TABLE OF CONTENTS

• Why this matters
• What HR1.2 requires
• What your human rights policy should include
• How a human rights policy is different from a code of conduct
• How you can integrate HRDD into your policy
• Why the policy must be public
• In Summary

Why this matters

If your company is working to meet HR1.2, you need more than a general statement that you respect human rights. You need a formal human rights policy that is publicly accessible and explains how your company protects and promotes human rights in practice. This matters because stakeholders need to understand your company’s expectations, processes, and standards across its operations and value chain. A strong policy also helps your company prevent harm, respond effectively when issues arise, and build accountability over time.  

What HR1.2 requires

HR1.2 is about establishing  a formal human rights policy. While HR1.1 (which is for smaller companies) is about making a general commitment to respect human rights, HR1.2 goes further. It requires a documented policy that explains how your company will identify risks, prevent negative impacts, and respond when harm occurs.

Your policy should show not only what your company believes about human rights, but also how it puts that commitment into action.

What your human rights policy should include

To meet HR1.2, your company’s human rights policy should:

• Include a public commitment to respect human rights: Start with a clear public statement that your company respects human rights. This statement should be easy to understand and should reflect your company’s commitment across all areas of its business.

• Explain how you identify and assess human rights risks: Your policy should describe your approach to identifying, assessing, and addressing potential negative human rights impacts. This is a core part of human rights due diligence (HRDD). It helps show that your company is not only making a commitment, but also taking steps to understand where risks may exist.
  For example, your policy can explain how your company reviews its operations, suppliers, business relationships, and other parts of its value chain to identify where people may be at risk of harm.

• Describe how your company will address harm: Your policy should include a plan for remediation if harm occurs. In other words, it should explain what your company will do when it causes or contributes to a negative human rights impact, or when harm is linked to its operations or value chain.
  This helps demonstrate accountability and shows stakeholders that the company is prepared to respond when things go wrong.

• Refer to recognized international frameworks: Your policy should reference relevant international human rights covenants and frameworks. This includes: the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, and the International Labour Organization (ILO) standards. These references help show that your company’s approach is aligned with widely recognized human rights principles. 

• Be approved by the highest governing body: The policy should be approved by the highest governing body, such as the board of directors. This is important because it shows that responsibility for human rights is taken seriously at the highest level of the company.
  Board-level approval also strengthens accountability and supports integration across the business.

• Define who and what the policy covers: Your policy should clearly state its scope. It should cover all individuals and communities affected by your company’s operations and value chain. This may include workers, contractors, suppliers, customers, local communities, and other potentially affected stakeholders.
  A clear scope helps ensure that the policy is applied consistently and does not leave out important parts of the business or value chain.

How a human rights policy is different from a code of conduct

Many companies already have a code of conduct or a supplier code of conduct. These documents can be useful, but they do not automatically meet HR1.2.

A general code of ethical conduct often focuses on expected behavior. A supplier code of conduct may set expectations for business partners. However, HR1.2 requires a policy that clearly includes the specific elements listed above and meets the compliance criteria.

In practice, the code of conduct may define the rules, while the human rights policy explains the due diligence process that helps your company apply, monitor, and improve those rules over time.

If your company wants to use an existing code of conduct to meet HR1.2, review it carefully. Make sure it includes a public human rights commitment, a due diligence approach, a remediation plan, references to international frameworks,  covers affected people across operations and value chains, and is approved by the highest governing body.

How you can integrate HRDD into your policy

A strong human rights policy should make your company’s due diligence approach visible and practical. To do this, your policy should answer a few key questions.

• How will your company identify potential impacts?
  Explain how your company will look for actual and potential human rights risks in its operations and value chain. This may include risk assessments, stakeholder engagement, supplier reviews, internal monitoring, or other due diligence processes.

• How will your company prevent and reduce harm?
  Describe how your company will act on the risks it identifies. This could include updating internal procedures, setting supplier expectations, training teams, strengthening oversight, or changing business practices.

• How will your company respond when harm occurs?
  Make clear what your company will do if adverse impacts happen. This should include remediation and corrective action, as well as a process for learning from the issue and improving future practice.

• How will your company communicate expectations?
  Your policy should provide clear guidance to internal and external stakeholders. Employees, suppliers, investors, customers, and communities should be able to understand the company’s approach and what is expected of them.

Why the policy must be public

Publishing your human rights policy supports transparency and accountability. It allows stakeholders to see your company’s commitments and approach. This can help build trust, strengthen relationships, and reduce risks linked to human rights violations.

A public policy also creates a foundation for broader human rights work. It supports due diligence processes under HR2 (human rights assessment and strategy) and HR3 (preventing, mitigating, remediating negative impacts), helps guide supplier engagement under HR4 (supplier engagement), and provides a basis for tracking performance and taking corrective action when needed.

In Summary

If your company is preparing to meet HR1.2, start by reviewing any existing human rights, ethics, or supplier policies. Check whether they include all required elements. If they do not, update them or develop a dedicated human rights policy. 

Then review whether the policy is known and being used in practice across your operations and value chain. A policy is most effective when it is supported by clear processes, ownership, and regular follow-up.