31 Which departments need to have understanding and ownership of these policies and procedures, and how can we involve them in their development? Who should sign off on the final policy commitment at the top of the enterprise, to send the signal to all personnel that this is a priority? How will we communicate our policy commitment publicly, bearing in mind the different ways our stakeholders are able to access information? B. HUMAN RIGHTS DUE DILIGENCE GUIDING PRINCIPLE 17 In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence: (a) Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships; (b) Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations; (c) Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve. Q 26. Why does this matter? It is through human rights due diligence that an enterprise identifies the information it needs in order to understand its specific human rights risks at any specific point in time and in any specific operating context, as well as the actions it needs to take to prevent and mitigate them. “Human rights risks” refers to the risks of having an adverse impact on human rights, as against risks to the enterprise itself, although the former increasingly leads to the latter.

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