Red Flag 14. Commodities with unclear provenance and visibility into impacts on workers or communities

Commodities with unclear provenance and visibility into impacts on workers or communities /

The business’s commercial success substantially depends upon commodities with unclear provenance and visibility into impacts on workers or communities.

For Example /
  • Using resources with limited traceability (including mass balance and spot markets):
  • Agricultural and other “soft” commodity products (e.g., wood/paper, sugar, coffee, cocoa, wheat, soybeans, cattle, palm oil, cotton)
  • Energy (e.g., oil and gas)
  • Metals, minerals and metalloids (e.g., iron ore, copper, aluminum, gold, cobalt, silica)
Higher-Risk Sectors /
  • Commodity traders, including:
  • Trading companies
  • Companies with trading arms
  • Market-based/ financial sector commodity traders
  • Companies using commodities in the process of manufactured products, including:
  • Agricultural commodities:
  • Food and beverage industry
  • Fast-moving consumer goods industry
  • Apparel industry
  • Metals, metalloids and precious stones:
  • Jewelry companies (e.g., metals and precious stones)
  • Electronics and IT industries
  • Renewable energy industry (e.g., polysilica)
  • Minerals and elements (e.g., mica, cobalt):
  • Electronics and IT industries
  • Automotive industry
  • Paints and coatings industry
  • Cosmetics and personal care industry
  • Construction industry
  • Greenhouse gas emissions-based market participants, including:
  • Trading companies
  • Carbon offset project developers
  • Carbon market intermediaries and brokers
  • Corporate offset buyers
Download Red Flag 14

Questions for Leaders /

  • What effort has the company made to understand the sources of its key inputs/ingredients and the environmental or socially-related risks/issues that arise in the value chain?
  • How does the company find out about human rights risks associated with the commodities on which it relies? Does it do so at the stage of product design or sourcing? What does it do to address the risks it finds?
  • What is the company’s view on building longer-term sourcing commitments for the commodities on which it relies in order to make them more traceable?
  • How is climate change (water scarcity, temperature increases, extreme weather events) affecting the people where the commodity is sourced, processed or distributed?
  • To what extent does the company’s value proposition rely on the price of an agricultural commodity being depressed below levels deemed sufficient to sustain living incomes/ wages? Does the business model rely on substantial market power to drive down pricing? (See further Red Flag 19).

Understanding Risks
and Opportunities /

  • IHRB notes that a wide range of agricultural and mined commodities can be associated with adverse human rights impacts “at the point of production or extraction”, including impacts on:
    • Workers: Such as unfair, unsafe or unhealthy working conditions, child and forced labor, as well as exploitation and/or discrimination of migrant workers. Where lowest cost is the largest business driver (e.g. in the commodities market), farmers, stockbreeders, fishermen and smallholders have limited influence in negotiating terms of trade and receive an ever-diminishing share of the fruits of their labor. (See further Red Flags 1 and 19).
    • Communities: Such as activities taking place in the absence of adequate community consent, resettlement of indigenous communities without Free, Prior and Informed Consent (FPIC), public/private security forces infringing on workers’, Indigenous Peoples’, and communities’ rights.”
  • Where commodities of unknown provenance are bought, sold, traded and hedged, it becomes difficult for companies upstream in the value chain to understand where the materials came from or under what conditions they were produced, and therefore to influence these decisions so as to address potential negative impacts on the rights of people in the value chain.
  • The physical impacts of climate change, already being felt in certain regions, are expected to further intensify the impacts on people in the value chain. A recent report by PWC, details how extreme heat and prolonged drought are expected to disrupt major commodity supply chains—for example, by 2050 over 70% of cobalt and lithium production will be impacted—due to concentrated sourcing patterns in particular regions. These conditions not only threaten yield and extraction costs—they are also anticipated to drive down worker productivity and directly endanger the health, safety, and livelihoods of miners and farmworkers.
  • In parallel, the global transition to a low carbon economy and the digital transformation are increasing demand for a number of commodities that have been linked to severe human rights risks and impacts. The extraction, processing and, in some cases, transportation of key minerals used in clean energy and information technology applications have been linked to issues such as child labour, forced labour, land grabbing, deforestation and environmental pollution. Reports indicate that companies accounting for 75 percent of the global battery market have connections to one or more supply chain companies facing allegations of severe human rights abuses. This is a worrying trend, particularly when coupled with projections for dramatically increasing demand for such commodities. The International Energy Agency has predicted that mineral demand for clean energy applications alone is set to grow by three and a half times by 2030 on the pathway to reaching global net zero emissions by 2050.
  • In response to net zero emissions commitments, demand has increased for greenhouse gas (GHG) emissions-based commodities, notably carbon credits. These commodities represent GHG emissions that were avoided, reduced or removed, for example through projects that prevent deforestation or plant trees. Governments, companies, and individuals may purchase these credits to compensate for, or “offset,” their emissions elsewhere. However, human rights due diligence on projects generating carbon credits is often inconsistent—many schemes fall short on meaningful community consultation, land rights protections, and equitable benefit-sharing. As a result, some of the underlying projects from which market-based carbon commodities are sourced have been linked to human rights violations.
  • Some examples of risks to people associated with this business model include:
    • Child Labor: Research by Impact details the pervasiveness of child labor throughout the artisanal cobalt mining sector in the Democratic Republic of the Congo (DRC). For example, mica mining, particularly in illegal small-scale artisanal mines, has been associated with child labor. Over 22,000 child laborers have been identified across only two geographic areas in India (which cover less than half the so-called “mica mining belt”).
    • Forced Labor: Research across multiple organizations has explored how the textile/apparel, agricultural and renewable energy sectors have pervasive connections to forced labor in China’s Uyghur Region, with implications across international commodities markets associated with these sectors, including for cotton, tomatoes and polysilicon (used for solar panels). A recent study by Global Rights Compliance has detailed how China’s expansion of critical mineral exploration, mining, process and manufacturing in Xinjiang region is a critical risk for companies across multiple sectors – from electronics to aerospace to energy.
    • Land grabbing and forced evictions: In the DRC, Amnesty International has documented multiple cases of forced evictions of entire communities as companies seek to expand industrial-scale cobalt and copper mining projects in response to the growing demand for these commodities for use in rechargeable batteries.
    • Violation of free, prior and informed consent: In Cambodia, a two-year investigation by Human Rights Watch of Cambodia’s Southern Cardamon REDD+ carbon crediting project revealed widespread mistreatment of the Chong people, as well as extended project-related activities in the absence of consent of impacted Chong communities.
    • Deforestation and environmental pollution: In Indonesia, the world’s largest producer of nickel (a critical input to renewable energy and electric vehicle batteries), Climate Rights International found that there has been extensive deforestation and water pollution as part of the nickel industry’s recent expansion there, resulting in severe impacts for the livelihoods of local communities.
  • Business, Reputational, Operational, Regulatory and Legal Risks: Commodity markets are synonymous with extreme price pressure on farmers and other workers at source, which can undermine availability of product and stability of supply. The company also risks being involved in business relationships with disreputable organizations or individuals, including groups using forced or child labor or operating unsafe working environments, or may be financially supporting conflict. Operational challenges, reputational damage and even legal risks can arise where such connections come to light and the business must act reactively to exclude such sources from their value chain. Where traceability to individual companies is limited, entire industries can face civil society pressure to improve (e.g. in the case of palm oil).

  • The US Government enacted the Uyghur Force Labor Prevention Act in 2021, which prevents the entry of products made with forced labor into the United States by investigating and acting upon allegations of forced labor in supply chains. Thousands of shipments from the electronics, apparel, footwear, pharmaceutical, agricultural, industrial, and automotive sectors have been reviewed for connections to forced labor, resulting in goods “totaling hundreds of millions of US dollars” being denied entry at the US border.

  • In 2023 the Amsterdam City Council decided to ban Colombian coal from the Port of Amsterdam in response to reports and complaints that this “blood coal” was associated with serious human rights violations. Relatedly, in August 2025, the Dutch National Contact Point formally accepted a complaint by Colombian farming communities, supported by PAX and SOMO, against HES International and the port authorities of Rotterdam and Amsterdam for their involvement in transporting “blood coal” linked to forced displacement of over 59,000 people in a northern mining region of Colombia.

  • In 2022, Peruvian indigenous leaders filed a case with the Dutch National Contact Point against the Louis Dreyfus Company B.V. (LDC) arguing that despite abundant public information concerning grave environmental and human rights impacts, LDC continued to purchase crude palm oil from the Ocho Sur Group whose oil palm plantations are involved in the illegal deforestation of over 12,000 ha of Amazon virgin forest, human rights violations of the Indigenous Community of Santa Clara de Uchunya and the Shipibo-Konibo people and corruption schemes for land grabbing.

  • A Global Witness report found that several major international brands were sourcing palm oil from Brazilian plantations linked to violence, torture and land fraud. Based on mill lists or on public information available on trade data systems, Global Witness identifies 20 companies, including Danone, Ferrero, Bunge, Hershey, Kellogg, Nestlé and Pepsico, with direct or indirect links to human rights abuses.

  • In December 2021, the non-profit organization Public Eye released research alleging that Swiss-based commodity traders, together owning over 550 plantations of various agricultural commodities across the world on at least 2.7 million hectares, fail to take sufficient responsibility for human rights and environmental abuses on their land holdings, including evictions, labor abuse, and deforestation. Their interactive platform names several agricultural traders, including Archer Daniels Midland, Bunge, Cargill, Chiquita, LDC, Neumann Kaffee Gruppe and Viterra.

  • In 2023, the Centre for Research on Multinational Corporations (SOMO), published a report documenting allegations of sexual abuse, harassment and exploitation linked to the Kasigau Corridor conservation project in southern Kenya, operated by the California-based firm Wildlife Works. This project is the source of “carbon offsets” purchased by companies such as Shell and Netflix.

  • The Dutch National Contact Point for the OECD Guidelines for Multinational Enterprises (NCP) received a complaint from a consortium of 22 Italian associations and NGOs in 2022 alleging violation of the OECD Guidelines by Stallantis N.V. and FCA Italy S.p.A and requesting the disclosure of detailed information on their suppliers’ operations at cobalt and other minerals mining sites in the Democratic Republic of the Congo. The complaint, which represents one of the first focused on a company’s mineral supply chain, was accepted by the Dutch NCP (after being deferred by the Italian NCP) and is pending decision.
  • Regulatory Risk: The EU’s deforestation regulation, currently scheduled to come into effect from 30 December 2025 (and June 2026 for smaller companies) requires companies to prove key agricultural commodities (e.g., soy, palm oil, coffee, cocoa) coming into the EU have deforestation-free origins. The regulation also includes provisions around violations of nationally applicable laws that relate to land rights, environmental protection, labor rights, and free, prior and informed consent.
  • Business Opportunity: Focusing on improved livelihoods for people within the supply chain helps to build more resilient corporate supply chains. Opportunities for price reduction and new sources can be unlocked:

Barry Parkin, Chief Procurement and Sustainability Officer of Mars, has noted that supply chains are “broken.” In a 2018 article arguing that the “commodity era is over,” he identifies win-win opportunities to “move beyond commodities that are bought and sold in markets where the lowest cost is the largest business driver. Instead, we must shift to long-term models for corporate buying that are anchored on building mutuality, reliability, resilience and risk management into the core of our buying patterns.”

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

  • Companies risk being directly linked to human rights impacts as a result of harmful practices associated with the commodities going into their products.
  • Where companies ought to be aware of risks associated with commodities incorporated in their products, including, for example, where a commodity is overwhelmingly sourced from one location where it is associated with human rights impacts, the company may be contributing to impacts if it fails to use its leverage to try to address the impacts, either alone, or in collaboration with others.

Addressing impacts on people associated with this red flag indicator can contribute to a variety of SDGs, depending on the impacts associated with the commodities. This may include, for example:

  • SDG 1: Eradication of poverty in all its forms.
  • SDG8:Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all, in particular:
    • Target 8.7 Eradication of forced labor, modern slavery and human trafficking, securing the prohibition and elimination of the worst forms of child labor, including the recruitment and use of child soldiers, and ending child labor in all its forms by 2025.
  • SDG 10: Reduce inequality within and among countries.
  • SDG 12: Ensure sustainable consumption and production patterns, in particular:
    • Target 12.6 Encourage companies, especially large and transnational companies, to adopt sustainable practices and to integrate sustainability information into their reporting cycle.
  • SDG 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels, in particular:
    • Target 16.2 End abuse, exploitation, trafficking, and all forms of violence against and torture of children.

Taking Action /

Risk Identification and assessment

  • What opportunities exist to build greater visibility into our direct and indirect sourcing relationships?
  • Which commodities that we use may be of higher risk from a human rights perspective, based on known information about potential source countries?
  • How might the company’s actions to address its climate-related risks and opportunities change its reliance on certain commodities? How does the company determine the human rights risks associated with those changes? How has the company factored such considerations into its overall approach to its climate change mitigation and adaptation planning and implementation?
  • How have environmental, social and human rights-related safeguards been built into the process of sourcing carbon-based commodities?
  • Where information about impacts associated with the commodity is scant, how can we learn from known information about human rights impacts associated with other commodities sourced from the same area?
  • Which partnerships, including with peers, international organizations, academics or NGOs, can we leverage to gain greater transparency or ensure traceability? Where no initiatives exist, can we create one?

Taking action

  • What leverage do we have with our direct suppliers, traders and processors to address risks and impacts?
  • How can we increase our leverage e.g., through contractual clauses, commercial conversations, expertise, joint capacity building, etc?
  • Have we considered whether and how we can reduce our reliance on commodities markets and increase our engagement, visibility and leverage with the producers of the raw materials on which our business relies? Have we considered available examples from other companies to articulate the longer-term business benefits of this approach?

Transparency, shortening of supply chains and longer-term commitments from buyers can “demystify complex supply chains,” and allow “different actors [to] identify and minimize risks and improve conditions on the ground and inform whether and where progress is being made.”

  • The Child Labour Platform, a multistakeholder initiative, aims to convene stakeholders to address the root cases of child labor in the agricultural and mining sectors – with a focus on cocoa and cobalt – through initiatives aimed at prevention, assessment and remediation, provision of guidance to improve company practice, as well as to develop innovative collaboration models.
  • In September 2024, the Solar Energy Industry Association sought public comments on their draft solar supply chain traceability standard which is the first of its kind and details how to conduct forced labor-focused due diligence, including building a traceability system to trace the provenance of materials from upstream suppliers. As of September 2025, the updated standard is still awaiting final publication.
  • In 2018, the BMW Group and Codelco, a Chilean copper mining company, signed an agreement to cooperate on a sustainable and transparent supply of copper. In the “decommoditized” copper market, prices reflect differences in levels of certification.
  • Many large consumer goods companies are disclosing the source of their palm oil through the Roundtable on Sustainable Palm Oil, including Unilever, which, in 2018 announced that it was “the first consumer goods company to publicly disclose the palm oil suppliers and mills it sources from” (both directly and indirectly), and Nestle, which reported that by the end of 2023, 96% of its palm oil supply was deforestation-free and has implemented satellite monitoring systems to detect and address deforestation risks. The Roundtable on Sustainable Palm Oil (RSPO) maintains a “Shared Responsibility” framework, requiring members to incrementally increase their uptake of certified sustainable palm oil, with specific targets set for different member categories. In 2024, the RSPO introduced a verification manual and sanction mechanisms to ensure compliance with these commitments.

  • The Global Battery Alliance convenes actors across the battery value chain to align on sustainability performance expectations for batteries around principles of transparency, traceability, accountability and circularity. The organization’s Battery Passport is an emerging global sustainability reporting and certification scheme for batteries, which can help supply chain companies demonstrate their commitment to build supply chain transparency, while managing reputation risk and becoming more resilient to supply chain disruptions.

  • The Taskforce on Scaling Voluntary Carbon Markets was a multi-stakeholder initiative working “to scale effective and efficient voluntary carbon markets”. Members, including buyers and sellers of carbon credits, standard setters, civil society, and academics, were focused on recommending solutions to issues compromising the integrity and effectiveness of voluntary carbon markets, including ongoing concerns about the social impacts of carbon projects. The Integrity Council for the Voluntary Carbon Market was one of the outcomes of this initiative.

  • A growing share of food commodities are now marketed as value-added (sustainable) products. California-based B-Corp Uncommon Cacao supplies raw cocoa beans to artisan chocolate makers disconnected from world market prices. It aims to provide a transparent alternative to commodity exchange and certified cocoa by setting fixed farm gate and export prices annually to help farmer incomes grow.
  • In September 2019, Mars launched “Our Palm Positive Plan”, which is focused on transforming their “palm supply chain to deliver deforestation-free palm oil and advance respect for human rights”. A key element of their approach is simplifying, validating and making their palm oil supply chain more transparent, including publication of their palm oil suppliers and mills, which declined from more than 1500 to less than 100 in the initial stages of their commitment. They have also focused on fostering and building long-term relationships with suppliers based on their alignment to and performance against criteria set by Mars, including criteria focused on targeting damaging recruitment fees typically paid by migrant plantation workers. As of 2024, the company reports 100% traceability to mill level and 96.3% to plantation level, with 99.8% of its palm oil certified under the Roundtable on Sustainable Palm Oil (RSPO) standards. Mars has also made commitments to responsible cocoa procurement.
  • An impact investing fund created by Danone, Firmenich, Mars and Veolia with respect to vanilla, offered a 10-year commitment, cooperative and a minimum price, through an “innovative model where formers and industry players share both the benefits and risks.” The project estimates that 60% of cured vanilla’s value will go back to farmers (compared to initially observed shares of 5% to 20%).
  • Amsterdam-based startup Sourcery is a global sourcing and digital trade platform that aims to connect brands, manufacturers, traders and growers in the cotton supply chain. The platform enables concrete, verifiable data on the conditions around cotton growing – tracked by and licensed to the farmers who grow it – to be attached to the cotton traded on international markets, which has the potential to increase transparency and traceability of cotton supply chains.

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.