Processes to remediate negative impacts

Objet de l’information

Disclosure 2-25 requires an organization to describe its commitments and processes for providing for or cooperating in the remediation of negative impacts that it identifies it has caused or contributed to.

Where a negative impact is directly linked to the organization’s operations, products, or services by a business relationship and the organization has not contributed to the impact, the organization is not responsible for providing for or cooperating in remediation. It can, however, play a role in remediation. Directly linked impacts should therefore be addressed separately from impacts caused or contributed to.

Remedy or remediation means the means used to counteract or make good a negative impact. Depending on the circumstances, remedies can include apology, restitution, restoration, rehabilitation, financial or non-financial compensation, guarantees of non-repetition, injunctions or sanctions. Internal corrective or disciplinary action should not automatically be presented as remedy for an affected stakeholder.

The organization must describe its approach to identifying and addressing grievances, including the grievance mechanisms it has established or participates in. A grievance mechanism is a routinized state-based or non-state-based, judicial or non-judicial process through which stakeholders can raise grievances and seek remedy.

Grievance mechanisms should be distinguished from whistleblowing mechanisms. Whistleblowing mechanisms enable individuals to report wrongdoing or breaches of law regardless of whether the reporters themselves have been harmed and are reported under Disclosure 2-26. A shared channel can be relevant to both disclosures only where its different purposes, users and processes are explained clearly.

The organization should identify the intended purpose and users of each grievance mechanism, the impacts or topics it covers, how it operates and who administers it, whether it operates centrally or locally, how grievances are investigated, whether information is communicated to the highest governance body, how confidentiality and non-retaliation are protected, and whether users can raise grievances anonymously or through a third-party representative.

Grievance mechanisms can include operational-level mechanisms, collective-bargaining mechanisms, state-based judicial and non-judicial mechanisms, industry-association mechanisms, and mechanisms administered by international organizations, civil-society organizations or multi-stakeholder initiatives.

The organization must also describe other processes through which it provides for or cooperates in remediation. These are processes other than grievance mechanisms and can lead to remediation without a formal complaint, for example when an actual impact is identified through an impact assessment, human rights due diligence, monitoring, an audit or a civil-society report.

The organization must describe how stakeholders who are intended users of its grievance mechanisms are involved in their design, review, operation and improvement. General stakeholder engagement should not be presented as intended-user involvement unless it specifically concerns the grievance mechanisms and influences how they are designed or operated.

The organization must describe how it tracks the effectiveness of grievance mechanisms and other remediation processes and provide examples of effectiveness, including stakeholder feedback. Effectiveness can be assessed against the UN Guiding Principle 31 criteria: legitimacy, accessibility, predictability, equitability, transparency, rights-compatibility, continuous learning, and, for operational-level mechanisms, engagement and dialogue.

The organization can additionally report how intended users are informed and trained, the hours and languages in which mechanisms are available, non-retaliation protections, user satisfaction, the number and types of grievances, percentages addressed, resolved and resolved through remediation, repeated or recurring grievances, and changes made in response to lessons learned.

Quantitative grievance information is optional and is unlikely to be sufficient on its own. A low number of grievances can mean that few incidents occurred, but it can also indicate that intended users do not know about or trust the mechanism. Closure rates should not be presented as remediation rates unless the reported cases resulted in remedy.

The operation of grievance mechanisms and other remediation processes is reported under Disclosure 2-25. Actual actions taken to remediate negative impacts for material topics are reported under GRI 3-3-d-ii. Environmental remediation falls within Disclosure 2-25 only where it is connected to impacts on stakeholders or to grievances raised by stakeholders.

If the organization has not established or does not participate in a grievance mechanism, does not have other remediation processes, does not involve intended users, or does not track effectiveness, it should report this fact directly. Reasons for omission are permitted where required information exists but cannot be reported; the affected requirement, applicable reason and required explanation must then be provided in the GRI content index.

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