Policy commitments

Objet de l’information

Disclosure 2-23 requires an organization to describe its overall policy commitments for responsible business conduct, including its specific policy commitment to respect human rights. The disclosure is not limited to policies associated with material topics or to material impacts, risks and opportunities.

Policy commitments can be set out in a standalone policy or across several documents, such as a Code of Conduct, Human Rights Policy, Environmental Policy or Business Partner Code. The organization should describe the expectations, values, principles and norms of behaviour established by the commitments rather than only listing document titles.

The organization must identify the authoritative intergovernmental instruments referenced by its policy commitments. These should be distinguished from private standards, certifications and voluntary initiatives in which the organization participates.

The organization must report whether the policy commitments stipulate conducting due diligence. Due diligence is the process used to identify, prevent, mitigate and account for how the organization addresses its actual and potential negative impacts. Financial, legal, acquisition, KYC or supplier-screening procedures should not be presented as responsible-business-conduct due diligence unless they address this purpose.

The organization must report whether the policy commitments stipulate applying the precautionary principle. The official term “precautionary principle” should be used rather than general expressions such as “precautionary approach”, “cautious decision-making” or “risk-based thinking”.

The organization must report whether its policy commitments stipulate respecting human rights. It must also separately describe its specific policy commitment to respect human rights, including the internationally recognised human rights covered and the categories of stakeholders, including at-risk or vulnerable groups, to which the commitment gives particular attention.

Internationally recognised human rights include, at a minimum, the rights set out in the UN International Bill of Human Rights and the fundamental rights established in the ILO Declaration on Fundamental Principles and Rights at Work. If the commitment covers all internationally recognised human rights, a brief statement of this fact is sufficient. If it covers only selected rights, the organization must identify those rights and can explain the limitation.

The stakeholder categories and at-risk or vulnerable groups reported should be those given particular attention in the policy commitment itself. A stakeholder assessment or impact assessment can support the commitment but should not be used as a substitute for the policy wording.

For each policy commitment, the organization must provide a public link where the commitment is publicly available. Where it is not publicly available, the organization must explain the reason. An intranet or restricted portal is not a public source.

The organization must report the approval level of each policy commitment and whether it is the organization’s most senior level. The most senior level can be the highest governance body or the most senior executive, depending on the organization’s governance structure. Committee approval should not automatically be treated as approval at the most senior level.

The organization must report the extent to which each commitment applies to its activities and business relationships. Where a commitment applies only to selected activities or relationship types, these should be identified. The organization should also explain whether business relationships are obligated to comply with the commitments or are only encouraged to align with them.

The organization must describe how the commitments are communicated to workers, business partners and other relevant parties. It can additionally explain whether the commitments must be read, agreed to or regularly signed, the communication channels used, and how barriers are removed through accessible formats and relevant languages.

Communication under Disclosure 2-23 should be distinguished from embedding and implementation under Disclosure 2-24. Allocation of responsibility, integration into operational procedures, implementation through business relationships and implementation training are reported primarily under Disclosure 2-24.

If a policy commitment or practice does not exist, the organization should report this fact directly. Reasons for omission are permitted for Disclosure 2-23 where required information exists but cannot be reported. In that case, the affected requirement, applicable reason and required explanation must be provided in the GRI content index.

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