Communicating efforts to prevent and address impacts is a critical step in the human rights due diligence process. FIs should be prepared to demonstrate the effectiveness of its efforts which requires proactive communication with affected stakeholders and other relevant groups.

The UNGPs deliberately use the word ‘communicating’ to emphasise that human rights due diligence encompasses a broader spectrum of ways to convey information to stakeholders than formal reporting alone. An FI should therefore assess the best means of communication for each of its relevant stakeholder groups. It is important to note that FIs which are involved with severe human rights impacts should report formally on their efforts to prevent and address them.

How should FIs communicate on human rights in the context of own operations and consumer lending?

Communicating on human rights performance within an FI’s own business operations and consumer lending operations is important for both internal and external audiences.

  • Internal reporting (e.g. to employees, management team) can foster accountability and helps identify areas for improvement. Employees and other workers may be best reached through internal newsletters and other means that the company normally uses to inform them of important developments. A trade union (where workers are unionised), works council or workers’ committee are important mechanisms through which to communicate performance on specific issues concerning workers. The level of communication may be more informal, depending on the issue; team meetings may present a good opportunity to engage in dialogue.
  • External or public reporting can demonstrate commitments to human rights to regulators, stakeholders, and partners (including commercial partners and suppliers). Communicating to customers or civil society can serve an important awareness raising function while also contributing to improved accountability. In all cases, reporting should reflect actual practice.


Increasingly, FIs are identifying their roles as an employer, as a purchaser of goods and services, and as a provider of financial services in their human rights communications, alongside lending and investment activities. In practice, this requires close coordination between departmental leads for human rights reporting, and those responsible for key areas, such as human resource management, procurement and contractor management, as well as consumer lending operations.

    

    

                        

                    


                

                    
                


                

                    

                        
Communicating on workforce human rights issues should include an overview – and where relevant update – of:


    

  • Approaches to identify salient risks for the workforce (and a definition of which rightsholders are included in the definition of the workforce, such as contract workers and agency staff), including assessment, prioritisation and stakeholder engagement, and the outcomes of this process
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  • How salient workforce risks are managed through policies and processes, as well as relevant workplace initiatives and programmes to address one or several of these risks, and training for FI staff
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  • How salient workforce human rights risks are monitored and tracked, including how effectively risks are managed
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  • How grievances are received and managed, as well as key outcomes and effectiveness / performance indicators
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  • Full explanation of how the FI provides access to remedy for its employees and non-employee workers, including the role of trade unions and recognised worker representatives.
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As a purchaser of goods and services, an FI should seek to communicate the following:


    

  • The FI’s potential contribution or link to potential human rights impacts through procurement practices, and mapping sectoral supply chains which are particularly relevant to FI procurement (e.g. services or ICT)
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  • An overview of assessment, prioritisation and stakeholder engagement (including key stakeholders such as trade unions) on salient risks associated with FI procurement practices, and the outcomes of this process
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  • How salient risks associated with procurement are managed through policies and processes for supplier / contractor due diligence, as well as supplier / contractor screening and on-boarding, contractual obligations and ongoing supply chain / contractor human rights performance measures, as well as training for FI staff
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  • An overview of the process to manage and monitor salient issues associated with procurement, including supplier / contractor human rights performance tracking metrics
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  • How affected stakeholders from within the FI’s supply chain or other commercial partners are able to access remedy, with a particular focus on supply chain workers’ access to effective grievance mechanisms, and the role of trade unions and recognised worker representatives
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  • How the above is informed by ongoing stakeholder engagement in relation to supply chains and service providers.
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As a provider of financial services to individuals, an FI can seek to communicate the following:


    

  • Approaches to identify salient risks for retail customers (including vulnerable groups within the customer base), including assessment, prioritisation and stakeholder engagement, and the outcomes of this process
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  • How salient risks for retail customers are managed through policies and processes, as well as relevant workplace initiatives and programmes to address risks (including training)
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  • How salient consumer lending human rights risks are monitored and tracked
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  • Full explanation of how the FI provides access to grievance and remedy for consumer lending customers
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  • How the above is informed by ongoing stakeholder engagement in relation to consumer lending.
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Increasingly, legislation also requires reporting on human rights. Reporting might involve dedicated human rights reports or human rights performance indicators might be integrated into broader institutional reporting frameworks (e.g. sustainability reports).


Although the content of reporting will vary by institution, key elements typically include:


    

  • Statement of most important (salient) human rights risks identified during reporting period, as well as any severe impacts on human rights
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  • Description of institution’s approach to identifying and managing human rights risks and impacts in relation to own-business operations and, where applicable, consumer and wholesale banking operations (e.g. relevant policies and strategies, risk management and monitoring processes and mechanisms, stakeholder engagement, etc.)
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  •  Reporting on key human rights performance indicators against specific policies / targets etc.
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  • Specific actions taken or to be taken by the institution in response to identified actual or potential adverse human rights impacts and description of broader ‘lesson learned’ where applicable
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  • Examples of good practices or new initiatives to promote human rights and improve institutional performance on human rights during the reporting period.
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Case studies and further reading






Case study: ING human rights reporting on own workforce and consumer banking




ING’s fifth annual Human Rights Report includes a focus on its own workforce, as well as an update on ongoing efforts to address the identified salient human rights issues in retail banking activities (first disclosed in the 2022 human rights review).


In 2023, ING carried out a new salient human rights issue assessment for its workforce, including internal as well as third-party and contract (self-employed) external workers. The assessment took into consideration the complaints raised by workers and the issues that local Human Resources observed. ING also engaged with its European Works Council (EWC). The assessment revealed that ING has the potential to cause, or to contribute to, three salient human rights issues with respect to its workforce: (1) Discrimination, (2) Work-related stress, and (3) Harassment.


The previous 2021/2022 Human Rights Review had identified three salient human rights issues that ING could be associated with in its role as a retail finance service provider: (1) Discrimination and lack of access to finance for basic needs, (2) Financial distress that threatens customers’ ability to meet their basic needs, and (3) Privacy breaches as a result of compromised integrity of customer data.