Embedding policy commitments

Objet de l’information

Disclosure 2-24 requires an organization to describe how it embeds each of its policy commitments for responsible business conduct throughout its activities and business relationships. This includes the organization’s specific commitment to respect human rights.

The disclosure must explain four elements for each policy commitment:

1. how responsibility for implementation is allocated across different levels within the organization;2. how the commitment is integrated into organizational strategies, operational policies and operational procedures;3. how the commitment is implemented with and through business relationships;4. the training provided on implementing the commitment.

The analysis should begin with the complete inventory of policy commitments reported under Disclosure 2-23. The organization should not select only those commitments for which implementation is most developed. Where several commitments use the same embedding arrangements, the organization can describe the common process and identify the commitments to which it applies.

For responsibility allocation, the organization can describe the most senior level with oversight of or accountability for implementation, the functions with day-to-day responsibility, their reporting lines and the reasons responsibility is assigned to them. It can also explain whether responsible business conduct is formally discussed by the highest governance body or senior executives and whether cross-functional or cross-level discussion mechanisms exist.

Oversight, accountability and day-to-day responsibility should be distinguished. The term “Board” should be used only where the Board is the organization’s highest governance body, and the official term “senior executives” should not be replaced automatically by broader internal categories such as senior leaders.

For integration, the organization should describe how policy commitments are aligned with risk-management systems, management policies, economic, environmental, social and human rights impact assessments, due diligence processes and financial or other performance incentives.

The organization should also explain how the commitments are applied when making decisions, such as decisions about sourcing, investment, operating locations, products, customers or projects, and the systems used to monitor compliance throughout activities and business relationships.

For implementation with and through business relationships, the organization can describe procurement and investment policies and practices, pre-qualification and screening criteria, bidding requirements, contracts, investment agreements, supplier codes and the use of commitments when deciding whether to initiate, continue, suspend or terminate a relationship.

The disclosure can also explain how the organization enables or supports business partners and other parties through capacity building, peer sharing or corrective-action support, and any incentives offered for implementation, such as price premiums, increased orders or long-term contracts.

For training, the organization should describe the content, audience, mandatory status, form and frequency of the training and any methods used to assess effectiveness. It should explain whether training covers general implementation or specific situations and whether it is provided to workers, persons with day-to-day responsibility, persons with oversight or accountability, business partners and other relevant parties.

Numbers or percentages of workers, business partners or other parties trained are optional additional information. Where such metrics are reported, the eligible population, denominator, overlapping groups and reporting-period basis should be defined clearly.

The disclosure should report actual implementation. Where a commitment has not yet been embedded in a particular activity, function, geography or relationship type, the organization should state this directly rather than narrowing the reporting boundary or implying full implementation.

If a required policy, practice or process does not exist, the organization can comply by reporting this fact. Reasons for omission are permitted for Disclosure 2-24 where required information 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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