A/HRC/44/43
(c)
Ensuring that corruption and human rights risks are considered in employee
onboarding systems;
(d)
Having standard codes of conduct or ethics adopted by the board, and
ensuring the inclusion of contractual clauses (including in contracts with intermediaries)
incorporating human rights and anti-corruption provisions;
(e)
auditing;
(f)
Including human rights and corruption as areas covered in non-financial
Building capacity by including human rights in anti-corruption training;
(g)
Integrating the identification of human rights risk and the identification of
anti-corruption risk;
(h)
Incorporating corruption risks into human rights due diligence by engaging
the company’s compliance department;
(i)
Organizing sectoral peer-learning;
(j)
Integrating human rights considerations into whistle-blower and reporting
mechanisms, including through hotlines and grievance mechanisms;
(k)
Implementing all applicable anti-corruption and human rights laws and
standards during preparatory stages for the Olympics.96
54.
However, despite these good practices, challenges to aligned approaches persist.
These include sustainability, supply chain and human rights departments on the one hand
and legal and compliance departments on the other working independently in silos,
focusing on, respectively, human rights and anti-corruption measures. Such a division has
resulted in poor communication, diligence fatigue, a lack of shared objectives and
challenging auditing processes where red flags were missed; a lack of coordination, sharing
of information and collaboration within different parts of a business, for example between
geographic offices and headquarters and between different departments; poor informationsharing and knowledge management regarding business and human rights and anticorruption cases and issues; insufficient training, guidance and support on how to
implement business and human rights responsibilities and anti-corruption measures
alongside each other; and resistance from operations, weary from dealing with multiple
interlocutors.
55.
Contributors emphasized that there was no one-size-fits-all approach and no
concrete trend towards companies developing single integrated compliance or risk
frameworks covering both corruption and human rights. Alignment is not the same as
integration. As some contributors noted, fully integrating anti-corruption and human rights
due diligence could risk watering down core commitments to respect human rights. The
goal of human rights due diligence is eliminating risks to people, and such due diligence is
a values-driven endeavour. Since responsible business conduct focuses on corruption
prevention and respect for human rights, it is key for corporate boards and managers to
ensure that both priorities incrementally support a holistic corporate culture and
management approach.
56.
Contributors acknowledged that company codes of conduct and contractual
requirements for suppliers and agents often have an integrated voice, linking anti-bribery
obligations to measures respecting human rights. Likewise, other aspects of international
regulatory and compliance diligence are integrated. Some sectors that raise concerns, such
as the pharmaceutical and extractive sectors, have made headway in addressing corruption
and business-related human rights abuses, but not necessarily in an aligned way. For
example, they may have separate human rights and corruption working groups and trade
associations. Practically speaking, in the anti-corruption context, diligence falls into several
categories, including employee diligence, third-party (or transaction-related) diligence,
mergers and acquisitions diligence and operational diligence, including anti-corruption risk
96
16
See https://stillmed.olympic.org/media/Document%20Library/OlympicOrg/Documents/Host-CityElections/XXXIII-Olympiad-2024/Host-City-Contract-2024-Principles.pdf.
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