and access remedy, such as the Dutch Pension Fund Agreement on Responsible Investment. Who provides remedy? Develop a robust grievance mechanism Some FIs, such as private equity infrastructure that involves (1) proactively firms or banks providing project supporting company preparedness for remedy lending, may be more likely than before harm occurs by communicating others to contribute to, or in some expectations regarding remedy and grievance cases cause, adverse impacts through their relationships with clients and mechanisms to investees and clients; (2) portfolio companies. In these cases, reactively using leverage where harm occurs FIs are expected to cease the action to influence portfolio companies and clients causing the harm and play a direct to focus on remedy, engage with affected role in providing remedy. Where an FI has contributed to harm, they are people, and ensure that there is a meaningful also expected use their leverage to remedy outcome; and (3) participating in influence other actors contributing to multi-stakeholder initiatives where clients the harm to mitigate the harm and and portfolio companies participate and to provide remedy. However, even if that incorporate a grievance and remedy FIs are not contributing to harm, they may still be directly linked to adverse component. human rights impacts through their products and services. FIs should use Explore innovative contract clauses or their leverage to promote and enable financial vehicles up front to capture the remedy for victims of their value risk of harm/adverse investment externalities chains. and ensure that there are funds available to provide remedy before harm occurs. Consider the innovations and lessons from grievance mechanisms and accountability frameworks that have evolved in other settings, such as in project and development finance. Networks and platforms, such as the Grievance Redress and Accountability Mechanism partnership, exist to build capacity and a community of practice for FIs and other entities in their efforts to meet the UNGPs’ requirements. Central to making progress on remedy are efforts to shift institutional culture. While difficult to achieve, when cultural changes within FIs reach a tipping point, the changes can be profound. It takes strong leadership, clear communication, and the need to view complaints not simply as a source of reputational risk, but as a source of learning that is essential for improved performance and accountability. 25 HUMAN RIGHTS ROADMAP FOR TRANSFORMING FINANCE