Comments on Corporate Human Rights Benchmark Draft Indicators

On September 30, 2015, MSI Integrity submitted comments to the public consultation on the proposed indicators for the Corporate Human Rights Benchmark. Consistent with our expertise, our submission focused solely on the indicators relating to multi-stakeholder initiatives (MSIs). Our full submission is publicly available on the CHRB consultation feedback website, and can be downloaded here.

We support the CHRB’s underlying aim of “incentiviz[ing] better human rights performance over time” (CHRB Framework Paper) and see the value of measuring companies on their human rights performance. However, the proposed indicators relating to MSIs may risk undermining that objective. This is because they are not sufficiently connected to human rights performance or outcomes. Instead, they ask whether companies are members of an MSI, without considering the quality and rigor of that MSI and whether it has the potential to improve a company’s human rights outcomes. We are concerned about the incentives this could create, including a race to join or form MSIs without considering whether initiatives are sufficiently designed or implemented to encourage human rights protection.

We submit that if the CHRB wishes to include MSI-specific indicators, the indicators must entail an assessment of whether an MSI has the potential to be effective as a human rights instrument, and therefore whether membership in that MSI is a sufficient proxy or indicator of human rights commitment or leadership. This entails examining whether the MSI meets international good practices for effective MSI design. We would encourage CHRB to examine utilizing reliable measures of MSI effectiveness, such as the seven core components of MSI design in MSI Integrity’s MSI Evaluation Tool. In addition, the CHRB should measure a company’s performance in the MSI, including their compliance with the MSI’s standards and/or whether grievances are pending in the MSI.

We recognize that building robust indicators is not an easy task. We are always eager to share our research and experiences regarding evaluating MSIs and developing indicators to avoid anyone needing to reinvent the MSI wheel. We hope our input will ensure that MSI-related indicators in CHRB or any other benchmarks are robust and advance the aim of improving human rights protection.

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