Red Flag 7. Financial or advisory services that enable high-risk clients to cause harm

Financial, research or advisory services to high-risk clients /

Providing finance or advice to clients where its use is likely to undermine human rights.

For Example /
  • Providing finance to projects or borrowers where adverse impacts on communities are foreseeable
  • Providing legal advice premised on operating in legal gray areas or exploiting the lack of laws that are relevant to the protection of human rights
  • Providing management consultancy services to government clients that may enable corruption
  • Providing tax advice that supports the aggressive minimization of tax payments (See also Red Flag 24)
Higher-Risk Sectors /
  • Finance
  • Legal services
  • Management consulting
  • Accountants
  • Insurance
  • Public relations firms
Download Red Flag 7

Questions for Leaders /

  • How does the company identify clients with higher risk of association with human rights impacts? What are the triggers for review and/or periodic assessment and how are decisions elevated within the company where the risks are high?
  • Is there an example of a decision not to engage in, or to disengage from, a business relationship on the basis of human rights concerns?
  • Through what channels can employees raise concerns about clients and how does the company know whether they feel able to do so in practice?
  • If the company takes on a higher risk client, what does it do to minimize the chances of the company’s services enabling human rights impacts?

Understanding Risks
and Opportunities /

Financial or advisory services can enable companies to act in ways that increase the risk of impacts on people. Further, risks to people can arise even where financial or advisory services are provided in compliance with applicable laws and regulations. Some examples of human rights impacts connected to such services are listed below.

  • Providing finance, insurance or advice for large infrastructure or other projects requiring relocation of communities can, without proper mitigation measures, be associated with forced relocation, the loss of adequate housing and livelihoods, the destruction of sacred indigenous sites, environmental damage and violence against community members. Where the advice relates to a project or facility in a geography undergoing conflict, there is a risk of connection to impacts on the right to life. In the case of finance, risks can be exacerbated where a financier is a non-lead bank in cases of multi-bank syndicated loans for project finance. (See Red Flag 15).
  • In February 2021, the Telegraph reported that “consulting firm McKinsey has agreed to pay $573 million” in order “to settle claims by US states that the consulting company helped fuel the opioid epidemic by providing marketing advice to drugmakers including Purdue Pharma and Johnson & Johnson.”
  • Accounting and Taxation advice on aggressive, but legal, taxation minimization strategies can deprive governments of the resources needed to address poverty and to finance programs seeking to protect and fulfil rights. (See also Red Flag 24).
  • In relation to legal advice, risks can arise where there is a gap between domestic laws and international human rights standards. For example, advice to employers in relation to legal tactics to undermine labor rights can negatively impact the practical enjoyment of those rights, e.g. the right to collective bargaining. Advice on bringing certain claims under stabilization clauses in investment agreements with host governments (which provide protections for investors against future changes in law) can interfere with a State’s bona fide efforts to implement laws, regulations or policies in a non-discriminatory manner in order to meet its human rights obligations.
  • Reputational Risks: Connection to severe human rights impacts can have reputational effects for financial and advisory service providers; where such connections are repeated or persist over time, it can lead to public questioning of the company’s social license to operate. In 2018 a Forbes opinion article cited connections to human rights impacts as the basis for asserting that “McKinsey & Co fails as a global leader.” At worst, it can bring an entire industry into disrepute. In 2020 an investigative article relying on the Luanda Leaks asserted that “consultants, accountants and lawyers provided vital support at each step of the way” and argued for the need for greater regulation over the “key role Western professionals play in maintaining an offshore industry that drives money laundering and drains trillions from public coffers.” Civil society is increasingly highlighting the connection between finance and advisory services and impacts, most visibly in campaigns for divestment by banks from companies or projects associated with human rights impacts, such as in the case of banks lending to the private prison industry.
  • Financial Risks: In February 2021, the Telegraph reported that “consulting firm McKinsey has agreed to pay $573 million” in order “to settle claims by US states that the consulting company helped fuel the opioid epidemic by providing marketing advice to drugmakers including Purdue Pharma and Johnson & Johnson.” Banks can be required to compensate communities for adverse impacts connected to their finance: in 2020 an Australian bank agreed to contribute the money that it earned from a loan to a sugar company to Cambodian families that were forcibly displaced by the company, as a form of contribution to remedy. This followed a decision in which the Australian National Contact Point found that it was “difficult to reconcile” the bank’s decision to take on the client “with its own internal policies and procedures” as the risks would have been “readily apparent.” Financial risks can also arise where banking clients are unable to repay loans due to the high costs associated with conflict with communities proximate to projects. Finally, pressure associated with a service provider’s connection to a human rights impacts can lead to them finding it necessary to end a business relationship, (e.g. in the case of the Dakota Access Pipeline), with financial consequences for the company.
  • Business Opportunity Risks: Where advisors are unable to advise clients appropriately on the human rights risks associated with corporate decisions or activities, they risk losing business of increasingly sophisticated clients seeking these insights. The International Bar Association has noted that “lawyers, both as in-house counsel and as members of law firms, are increasingly asked to help businesses understand what the responsibility to respect human rights implies.” The Working Group on Business and Human Rights has noted a “[l]ack of understanding by some lawyers of the links between human rights risks, legal risks, commercial risk and reputational risks and, specifically, a failure to appreciate that, even where no material legal risks can be identified, that there can still be commercial and reputational consequences coming from a company’s behaviour, especially since the endorsement of the Guiding Principles and the growing focus … on the company’s performance on managing human rights risks.”

*For an explanation of how companies can be involved in human rights impacts, and their related responsibilities, see here.

  • While it is typically the client, rather than the provider of financial or advisory services, that is directly causing the harm to human rights in these contexts, the services provider is itself a business enterprise with a responsibility to respect human rights.
  • The service provider’s relationship to the impact is more likely to sit somewhere along the continuum between contribution and linkage. As noted by John Ruggie in the context of finance, a variety of factors can determine where on that continuum a particular instance may sit. They include the extent to which an advisor has enabled, encouraged, or motivated human rights harm by the client; the extent to which it could or should have known about such harm; and the quality of any mitigating steps it has taken to address it. Some examples are below:
    • If a company provides financial or advisory services to a client, and the client, in the context of using the services, acts in such a way that it causes (or is at risk of causing) an adverse impact, the services provider will be directly linked to the impact through its business relationships.
      • The UNGPs do not automatically require the service provider to end a relationship with a client as a result. Rather, they are expected to use their leverage – their influence over the client or other relevant parties – to seek to change the behaviors or practices causing the harm. If the company does not have sufficient leverage to influence the relevant parties, then it should seek to increase that leverage. And where the company cannot increase its leverage, it should consider disengagement from the relationship(s) taking into account several key factors, including whether disengagement would cause further human rights harms. (See Guiding Principle 19).
  • If a company knew or should have known about human rights risks inherent in a project for which it is providing financial or advisory services, but does not take adequate steps to seek to get its client to prevent or mitigate them, it may be considered to have facilitated – and thus contributed to – any impacts that occur. In such a case, the financier/advisor should:
    • cease its contribution,
    • use its leverage to mitigate any remaining impact to the greatest extent possible
    • provide for or participate in effective remedy processes.
    • Disengagement from the relationship will not, in many cases, be sufficient to fulfill the responsibility to provide remedy where the financier/advisor has contributed to impacts.

Providing financial or advisory services to companies or governments in a way that supports human rights standards – by helping them to understand their own responsibilities or by seeking to use leverage with the client where risks to people arise – can contribute to various SDGs, including, but not limited to:

SDG 8: On Decent Work and Economic Growth.

SDG 10: On Reducing Inequalities.

SDG 12: On Responsible Consumption and Production.

SDG 16: On Peace, Justice and Strong Institutions.

SDG 17: on Partnerships for the Goals.

In 2020, “leaders from a host of law firms from across the globe” as well as accountancy firms, were amongst leaders to endorse a UN statement on co-operation in support of sustainable development goals, recognizing the critical role they play in doing “business in a better world.”

Taking Action /

Adapted from Shift’s, Human Rights Due Diligence in High Risk Circumstances: Practical Strategies for Businesses: Identifying potentially higher risk customers/clients.

Example Diagnostic Questions:

Concerning the customer/client

  • Do customers/clients have known and effective internal governance and accountability structures?
  • Do they have known and effective processes for managing environmental, social and human rights risks?
  • Do they have a record of, or reputation for, breaching the law?
  • Do they have a record of, or reputation for, negatively impacting human rights?
  • Are they known or likely to engage in corrupt practices?
  • Are they in conflict with stakeholders?
  • Is this a government owned or connected entity and does that suggest greater or lesser risk to human rights?

Does the structure or duration of the relationship significantly limit the business’ leverage?

Concerning the financial/advisory service provider

  • How often do we remain sensitive to changes in the operating environment and the scope of services being provided to the client? Do we reevaluate the risks:
    • prior to a new activity or relationship;
    • prior to major decisions or changes in the operation;
    • in response to or in anticipation of changes in the operating environment (e.g. rising social tensions)
    • periodically throughout the life of an activity or relationship?
  • How do we engage internal stakeholders (our people) in ways that:
    • raise awareness of high risk circumstances
    • create expectations about identifying and escalating these types of risks
    • address potential disincentives to raising issues (e.g. revenue targets or culture)
  • How do we use leverage with the client?
  • What avenues of leverage do we consider and explore with regards to clients where there is a risk of human rights impacts? For example, can we increase the leverage available in collaboration with other stakeholders (eg. via a syndicate or through industry initiatives?)
  • How do we track the effectiveness of our attempts to use leverage? How do we learn and adapt?

*Mitigation examples are current or historical examples for reference, but do not offer insight into their relative maturity or effectiveness.

Stregthening Due Diligence: Financial and advisory services providers can put in place robust processes to check the impulse to make decisions based on profit alone when it comes to accepting clients, and ensure potential connections to impacts on people are included as vital considerations. Moreover, human rights due diligence requires financial and advisory services companies to take action where they identify a connection to an impact, including by using leverage with clients to improve outcomes for people.

  • When it conducts due diligence on specific clients, Dutch bank ABN Amro uses a wide variety of sources that inform it about the views of local communities or unions. In the due diligence process, ABN’s assessment includes:
    • the client’s policies and practices in dealing with human rights relevant to its operations;
    • whether the client’s policies and practices follow international standards;
    • the client’s track record on respecting human rights
    • the client’s human rights due diligence processes and the monitoring of its human rights performance.
    • ABN also conducts regular training on due diligence (including escalation processes) for key departments involved in credit, front office, “Know Your Client” and credit risk processes; holds quarterly meetings between sustainability departments, business lines and senior management to discuss progress of human rights performance, and holds regular meetings between sustainability teams and business teams to enable smoother decision making at deal time. The bank has mapped the diamond value chain and used the results to issue client briefings and guides.
    • Insurer Allianz reports that it has developed a human rights due diligence process as part of its overall ESG approach, which is integrated into the broader risk management system. The due diligence process uses a combination of a sector- and country approaches and Allianz has developed thirteen ESG guidelines for sensitive business sectors, which include sector-specific human rights aspects.
    • In its “internal guide on human rights for mergers and acquisitions teams” Total demonstrates “recogni[tion] that human rights risk management needs to be integrated in legal risk management processes.” (See Working Group on Business and Human Rights).
  • Using Leverage: In 2017 bank ABN AMRO announced that it was attempting to use its influence over ETE (parent company of ETP, a contractor in the Dakota Access Pipeline) “to strongly stress the need for it to influence ETP with a view to reaching an agreement that is suitable for all parties impacted, and that this solution be accomplished without violence and with FPIC [Free Prior and Informed Consent] at the forefront.” It halted new business with ETE and announced that “[i]f such a solution is not achieved, the ultimate consequence will be discontinuation of the relationship.”
  • Collaborative Action: The banks that make up the Asia Pacific Banks Alliance have recognized the connection between finance and modern slavery via “retail accounts used to exchange funds with traffickers, forced labour in commercial supply chains, or investments being made in industries that have known issues with labour exploitation.” In collaboration with NGO The Mekong Club and the Thomson Reuters Foundation, they have developed modern slavery indicators tailored to the Asia-Pacific region, using case studies and data to inform outcomes and have “identified over 2000 victims of modern slavery.”
 

Finance:

  • The Dutch Banking Sector Agreement’s paper on Enabling Remediation gathers some of the most recent thinking in relation to:
    • how to understand the responsibility of a bank when connected to an impact through the activities of a client.
    • the practical roles banks could play and actions a bank could take to enable remedy in practice, across all forms of responsibility.
  • The Equator Principles Association’s EP4.

Legal Advice:

Taxation Advice:

  • The B Team’s Responsible Tax Principles were developed through dialogue with a group of leading companies, convened by The B Team with contributions from civil society, institutional investors and international institution representatives.

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

Linkedin-in

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.