Human Rights

Drawing on our backgrounds in human rights law, advocacy and compliance, we work closely with leading companies and investors to design and implement tailored human rights policies aligned with leading international frameworks.

We create standalone human rights policies and help clients embed human rights considerations into other company’s management systems (e.g. compliance, procurement, human resources and grievance mechanisms).

We help clients define their human rights policies and internal processes in line with the UN Guiding Principles on Business and Human Rights. We lead benchmarking exercises for clients to map out trends among peers and understand emerging best practices, and engage with internal stakeholders to raise awareness of business & human rights issues and ensure buy-in.

We conduct gap analysis and develop action plans to enable clients to achieve their human rights goals, and monitor their progress on implementation. We provide training to senior executives and teams responsible for implementing the action plans, to raise awareness of human rights issues and enable them to put policies into practice.

Under the UN Guiding Principles on Business & Human Rights, companies are obliged to “know and show” how they address human rights impacts, to ensure transparency and accountability to stakeholders. Many firms are also subject to evolving regulatory requirements for companies to report on how they conduct human rights due diligence, as well as voluntary initiatives that require signatories to report.

We assist with preparing human rights sections of annual and sustainability reports for internal and external stakeholders, as well as disclosures in line with GRI and other reporting standards.

We work continuously with clients to help them implement their human rights strategy and stay in front of emerging risks in their operations and value chains. We leverage our regional expertise to act as a trusted advisor on diverse business & human rights issues, from analysing business responses to state-led human rights abuses in Myanmar, to cataloguing Ukrainian human rights defenders and journalists in need of additional protections on social media platforms. We regularly complete bespoke research projects to provide our clients with the specialised knowledge they need to identify the most at-risk rightsholders and prevent human rights abuses.

Our Human Rights practice assembles industry-leading multilingual project teams to conduct on-the-ground field research for investors and companies on their human rights impacts.

Stakeholder engagement is at the heart of our approach. We combine meaningful consultation with workers, communities and other affected rightsholders with commentary from local and regional experts, and in-depth public domain research. We assess impacted rights and rightsholders with reference to international human rights instruments, such as: the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights (ICESCR), and the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

We identify and prioritise salient human rights risks based on the principles of severity and likelihood, as defined in the UN Guiding Principles on Business and Human Rights (UNGPs). We provide actionable recommendations to both mitigate risks and enhance human rights performance based on: whether the client is causing, contributing or directly linked to a risk, the amount of leverage it has, and its current management of the risk.

We develop action plans with clear allocation of responsibilities and KPIs to support clients to put our recommendations into practice. Once mitigation measures are in place, we assist clients in monitoring their activities as well as particular suppliers, contractors and other high risk actors, and anticipating the response of state and civil society stakeholders.

Companies have a responsibility to provide access to remedy for workers, communities and other stakeholders impacted by their operations. The UNGPs set out criteria for grievance mechanisms to be effective, such as being accessible, equitable and transparent. We independently assess the strength of existing mitigation and remediation measures, and provide recommendations to improve practices.

Businesses have a responsibility to prevent or mitigate adverse human rights impacts that are directly linked to their operations through their business relationships. Drawing on approaches from our industry-leading business intelligence practice, we evaluate the human rights track record of prospective and current business partners (such as acquisition targets, suppliers, customers and joint venture partners) to identify risks, propose mitigating actions and plan engagement strategies.

Businesses often lack detailed information on their third parties’ internal policies and procedures. They may want or need to conduct an “outside-in” assessment using publicly available information. We build a nuanced picture of the third-party’s track record without requiring inside access. Our approach combines deep public record research, analysis of publicly available policies, and conversations with local country and sector experts as well as contacts in the human rights, NGO and activist space.

Before a new relationship, businesses need to know what they are getting into. Our analysis helps businesses identify “red flags” relating to human rights and potential gaps in policies. We identify, contextualise and prioritise risks, based on the country context and international frameworks, such as the UN Guiding Principles on Business & Human Rights and the IFC’s Environmental and Social Performance Standards. We provide standalone reports or can combine this with integrity due diligence and broader ESG analysis.

We make actionable recommendations for how to mitigate identified human rights risks, focused on engaging with the business partner to understand their policies and identify areas for improvement. We also provide ongoing support, monitoring third-party activities in high-risk sectors and existing human rights issues, and providing regular updates and guidance on engagement strategy.

Regulations increasingly mandate supply chain due diligence, with increased scrutiny on human rights risks beyond first tier suppliers. Wallbrook helps clients proactively manage potential and actual adverse human rights impacts throughout their supply chain and develop approaches to engage with high-risk suppliers globally.

Wallbrook supports the identification and prioritisation of human rights risks in complex supply chains through policy review, policy gap analysis, risk rating, and targeted risk assessments. Our risk analysis accounts for local risks, sector risks, sector standards, and relevant human rights frameworks.

We conduct targeted research to assess suppliers’ human rights track records and identify the highest risks for exposure to modern slavery and other concerns. We engage with our global network, including activists, journalists, workers’ rights organisations and investigators on the ground, to obtain first-hand information regarding suppliers’ track record. We analyse findings to formulate recommendations for policy upgrades and new practices, and flag cases that warrant further due diligence.

We facilitate engagement with suppliers on working conditions and recruitment practices. We visit supplier sites, review policies and interview management and workers to carry out gap analysis against the clients’ policies and leading frameworks, and provide recommendations for clients to use their leverage to drive up standards and performance.

We help investors assess human rights risks at the portfolio and investee level, including supply chain issues in their prospective and active investments. We carry out in-depth risk assessments (e.g., for investments in high-risk sectors and regions) and provide tailored analysis on critical issues.

Leading investors are increasingly going beyond analysing financially material risks in their portfolios, to assess their most salient human rights risks – those that present the most severe potential impact to people.

We leverage our experience in assessing human rights risks for corporates and our regional expertise to help investors screen portfolios for their highest risk assets.

We also help investors get ahead of supply chain issues pre-transactions, spotlighting high risk sectors and regions, providing tailored analysis on critical issues.

We prioritise actual and potential impacts based on their saliency, focusing on the risks that are most severe in scale and scope and the most difficult to remediate, as well as the level of influence and control investors have over the asset.

We make recommendations and design action plans for investors to engage with and monitor their highest risk holdings, tailored based on the type of investment and level of control.

When our clients receive reports of wrongdoing in their operations, they come to Wallbrook to carry out an independent investigation and advise on next steps.

We support our clients to understand and respond to allegations of human rights abuses, whether from internal (e.g. whistleblower) or external reporting (e.g. the press and NGOs). We analyse publicly available information and company documents, and speak to former employees and experts on the ground, to provide an independent assessment of the facts. As well as intelligence gathering, we interview victims, witnesses, whistleblowers and other parties familiar with the matter. Our team has experience conducting fact-finding exercises to support external counsel.

We evaluate allegations in the context of local law and international human rights and labour standards. Based on our findings, we make actionable recommendations in line with leading international frameworks, such as the UN Guiding Principles on Business & Human Rights and the IFC’s Environmental and Social Performance Standards, including on providing remedy if an adverse human rights impact has occurred.

Our team has deep experience leading desktop and field investigations into labour and human rights abuses, including discreet “outside-in” investigations.  Our foundational principle for engaging with stakeholders is to Do No Harm. We seek to undertake ethical, responsible and safe research ensuring the wellbeing of our staff and those we interview.

We work with human rights law firms to achieve justice for communities harmed by corporate wrongdoing. These companies often have a pattern of bad behaviour and lack credible human rights policies. Leveraging our backgrounds in advocacy, human rights investigations and due diligence, we conduct fact-finding investigations, gathering testimony from impacted groups and compile evidence from media, NGO reports and court records to strengthen the case for partner firms and their clients.

We leverage our expertise to provide NGOs with cutting edge research on critical human rights and environmental issues. Leading organisations such as the World Wildlife Fund (WWF-UK), call on our expertise to inform their advocacy efforts for more sustainable policies.