rights in North Korea and former Attorney-General of Indonesia (Chair of EPG)
3. Rafendi Djamin, Indonesian Representative to the ASEAN Intergovernmental Commission on Human Rights
4. Paul Druckman, Chief Executive Officer of the International Integrated Reporting Committee
5. Teresa Fogelberg, Deputy Chief Executive at the Global Reporting Initiative
6. Filip Gregor, Lawyer at Frank Bold
7. Alexandra Guaqueta, Chair of the UN Working Group on Business and Human Rights
8. Peter Herbel, Former Senior Vice-President and General Counsel of Total
9. Adam Kanzer, Managing Director and General Counsel of Domini Social Investments
10. Makarim Wibisono, Executive Director of the ASEAN Foundation
11. Colin Melvin, Chief Executive Officer of Hermes Equity Ownership Services Ltd.
12. Roel Nieuwenkamp, Chair of the OECD Working Party on Responsible Business Conduct
13. Christopher Ng, Regional Secretary of UNI Apro
14. Gro Nystuen, Member of Ethical Council of The Government Pension Fund of Norway
15. John Ruggie, Chair of Shift’s Board and former Special Representative of the UN Secretary-General for Business and Human Rights
16. Thomas Thomas, Chief Executive Officer of the ASEAN CSR Network
The reports from the EPG meetings are available here:
UN Working Group on Business and Human Rights
The UN Working Group on Business and Human Rights has expressed its firm support for RAFI and is engaging with this project as part of its mandate to promote implementation of the Guiding Principles and as part of its strategy to collaborate with stakeholders to provide further clarification on the application of the Guiding Principles. See the UN Working Group’s statement on its support for the project for further information.
Global Reporting Initiative (GRI)
In December 2013, GRI and RAFI signed a Memorandum of Understanding to underline their mutual commitment to advancing meaningful corporate human rights reporting. Both GRI and RAFI believe that robust human rights reporting is a key means of advancing the integration of respect for human rights into business practices, as called for by the UN Guiding Principles. RAFI will seek, through an open and multi-stakeholder consultative process, to identify opportunities for the language of the reporting and assurance frameworks to dovetail to the greatest extent possible with the GRI Sustainability Reporting Guidelines.
The project team has welcomed the active engagement of many stakeholder groups and commentators in the project and is committed to wide, deep, and collaborative consultation with stakeholders from all relevant backgrounds to shape the project going forward.
Key consultation take-aways
The RAFI project team has just released the ‘take-aways from the RAFI consultations in January – July 2014.’
This document summarizes stakeholder inputs to the RAFI process from the latest series of consultations held between January and July 2014, and provides suggested next steps. This document draws upon discussions at a project workshop in New Delhi in March 2014, expert multi-stakeholder consultations in London and New York in April-May 2014, individual discussions with ASEAN expert stakeholders in June-July 2014, meetings of the Eminent Persons Group in March and June, and bilateral consultations and interviews with a variety of organisations and individuals throughout the first half of 2014. Collectively, these discussions involved over 120 individuals from business, civil society, governments as well as legal, assurance, academic and other expert backgrounds.
Fuller meeting and consultation reports as well as the documents discussed at the consultations are available in the Consultations section below.
All views and comments, whether on these take-aways, the documents discussed at the consultations, or on the initiative more broadly, are welcomed and can be sent to the RAFI project team via Anna Triponel at Shift (anna.triponel[at]shiftproject.org).
On 16 September 2014, Shift facilitated a half-day consultation as part of the 2014 African Regional Forum on Business and Human Rights held by the UN Working Group on Business and Human Rights in Addis Ababa, Ethiopia. The consultation was attended by 75 participants, primarily from civil society from across Africa, including from South Africa, Malawi, the Democratic Republic of Congo, Cameroon, Morocco, Guinea and Ethiopia. A few of the participants were from business, government and national human rights institutions.
The presentation for the consultation is available here.
In March, JSL Stainless Limited hosted a consultation on RAFI in New Delhi, India, organized in collaboration with the Centre for Responsible Business, and the RAFI project team. The meeting was attended by participants predominantly from the business sector, but with a number also from investment, government and civil society backgrounds.
From February to April 2014, the RAFI project team interviewed approx. 20 individuals from companies, investors and civil society organisations to discuss the types of questions and indicators that would elicit the kinds of information about a company’s human rights performance that it is meaningful for stakeholders to read, viable for companies to provide, and which support good human rights due diligence.
In April – May 2014, RAFI conducted its second round of expert consultations in London and New York to build on these interviews as well as the first round of expert consultations that took place in October – November 2013. These expert consultations involved a cross-section of representatives working in companies, non-governmental organizations, government, audit and assurance providers, investors, and academia. The primary focus of this expert consultation was the overall shape of, and approach to, the RAFI reporting framework, as well as some illustrative examples of the kinds of ‘smart questions’ that might form its content.
The background documents that were discussed at the second round of expert consultations are as follows:
Background documents (that are available here), were also circulated to the participants.
The RAFI project team welcomes all comments and feedback on these documents for consultation, which it will be revising in light of comments received. Meeting reports from this second round of expert consultations are available here:
RAFI held a number of expert consultations in October – November 2013 in London, New York and Jakarta as well as CSO consultations in Jakarta and multi-stakeholder workshops in Bangkok and Medellin. Through these meetings, the project team consulted with over 150 individuals from business, civil society, governments as well as legal, assurance, academic and other expert backgrounds. The team has also held a wide range of bilateral consultations with individuals and organizations since June 2013.
In February, RAFI published the project team’s key take-aways from these consultations, which will guide the project’s direction in 2014. They are available here: Take-aways from RAFI Consultations.
Full reports of the discussions that have taken place on RAFI can be found here:
- Bangkok multi-stakeholder workshop report, 22 Nov 2013
- Jakarta consultation report, 20 Nov 2013
- Jakarta CSO consultation report, 18 Nov 2013
- New York consultation report, 23 Oct 2013
- London consultation report, 17 Oct 2013
- Medellín Workshop Report, 30 Aug 2013
5. Background research
During consultations, participants asked to what extent current company disclosure covers key elements of the UN Guiding Principles. Shift undertook research to offer an initial response to this question. A short summary of findings was presented in the April/May 2014 consultations. The fuller report is now available here.
During consultations, the RAFI project team noted the widely differing ways in which the terms ‘assurance’ and ‘audit’ are used by different stakeholders from different fields of practice. Adam Carrel from EY, a participant in the RAFI New York 2013 consultation, kindly undertook to provide a white paper that could offer some background regarding these distinctions, including some perspectives on the relative strengths and weaknesses of current audit and assurance models and lessons that RAFI might draw from them. The opinions expressed represent his perspectives and not necessarily those of EY. The white paper is available here.
6. Further Resources
The RAFI Framing Document from November 2013:
- Recaps the rationale for the project;
- Summarizes the project’s vision and objectives;
- Positions the project in the wider context of other initiatives and developments; and
- Describes the processes envisaged for consultation and collaboration.
It is accessible here.
Discussion paper & stakeholder feedback:
In May 2013, the project team issued a discussion paper that recognized a range of challenges the project would have to tackle, with some ideas and questions on how they might be approached. It invited comments from all stakeholders during a two-month period, which was then extended for a further two months in light of the levels of interest.
Over thirty-five sets of comments were submitted in response, from individuals, organizations, and associations that collectively represent many thousands of members. The issues raised – both publicly and privately – provided the foundation for consultations going forward. See below for the comments submitted.
The project team issued a document responding to issues raised, accessible here updated as of October 2013, which summarises the themes emerging from those comments and provides some preliminary responses.
1. Accountability Counsel
2. Alan Fine
3. ASEAN Services Employees Trade Union Council (ASETUC)
4. Asia Pulp & Paper (APP) Indonesia
5. Association of Chartered Certified Accountants (ACCA)
7. Centre for Labour and Social Studies (CLASS), Nepal
8. CICS, part of Ceram Group
9. Claire White
10. CSR + D (European Network for Corporate Social Responsibility and Disability)
11. Deloitte Touche Tohmatsu Limited
12. DNV Business Assurance
13. Hermes Equity Ownership Services
14. Indonesian Center for Environmental Law
15. Indah Amaritasari
16. Institute for Human Rights and Business (IHRB)
17. International Corporate Accountability Roundtable (ICAR)
18. International Federation for Human Rights (FIDH)
19. International Organisation of Employers
21. International Trade Union Confederation (ITUC)
22. Professor Adrian Henriques, Middlesex University Business School
23. National Union of Bank Employees (NUBE)
24. Nicholas Rowe
25. RAISE Health Initiative for Workers, Companies, and Communities
26. TIGERS Success Series
27. TRaC Global
28. UNI Global Union Asia Pacific Regional Organization (UNI Apro)
7. Other News
For further information about Shift's participation in the project, please contact Anna Triponel: anna.triponel[at]shiftproject.org. For all materials relating to the project, including all public stakeholder comments received, please visit the RAFI portal, kindly hosted by the Business and Human Rights Resource Centre here.
Shift is pleased to be partnering on RAFI with: