The Call to Action 01 Adapt Core Business Activities to Respect Human Rights Adopt a human rights policy. Establishing robust human rights policies applicable to all business lines is a critical first step for many FIs. While bank and investor human rights policies exist, they remain limited. Responsible investment policies are often framed around ESG and sustainability, with only occasional reference to specific human rights issues, as opposed to robust commitments to respect internationally recognized human rights and conduct human rights due diligence. Policy commitments may be stand- alone or integrated into broader ESG policies. In both cases, it is essential that they 3 align with the expectations of the UNGPs. Embed human rights into corporate governance and business strategies. The Illustrative actions set out by UNGPs UNGPs should be the north star for not only 10+ Roadmap achieving ESG goals, but also for guiding the design of FI business models and business “Adopt human rights policies and embed strategy, as they may carry inherent human human rights due diligence and develop grievance management approaches in line rights risks. Human rights respect needs to be with the UNGPs in their own governance at the heart of an FI’s culture, from the board of frameworks and in the investment directors and C-suite to deal teams, investment decision-making process.” portfolios, environmental and social risk management, public policy, human resources, and procurement. It means having proper incentives and checks to make sure human rights risks are addressed swiftly and appropriately. Where investors sit on portfolio company boards, such as general partners in private equity, it also means using leverage so that board committees have in place explicit human rights mandates, executive pay is tied to corporate human rights performance, and human rights respect is embedded 4 in the corporate business model and strategies. Challenge financial and business practices that are inconsistent with respect for human rights. All business functions and relationships must respect human rights. Lobbying—including through trade associations—at the expense of human rights is inconsistent with the UNGPs. So is financing companies that may be involved with 19 HUMAN RIGHTS ROADMAP FOR TRANSFORMING FINANCE

Human Rights Roadmap for Transforming Finance - Page 19 Human Rights Roadmap for Transforming Finance Page 18 Page 20