Human rights compliance programs
If you could start over, would yours be a human rights compliance program?
We have had an incredible journey these past 5 years. We’ve moved all the way from ‘rules-based’ compliance through to values-driven culture building.
With a background of a revitalised mission, vision and values, and incredibly high employee engagement, we are also revisiting our human rights program. And as we’ve done so I can’t help but ask myself how our compliance program would look if we had started with a human rights focus in the first place.
Ultimately, corruption causes or exacerbates many of the human rights miseries we see. So why not cover both areas in one fell-swoop?
Companies starting out on their compliance journey will ask, “what is a compliance program? Does it cover all topics that can come through a whistle-blowing channel? Is it anti-corruption alone? Or is it broader?"
Often anti-corruption is the motivator and thus the starting point. Another take is that the key is human rights; that a human rights focus would have better results compared to an anti-corruption approach.
For a start, engagement is so much easier on human rights. We all agree they’re important, even if not everybody knows exactly how they're formulated legally.
Anti-corruption work is easy to paint as a show-stopper. By contrast, that’s definitely not the way human rights are viewed. If a busy sales employee spares valuable time for compliance work, buy-in is easier on human rights. There’s something fundamental in human rights that we all want to participate in, and contribute to. I’ve had extremely senior sales people volunteer to talk to audiences on human rights… that hasn’t happened (yet) on anti-corruption!
The compliance activities and their outcomes are broadly the same. For human rights compliance you will have many of the same activities as for anti-corruption work - you still need great tone from the top, policies & procedures, risk management, due diligence, contract management, etc. You still need to master your supply chain. The difference is how the compliance activities are positioned ... as human rights work.
That's not to say we should ignore the different natures of the risks or how we mitigate them in different business processes, industries or geographies.