Policy paper

UK National Action Plan on implementing the UN Guiding Principles on Business and Human Rights: progress update, May 2020

Published 27 May 2020

This was published under the 2019 to 2022 Johnson Conservative government

The UK’s National Action Plan follows the same structure as the UN Guiding Principles on Business and Human Rights (UNGPs), which are based on 3 pillars: duties of the state, expectations for business, and access to remedy.

Pillar 1: duty of the state to protect human rights

Pillar 1 of the UNGPs sets out the duty of the state to protect human rights. In order to give effect to this, the government has:

1. Introduced the Modern Slavery Act. This both updated the law and introduced a requirement for businesses with a turnover of £36 million or more to publish a statement on their website. The statement must set out what steps the business has taken to ensure modern slavery is not taking place in its business and supply chains.

2. Launched the Modern Slavery Assessment Tool. This supports public bodies in assessing their own supply base for modern slavery risks, and provides tailored recommendations to suppliers on how to improve their anti-slavery processes.

3. Published a Policy Procurement Note and detailed guidance document, setting out a risk-based approach to mitigating modern slavery in government supply chains and specific measures to be adopted at each stage of the commercial life-cycle.

4. Implemented the requirements of the OECD 2012 common approaches for undertaking environmental and social due diligence. These requirements are to identify, consider, and address the potential environmental and social impacts and risks relating to applications for officially supported export credits, as an integral part of decision-making and risk management systems.

5. Worked to raise awareness and increase the impact of the Voluntary Principles Initiative. See the 2019 update report on GOV.UK. The Voluntary Principles Initiative advances the implementation of the Voluntary Principles on Security and Human Rights, through guidance on responsible business practices to oil, gas and mining companies, which often operate in high-risk and conflict-affected areas.

6. We continued to work closely with the UK Private Security Company (PSC) sector through the Security in Complex Environments Group, which provides a valuable forum to strengthen further industry standards for UK-based PSCs operating internationally.

7. Invested £1.5 million from the FCDO’s Human Rights and Democracy Programme in promoting the UNGPs and supporting business and human rights.

8. Developed partnerships with other countries seeking to implement UNGPs.

9. Strengthened international rules relating to digital surveillance

Pillar 2: government expects business to respect human rights

Under pillar 2, the government expects business to respect human rights. To support practical action by businesses, the government has:

1. Amended and subsequently strengthened the Companies Act to require certain companies to report on material human rights impacts, where relevant for an understanding of the business, as part of their annual reports. The Department for Business, Energy and Industrial Strategy has been assessing early experience with these changes to strategic reporting by companies, which were introduced a while ago. Research examining stakeholder perceptions of the non-financial reporting regime since the changes were made was published in October 2019.

2. Provided guidance to companies on the transparency in supply chains requirement of the Modern Slavery Act and launched a contacts database for businesses to register for tools and resources to support effective reporting under the Act.

3. Partnered with the cyber growth partnership industry guidance on accessing human rights risks relating to cyber security exports.

4. Provided funding for the Corporate Human Rights Benchmark Initiative, a private sector initiative that seeks to rank the largest companies in the world on their human rights performance.

5. Supported the UNGPs’ Reporting Framework, a voluntary, comprehensive guide for companies to report on how they respect human rights.

6. Continued to update and promote the joint FCDO-DIT Overseas Business Risk (OBR) service, providing information about business environments in the countries where UKTI has a presence.

7. Continued to provide financial support to the UN Global Compact. This encourages and enables companies to align their operations and strategies with universally accepted principles on human rights, labour, environment and anti-corruption.

Pillar 3: access to remedy for human rights abuses by businesses

Pillar 3 supports the access to remedy for human rights abuses by businesses. In order to support access to remedy the government has:

1. Tasked our trade promotion teams, in the markets where they operate, to advise UK companies on establishing or participating in grievance mechanisms, and collaborating with local authorities where necessary.

2. Encouraged companies to extend effective grievance mechanisms to their overseas operations.

3. Supported projects through the FDCO human rights and democracy programme fund to work on remedy procedures in other countries.

4. Commissioned an independent survey of the UK provision of access to remedy.