Embed in management systems

1. Embedded commitment: The company has a policy commitment to ongoing stakeholder engagement, and embeds it in its governance, culture, and management strategy.​

Create a Tailored Engagement Plan​

2. Inclusiveness: The company listens to a full range of rights-holders across the value chain and has a process to identify legitimate representatives.
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3. A Focus on Those Most at Risk​:  The company prioritizes engaging with the rightsholders who are most likely to be harmed by its operations​, and therefore where early engagement is critical.​​

Conduct appropriate  activities

​​4. Informed Participation: The company establishes ongoing, two-way communication with affected rights holders that provides affected stakeholders with relevant critical information well in advance of key decision points.

5. Trust and Accountability: The company establishes procedures, tailored to the context, to build rights holder trust and accountability for its actions.​

Ensure follow through

6. Stakeholder-informed Action Plan: The company analyzes information obtained through affected stakeholder engagement and collaborates with rights holders to formulate an action plan.

7. Monitoring, Transparency, and Continuous Improvement​: The company establishes and maintains a transparent and stakeholder-informed monitoring and evaluation (M&E) system.​

effectiveness criterion 3

our approach

financial materiality

Stakeholder Engagement Main Page > Four Pillars > ​Effectiveness Criterion 2

2. Inclusiveness​​​

The company listens to a full range of rights holders and has a process to identify legitimate representatives.

what this means

questions for portfolio companies

What to look for

Issue & SEctor considerations

for workers

High risk situations

Considerations in relation to agriculture, forestries, and fisheries

• In the agricultural, forestry and fisheries sectors,smallholder farmers and fishers and their families who often work alongside, are particularly vulnerable to market fluctuations, climate impacts, and land insecurity.[1] 
  
  

Considerations in relation to digital technologies: 

• The ubiquity of technology makes mapping and identifying stakeholders particularly challenging. The approach to identifying affected stakeholders will vary depending upon the nature of the product, service, or technology, geographic reach, intended use, and anticipated impacts.[2] To understand privacy, AI bias, or censorship issues and their impact on marginalized and vulnerable communities, the company can be engaging with digital rights organizations – for example the Global Network Initiative in the case of privacy and the Collective Impact Coalition (CIC) for Ethical AI in the case of AI bias.[3] Snowballing, a method of leveraging existing connections to identify stakeholders to consult, can help a company reach underrepresented people.[4]
  
  
• The degree of respect for rule of law in a country context is a key determinant of risk to users and therefore companies should take it into account when conducting stakeholder mapping. Where freedoms are restricted, stakeholders often face risk of reprisal for participating in engagement and grievance processes. In such settings, safeguarding the anonymity of rights holders is essential to enabling meaningful participation.
  
  

Considerations for communities surrounding large-scale land-based investments: 

• Mining operations can create downstream effects, especially when operations are located near rivers, roads, or railways, which can extend the reach of those impacts (OECD 2017, 39). 
  
  
• Land-based projects can frequently affect the rights of Indigenous Peoples, particularly their right to FPIC, as well as civilians in armed conflicts that are oriented around ownership over contested territories.
  
  

Considerations for the financial services sector: 

• Financial institutions should pay particular attention to the unbanked, underbanked, small-scale entrepreneurs, rural communities, elderly individuals, and low-income borrowers – the populations who are most at risk of harm, including by exclusion. Alongside barriers to access to financing, these individuals are vulnerable to unfair fees, predatory lending, or discriminatory practices.[5] Identifying who is excluded from financial models can help uncover hidden risks
  
  
• Like any company, financial institutions must conduct their own robust due diligence to understand the upstream and downstream social and environmental impacts of the projects they finance.[6]

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[1] Verité, “Coffee Project: Guidance on Stakeholder Engagement” (Verité, n.d.), 9, http://verite.org/wp-content/uploads/2024/02/coffee-project-tool9-guidance-stakeholder-engagement.pdf.
[2]  Emil Lindblad Kernell and Cathrine Bloch Veiberg, “Cross-Cutting: Stakeholder Engagement Guidance on HRIA of Digital Activities” (The Danish Institute for Human Rights, 2020), 11, https://www.humanrights.dk/files/media/document/Cross-cutting_%20Stakeholder%20Engagement_ENG_accessible.pdf.
[3] “Investing in Stakeholder Engagement for Improved Digital Technologies” (Business and Human Rights Resource Center, April 2024), 2, https://media.business-humanrights.org/media/documents/2024_Tech_investor_briefing.pdf.
[4] Emil Lindblad Kernell and Cathrine Bloch Veiberg, “Cross-Cutting: Stakeholder Engagement Guidance on HRIA of Digital Activities” (The Danish Institute for Human Rights, 2020), 11-12, https://www.humanrights.dk/files/media/document/Cross-cutting_%20Stakeholder%20Engagement_ENG_accessible.pdf.
[5] Kindra Mohr, “Fintech: Managing Human Rights Risks to Maximize Social Benefits | Blog | Sustainable Business Network and Consultancy | BSR,” BSR (blog), April 3, 2025, https://www.bsr.org/en/blog/fintech-managing-human-rights-risks-to-maximize-social-benefits.
[6] Deloitte, “The Upside to Being Upstanding: The Human Rights Imperative for Banks” (Deloitte, n.d.), 6, https://www2.deloitte.com/content/dam/Deloitte/us/Documents/financial-services/us-the-upside-to-being-upstanding--the-human-rights-imperative.pdf#:~:text=“duty,keep%20out%20of%20the%20market.