A policy is just words on paper without action to put it into practice. In order to implement its commitment, respect for human rights needs to become part of the company’s culture or “DNA” – in other words, it needs to be an integral part of how it operates. Embedding is about creating the right “macro-level” environment for a policy to be effective. It includes training, performance and accountability structures, “tone at the top” from senior management and the Board, and a sense of shared responsibility for meeting the company’s human rights commitments.

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