Red Flag 23. Markets where regulations fall below human rights standards

Markets where regulations fall below human rights standards /

The business’s commercial success substantially depends upon: operating in, lobbying for or expanding into markets where laws or regulations fall below international human rights and environmental standards

For Example /
  • Tobacco companies with growth strategies for markets without laws requiring warnings on packaging
  • Food and beverage companies with growth strategies for high salt/ sugar products for markets without laws requiring nutritional information on packaging
  • Alcoholic beverage companies engaging in sponsorship activities in geographies without laws on exposure of children to alcohol-related marketing
  • Collecting or holding sensitive personal information in geographies with underdeveloped privacy laws
  • Lobbying against laws that protect workers or communities from corporate human rights impacts (e.g. lobbying against increases in the legal minimum wage)
  • Manufacturing (e.g., apparel, footwear, automotive, electronics) where labor is outsourced to jurisdictions where wages are well below living wage levels and/or working conditions are poor, to minimize costs
  • Advancing circularity goals by diverting waste to informal hubs or collecting waste for “reuse” and “recycling” in geographies with lax or poorly enforced labor, health and safety protections (e.g., electronic, textile, plastic, battery waste)
  • Low carbon transition plans/strategies that rely on projects (e.g., renewable energy, biofuels, nature-based solutions) in jurisdictions with absent or poorly enforced environmental or land rights
Higher-Risk Sectors /

Various, depending on the subject of regulation, including: food, drink and tobacco sector; basic metal production sector; oil and gas production and oil refining sector; mining sector; mechanical and electrical engineering sector; technology sector, automotive sector, energy sector; textiles, clothing, leather and footwear sector; and professional services sector, including law firms.

In particular, when operating in, expanding into, or primarily sourcing from:

  • geographies with less developed legislative and regulatory frameworks, including least developed and developing countries;
  • geographies in which corruption, political instability or conflict affects the effective enforcement of laws (see, e.g. Transparency International’s annual Corruption Perception Index, International Crisis Group’s CrisisWatch, Freedom House’s Freedom in the World)
Download Red Flag 23

Questions for Leaders /

  • Has the company assessed whether its climate strategies – including its climate transition or circular economy strategies – could succeed without any reliance on these gaps in legal frameworks?
  • Where impacts on people connected to the business arise in a geography of manufacture or sourcing, does the company undertake a root cause analysis and seek to understand whether and how the company’s business model creates a reliance on, e.g. labor/wage conditions that give rise to these risks?
  • How does the company explain applying different standards related to human rights and the environment in different jurisdictions?
  • How does the company know whether its lobbying activities on regulation are aligned with human rights principles, policies and commitments and consistent across functions and locations?
  • Has the company ever supported new regulations relevant to human rights or health protections in its sector or operations?
  • How has the company assessed whether the regulations it has opposed would have helped improve informed choice and/ or human rights, and how and to whom does it explain its conclusions?

Understanding Risks
and Opportunities /

Where companies operate in or source responsibly from non-home markets, they can be a catalyst for growth and prosperity. However, where the business model is substantially dependent on gaps in legal frameworks that may not exist in their home market, the company can be seen to be exploiting these governance gaps at this risk of impacts on people:

“The root cause of the business and human rights predicament today lies in the governance gaps created by globalization -between the scope and impact of economic forces and actors, and the capacity of societies to manage their adverse consequences. These governance gaps provide the permissive environment for wrongful acts by companies …”
— Protect, Respect and Remedy: A Framework for Business and Human Rights, UN Doc A/HRC/8/5 (7 April 2008)

Companies exploiting such gaps may engage in:

  • Practices associated with maintaining this business model feature risk perpetuating a “race to the bottom,” as countries compete with lower regulatory standards to attract corporate investment.

    • This may manifest, for example, with the siting and re-siting of operations or sourcing in locations with no or low minimum wages or inadequate labor or environmental protections, affecting peoples’ right to health, right to a family life, right not to be subjected to forced labor and numerous other impacts. The impact on individuals working for suppliers of foreign brands in geographies where legal protections are weaker has been well documented, including for examples in this study of Female Migrant Workers in Bangalore’s Garment Industry. Other examples include siting call centres in jurisdictions with underdeveloped overtime laws and worker protections; sourcing electronics from jurisdictions with weaker migrant workers protections or collective bargaining protections; or moving factories over borders where there is weak enforcement of labor standards.

    • In its 2015 report, Human Rights Watch documented how Cambodia’s rise as a garment manufacturing hub was enabled by low wages and favorable trade conditions, but sustained in part through systemic labor rights abuses. The report discusses widespread use of short-term contracts to discourage organizing, failure to enforce labor laws, suppression of independent unions, and impunity for abusive practices—all of which helped maintain Cambodia’s competitive position in global supply chains, attracting foreign business.

  • Lobbying against measures or laws that protect people from human rights impacts, for example lobbying against:

    • (increased) minimum wage laws, affecting among other things, the right to just and favorable conditions of work, including decent remuneration;

    • Indigenous title to land affecting ­­Indigenous Peoples’ rights;

    • restrictions on emissions into land, sea and air, affecting the right to an adequate standard of living and to a clean, healthy and sustainable environment;

    • laws that support informed choice or plain packaging/non-marketing of harmful products such as cigarettes, affecting the right to health.

  • Legal strategies that prevent the state from protecting people from human rights impacts (potentially various), for example:

    • seeking to use investment treaties (including stabilization clauses) and closed arbitration processes to limit states’ abilities to enact or amend legislation or regulations that increase human rights protection;

    • seeking to enforce intellectual property rights against public health imperatives.

  • Reputational and operational: Risks arise due to inconsistencies between what the company says in public and in private regarding regulatory protections, and in what it does in different parts of the world based on different levels of regulatory protection. Reputations may also be open to attack where the company invests considerable resources in weakening human rights or environmental protections. Some examples of where these types of risks have arisen include:

    • Kellogg’s attracted negative attention when it sued the Mexican government over a labelling policy requiring food manufacturers to include warning labels on the front of any boxes they sell in Mexico to educate consumers on excess sugar and fat. Similarly in the USA in 2023, major food manufacturers including General Mills, Kellogg’s, Conagra, and trade bodies like the Consumer Brands Association strongly opposed updated FDA proposals restricting the “healthy” label for foods high in added sugars, sodium, or fats. They argued the rules violated First Amendment rights and unfairly targeted nutrient-dense foods. Media highlighted that corporate claims were “drawing on big tobacco’s playbook,” with critics pushing back on potential conflicts of interest and misalignment with public health goals.

    • The Guardian reported on a leaked email sent by a senior executive from Philip Morris International regarding their lobbying plans to counter the World Health Organization’s efforts to crack down on vaping by young people and further smoking restrictions.

    • The Association of Convenience Stores (ACS), which includes major UK supermarkets like Sainsbury’s and Asda, has lobbied UK MPs to weaken or block a planned ban on disposable vapes, which aims to address the negative health impacts of disposables for young people and other vulnerable users. Public health groups have again argued that this behavior is “straight from the playbook of Big Tobacco”.

Reputational, regulatory and financial risks:

Legal and financial risk:

Under the UN Guiding Principles on Business and Human Rights, the corporate responsibility to respect human rights “exists independently of States’ abilities and/or willingness to fulfil their own human rights obligations, and … exists over and above compliance with national laws and regulations protecting human rights” (Principle 11, Commentary). In other words, “all business enterprises have the same responsibility to respect human rights wherever they operate” (Principle 23, Commentary), whether or not they have a domestic legal obligation to do so. As such, adopting an inherently uneven, compliance-based approach risks breaching the company’s responsibility in places where laws do not meet internationally accepted human rights standards.

The UNGPs note that companies should, “strive for coherence between their responsibility to respect human rights and policies and procedures that govern their wider business activities and relationships [including] …. lobbying activities where human rights are at stake” (Principle 16, Commentary).

Where the company actively lobbies against or takes action to constrain laws that have the practical effect of furthering respect for human rights, it risks contributing to human rights impacts, whether as a sole contributor or as a result of the aggregate contribution of several actors.

Where a company is benefiting from an absence of protection of rights in the countries where it operates, it may be directly linked to impacts; where it is aware of this and does nothing, it may, depending on a number of factors, be considered to be contributing to the impacts.

Addressing impacts on people associated with this red flag indicator can contribute to a range of SDGs depending on the impact concerned, for example:

  • SDG 3: No poverty, in particular Target 3.5: strengthen the prevention and treatment of substance abuse, including narcotic drug abuse and harmful use of alcohol; and Target 3.10: strengthen the implementation of the World Health Organization Framework Convention on Tobacco Control in all countries, as appropriate.

  • SDG 8: Decent Work and Economic Growth, in particular Target 8.5: by 2030, achieve full and productive employment and decent work for all women and men, including for young people and persons with disabilities, and equal pay for work of equal value.

  • SDG 12: Responsible Consumption and Production, in particular Target 12.2: Sustainable Management and Use of Natural Resources and Target 12.5: by 2030, substantially reduce waste generation through prevention, reduction, recycling and reuse.

  • SDG 13: Take urgent action to combat climate change and its impacts, in particular Target 13.2 integrate climate change measures into national policies, strategies and planning and Target 13.4 implement the UN Framework Convention on Climate Change.

  • SDG 16: Peace, justice and strong institutions, in particular: Target 16.7: ensure responsive, inclusive, participatory and representative decision-making at all levels; and Target 16.10: ensure public access to information and protect fundamental freedoms, in accordance with national legislation and international agreements.

Taking Action /

  • Do we have a policy on when and how we will lobby against regulatory initiatives that include provisions aimed at access to information, improving consumer health or protecting other human rights? Are we aware of lobbying being undertaken on our behalf via trade associations and have we assessed those positions in light of our own commitments and responsibilities?

  • Have we assessed whether and to what extent our engagements with governments on regulatory developments are in line with our responsibility to respect human rights and the environment and enable governments to introduce human rights or environmental protections?

    • Have we examined our lobbying activities in light of our own human rights commitments and strategies?

    • Have we taken action to address any misalignments between our climate change lobbying and/or the climate change lobbying activities of our trade associations, coalitions, alliances or funded thinktanks and our publicly stated climate commitments?

  • Do our government affairs team engage routinely with our corporate responsibility/ sustainability/ human rights teams, with a view to internal alignment?

  • Where we use external lobbying organizations, are our corporate responsibility/ sustainability/ human rights team consulted on the terms of their mandate?

  • Do we disclose our position on key public policy issues? Do we reveal our external memberships, donations and methods of influence? If not, why not?

  • Do we disclose our operations (inclusive of tax activities) and primary sourcing countries across different geographic jurisdictions? If not, why not?

  • Applying purpose and principles to lobbying activities:

    • In 2017 Campbell’s Soup withdrew from the Grocery Manufacturers Association citing “our purpose and principles,” including positions on food labelling. When the United States Food and Drug Administration agreed to extend a deadline for food and beverage companies to introduce a “Nutrition Facts Panel,” the company announced it was “continuing to strive to meet the original deadline.”

    • AP7, BNP Paribas Asset Management and the Church of England Pensions Board collaborated to develop The Global Standard on Responsible Climate Lobbying, which is intended to bring about transparency and accountability for the commitment of investors and companies to responsible climate lobbying.

    • In 2024 and 2025, Unilever undertook a Climate Policy Engagement Review to assess the degree of alignment between the company’s climate policy positions and the positions of the trade associations to which the company is a member. Following the review, the company has publicly committed to rectifying the misalignments, including using its leverage to urge more proactive climate policy positions from the industry bodies with which it works. As a result of its efforts, Unilever was ranked as the highest-scoring company by InfluenceMap, which annually tracks corporate climate lobbying behavior, and, as of May 2025, remains the highest scoring company.

    • Recent CEO Water Mandate initiatives (Net Positive Water Impact and Forward Faster Initiative) are underpinned by its Principles for Responsible Water Policy Engagement, which speak to the manner in which companies can responsibly engage on water-related policy.

  • Contributing to a regulatory environment that enables respect for rights:

    • In 2020, 101 investors came together under the Investor Alliance for Human Rights, to call on all governments to develop, implement and enforce mandatory human rights due diligence requirements for companies headquartered or operating within their own jurisdictions or, where appropriate, to further strengthen these regulatory regimes where they already exist. The IAHR also hosts an EU-specific Regulations Thematic Investor Group which aims to influence EU sustainability legislation.

    • Oil and gas companies have jointly pressed a government to improve transparency requirements before proceeding with bids for concessions, in order to level the playing field and avoid human rights performance becoming a competitive issue. (See Shift’s Using Leverage guide at p. 22).

    • The Extractive Industries Transparency Initiative is a multistakeholder initiative — involving governments, companies, and civil society — focused on promoting transparency in the oil, gas, and mining sectors. Membership is voluntary, but membership requires public reporting of payments, contracts, and industry data, with the intent of improving oversight of natural resource revenues, improving, government accountability and enabling more informed public participation in decisions that affect peoples’ livelihood and environments.

    • The Bangladesh Accord on Fire and Building Safety, signed in 2013 after the Rana Plaza factory collapse, is a legally binding agreement between global garment brands, trade unions, and NGOs to improve workplace safety in Bangladesh’s garment sector. It established independent factory inspections, public reporting, and mechanisms for workers to raise safety concerns. In 2023 a renewed International Accord was signed and, effective since November 2023, is a framework agreement for implementing country programs in Pakistan, Bangladesh and any future programs in other garment producing countries.

    • In 2014, eight apparel brands wrote to the Cambodian deputy prime minister and the chairman of the local Garment Manufacturers Association to say they were “ready to factor higher wages” into their pricing.

  • Examples of sector-specific collaborative initiatives:

    • The Voluntary Principles on Security and Human Rights (VPSHR), launched in 2000, is a voluntary, multi-stakeholder initiative—comprising governments, extractive and energy companies, and NGOs—that offers guidance to ensure security operations respect human rights. It establishes three core areas: risk assessment, and protocols for engaging with both public and private security providers—including proportional use of force, human rights training, credible investigation of abuse allegations, and regular community consultation.

    • The Fair Circularity Initiative brings businesses, including Pepsico, TetraPak and Unilever, together to work toward respecting the human rights of workers within the informal waste sector, including through collaboration with local waste picker organizations in different regions.

    • In 2019, three leading apparel brands, a denim supplier, and a coalition of labor unions and women’s rights organizations signed an agreement to prevent and address gender-based violence and harassment in garment factories in Lesotho. 

  • Companies striving to ensure a living wage across their operations and supply chain seek to mitigate the effects of operations in countries in which there is no, or an inadequate, minimum wage. ACT (Action, Collaboration, Transformation) is an “agreement between global brands and retailers and trade unions to transform garment, textile and footwear industry and achieve living wages for workers through collective bargaining at industry level linked to purchasing practices.” Through industry-level collective bargaining in sourcing countries, companies seek to avoid competing with each other based on lower wages (and regulations that enable this), but rather on other factors.

  • Mondragon is a federation of worker-owned cooperatives based in Spain’s Basque Country, operating across manufacturing, retail, finance, and education sectors. Each of the federation’s 70,000 workers is a co-owner with equal voting rights and equitable profit sharing, with Executive pay capped relative to the lowest-paid worker. The model does not rely on relocation to lower standard jurisdictions, but instead emphasizes local employment and democratic governance.

General

Responsible policy & political engagement

Fair Circularity

Sector-specific tools and resources

  • ACT (2023) Accountability and Monitoring Report is a comprehensive report that showcases collaborative efforts among brands and retailers to design, measure, and monitor transformative practices.

  • Swedwatch (2025) Human Rights Defenders at Risk in the Transition to Green Energy details how much of the renewable energy expansion is happening in countries with restricted civic space and weak human rights protections and how this puts communities, especially human rights defenders, at risk of harassment, legal persecution and violence.

Citation of research papers and other resources does not constitute an endorsement by Shift of their conclusions.

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.