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separate question of how much of the information obtained through tracking
the enterprise should communicate externally. Regardless, by maximizing
the information it has about its human rights performance, the enterprise
enables robust internal accountability and lays the basis for whatever external
communication is required or advisable.
Tracking human rights issues and responses will also help it to identify trends and
patterns. This provides senior management and others with the “big picture”:
it highlights repeated problems that may require more systemic changes to
policies or processes, and it brings out best practices that can be disseminated
across the enterprise to further reduce risk and improve performance.
Q 49. How should the effectiveness of responses be tracked?
There is no single answer to this question. The tracking processes must make
sense within the enterprise’s wider systems and culture if they are to contribute
to embedding respect for human rights. There may be other tracking systems
within the enterprise that offer relevant and effective models—perhaps in the
area of health and safety or environmental performance. Processes for tracking
responses to human rights impact that are integrated into other tracking systems
may bring benefits by “normalizing” attention to human rights. They may also
bring risks if they do not allow for the kind of qualitative feedback—including,
where possible, feedback from those potentially affected—that is necessary to
address impact on human rights.
If there are human rights issues that result from environmental impacts—for
example, related to water and health—there may be established and quite
precise international as well as national standards that offer ready metrics.
This does not necessarily mean that those who believe they are being harmed
trust those standards or trust the enterprise (or any third party paid by the
enterprise) to be honest in the measurements it provides. In situations such
as these, the enterprise should consider the scope for agreeing with affected
stakeholders on an individual or organization that all concerned will trust to
provide accurate assessments. Alternatively, joint fact-finding by company and
community representatives may be possible. This will often require either that
affected stakeholders are able freely to identify an expert to represent them in
that process, or that one or more of the affected stakeholders are themselves
trained so they have the necessary expertise to participate in the joint process.
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