HUMAN RIGHTS POLICY

[ORGANIZATION NAME]

Policy Number: ________________
Effective Date: ________________
Last Revised: 2026-01-22
Policy Owner: ________________
Approved By: ________________

1. POLICY STATEMENT

1.1 Our Commitment

[Organization Name] is committed to respecting and supporting human rights in all aspects of our business. We recognize our responsibility to respect human rights as articulated in the United Nations Guiding Principles on Business and Human Rights ("UNGPs"), and we are committed to implementing these principles throughout our operations and value chain.

1.2 Guiding Frameworks

This policy is informed by:

☐ UN Universal Declaration of Human Rights - The foundational statement of human rights
☐ International Covenant on Civil and Political Rights
☐ International Covenant on Economic, Social and Cultural Rights
☐ UN Guiding Principles on Business and Human Rights - The authoritative global standard for business and human rights
☐ ILO Declaration on Fundamental Principles and Rights at Work - Core labor standards
☐ ILO Core Conventions - Fundamental labor rights conventions
☐ OECD Guidelines for Multinational Enterprises - Responsible business conduct guidelines
☐ UN Global Compact - Ten principles for responsible business

1.3 Scope

This policy applies to:

☐ All of [Organization Name]'s operations, activities, and relationships worldwide
☐ All employees, officers, directors, and contractors
☐ All subsidiaries and affiliates
☐ All business partners, suppliers, and other third parties acting on our behalf or in our value chain

2. GOVERNANCE AND ACCOUNTABILITY

2.1 Board Oversight

The Board of Directors has ultimate responsibility for human rights:

☐ The [Board/Committee Name] provides oversight of human rights matters
☐ Human rights performance is reviewed [quarterly/annually] at Board level
☐ The Board receives reports on salient human rights issues and due diligence activities

2.2 Management Responsibility

2.3 Human Rights Lead

A designated Human Rights Lead shall:

☐ Coordinate implementation of this policy
☐ Lead human rights due diligence activities
☐ Report to senior management and the Board
☐ Engage with stakeholders on human rights matters
☐ Monitor and evaluate human rights performance

3. HUMAN RIGHTS COMMITMENTS

3.1 Salient Human Rights Issues

Based on our operations and value chain, we have identified the following salient human rights issues:

Workplace:
☐ Freedom from discrimination
☐ Safe and healthy working conditions
☐ Fair wages and working hours
☐ Freedom of association and collective bargaining
☐ Privacy and data protection
☐ Freedom from harassment

Supply Chain:
☐ Forced labor and modern slavery
☐ Child labor
☐ Occupational health and safety
☐ Living wages
☐ Land rights and indigenous peoples' rights
☐ Environmental impacts on human rights

Communities:
☐ Right to a healthy environment
☐ Land and property rights
☐ Access to water
☐ Security and human rights
☐ Indigenous peoples' rights

Products and Services:
☐ Product safety and consumer health
☐ Privacy and data protection
☐ Responsible use of technology

3.2 Specific Commitments

3.2.1 Prohibition of Forced Labor and Modern Slavery

We prohibit:

☐ All forms of forced, bonded, or compulsory labor
☐ Human trafficking
☐ Debt bondage
☐ Involuntary servitude
☐ Withholding of identity documents
☐ Charging recruitment fees to workers

We commit to:

☐ Conducting due diligence to identify forced labor risks
☐ Implementing controls to prevent forced labor
☐ Publishing an annual Modern Slavery Statement
☐ Providing remedy if forced labor is discovered

3.2.2 Prohibition of Child Labor

We prohibit:

☐ Employment of children below the minimum working age
☐ Employment of persons under 15 (or 14 where ILO Convention 138 permits)
☐ Hazardous work by young workers (under 18)

We commit to:

☐ Verifying worker ages before employment
☐ Supporting remediation if child labor is discovered
☐ Addressing root causes of child labor in our value chain

3.2.3 Freedom of Association and Collective Bargaining

We respect:

☐ Workers' right to form and join trade unions
☐ Workers' right to bargain collectively
☐ Workers' right to organize without interference

We commit to:

☐ Not discriminating against union members
☐ Engaging constructively with worker representatives
☐ Providing alternative worker voice mechanisms where law restricts these rights

3.2.4 Non-Discrimination and Equal Opportunity

We prohibit discrimination based on:

☐ Race, ethnicity, or color
☐ Gender or sex
☐ Sexual orientation or gender identity
☐ Religion or belief
☐ Political opinion
☐ National or social origin
☐ Age
☐ Disability
☐ Pregnancy or family status
☐ Any other protected characteristic

We commit to:

☐ Providing equal opportunity in employment
☐ Addressing systemic discrimination
☐ Promoting diversity and inclusion

3.2.5 Safe and Healthy Working Conditions

We commit to:

☐ Providing safe and healthy workplaces
☐ Identifying and controlling workplace hazards
☐ Providing appropriate training and protective equipment
☐ Investigating incidents and implementing corrective actions
☐ Continuously improving health and safety performance

3.2.6 Fair Wages and Working Hours

We commit to:

☐ Paying at least legal minimum wages
☐ Working toward living wages
☐ Providing legally mandated benefits
☐ Respecting working hour limits
☐ Compensating overtime appropriately

3.2.7 Privacy

We commit to:

☐ Protecting personal data in accordance with applicable laws
☐ Using data only for legitimate purposes
☐ Implementing appropriate security measures
☐ Respecting individuals' privacy rights

3.2.8 Land and Indigenous Peoples' Rights

We commit to:

☐ Respecting land and property rights
☐ Obtaining free, prior, and informed consent (FPIC) from indigenous communities
☐ Engaging with affected communities
☐ Avoiding involuntary resettlement

3.2.9 Security and Human Rights

Where we engage security providers, we commit to:

☐ Conducting due diligence on security providers
☐ Requiring adherence to human rights standards
☐ Prohibiting excessive use of force
☐ Reporting and addressing any abuses

3.2.10 Environmental Human Rights

We recognize the connection between environmental impacts and human rights:

☐ Right to a healthy environment
☐ Right to clean water
☐ Right to health
☐ Right to food

We commit to managing environmental impacts that affect human rights.

4. HUMAN RIGHTS DUE DILIGENCE

4.1 Due Diligence Framework

In accordance with the UN Guiding Principles, we conduct ongoing human rights due diligence to:

☐ Identify actual and potential human rights impacts
☐ Assess the severity and likelihood of impacts
☐ Prevent and mitigate adverse impacts
☐ Track our performance
☐ Communicate how impacts are addressed
☐ Provide remedy for impacts we cause or contribute to

4.2 Identification and Assessment

We identify and assess human rights risks through:

☐ Human rights impact assessments (HRIAs)
☐ Country and sector risk assessments
☐ Stakeholder engagement and consultation
☐ Supplier assessments and audits
☐ Grievance mechanism data analysis
☐ External expert consultation

4.3 Prevention and Mitigation

We prevent and mitigate adverse impacts through:

☐ Integration into policies and procedures
☐ Contractual requirements for business partners
☐ Training and capacity building
☐ Monitoring and verification
☐ Supplier development programs
☐ Collaboration with stakeholders

4.4 Tracking Performance

We track our human rights performance through:

☐ Key performance indicators (KPIs)
☐ Audit and assessment results
☐ Grievance mechanism data
☐ Stakeholder feedback
☐ External benchmarks and ratings

4.5 Communication

We communicate our human rights performance through:

☐ Annual sustainability/ESG reports
☐ Human rights disclosures
☐ Modern Slavery Statements
☐ Stakeholder engagement
☐ Responses to inquiries

5. GRIEVANCE MECHANISMS AND REMEDY

5.1 Access to Remedy

We are committed to providing access to remedy for individuals and communities that may be adversely affected by our activities.

5.2 Grievance Mechanisms

We maintain grievance mechanisms that are:

☐ Legitimate - enabling trust and accountability
☐ Accessible - known and accessible to affected stakeholders
☐ Predictable - clear procedures with timeframes
☐ Equitable - fair treatment for all parties
☐ Transparent - keeping parties informed
☐ Rights-compatible - aligned with human rights standards
☐ Source of continuous learning - improving policies and practices

5.3 Reporting Channels

Concerns can be reported through:

5.4 Non-Retaliation

We prohibit retaliation against anyone who:

☐ Reports a human rights concern in good faith
☐ Participates in an investigation
☐ Exercises their human rights

5.5 Remedy

When we identify that we have caused or contributed to adverse human rights impacts, we will:

☐ Acknowledge the impact
☐ Engage with affected stakeholders
☐ Provide appropriate remedy, which may include:
- Apologies
- Restitution or compensation
- Rehabilitation
- Guarantees of non-repetition
- Changes to policies or practices

6. SUPPLY CHAIN AND BUSINESS RELATIONSHIPS

6.1 Supplier Requirements

We require our suppliers to:

☐ Comply with our Supplier Code of Conduct
☐ Respect human rights in their operations
☐ Conduct due diligence on their own suppliers
☐ Permit audits and assessments
☐ Implement corrective actions for non-compliance

6.2 Due Diligence on Business Partners

We conduct human rights due diligence on:

☐ Suppliers (particularly high-risk suppliers)
☐ Joint venture partners
☐ Agents and distributors
☐ Contractors and service providers
☐ Merger and acquisition targets

6.3 Leverage

We use our leverage to promote human rights by:

☐ Setting clear expectations in contracts
☐ Building supplier capacity
☐ Collaborating with industry peers
☐ Engaging with governments and regulators
☐ Supporting multistakeholder initiatives

6.4 Disengagement

We may disengage from business relationships when:

☐ Severe human rights abuses are identified
☐ The partner is unwilling to address issues
☐ Remediation efforts are unsuccessful
☐ Continued engagement would cause or contribute to harm

Disengagement is a last resort, and we consider the human rights implications of disengagement.

7. STAKEHOLDER ENGAGEMENT

7.1 Engagement Approach

We engage with stakeholders to:

☐ Identify human rights risks and impacts
☐ Understand stakeholder perspectives
☐ Inform our due diligence activities
☐ Develop and evaluate remedies
☐ Report on our performance

7.2 Affected Stakeholder Engagement

We prioritize engagement with stakeholders whose human rights may be affected:

☐ Workers and their representatives
☐ Local communities
☐ Indigenous peoples
☐ Civil society organizations
☐ Human rights defenders

7.3 Vulnerable Groups

We pay particular attention to impacts on vulnerable groups:

☐ Women
☐ Children
☐ Indigenous peoples
☐ Migrant workers
☐ Persons with disabilities
☐ LGBTQ+ individuals
☐ Racial and ethnic minorities
☐ Other marginalized groups

8. TRAINING AND AWARENESS

8.1 Training Programs

We provide human rights training to:

8.2 Awareness

We promote human rights awareness through:

☐ Internal communications
☐ Policy documents and guidance
☐ Inclusion in codes of conduct
☐ Performance expectations

9. IMPLEMENTATION AND MONITORING

9.1 Integration

This policy is integrated into:

☐ Business strategy and planning
☐ Risk management processes
☐ Procurement and supplier management
☐ Project development and approval
☐ Mergers and acquisitions
☐ Performance management

9.2 Monitoring

We monitor implementation through:

☐ Regular self-assessments
☐ Internal audits
☐ External audits and assessments
☐ Grievance mechanism analysis
☐ Stakeholder feedback
☐ Third-party evaluations

9.3 Reporting to Leadership

Human rights performance is reported to:

☐ Executive leadership [frequency: _______]
☐ Board/Committee [frequency: _______]

9.4 External Reporting

We publicly report on human rights through:

☐ Annual sustainability/ESG report
☐ Modern Slavery Statement (annual)
☐ Human rights-specific disclosures
☐ Responses to external inquiries and ratings

10. POLICY GOVERNANCE

10.1 Policy Review

This policy is reviewed:

☐ Annually, at minimum
☐ Upon significant changes to operations or business relationships
☐ Upon changes to relevant laws or standards
☐ Following significant human rights incidents

10.2 Policy Approval

This policy is approved by:

☐ The Board of Directors
☐ The Chief Executive Officer
☐ [Other relevant approval authority]

10.3 Related Policies

This policy is supported by:

☐ Code of Conduct
☐ Supplier Code of Conduct
☐ Modern Slavery Policy
☐ Health and Safety Policy
☐ Environmental Policy
☐ Diversity and Inclusion Policy
☐ Data Privacy Policy
☐ Security Policy

11. DEFINITIONS

"Adverse Human Rights Impact" means a negative effect on the ability of individuals to enjoy their human rights.

"Due Diligence" means the ongoing process through which we identify, prevent, mitigate, and account for how we address our actual and potential adverse human rights impacts.

"Salient Human Rights Issues" means the human rights that stand out because they are at risk of the most severe negative impact through our activities or business relationships.

"Stakeholder" means any individual or group that may be affected by or have an interest in our activities.

"Value Chain" means all entities involved in creating our products and services, including suppliers, contractors, business partners, and entities involved in distribution and use.

APPROVAL AND CERTIFICATION

This Human Rights Policy has been approved by:

Chief Executive Officer:

Signature: _________________________________

Printed Name: _____________________________

Date: ____________________________________

Board Chair:

Signature: _________________________________

Printed Name: _____________________________

Date: ____________________________________

Board Approval Date: _________________________

NOTICE: This policy template is provided for informational purposes only and does not constitute legal advice. Human rights requirements vary by jurisdiction and are subject to evolving legal frameworks, including the EU Corporate Sustainability Due Diligence Directive. Organizations should consult with legal and human rights experts before implementing this policy.