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

 Questions for Portfolio Companies

• Do you know who the most vulnerable workers are in your value chain? Have you taken steps to reduce barriers to social dialogue for these groups?
• What methods do you use to measure worker satisfaction and how often do you conduct these assessments?
  ​

What to look for
​There are several ways companies can identify high-risk workers, including those in high-risk geographies or hazardous industries, as well as those engaged in piece-rate or informal work.
​

• The International Trade Union Confederation’s (ITUC) Global Rights Index provides an annual assessment of how well countries protect the fundamental rights and freedoms of workers and trade unions. 
• Local unions play a critical role in protecting worker rights and must be part of any engagement process. 
• While many unions are working to better include marginalized people—including women and migrant workers[1] — this is not always guaranteed. For this reason, and because the most vulnerable workers may fall outside traditional union structures, companies should also consult local CSOs. 

To ensure vulnerable groups are not overlooked, companies may need to do targeted outreach or separate consultations.[2]

---

[1] “Unions in Latin America’s Energy Sector Work towards a Gender-Sensitive Just Transition,” IndustriALL, May 8, 2025, https://www.industriall-union.org/unions-in-latin-americas-energy-sector-work-towards-a-gender-sensitive-just-transition.
[2]Global Compact Network Germany and twentyfifty Ltd, “Stakeholder Engagement in Human Rights Due Diligence: A Business Guide” (Federal Ministry for Economic Cooperation and Development, October 2014), 13, https://www.globalcompact.de/migrated_files/wAssets/docs/Menschenrechte/stakeholder_engagement_in_humanrights_due_diligence.pdf#:~:text=When%20engaging%20representatives%20and%20experts%2C,could%20be%20excluded.