From Ruggie to Resilience: How the UNGPs Shaped Investor Stewardship

Introduction: the governance gap and the Ruggie answer /

This essay is part of Shift’s series marking the 15th anniversary of the UN Guiding Principles on Business and Human Rights.

When John Ruggie began his tenure as UN Special Representative on Business and Human Rights in 2005, globalisation had outpaced the capacity of states to regulate cross-border corporate conduct, leaving permissive environments in which serious human rights harms could occur with impunity. 

The UN Guiding Principles on Business and Human Rights (UNGPs), unanimously endorsed by the Human Rights Council in June 2011, were his answer1. They provided the first authoritative global standard, organised around three pillars – the State duty to protect, the corporate responsibility to respect, and access to remedy – and gave the field a shared vocabulary that survives to this day.

From the perspective of a portfolio manager or investment analyst, the UNGPs mattered because they translated loosely defined “social” risk into a structured concept – human rights due diligence (HRDD) – that could be benchmarked, engaged on and increasingly priced into valuations. This article traces the framework’s evolution from soft-law convening text into the conceptual engine of mandatory disclosure and liability regimes worldwide. It argues that the UNGPs have hardened in law – but that hardening is being politically contested, in a de-globalising world, with material consequences for issuers and investors.

The Ruggie framework and what changed
in 2011 /

Pre-2011, the corporate human rights debate was deadlocked. The 2003 ‘UN Draft Norms’ had attempted a route to mandatory human rights obligations on companies, and failed2; the OECD Guidelines for Multinational Enterprises were voluntary, with weak enforcement through National Contact Points (NCPs) that had “slumped into disuse”3. Ruggie’s “principled pragmatism” reframed the problem. Pillar I of his proposed ‘Protect, Respect and Remedy’ framework – the foundation of the UNGPs – confirmed the State’s pre-existing duty under international human rights law. Pillar II articulated, for the first time, a corporate responsibility independent of State action – a social-licence expectation operationalised through HRDD: identifying, preventing, mitigating and accounting for impacts. Pillar III combined judicial and non-judicial remedy, including operational-level grievance mechanisms.

Crucially, the UNGPs introduced the analytical triad of “cause, contribute and directly linked” – three distinct tiers describing a company’s relationship to a human rights harm, each carrying its own remedial expectation. A company that causes harm must cease and remediate it; one that contributes must cease its contribution, remediate it and use leverage to mitigate any remaining impact; and one whose operations, products or services are directly linked to harm through a business relationship is expected to use its leverage to seek to influence the entity causing the harm, even where it has not contributed to the harm itself.

Although “directly linked” appears to be the most remote tier of involvement under the UNGP framework, it is the one that defines the financial sector’s exposure. A capital provider will rarely cause a human rights harm and infrequently contribute to one, but each is routinely linked to harm through the financing or commercial relationship that makes the harm possible.

Diffusion (2011–2017): from principles to practice /

The first wave of implementation of the UNGPs moved through three vectors.

First, the 2011 update of the OECD Guidelines incorporated a dedicated human rights chapter explicitly aligned with the UNGPs, the most consequential immediate adoption.4 The IFC Performance Standards5, ISO 260006 and Global Reporting Initiative (GRI) standards7 followed; National Action Plans (NAPs) proliferated, beginning with the United Kingdom in 20138.

Second, corporate uptake – albeit this was uneven. Early adopters such as Unilever9, Nestlé10 and Microsoft11 began publishing salient human rights issues reports; but adoption was slow in Southeast Asia and Sub-Saharan Africa where agribusiness and extractives industries dominate12. The UNGP Reporting Framework, supported by Federated Hermes and UK AID gave investors a comparable basis for engagement on UNGP disclosure13, and over 100 investee companies subsequently revised disclosures and practices in response.

Third – and most importantly for stewardship practice – OECD NCPs became the de-facto enforcement layer. NCP final statements adverse to a portfolio company acted as a strong stewardship signal. They are admissible evidence in subsequent civil litigation in some jurisdictions, are referenced by index providers and ESG ratings, and increasingly inform exclusion decisions by asset owners such as Norges Bank Investment Management (NBIM).

What is a National Contact Point (NCP)?

NCPs are state-based, non-judicial grievance offices established under the OECD Guidelines for Multinational Enterprises. Each of the 52 jurisdictions adhering to the Guidelines must host an NCP. Their role is twofold: to promote responsible business conduct, and to handle “specific instances” – complaints from any individual, NGO or trade union with a legitimate interest, alleging that a company operating in or from that jurisdiction has not observed the Guidelines.

NCPs cannot impose fines or compel parties to participate. They offer good offices, mediation and conciliation, and issue a public final statement that may include findings of non-observance and recommendations. Since the 2011 revision of the Guidelines incorporated the UNGPs in a new human rights chapter, the human rights due diligence (HRDD) standard is squarely within their remit, covering not only operating subsidiaries but also business relationships, lenders, investors and supply chains.

Two early cases set the tone. The UK NCP’s September 2009 final statement on Survival International v. Vedanta Resources found that the company had failed to engage the Dongria Kondh Indigenous community in adequate and timely consultations over the proposed Niyamgiri bauxite mine in Odisha and recommended that Vedanta integrate human and indigenous rights impact assessments into its project management14. The statement was widely credited with prompting divestment by the Church of England15 and reinforced existing exclusions by Norges Bank Investment Management (NBIM), which had already excluded Vedanta in 2007 on a separate Council on Ethics recommendation16 – an early demonstration that NCP findings could move capital even where they could not compel the company.

A decade later, in Lungowe v. Vedanta Resources [2019] UKSC 20, the UK Supreme Court held – at the jurisdictional stage – that Zambian villagers harmed by discharges from a different Vedanta subsidiary, Konkola Copper Mines, had an arguable claim that the UK-listed parent owed them a direct duty of care. Although the case settled in 2021 without admission of liability, Lungowe established that group-wide policies and public sustainability commitments could give rise to such a duty17 – converting a UNGP-style narrative about parent oversight into a concrete litigation risk.

POSCO International and Papuan palm oil: a defining test case /

No single case better illustrates the post-Ruggie NCP system than the complaint against POSCO International. In December 2019, KTNC Watch (Korea), Yayasan Pusaka, WALHI Papua and SKP-KAMe (Indonesia) filed a specific instance with the Korean NCP, supported by Mighty Earth’s campaigning research18.

The complaint targeted three respondents: POSCO International as the controlling owner of PT Bio Inti Agrindo (PT BIA); the Korean National Pension Service (NPS) as institutional shareholder; and the Export-Import Bank of Korea (KEXIM) as lender. PT BIA had cleared roughly 27,000 hectares of rainforest in Merauke, Papua, allegedly without Free, Prior and Informed Consent (FPIC) of customary landowners and with downstream pollution of the Bian River19.

The case was novel for two reasons. First, the Korean NCP accepted KEXIM as a multinational enterprise within the scope of the OECD Guidelines, only the second time globally that an export credit agency had been so treated20. This extended the reach of HRDD expectations to public-sector financiers.

Second, the campaign produced a tangible policy outcome: in March 2020, POSCO International adopted a group-wide No Deforestation, No Peat, No Exploitation (NDPE) policy and pledged remediation, an engagement-driven shift faster than any that litigation could have delivered.

The Korean NCP’s January 2022 final statement, however, closed the case without securing on-the-ground remedy and was criticised by complainants for endorsing POSCO’s NDPE adoption and Roundtable on Sustainable Palm Oil (RSPO) certification as “best practice” without ground-truthing21.

Three lessons crystallise for portfolio managers. Equity and debt investors are now squarely “directly linked” to harm under UNGPs logic, with reputational and increasingly legal consequences. NCP outcomes can shift corporate policy faster than courts but rarely deliver remedy to rights-holders – they are signalling devices, not enforcement bodies. And certification labels such as RSPO or Forest Stewardship Council (FSC) are weak proxies for HRDD, a point reinforced by Mighty Earth’s parallel Korindo case at the FSC.22

The hardening phase (2017–2024): UNGP norms become law /

The decisive shift after 2017 was the conversion of Pillar II into mandatory HRDD statutes.

France’s Loi de Vigilance (2017) pioneered statutory corporate due diligence backed by a civil liability mechanism. A wave of national regimes followed: the Netherlands’ Child Labour Due Diligence Act (adopted in 2019), Germany’s Lieferkettensorgfaltspflichtengesetz (in force 2023, with administrative penalties), the Norwegian Transparency Act (in force July 2022) and Switzerland’s parliamentary counter-proposal (in force 2022, after the Responsible Business Initiative passed the popular vote but failed the cantonal majority in November 2020)23.

The capstone was the EU Corporate Sustainability Due Diligence Directive (CSDDD), adopted in May 2024 and explicitly anchored in the UNGPs and OECD Guidelines. The UN Working Group on Business and Human Rights, in its UNGPs 10+ Roadmap (November 2021), endorsed mandatory HRDD as part of the “smart mix” of measures Ruggie originally envisaged in the UNGPs themselves (Principle 3)24.

For investors, three related developments were important in connecting the CSDDD to their role and interests. The Corporate Sustainability Reporting Directive (CSRD – the EU framework for sustainability disclosure) elevated human rights data from voluntary frameworks (GRI, SASB) to mandatory, audit-grade disclosure across issuers. The Sustainable Finance Disclosure Regulation (SFDR – the EU disclosure regime for asset managers) embedded UN Global Compact and OECD Guidelines violations directly in its mandatory Principal Adverse Impact (PAI) indicators – though the November 2025 SFDR 2.0 proposal would scale entity-level PAI reporting back to product-level only. And the Shareholder Rights Directive II (SRD II – the EU framework on stewardship and engagement) provided procedural rails for asset managers to vote and engage on these issues.

The pushback (2024–2026): resilience despite deregulation /

In early 2025, the European Commission began a process of Omnibus revision packages tackling different EU laws with the stated objective of reducing the regulatory burden on EU business. The first Omnibus reopened the recently agreed CSDDD and the CSRD and led to a year of intense negotiations. The final Omnibus I package25, adopted in February 2026 and in force from 18 March 2026, has substantially scaled back the scope of companies covered by the CSDDD. The Directive now applies to firms with over 5,000 employees and €1.5 billion turnover, materially narrowing the scope from over 6,000 companies to 1,300; the EU-wide harmonised civil liability regime has been deleted (meaning that liability reverts to national law); mandatory Paris-aligned climate transition plans have been removed.

Fortunately, sustained civil society and investor campaigns alongside continued advocacy from supportive business voices preserved the risk-based model of human rights due diligence in line with the UNGPs and OECD Guidelines. This is the conceptual core Ruggie articulated in 201126.

On the one hand, with the in-scope universe of the CSDDD cut by 80%, and implementation deferred to financial year 2029, the CSDDD’s capacity to function as a hard-law floor for issuer behaviour is now much more limited than the 2024 text envisaged. On the other hand, the implications for investors are more nuanced than the headlines suggest.

For hundreds of companies, reputational, operational and litigation risk are now reinforced by legal harmonisation around the concept of risk-based due diligence itself. The implications of the legislation will flow through supply chains within and beyond the EU, so the limited number of companies directly in scope does not prevent the law from shaping practices in a much broader set of connected counterparties. Meanwhile, legislative initiatives in Switzerland, Malaysia, Indonesia and Thailand that had been waiting on the resolution of the Omnibus process are now reinforcing convergence around the same UNGP/OECD expectations.

UNGP-grade HRDD is therefore now the minimum expected practice based on a mix of law and other factors. Issuers that look to tick-box rather than meaningful compliance will find themselves exposed to scrutiny from national enforcement bodies in addition to civil society and asset owners.

Conclusion: from Ruggie’s vision to enduring investor expectations

Three observations follow from the journey initially embarked on by John Ruggie.

First, the conceptual durability of the UNGPs is striking. Even as the perimeter of EU legislation has narrowed, no competing framework has emerged. The vocabulary of salience, leverage, cause and contribution, FPIC, and access to remedy is now embedded in stewardship codes, ESG ratings, IFC standards and the training of investment analysts. And although the CSDDD’s in-scope perimeter has narrowed, the perimeter of investor expectations has not : stewardship policies, exclusion frameworks and SFDR PAI indicators apply UNGP-grounded standards across the full investee universe, regardless of whether the issuer falls within the Directive’s revised thresholds.

Second, mechanism limits are now widely understood. NCPs, as the POSCO Papua case demonstrated, are uneven and rarely deliver remedy. They function best as escalation signals feeding investor engagement and litigation strategies, not as standalone remedy channels.

Third, the test of the next decade is whether the move of HRDD into hard law brings substantive results, driving real prevention and remedy, or collapses into tick-box compliance.

Ruggie himself maintained that the Principles were not focused on creating new international law obligations, but were intended to elaborate the implications of existing standards into a coherent template. The hardening of that template is the story of the past 15 years. For investors, the signal worth watching is whether issuers routinely demonstrate evidence of using their leverage to mitigate and remediate identified harms. This is the expectation set by Ruggie, and the unfinished work of the next decade.

* Dr. Christine Chow has 25+ years’ experience in investment management focused on technology, governance and sustainability. She was Managing Director at UBS Asset Management, leading global stewardship, thematic research and impact engagement, and previously global Head of Stewardship at HSBC Asset Management and a board member of HSBC Asset Management UK Limited, and Head of Asia and global technology at Federated Hermes EOS. From 2019 to 2025 she served as Board member and Chairman of the International Corporate Governance Network (ICGN), an investor-led body representing around US$100 trillion in assets across over 40 countries. Her PhD thesis on responsible investment was short-listed for a United Nations award in Sweden for industry relevance and academic excellence.

1 UN Human Rights Council, Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework, UN Doc. A/HRC/17/31 (21 March 2011), endorsed by HRC Resolution 17/4 (16 June 2011). Source: https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf

2 Miretski & Bachman (2011) Global Business and Human Rights – The UN ‘Norms on the Responsibility of Transnational Corporations and Other Business Enterprises with Regard to Human Rights’ – A Requiem Deakin Law Review, Vol. 17, No. 1, 2012. Most states expressed strong reservations, emphasising their determination not to depart from the traditional framework of international law, which stresses the central and pivotal role of the state as a legal subject of public international law. The Norms were eventually abandoned in 2005

3 https://johnruggie.scholars.harvard.edu/sites/g/files/omnuum3761/files/john-ruggie/files/ruggie_tamarynnelson.pdf. P. 2.

4 OECD, OECD Guidelines for Multinational Enterprises (2011 edition introducing a dedicated human rights chapter; updated 2023).

5 The 2012 edition explicitly recognises that in high-risk circumstances, clients may need to complement their existing environmental and social due diligence (ESDD) processes with specific Human Rights Due Diligence (HRDD)

6 ISO 26000 positions due diligence as a continuous process rather than a one-time check, requiring organisations to assess their impacts on society and the environment.

7 https://www.globalreporting.org/media/rcqpsy01/gri-due-diligence-guide-final.pdf. The 2021 updates to the GRI Standards give full effect to the due diligence process as articulated in the OECD MNE Guidelines and the UNGPs.

8 https://globalnaps.org/country/united-kingdom/

9 https://www.unilever.com/sustainability/respect-human-rights/our-salient-human-rights-issues/. Began in 2015.

10 https://www.nestle.com/sustainability/human-rights/approach. Began in 2009.

11 https://blogs.microsoft.com/on-the-issues/2016/12/09/expanding-partnerships-transparency-human-rights/. Began in 2016.

12 https://melbourneasiareview.edu.au/obstacles-to-implementing-the-un-guiding-principles-on-business-and-human-rights-in-southeast-asia/?print=pdf#:~:text=Indonesia%2C%20Malaysia%20and%20Thailand—members,with%20significant%20human%20rights%20risks.

13 https://www.ungpreporting.org/about-us/

14 https://www.minesandcommunities.org/article.php?a=9543#:~:text=The%20UK%20NCP%20concludes%20that%20Vedanta%20has%20not%20complied%20with,67. UK National Contact Point, Final Statement by the UK NCP: Survival International and Vedanta Resources plc (25 September 2009); follow-up statement, 12 March 2010

15 https://www.responsible-investor.com/church-of-england-funds-sell-millions-in-vedanta-shares-in-boycott/

16 https://www.banktrack.org/download/briefing_on_vedanta_and_the_niyamgiri_hills/vedanta.pdf

17 Lungowe v. Vedanta Resources plc [2019] UKSC 20. https://www.supremecourt.uk/cases/uksc-2017-0185

18 https://www.oecdwatch.org/complaint/ktnc-watch-et-al-vs-national-pension-service/

19 KTNC Watch, Yayasan Pusaka, WALHI Papua and SKP-KAMe, Specific Instance against POSCO International, the National Pension Service and the Export-Import Bank of Korea, filed with the Korean NCP, 12 December 2019.

20 OECD Watch, “Korean NCP accepts complaint against Korean export credit agency and others” (17 March 2020). KEXIM was deemed within the OECD Guidelines’ definition of a multinational enterprise – only the second NCP determination of its kind globally.

21 https://hrn.or.jp/wpHN/wp-content/uploads/2024/11/East-Asia-Report-final.pdf. POSCO International, “No Deforestation, No Peat, No Exploitation Policy” (1 March 2020); Mongabay, “South Korea’s POSCO vows zero deforestation in Papua palm oil operation” (5 March 2020). Korean Ministry of Trade, Industry and Energy / Korean NCP, Final Statement on POSCO International (18 January 2022).

22 https://fsc.org/sites/default/files/2019-11/Korindo%20Group_Additional%20Social%20Analysis%20by%20FSC%20International.pdf. Mighty Earth, Burning Paradise: Palm Oil in the Land of the Tree Kangaroo (September 2016); and Mighty Earth, “Two-Year Investigation Finds Major Palm Oil Producer Korindo Guilty of Rainforest Destruction and Human Rights Abuses” (October 2021).

23 Each has since faced significant setbacks: the Dutch Act never entered into force and is set to be revoked; Germany’s LkSG reporting obligation and most fine proceedings were scrapped in September 2025 ahead of CSDDD transposition; Switzerland’s counter-proposal has been widely criticised as ineffective, triggering a second Responsible Business Initiative in May 2025; and only Norway has produced an enforcement action – a c. €38,500 fine on retailer Varner in September 2024, under appeal. None of the four creates civil liability. France therefore remains the only regime where a private claimant can take a listed company to court and seek a remedy. Loi n° 2017-399 du 27 mars 2017 (France); Lieferkettensorgfaltspflichtengesetz (Germany, in force 1 January 2023); Norwegian Åpenhetsloven (Transparency Act, in force 1 July 2022); Swiss Code of Obligations Articles 964a–c (in force 2022).

24 Directive (EU) 2024/1760 on Corporate Sustainability Due Diligence (5 July 2024). UN Working Group on Business and Human Rights, UNGPs 10+: A Roadmap for the Next Decade of Business and Human Rights (November 2021).

25 The EU Omnibus I package (Directive (EU) 2026/470, in force 18 March 2026) is a “simplification” directive for revisions to CSDDD and CSRD put forward by the European Commission. https://finance.ec.europa.eu/publications/omnibus-i-package-commission-simplifies-rules-sustainability-and-eu-investments-delivering-over-eu6_en

26 https://www.iigcc.org/media-centre/weakening-eus-sustainability-rules-risks-damaging-competitiveness-and-growth-warn-companies-investors

Dr. Christine Chow /

Board Member

She/Her

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Dr. Christine Chow has more than 25 years’ experience in investment management spanning sustainable investment, corporate governance, technology and AI.

She has held senior leadership roles at UBS Asset Management, HSBC Asset Management and Federated Hermes, where she led global stewardship, thematic research, responsible investment and engagement with companies on sustainability and governance issues. She was the human rights engagement lead at Federated Hermes, where she pioneered its approach to global value chain engagement with electronics companies, and advocated for provenance and traceability of critical minerals.

Christine served as Managing Director at UBS Asset Management, leading on global stewardship, thematic research and impact engagement. Previously, she was Global Head of Stewardship and a board member of HSBC Asset Management UK Limited, and Head of Asia and Global Technology at Federated Hermes EOS. From 2019 to 2025, she served as a board member and then Chair of the International Corporate Governance Network (ICGN), a global investor-led organisation representing around US$100 trillion in assets under management across more than 40 countries.

Christine is recognised internationally for her work on responsible investment, AI governance and corporate stewardship. She has published influential work on responsible AI and data governance and was a member of the UK Parliament’s All-Party Parliamentary Group on Artificial Intelligence, serving on its Data Governance Task Force. She is the Appointed Advisor of AFRC in Hong Kong, the independent regulator of the accounting profession, and Emeritus Governor of the London School of Economics. Her PhD research on responsible investment was shortlisted for a United Nations award recognising industry relevance and academic excellence.

David Vermijs /

Director

He/Him Amsterdam

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As Director, David engages with business partners to better identify, prioritize and act on salient human rights issues, embedding the UN Guiding Principles in companies’ decision-making processes.

Specializes in Business Enterprises

As Director, David engages with business partners to better identify, prioritize and act on salient human rights issues, embedding the UN Guiding Principles in companies’ decision-making processes.

David has over a decade of experience advising multinational corporations, governments, NGOs and others on business and human rights. Prior to joining Shift, David provided research assistance to the Special Representative of the UN Secretary-General for business and human rights John Ruggie. As part of his contributions, David field-tested human rights due diligence with a group of Dutch companies and their stakeholders, and he supported research on company-led grievance mechanisms.

From 2008 to 2010, David was the lead consultant on an 18-month project, the Business and Human Rights Initiative, under the umbrella of the Global Compact Network Netherlands. The initiative was a collaboration between 10 Dutch multinationals – ABN AMRO, AkzoNobel, Essent, KLM, Philips, Rabobank, Randstad, Shell, TNT and Unilever – and led to the publication of a ground-breaking business guidance tool, How to Do Business with Respect for Human Rights, in 2010. Through his work at Shift, David led the update of this publication from 2014 to 2016 with the support of the Dutch government under their National Action Plan on implementing the Guiding Principles.

Another major guidance tool David has helped develop addresses due diligence on child labor, published by the International Labour Organization (ILO) and the International Organisation of Employers (IOE) in 2015. The guidance was the result of a multi-year, multi-stakeholder, multi-country project led by David involving the ILO, IOE, companies, unions, NGOs and other stakeholders.

David was previously a Research Fellow at the Corporate Responsibility Initiative at the Harvard Kennedy School, including assisting in teaching on business and human rights, global governance, corporate governance and leadership. David sits in a personal capacity on the board of the Dutch Social and Economic Council International Corporate Social Responsibility Committee. He has a Masters in Public Policy from the Harvard Kennedy School and a Bachelor of Arts in Business from Radboud University Nijmegen in the Netherlands. David is a Dutch national, speaks English and Dutch and is proficient in Spanish and German.

Anna Triponel /

Senior Associate

She/Her London

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As a Senior Associate with Shift, Anna advises companies, lawyers, investors and business associations on how to put the Guiding Principles into practice.

As a Senior Associate with Shift, Anna advises companies, investors and business associations on how to put the Guiding Principles into practice. Trained as a lawyer, Anna focuses particularly on working with legal professionals on their role in implementing the Guiding Principles and has led work on analyzing regulations in various jurisdictions and how they align to the Guiding Principles. She also has particular expertise on the UN Guiding Principles Reporting Framework. 

Prior to joining Shift, Anna provided input to the work of the Special Representative of the UN Secretary-General for business and human rights John Ruggie as a legal consultant. During this period, Anna also opened the New York office of the Public International Law & Policy Group, where she advised government officials, opposition leaders, human rights victims and civil society organizations on human rights, constitutional reform and transitional justice in Burma, Côte d’Ivoire, Egypt, Kenya, Libya, Somaliland, Tunisia, Uganda and Zimbabwe.

Anna was previously a mergers and acquisitions associate at the law firm of Jones Day in New York, where she advised a broad range of multinational companies on cross-border mergers and acquisitions, joint venture, private equity and venture capital transactions. She founded and led the law firm’s International Law Pro Bono Group. She began her career as an advisor to the World Bank, advising on development governance structures to better meet the Millennium Development Goal of achieving universal primary education.

Anna is a (non-practicing) lawyer qualified in New York, England & Wales and France. She is a frequent expert speaker and writer on business and human rights and is the recipient of various professional awards, including the Empire State Counsel Award for changing the lives of those unable to afford counsel and the Seymour-Reuben Award for shaping international law. Anna has a Masters in International Law from American University Washington College of Law and a degree in common and civil law from the University of Paris X. She has been awarded the Business Sustainability Management certificate from the Cambridge Institute for Sustainability Leadership (CISL) and the MBA Essentials certificate from London School of Economics (LSE). Anna is a British and French national and speaks English and French.

Martyn Platt /

Head of Human Resources

He/Him

As Head of Human Resources, Martyn leads Shift’s global people strategy and oversees all aspects of HR across the organization.

As Head of Human Resources, Martyn leads Shift’s global people strategy and oversees all aspects of HR across the organization. He ensures that Shift’s systems, policies and practices foster a thriving, inclusive and values-driven culture that supports our mission to embed respect for people’s dignity at the core of business practice.

Martyn brings over a decade of HR leadership experience across mission-driven and international organizations working at the intersection of business and society. Prior to joining Shift, he was Director of People Development & Culture at the PRI and earlier worked with Business in the Community. In these roles, he developed and embedded HR business partnering models, guided the organizations through significant growth and transformation, and partnered with senior leaders to design and implement people strategies that supported the delivery of their mission. Most recently, he served as a consultant with the WeProtect Global Alliance, where he supported the establishment of their HR function.

He is a Chartered Member of the CIPD and holds a Level 7 Diploma in Human Resource Management, as well as an ILM Level 7 Certificate in Executive Coaching and Mentoring, reflecting his strong focus on leadership development and coaching. Martyn studied German and International Relations at the University of Exeter, including a year at the University of Würzburg in Germany. He later worked on education projects in Nicaragua, strengthening his global outlook and commitment to people-centred change.

Martyn is based in the United Kingdom.

Brianna Peterson /

Senior Advisor

She/Her Rome

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As a Senior Advisor at Shift, Brianna advises financial institutions and companies on how to put the UNGPs into practice, with a particular focus on the nexus between human rights and climate change.

Specializes in Financial Institutions

As a Senior Advisor at Shift, Brianna advises financial institutions and companies on how to put the UNGPs into practice, with a particular focus on the nexus between human rights and climate change. Brianna combines environment and climate change expertise with experience developing and implementing human rights policies, due diligence approaches and sustainability reporting.

Before Shift, Brianna spearheaded innovative sustainability initiatives at Sustainable Development Technology Canada and Export Development Canada (EDC). At EDC she led the development and implementation of exciting new portfolio approaches for climate change and human rights risk management, as well as aligning EDC’s corporate reporting with international reporting frameworks, such as the Task Force on Climate-related Financial Disclosures and the UNGPs Reporting Framework.  She also led EDC’s international sustainability negotiations and engagements, including as co-Chair of the Equator Principles Climate Change Working Group.

Prior to joining EDC, Brianna worked for nine years as a diplomat with Canada’s foreign ministry, including four years at the United Nations General Assembly where she led environment and development negotiations, advocacy and outreach on behalf of the Government of Canada, including for the creation of the UN Sustainable Development Goals.

Brianna has also advised international financial institutions including the World Bank Group, institutional investors, bilateral development agencies, and small- and medium-sized enterprises on the practical application of environment, climate change, human rights standards.

Brianna has an undergraduate degree in Chemical Engineering from Queen’s University and a Master’s degree in Environmental Change & Management from the University of Oxford.

Ashleigh Owens /

Director | Financial Institutions Lead

She/Her New York City

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As Shift’s Director / Financial Institutions Lead, Ashleigh leads our work with financial institutions and supports other partners across industries, leveraging her breadth of experience to tackle cutting-edge issues and entrenched challenges on the road to implementation of the UN Guiding Principles.

Specializes in Financial Institutions | Valuing Respect

As Director / Financial Institutions Lead, Ashleigh engages directly with financial institutions, companies and investors as they embed respect for human rights into their operations and business relationships. She also leads on pieces of research under our Valuing Respect Project, which is focused on developing better ways to evaluate business respect for human rights. Ashleigh has a breadth of experience approaching the Guiding Principles from business, legal and academic perspectives and brings a holistic view to Guiding Principles implementation.

Ashleigh was previously Executive Director at Ernst & Young’s Climate Change and Sustainability Services. At EY Japan, she led a team of consultants supporting policy-making, educational program and governance design, stakeholder dialogue and due diligence strategies for multinational and domestic companies across a variety of industries.  As founder of the EY Human Rights Network, she led the enhancement of EY’s human rights capabilities across EY’s global network. In her role she was a frequent speaker and moderator of dialogues at multi-stakeholder fora and functioned as a connector between civil society, government and corporate actors with a common goal of empowering business to respect rights.

From 2012 to 2014 she conducted research at the United Nations University in the field of Sustainability Science, specializing in business and human rights. She prepared research for the UN Working Group on Business and Human Rights and spent time at the UN Global Compact New York and the Office of the High Commissioner for Human Rights. Ashleigh later sat on the UN Global Compact’s Human Rights and Labour Working Group and drafted the Global Compact’s 2015 Guide on How to Develop a Human Rights Policy.

Ashleigh is a lawyer qualified in Australia and England & Wales and specialized in intellectual property law, labor law and public international law. She has advised governments and companies on state human rights obligations, companies on the nexus between bilateral investment treaties and human rights and fellow lawyers on integrating the Guiding Principles into legal advice. In 2007 she won the Intellectual Property Society of Australia & NZ prize.

Ashleigh has authored or contributed to a number of publications including: Business and Human Rights: Corporate Japan Rises to the Challenge (joint publication between EY Japan and Global Compact Network Japan), Corporate Social Responsibility Can Save Japan (Op-ed in Japan Times), Cumulative Human Rights Impacts (in UN Global Compact/ Maplecroft Business Dilemmas Forum) as well as several legal publications on intellectual property law in Australia and English translations of Japanese High Court judgments. She is also a member of the Advisory Board for the United Nations Institute for Training and Research (UNITAR)’s Division for Prosperity.

Ashleigh has degrees in Law and Asian Studies from the University of Western Australia, with studies also conducted at the University of Vienna and Sophia University in Japan. She has a Masters of Science in Sustainability from the United Nations University and has undertaken the institution’s Leadership for Sustainability program. Ashleigh is an Australian national, and is fluent in Japanese.

Rachel Davis /

Vice President and Co-Founder

She/Her Sydney

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As the Vice President and Co-Founder of Shift, Rachel helps shape our strategy and oversees a range of our collaborations with companies, governments, investors, civil society and other partners. Rachel is also responsible for driving our work on standards advocacy and with sports associations.

Specializes in Standard Setters | Sports and Human Rights

Rachel is one of Shift’s co-founders and has led work at Shift over the last decade on standard-setting, human rights and sports, financial institutions, conflict and international law.

As Vice President, Rachel shapes our strategy and oversees a range of our collaborations with companies, governments, investors, civil society and other partners. Rachel leads Shift’s work to influence standard-setters of all kinds to integrate the UN Guiding Principles into the rules that govern business, including engaging with governments and the European Union on mandatory human rights due diligence.

Rachel also has unique experience advising and leading efforts to drive respect for human rights into the operations of global sports governing bodies. Rachel was the Chair of FIFA’s independent Human Rights Advisory Board while it operated, between 2017 and 2021. She has advised the International Olympic Committee on human rights since 2018, including co-authoring recommendations for the IOC on a comprehensive human rights strategy with former UN High Commissioner for Human Rights, Zeid Ra’ad Al-Hussein.

Rachel has more than a decade of experience in implementing the Guiding Principles with a wide range of organizations, including public and private financial institutions and companies from diverse business sectors and geographies, and she frequently leads and facilitates engagements with senior audiences around the world. She is the co-author of the leading study of the costs of company-community conflict in the extractive sector.

Prior to co-founding Shift, Rachel was a senior legal advisor from 2006-2011 to the Special Representative of the UN Secretary-General on business and human rights, Harvard Professor John Ruggie. She played a pivotal role in the development of the Guiding Principles, advising on all aspects of the relationship between the Guiding Principles and national and international law.

Rachel is also a Senior Program Fellow with the Corporate Responsibility Initiative at Harvard Kennedy School and has experience at the highest levels of the Australian legal system and internationally, having clerked at the High Court of Australia and at the UN International Criminal Tribunal for the former Yugoslavia in The Hague. She has a particular interest in Indigenous peoples’ rights, having advised the Australian Federal Attorney-General’s Department on Indigenous affairs and acted as Ruggie’s liaison with the UN Permanent Forum on Indigenous Issues during his UN mandate.

Rachel has a Master of Laws degree from Harvard Law School and Bachelors degrees in Law and Politics from the University of New South Wales in Sydney, where she also lectured and published in law. She is a (non-practicing) lawyer qualified in New South Wales.

Federico Burlon /

Director

He/Him London

As Director at Shift, Federico engages with business partners to better identify, prioritize and act on salient human rights issues, embedding the UN Guiding Principles in companies’ decision-making processes.

Specializes in Business Enterprises

As Director at Shift, Federico engages with business partners to better identify, prioritize and act on salient human rights issues, embedding the UN Guiding Principles in companies’ decision-making processes.

Prior to joining Shift, Federico was Head of Delivery at Impactt. Federico managed a portfolio of clients, supported by a team of consultants. He led human rights assessment and remediation projects in the construction, energy, food and shipbuilding industries. This resulted in positive outcomes such as the return of passports and reimbursement of recruitment fees to workers and the strengthening of companies’ employment practices. Federico led Impactt’s engagement with the Supreme Committee for Delivery & Legacy in Qatar as external monitor of worker welfare in the construction of venues for the 2022 FIFA World Cup. He also developed Impactt’s Diagnostics community of practice, delivering for clients as well as building internal capacity to execute human rights assessments around the world, with a focus on worker voice.

Prior to Impactt, Federico was a Sustainability Manager at Tesco plc. He contributed to the roll out of Tesco’s ethical trading programme to the goods-not-for-resale value chain. Federico engaged with hundreds of product and services suppliers and internal purchasing and sourcing teams to raise awareness of human rights issues and to prioritise and address the findings from third-party social audits. He also worked on climate change to develop a roadmap to achieve Tesco’s carbon reduction commitments related to direct and supply chain emissions.

In prior roles, Federico worked with a variety of human rights organisations in the United Kingdom and United States.

Federico holds a MSc in Human Rights from the London School of Economics and a BA in Political Science and International Studies from Macalester College, with a focus on human rights law and international migration. He is a United World College Adriatic alumnus and is from Argentina.

Erika George /

Board Member

She/Her

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Erika George is Director of the Tanner Humanities Center and Samuel D. Thurman Professor of Law at the University of Utah. She has conducted leading research and is a passionate advocate for women’s rights, children’s rights, gender equality and environmental justice. 

Professor Erika R. George is the Associate Dean for Equity, Justice, & Engagement, Professor of Law, and Ernest Haddad Faculty Scholar at Boston University School of Law and a leading expert in business and human rights.

Professor George is the author of “Incorporating Rights: Strategies to Advance Corporate Accountability” (Oxford University Press, 2021), which examines the evolution of demands for corporate responsibility to respect international human rights. She was a founding member of the editorial board of the Business and Human Rights Journal (Cambridge University Press) and since 2022  has served on the board of Shift. 

Before joining BU Law in 2024, Professor George spent over two decades at the University of Utah as the Samuel D. Thurman Professor of Law. She directed the Tanner Humanities Center for four years and worked to enhance engagement and expand and diversify audiences for public humanities programs during her tenure. She also advocated for academic freedom and the right to read. Along with the former poet laureate of Utah, she co-founded the PEN America Utah Chapter to protect access to information and prevent censorship. 

Professor George is an elected member of the American Law Institute, an American Bar Foundation fellow, a trustee of Earthjustice, and serves on the Executive Board of the American Bar Association Center for Human Rights.

She is the recipient of numerous awards including the Society of American Law Teachers’ M. Shanara Gilbert Human Rights Award and the Salt Lake City Human Rights Commission Human Rights Award.

Professor George earned her BA with honors from the University of Chicago, a MA in International Relations from the University of Chicago, and a JD from Harvard Law School. She also clerked for Judge William T. Hart of the United States District Court for the Northern District of Illinois. She was a litigation associate at the law firm of Jenner & Block in Chicago before joining Human Rights Watch as a research fellow.

We recorded an interview with Professor George when she joined Shift’s Board in February of 2022. It is available here.

Erika George is Director of the Tanner Humanities Center and Samuel D. Thurman Professor of Law at the University of Utah. Prior to joining the University of Utah, Professor George served as a law clerk and litigation associate at prominent firms in both Illinois and New York. She also worked as a fellow and later consultant at Human Rights Watch, where she conducted investigations in South Africa on women’s rights, children’s rights, violence, the right to education and abuses related to the HIV/AIDS epidemic. She wrote a book-length report, Scared at School: Sexual Violence Against Girls in South African Schools, which received widespread media coverage in South Africa and internationally. She currently serves as special counsel to the Women’s Rights Division of Human Rights Watch.

Her scholarship has appeared in the California Law Review, the Michigan Journal of International Law, the New York University Journal of International Law and Policy, and the annual proceedings of the American Society of International Law.

Professor George has served on the Executive Committee of the U.S. Department of State Public-Private Partnership for Justice Reform in Afghanistan and as a member of the board of the American Civil Liberties Union of Utah. She is an Editor for the blog globaljusticeblog.com.

We recorded an interview with Professor George when she joined Shift’s Board in February of 2022. It is available here.

John Ruggie /

Founding Chair / In Memoriam

John Ruggie is the author of the UN Guiding Principles on Business and Human Rights.

In Memory of John Ruggie

John served as the founding Chair of Shift from 2011 to 2021. He was the Berthold Beitz Research Professor in Human Rights and International Affairs at Harvard’s Kennedy School of Government. He also taught at the Berkeley and San Diego campuses of the University of California, and at Columbia University where he became Dean of the School of International and Public Affairs. From 1997-2001 John served as UN Assistant Secretary-General for Strategic Planning in the cabinet of Kofi Annan; from 2002-2005 as Special Advisor to the Secretary-General for the Global Compact; and from 2005-2011 as Special Representative of the Secretary-General for Business and Human Rights.

A Fellow of the American Academy of Arts & Sciences, he received numerous awards from academic and professional societies for his contributions to social science, public policy and the development of international law. In addition to serving as Shift’s Board Chairman, John was also on the Board of Arabesque Asset Management Holding Company as well as Unilever’s Sustainability Advisory Council. His book, Just Business: Multinational Corporations and Human Rights, has been translated into Chinese, Japanese, Korean, Portuguese and Spanish.

Caroline Rees /

President and Co-Founder

She/Her New York City

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As Shift’s President, Caroline leads our strategic development and drives our thought leadership work on key challenges and opportunities in advancing corporate respect for business and human rights.

As the President and Co-Founder of Shift, Caroline leads our organizational strategy and development and drives our thought leadership work on key challenges and opportunities in advancing corporate respect for business and human rights. Caroline speaks extensively at events around the world and frequently facilitates dialogue and debate amongst companies, governments, investors and civil society. In recent years, Caroline has focused on improving corporate human rights reporting as a catalyst for better human rights risk management, and on improving the data and methods used in evaluating companies’ social performance as part of ESG (environmental, social and governance) analysis. She has written and spoken extensively on the relevance of business respect for human rights, and the UNGPs specifically, to movements that seek to advance sustainability, equality, ESG investing, stakeholder capitalism, and human and social capital.

Caroline previously spent 14 years with the British Foreign and Commonwealth Office. From 2003 to 2006 she led the UK’s human rights negotiating team at the UN and she ran the negotiations to establish the mandate of the Special Representative of the UN Secretary-General on business and human rights. The success of this initiative led to Professor John Ruggie’s appointment and from 2007-2011 Caroline was a lead advisor on his team and deeply involved in the drafting of the Guiding Principles.

From 2009 to 2011 Caroline was also the Director of the Governance and Accountability Program at the Corporate Social Responsibility Initiative at Harvard Kennedy School and she remains a Senior Program Fellow there. Caroline is a member of the Imperatives Board of the World Business Council for Sustainable Development, the Board of the Capitals Coalition, the Unilever Sustainability Advisory Council, and the Steering Committee of the Taskforce on Inequality and Social-related Financial Disclosures.

Caroline’s prior British foreign service career covered Iran, Slovakia, the UN Security Council in New York and the European Union in Brussels. Caroline has a Bachelor of Arts (Hons) from Oxford University and a Master of Arts in Law and Diplomacy from the Fletcher School of Law and Diplomacy at Tufts University. Caroline is a British national and speaks English, French and German.