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.
​
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 4

our approach

financial materiality

Stakeholder Engagement Main Page > Four Pillars > ​Effectiveness Criterion 3

3. A Focus on Those Most at Risk​​​

The company prioritizes engagement with the rights holders who are most likely to be harmed by its operations, and therefore where early engagement is critical.

what this means

questions for portfolio companies

What to look for

Issue & SEctor considerations

FOR workers

High risk situations

Companies should have in place an affected stakeholder prioritization plan that includes the following: 

• An impact and saliency assessment to identify the most vulnerable rights holders that are likely to be affected (TNFD 2023, 28; OECD 2017, 47-48).
  A company’s operations, products, or services can affect stakeholders to different degrees. In planning their engagement, companies should prioritize stakeholders based on severity, defined by the UNGPs as the impact’s scale (extent of the impact), scope (how widespread the impact is), and remediability (how easily the harm can be addressed), and likelihood of the harm occurring. Special attention must be paid to vulnerable groups—such as Indigenous communities, migrant and contract workers, women, children, and civilians in conflict—as well as local context factors like historical grievances or low trust from unresolved tensions (OECD 2017,  48–49). Early contact with the most vulnerable stakeholders prior to the start of a project or development of a new product is crucial to establishing a social license to operate.
  
  
  
• An assessment of barriers to engaging with affected stakeholders and a plan for how to overcome them​​.
  Vulnerable groups—such as contract and informal workers, people with disabilities, women and children, undocumented workers, displaced populations, and civilians in conflict—are often overlooked because they fall outside formal consultation channels or are less vocal. Companies should make a deliberate effort to reach out to these groups to ensure their perspectives and rights are not overlooked in decision-making and risk mitigation efforts.
  
  Companies should assess the unique vulnerabilities and participation barriers that affected stakeholders face, and develop plans to address them. Common obstacles include language differences, historical grievances, and threats to land and livelihoods. Special attention is required for groups with protected status– such as Indigenous Peoples under UNDRIP and ILO Convention 169– who are entitled to FPIC. Since rights holders’ needs evolve and new barriers may arise, engagement strategies should be revisited and updated regularly throughout a project’s lifecycle or operational changes (TNFD 2023, 28; OECD 2017, 49).
  
  Additionally, not all members of a group will share the same concerns or priorities (IFC 2007, 13). Within any group, the most vulnerable—those with the least power—often bear the greatest harms yet gain the fewest benefits from a project. When planning engagement, companies should give priority to these sub‑groups, even if they lack influence in the broader community (OECD 2017, 47–48).​

Example: Women and girls
Women and girls often face distinct challenges, such as low or unpaid labor, debt bondage, precarious employment, denial of land rights, and gender-based violence and harassment. In addition, companies should take into account women and girls’ societal responsibilities that may hinder their participation—such as caregiving duties – and particular challenges, such as limited access to transportation, payment of wages directly to a male family member, lack of menstruation supplies, and harassment and other safety concerns. Gender norms can restrict women’s ability to speak openly, particularly in mixed-gender settings, where fear of retaliation or social backlash may further silence their voices. To address these challenges, companies may benefit from organizing separate meetings with women at times that accommodate their schedules and in settings where they feel comfortable—such as spaces without the presence of men or government officials.

• At each stage of the project lifecycle or during business activity changes, identify the most vulnerable affected stakeholders and determine when each stakeholder group will be engaged, with a rationale based on the specific project phase or activity change for each group’s approach.
  Once the project progresses beyond this initial phase, ongoing engagement and communication with stakeholders and their representatives remain vital to maintaining trust and ensuring smooth business execution without delays. It is essential to recognize that stakeholders’ concerns, views, and perspectives may evolve over the course of the project's lifecycle. Therefore, stakeholder prioritization should be regularly reassessed to reflect these changing dynamics and contexts (IFC 2007, 17-18).