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Business and Human Rights:

A PRACTICAL GUIDE
Business and human rights: A practical guide
Business and human rights: A practical guide

Robert Bourns
President

Foreword
We hope our guide on business and human rights will be a We have worked to ensure there is awareness of business and
useful resource for all practitioners and firms, including those human rights in the legal profession. We have asked solicitors
working in specific practice areas of law such as corporate to start by looking within their own firms and businesses
governance, enterprise risk management, reporting and to assess their human rights impact. We encouraged firms
disclosure and disputes. It builds on existing resources, such to consider adopting steps to manage risks and prevent
as the IBAs Business and Human Rights Guidance for Bar and tackle potential abuse. We also encouraged solicitors
Associations and the IBAs Practical Guide on Business and and firms to look outside their own firms and consider how
Human Rights for Business Lawyers and its reference annex best to support their clients, including compliance with the
launched in 2016. requirements of the Modern Slavery Act 2015.

Promoting business, human rights and supporting the I am delighted that the legal profession is very engaged with
legal profession is central to the our work. We believe that this subject. Across the country firms and practitioners are
promoting business growth and respecting human rights leading by sharing peer learning and experience to ensure
go hand in hand. We were one of the first national bar that in their own supply chains and advice to clients human
associations to launch a national engagement programme rights are fully respected and risks are mitigated. I very
on the United Nations General Principles on Business and much hope that this guide is a useful resource for this work
Human Rights (UNGPs) and actively campaigned on this to be facilitated and enhanced, supporting our members as
issue for a number of years at home and internationally. trusted advisors of their clients and businesses in which they
are employed.

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Business and human rights: A practical guide

1. Business and human rights in the legal


profession in England and Wales
Human rights are relevant to solicitors and law firms as legal C
 ommercial supplier relationships and the goods
service providers and as businesses themselves. and services purchased to support the firms
operations, including outsourcing arrangements;
1.1 Legal advisers and business (e.g. agency staff for cleaning and security, suppliers
and human rights of stationary and catering) and

In their role as legal advisers, solicitors - both in-house Employment practices and health and safety.
counsel and external advisers - are increasingly asked by
clients to help them understand their responsibilities with They may consider making the respect for human rights
respect to human rights and how it may impact their part of their mission statement or law firms values and
business activities. ensuring that there is a clear culture in their organisations
to treat everyone with dignity and respect.
Business and human rights related issues may arise in a
variety of areas in which solicitors provide legal advice, such Law firms may also adopt a company policy on human
as transactional, advisory, and litigation work. rights, distribute it among employees, suppliers, and other
stakeholders. Firms may also clarify how the policy benefits
Solicitors play a key role in assisting their clients to identify the law firms activities, and how its clients, staff and others
human rights related risks and to devise strategies for benefit from the expectations set out in the policy. Firms
avoiding adverse impacts. may also consider having procurement rules which allow
for the exclusion of a tender where there is information
It may be the case that clients are unaware of developments showing misconduct by the company.
in business and human rights, in which case solicitors are
encouraged to raise awareness of legislation, policy and Moreover, training may be provided to employees in
international and national principles on the subject when functions relating to risk and compliance, procurement,
giving their advice. Businesses can then decide whether to and human resources, as well as to contractors in order
establish internal mechanisms to identify potential human to develop skills and experience that will allow them to
rights risks and mitigate them, as well as integrate principles identify human rights related risks and take appropriate
on business and human rights into their corporate policies measures to support these. This could include, making sure
and reporting frameworks. Such measures may also benefit that the agency staff that they retain are treated fairly and
a companys reputation, since it will be seen by the public paid properly.
and industry peers as adhering to international best practice.
Regarding client relationships, solicitors may decide to
1.2 Law firms as business enterprises conduct a human rights due diligence on their clients
in addition to complying with applicable regulatory
The manner in which a law firm operates has an effect on its requirements concerning, for example, conflicts of interest
management, employees, service providers, suppliers, and and anti-money laundering. The outcome of such a due
clients. Law firms have their own supply chains, procurement diligence could be shared with the relevant fee-earners who
processes and employment practices. Therefore, appropriate provide legal services to the client so that they are better
measures should be taken to prevent any adverse impact by able to:
themselves adhering to international and national standards.
Identify potential human rights related risks associated
Law firms may wish to focus their human rights impact with the client and its instructions and discuss these
assessment on the following three areas: with colleagues and the client, as required;

C
 lient relationships and the legal services provided
pursuant to those relationships

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Business and human rights: A practical guide

Raise and explore with the client human rights issues 1.3 Further guidance
that may be relevant to the legal advice required; and
Further guidance for businesses in general and the relevant
Integrate any potential outcomes of the human rights links to legislation, policy and international instruments can
due diligence into retention letters, legal advice and be found in appendix b the Further Resources section on
case management. page 11. Solicitors may wish to familiarise themselves with
information relevant to their practice areas, client base and
mode of operation.

2. Impact of human rights on UK


businesses, solicitors and law firms
2.1 United Nations Guiding Principles Furthermore, a surge in new legislation invoking common
on Business and Human Rights (UNGPs) principles such as the UNGPs, has included the EU Non-
Financial Reporting Directive (2014/95/EU), which is due to
Although the UNGPs and other international principles do be transposed into law in the UK by the end of 2016 which
not directly give rise to legal obligations, they have received will require large public interest entities to disclose in their
wide support as instruments that establish best practice for management report relevant information on their policies,
the private sector. main risks and outcomes relating to, amongst other areas,
respect for human rights.
The UNGPs were issued by UNs Human Rights Council in
2011 and unanimously endorsed. Ever since, the Principles 2.2 The Modern Slavery Act 2015
have been considered as an authoritative reference point
for businesses behaviour and are recognised as such by the An example of the importance of international standards on
Committee of Ministers of the EU, the G7 and incorporated business and human rights and their incorporation into the
in important frameworks such as the OECD Guidelines domestic legal framework is the UK Modern Slavery Act 2015.
on Multinational Enterprises, the UN Global Compact on
Human Rights and Labour Principles and the European The Act came into force in 2015 and includes a provision
Parliament directive on disclosure of non financial and to encourage business to take action to ensure their end-
diversity information. to-end supply chains are free from slavery. It also requires
large businesses, with an annual turnover of 35 million that
Since the endorsement of the UNGPs, significant steps operate at least a part of their business in the UK, to issue
were taken by governments, businesses and consumers to an annual statement to confirm what steps, if any, have
identify, mitigate and tackle the impact of human rights in been taken to ensure that no forced labour or trafficking is
business. Governments developed national action plans on involved in their supply chains.
business and human rights - the UK was first and a number
of countries followed. Businesses, big and small, embedded These can relate to:
the principles in their own policies and practices. Consumers
all over are increasingly demanding transparency and (a) the organisations structure, its business and its
accountability in business. supply chains;

(b) its policies in relation to slavery and human trafficking;

(c) its due diligence processes in relation to slavery and


human trafficking in its business and supply chains;

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Business and human rights: A practical guide

(d) the parts of its business and supply chains where performance indicators to assess effectiveness.
there is a risk of slavery and human trafficking taking
place, and the steps it has taken to assess and The Guidance provides practical tips on what businesses
manage that risk; should include in the statement, how to structure the
statement, and what needs to be done once the statement
(e) its effectiveness in ensuring that slavery and human has been produced. The guidance also sets out what is
trafficking is not taking place in its business or expected of companies when they identify an incidence
supply chains, measured against such performance of modern slavery 2.
indicators as it considers appropriate; 2 Transparency in Supply Chains etc. A practical guide, Guidance issued
under section 54(9) of the Modern Slavery Act 2015
(f) the training about slavery and human trafficking
available to its staff. The Act as been successful so far; a recent review showed
that in its first year 289 modern slavery offences were
While the Act was largely welcomed, concerns were raised prosecuted in 2016 and that there was a 40 per cent
about its limitations and the lack of time businesses have to rise in the number of victims identified. To give it further
prepare. The reporting obligation applies to financial years strength, in July 2016 the Prime Minister set up the first ever
starting on or after the 1st of April 2016. Some changes that Government task force on modern slavery, with the goal of
businesses have put in place to comply with the Act are: working to enforcing the Act and announced the creation of
a 33 million International Modern Slavery Fund, which will
Developing anti-slavery and human trafficking policies; and/or focus on high-risk countries from which we know victims are
including these in corporate social responsibility (CSR) policies; regularly trafficked to the UK.

Developing processes to investigate business and supply 2.3 Updated National Action Plan 2016
chain (contractors, sub-contractors, suppliers, contracts,
etc.) to determine the level of risk or exposure to risk; The 2013 the UK Government was the first to issue a National
Action Plan to implement the UNGPs, which was updated in
Identifying and prioritising high risk areas in the supply 2016.
chain and planning and setting out what steps are being
taken to address the risks; The updated plan reaffirms the Governments commitment
to implementing the UNGPs, setting out the role
Appointing senior individuals within companies with Government can play in helping businesses fulfil their
responsibility for investigation, compliance and the responsibilities to respect human rights, for example through
production of the statement; the introduction of Section 172 of the Companies Act 2006,
requiring directors to consider the impact on the community
Identifying training needs within companies to ensure that of the companys operations, and its 2013 revision, requiring
all responsible staff involved in supply chain management them to take into account human rights issues when making
and procurement are aware of the new obligations; their annual strategic reports.

Putting effective grievance and whistle blowing The Plan also provides a clear set of key principles for businesses:
mechanisms in place to cover any concerns about slavery
or human trafficking within any business or supply chain. comply with all applicable laws and respect internationally
recognised human rights, wherever they operate;
The Government also released guidance on these new
provisions, which focuses on five key areas: seek ways to honour the principles of internationally
recognised human rights when faced with conflicting
describing business model and supply chain relationships; requirements;

policies on slavery including due diligence and auditing; treat as a legal compliance issue the risk of causing or
contributing to gross human rights abuses wherever they
training; operate;

risk evaluation and management, and;

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Business and human rights: A practical guide

adopt appropriate due diligence policies to identify, This case is a significant landmark as it is the first time a
prevent and mitigate human rights risks, and commit to court has awarded damages against a British company
monitoring and evaluating implementation; in relation to modern slavery issues. It also sends a strong
message to businesses that the courts can and will enforce
consult people who may potentially be affected at all these new rules.
stages of project design and implementation, in a manner
that ensures free and informed participation and takes into 2.5 Other measures related to business
account language and other potential barriers to effective and human rights
engagement, paying particular attention to indigenous
peoples and other groups, including women and girls; Besides the updated National Action plan and the Modern
Slavery Act, the Government is able to enforce the UNGPs
emphasise the importance of behaviour in line with the through international instruments and domestic legislation
UNGPs to their supply chains in the UK and overseas. or policy.
Appropriate measures could include contractual
arrangements, training, monitoring and capacity-building; The UK has ratified a series of international treaties and
agreements the International Labour Organisations eight
adopt or participate in effective grievance mechanisms core conventions, the International Covenant on Civil and
which are transparent, equitable and predictable, to Political Rights, the International Covenant on Economic, Social
enable the remediation of any adverse human rights and Cultural Rights and the European Convention on Human
impacts they cause or to which they contribute; Rights - which enshrine human rights and fundamental
freedoms and have been given effect through the law.
be transparent about policies, activities and impacts, and
report on human rights issues and risks as appropriate as Currently the Human Rights Act 1998 ensures that
part of their annual reports. individuals in the UK have a remedy for the breach of
rights which are protected by the European Convention on
These provisions will be especially relevant for General Human Rights. It applies to all public authorities and other
Counsel operating within large businesses. bodies performing public functions, as private companies
sometimes do.
2.4 The Houghton case
The relevant legal framework in the UK also includes
The courts have also played their part in recognising the employment regulations that require companies not to
authority of the UNGPs. In June 2016, the High Court discriminate against employees on grounds of sex, race,
issued a landmark civil litigation ruling against a company in sexual orientation and religious belief, and environmental
relation to modern slavery issues. In 2015, a group of six men regulations.
brought legal action against DJ Houghton Chicken Catching
Services, based in the South East of England. The UK has enacted or reviewed legislation and policy to
comply with good corporate behaviour and respect for
These men alleged that in 2012 they were trafficked from human rights. These include:
Lithuania to the UK where they had to work on farms as
chicken catchers in inhumane and degrading conditions. The Bribery Act 2010 where, in line with OECD
An investigation showed that the men were working in commitments, UK companies are liable in the UK for acts
supply chains producing free range eggs for McDonalds, of bribery committed anywhere in the world;
Tesco, Asda and M&S.
Section 172 of the Companies Act 2006, as mentioned
The men were taken into the care of the national referral above, which makes it clear that company directors
mechanism for victims of human trafficking, but no criminal have a duty to act in a way which they consider would
charges were brought. A civil claim was filed and was heard in be most likely to promote the success of the company
the High Court earlier this year. Mr Justice Supperstone ruled which include the interests of the companys employees
that the men were owed compensation for the companys and the impact on the community of the companys
failure to pay statutory minimum wages, charging prohibited operations. The Act was revised in October 2013 to ensure
job-finders fees, failure to provide adequate facilities to wash, that directors of quoted companies consider human rights
rest, eat and drink and for unlawfully deducting workers pay. issues when making their annual strategic reports.

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Business and human rights: A practical guide

These measures create a robust framework on business and Although this might include breaches of human rights, this
human rights, however, legislation could be strengthened seems to fall short of the Governments responsibility to
in other areas. Public bodies, for example, are only required assess and address any negative human rights impacts
to have due regard for equality-related issues in their in its supply chain. It remains unclear if the steps the
procurement activity. Bids for a contract may be excluded Government is taking to allow for human rights to be
if evidence of grave misconduct by a company is found. reflected in public procurement.

3. Human rights due diligence


A starting point for many businesses may be to develop The goal of human rights due diligence is to evaluate the
a human rights policy promulgating its commitment to specific human rights footprint of the business in addition
respect human rights and the steps to follow through this to its standard business due diligence (including any due
commitment. Such a policy should be publicly available diligence carried out on third parties, such as suppliers).
and shared with employees. It could set out a procedure The due diligence should be an assessment of current and
for carrying out human rights due diligence on business potential adverse human rights impacts. It also enables a
operations. This includes the identification of potential business to identify operational risks. When such impacts
adverse human rights impacts. Such impacts may arise and risks have been identified, this enables a business to take
through causation, contribution, or direct linkage. appropriate steps to prevent a risk from materialising and
make appropriate arrangements when an incident occurs.
Causation For example, a business can make adjustments across
departments to different operational processes.
A business can cause an adverse human rights impact
when its actions lead directly to that impact, whether Human rights due diligence should be proportionate to the
intentionally or unintentionally. size and complexity of the business and, in particular, to the
level of risk of adverse human rights impact. The UNGPs
Contribution implementation guide recognises that it is not feasible for
all businesses to perform a human rights due diligence
A business can contribute to an adverse human on every business relationship in order to assess whether
rights impact by incentivising, facilitating or enabling their involvement may give rise to a negative human rights
(intentionally or unintentionally) a third party such as impact. However, it is advisable that businesses pay special
a supplier, a contractor, or a client to commit a human attention to individuals or groups that may be particularly
rights violation. vulnerable or marginalised and would be at a heightened
risk of being adversely impacted by the business operations.
Direct linkage This could, for example, include an assessment of the
different impact of such operations on women and children.
Even if a business does not cause or contribute to an
adverse human rights impact, it may nevertheless be The UNGPs propose a pragmatic approach by which
directly linked to such impact through its operations or businesses should prioritise the most severe potential human
the services, or products it provides to its customers. rights impacts, i.e. the most severe in scope or scale, or where
a delay may cause irreversible harm.

The procedure for the human rights due diligence should


be updated regularly and the due diligence itself should be
carried out at appropriate intervals, taking into account that
a business operations may change over time.

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Business and human rights: A practical guide

4. How do business and human rights


principles relate to professional duties
of solicitors?
The UNGPs and the business and human rights field It is possible that, unless specifically instructed as part
more generally reinforce the mandatory provisions of of their retainer, solicitors would not consider themselves
many professional codes, including the SRAs Code of instructed, empowered or competent in the context of the
Conduct which applies to Law Society members. Solicitors particular client relationship to advise on non-legal risks.
professional duties such as upholding the rule of law and the It is, however, well established that where in the course of
proper administration of justice, acting with integrity, acting taking instructions a solicitor learns of facts which reveal the
independently and in the best interests of their clients and existence of obvious risks, the solicitor is required to do more
maintaining public trust relate to business and human rights. than merely advise within the strict limits of the retainer.

These professional duties apply to all solicitors, both in private There is a duty to call attention to and advise on those risks.
practice and in-house, and set out their obligations to their In doing so, the solicitor will not be going beyond the scope
clients and wider to society3. While there is no specific legal or of his or her instructions but merely reporting back to the
professional obligation to advise clients with regard to their client on issues of concern which he or she has learned of in
responsibility to respect human rights, by increasing their the course of carrying out express instructions 5.
competence and knowledge in this area, solicitors (and firms)
can seek to act in a manner which furthers both obligations. An issue that is currently being debated in many European
For many clients it is also consistent with their holistic view of Bar Associations is the extent to which, if at all, the UNGPs
legal risk management which they may expect their solicitors might extend that duty to a duty to advise on appropriate
to understand and be aware of. action to mitigate or remediate the risk of adverse human
rights impacts which are non-legal in the sense that they
However, it is important to note that [t]he UNGPs were do not evidence a specific breach of an established and
not intended to override or supplement legal professional binding legal rule in the context in which the clients activities
codes of conduct, given the critical role that lawyers play in are taking place. It is a developing area which will be revisited
upholding the rule of law and supporting the administration in future guidance or practice notes.
of justice. Nor were they intended to create extrinsic
expectations for a lawyers conduct, which are grounded in It is important to note that the UNPGs are just a starting
the scope of services for which the lawyer has retained the point and do not impact upon a clients entitlement and
client, the relevant laws, and professional standards that rights to access independent representation, assert a robust
govern a lawyers conduct 4. legal defence to claims that it has engaged in conduct that
violates human rights, to seek judicial determinations of
Professional duties allow solicitors to provide independent human rights issues and to seek and access legal advice and
advice to clients and consider non-legal contextual factors, counsel about these issues.
such as human rights impacts of the clients activities 3 Guidance to the former SRA Code of Conduct 2007 states that:
(however certain human rights impacts may also carry legal Lawyers, law firms and those who work in them serve both clients and
society. In serving society, you uphold the rule of law and the proper
consequences if caught by specific regulations concerned administration of justice. In serving clients, you work in partnership with
with human rights, e.g. the Modern Slavery Act). the client making the clients business your first concern. The core duties
contained in rule 1 set the standards which will meet the needs of both
clients and society.

4 Ibid

5 Credit Lyonnais SA v Russell Jones & Walker (a firm) [2002] EWHC


1310 (Ch)

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Business and human rights: A practical guide

Appendix A: The UNGPs


The international human rights of individuals are established rights, transnational corporations and other business
in a variety of international and regional declarations and enterprises. The latter elaborated the UNGP and a guide for
treaties. The instruments that most states have approved implementation, which were adopted by the United Nations
and ratified are the United Nations Declaration on Human Human Rights Council in its Resolution 17/4 of 16 June 2011.
Rights, the International Covenant on Civil and Political
Rights and the International Covenant on Economic, Social The UNGPs establish a framework of three inter-related
and Cultural Rights. pillars:

By ratifying these treaties, States commit to respect, (i) The State duty to protect against human rights
guarantee, and protect the rights established therein to the abuses by third parties, including business enterprises,
individuals under their jurisdiction. Therefore, the subjects through appropriate policies, regulation, and
to whom this normative framework applies are States and adjudication;
individuals (and sometimes groups of individuals). Under
certain circumstances, States can be held responsible (ii) The corporate responsibility to respect human rights;
for human rights violations committed by third actors, and
such as companies. However, companies themselves can
generally not be held directly accountable for human rights (iii) The need for greater access by victims of human
infringements under international law. This means that there rights abuses to effective remedy, both judicial and
is a lack of protection for individuals. non-judicial.

A company can be held accountable for human rights This Guidance focuses on the second pillar, since the first
violations under domestic law, depending on the national pillar addresses State obligations and the third pillar regards
legislation. However, legislation that incorporates human victims reparations.
rights may be lacking or deficient. Moreover, as a result of
the globalisation of financial and legal markets, companies The second pillar applies to all business enterprises, both
often operate transnationally so that its corporate entities transnational and others, regardless of their size, sector,
may be subject to different legal jurisdictions, making location, ownership and structure. It establishes the main
accountability for human rights violations more difficult. principle that businesses should avoid infringing on the
human rights of others and should address adverse human
In order to address this lack of protection, international rights impacts with which they are involved. In order to
standards have been elaborated that seek to guide address any adverse human impacts businesses should take
businesses on how to conduct their activities in accordance adequate measures of prevention, mitigation and, where
with human rights norms and how to identify and address appropriate remediation.
potential human rights violations. Such principles do not
create legal obligations, but represent an emerging standard The human rights that should be respected by businesses
of responsible business conduct. Businesses are encouraged are those rights enshrined in international treaties and
to assess the potential and actual human rights impact of declarations, including for example the rights set out in
their activities, on their employees and others, and adjust the International Labour Organisations Declaration on
their actions to prevent any adverse impact. Where such Fundamental Principles and Rights at Work.
impact does occur, businesses are expected to provide some
form of judicial or non-judicial reparation. The potential adverse impact on human rights differs
depending on the nature of a business operations. For
Although many documents have been elaborated (see a example, the right to life of employees and members of
list of resources at the end of this note), perhaps the most the local community may be at risk in industries that are
important are the United Nations Guiding Principles on engaged in activities such as mining. However, for a business
Business and Human Rights. The former United Nations that operates in retail, a potential adverse impact could
Secretary General Kofi Annan appointed Professor regard the prohibition on slavery and servitude, rather than
John Ruggie as his Special Representative on human the right to life.

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Business and human rights: A practical guide

As implementation of the UNGPs framework and other not only with the soft-law expectation that adverse human
practical expertise in the area of business and human rights rights impacts should be avoided or mitigated, but also pose
grows, tensions with solicitors existing duties may also arise. an actual conflict with Principle 1. Is the solicitor required to
For example, how should a solicitor or firm respond when it resume with the instruction unconditionally on the terms
discovers through its own due diligence that a client retainer requested by the client or perhaps consider withdrawing from
may produce an adverse human rights impact which the the instruction altogether? There are no clear and easy answers
client does not wish to address? In this situation, Principles to these questions. Guidance could be sought from the SRA
4 and 5 (the duty to act in the clients best interest, and to about navigating the solicitors duties in a specific situation.
provide a proper standard of service, respectively) may conflict

Appendix B: Further Resources


Further information on business and human rights can be European Commission: Non-financial reporting. http://
found in the following documents/websites: ec.europa.eu/finance/company-reporting/non-financial_
reporting/index_en.htmISO 26000 Social responsibility,
The Law Society Practice Note on the Modern Slavery Act http://www.iso.org/iso/home/standards/iso26000.htm
http://www.lawsociety.org.uk/support-services/advice/
practice-notes/modern-slavery-act-and-section-54/ IBA Guidance, May 2016. http://www.ibanet.org/Legal_
published on 6 December 2016 Projects_Team/Business_and_Human_Rights_for_the_
Legal_Profession.aspx
United Nations: Guiding Principles on Business and Human
Rights. http://www.ohchr.org/Documents/Publications/ Transparency in supply chains etc, A practical Guide, 20
GuidingPrinciplesBusinessHR_EN.pdf October 2015

United Nations: Global Compact A Structured Process to Modern Slavery Act 2015. http://www.legislation.gov.uk/
Prioritize Supply Chain Human Rights Risks. https://www. ukpga/2015/30/contents/enacted
unglobalcompact.org/library/2851
The Modern Slavery Act 2015 (Transparency in Supply
United Nations: The Corporate Responsibility to Respect Chains) Regulations 2015. http://www.legislation.gov.uk/
Human Rights An Interpretative Guide. http://www.ohchr. ukdsi/2015/9780111138847
org/Documents/Issues/Business/RtRInterpretativeGuide.pdf
Transparency in Supply Chains Consultation Document
United Nations: Working Group on the issue of human (Feb 2015) and Government Response (July 2015).
rights and transnational corporations and other business https://www.gov.uk/government/consultations/modern-
enterprises. http://www.ohchr.org/EN/Issues/Business/Pages/ slavery-and-supply-chains
WGHRandtransnationalcorporationsandotherbusiness.aspx
ILO Resources on Forced Labour, Human Trafficking and
Organisation for Economic Cooperation and Development Slavery. http://www.ilo.org/global/topics/forced-labour/lang-
(OECD): OECD Guidelines for Multinational Enterprises. -en/index.htm
http://www.oecd.org/daf/inv/mne/48004323.pdf
Business and Human Rights Resource Centre.
UK National Contact Point, make a complaint about a http://business-humanrights.org/
multinational enterprise. https://www.gov.uk/guidance/uk-
national-contact-point-for-the-organisation-for-economic- Robert Bourns, president of the Law Society, keynote
co-operation-and-development-oecd-guidelines-for- speech on the International Bar Association launch of
multinational-enterprises the Business and Human Rights Reference Annex.
http://www.lawsociety.org.uk/news/speeches/international-
Updated National Action Plan, May 2016. https://www.gov. bar-association-launch-of-the-business-and-human-rights-
uk/government/publications/bhr-action-plan reference-annex/

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