Responding department: Social performance (also with input from Human Resources, Communications, Security, Legal)
Stock exchange symbol: (BG/LN)
also available: BG Group response to our Myanmar Foreign Investment Tracking Project
Does your company have a publicly available commitment to respect human rights?
Human Rights Policy: [link]
BG Group Approach to Human Rights: [link]
Additional relevant policies:
- Business Principles: [link]
- Social Performance Standard: [link]
- Environment and Climate Change Standard: [link]
- Human Resources Policy: [link]
- Employee Support Standard: [link]
See: [link] for more information
How are human rights governed in your company?
BG Group’s Executive Vice President, Policy and Corporate Affairs is responsible for ensuring compliance with the Human Rights Policy.
BG Group’s Head of Social Performance manages implementation of our Human Rights Policy and Social Performance Policy.
Our Board Sustainability Committee is one of six committees established by our Board of Directors. The Committee, which is made up of six non-executive directors plus our Chairman, oversees and monitors BG Group’s compliance with the Group’s Policies, particularly the Human Rights Policy, Social Performance Policy, HSSE Policy, Ethical Conduct Standard and License to Operate Policy. The Committee makes recommendations to the Board in relation to management processes designed to ensure compliance with our Policies, and ensures the appropriate allocation of resources to support the behaviours required by the Policies.
We believe that respect of human rights is a key element in sustainable value creation. Our commitment to respect human rights is codified in our Business Principles which define how we operate and express our core values and behaviours. They set out our commitment to the highest integrity in business relationships, including zero tolerance for corruption. They reinforce our commitment to providing safe and secure working environments, developing our employees and treating all our people with fairness, respect and decency. They express our intention to make a positive contribution to economic, social and environmental development in the countries where we operate and to ensure consistency of approach by service providers and contractors. Our Business Principles are approved by the Board and must be followed by all our people at all times, including when seconded to joint ventures.
How are human rights managed within your company?
We take a cross functional approach to managing human rights. Our systems to manage human rights are incorporated within several functional controls and standards, including Ethical Conduct, Environment and Climate Change, Safety, Security, Occupational Health, Social Performance, Contracts and Procurement and Human Resources.
For instance, our approach to identifying and managing actual and potential impacts on communities is governed by our Social Performance Standard and Environment and Climate Change Standard. These apply to all projects, including acquisitions, projects in new countries, and expansions of existing projects. Typically, we commission Environmental, Social and Health Impact Assessments (ESHIAs). We go beyond compliance with local regulation to meet internationally accepted best practice on managing social and environmental impacts. ESHIAs include an assessment of potential impacts on community health, safety and security; on natural resources on which people depend; impacts on cultural heritage and people’s livelihoods. As such, ESHIAs enable us to identify actual and potential impacts on the right to health, right to work, right to participate in cultural life, right to safety and security of the person, and other human rights issues identified through the research process.
Consultation with affected communities is built into how we identify and manage potential impacts. We take a participatory approach to conducting impact assessments to ensure that we understand and incorporate the concerns of community stakeholders. Our approach to consultation is transparent, inclusive and culturally appropriate – in alignment with the core human rights principle of non-discrimination. ESHIAs also identify potential mitigation measures, which are defined in consultation with potentially affected rights-holders. These mitigation measures are then incorporated into a project’s development and annual social performance plan and implemented by the relevant business function.
We have a human rights taskforce, which is made up of senior representatives from the relevant functions listed above (Human Resources, Contracts and Procurement, Security, Ethical Conduct, Environment, Legal and Social Performance), who meet twice yearly to identify any human rights risks and incidents across the business, provide assurance that our internal controls are appropriate for assessing and managing human rights issues, and track compliance with our Human Rights Policy.
Our human rights policy is one of nine BG Group policies. It is publicly accessible through our website. All BG Group employees, contractors and consultants are required to follow this policy, and ensure they are not complicit in human rights abuses when working for BG Group. In accordance with our Speak Up (Duty to Report) Policy, our personnel must report breaches, or concerns of potential breaches, of this Human Rights Policy, including in the supply chain, which they encounter during performance of their duties. Breach of a BG Group Policy may result in disciplinary action, up to and including dismissal. We apply this Policy in all joint operations where BG Group is the operator. When participating in joint venture companies not under BG Group control we encourage the adoption of a similar policy requirement.
What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?
BG Group’s approach to consultation is outlined in our Social Performance Standard; this covers engagement around potential human rights issues:
Consultation with affected stakeholders shall be led or coordinated by a BG Group or Asset representative, including where it is being conducted by a third party on behalf of the company. Consultation procedures shall:
- be cognisant of established community decision-making conventions and protocols, and be supplemented, as necessary, by additional mechanisms to address the needs of inadequately- represented, marginalised or vulnerable groups;
- ensure that identified communities have timely access to full, meaningful and accurate information about the Asset, including information relating to positive and negative impacts and mitigation measures identified in the impact assessment;
- ensure that engagement activities are two-way so that community issues and priorities are taken into account in business decision making; and
- record all formal consultation activities and outcomes, including the extent to which community viewpoints have been taken into consideration and all formal commitments and agreements made between the Asset and communities. It is also recommended that informal activities and outcomes are also recorded.
Where communities or other social groups are directly or indirectly affected by a BG Group Asset or project, the Asset shall establish a grievance mechanism to facilitate resolution of any grievances arising in relation to its activities. The scale and type of the grievance mechanism shall be compatible with the level of risks and impacts associated with the Asset or project’s activities. The grievance mechanism shall be readily accessible, follow understandable, transparent and culturally appropriate processes, be designed to resolve grievances promptly, shall not result in any cost or retribution to the party that originates the grievance, and shall not impede access to judicial or administrative remedies. The Asset shall ensure that potential users are fully informed about the grievance mechanism through its stakeholder consultation activities.”
All new joiners take a mandatory induction to our Business Principles. This includes content on our approach to human rights. As part of all our contractual agreements with suppliers, their personnel must be made aware of, and agree to comply with, our Business Principles and all mandatory policies and standards before they start work. All employees and contractors are made aware of the confidential hotline “Speak-up” where they can lodge concerns or grievances in a confidential way, and have them addressed.
Priority human rights issues: What are some of the priority human rights issues for your company?
- Health (including workplace health & safety, prevention of pollution)
- Workplace diversity / non-discrimination
- Displacement and community relocation
- Operations in conflict zones
- Relations with security forces
- Transparency in payments to governments / responsible tax practices
Actions on health
Health and safety [link]
Actions on workplace diversity / non-discrimination
Workplace diversity / non-discrimination [link]
Actions on operations in conflict zones
Human rights issues related to working in conflict zones and with security forces [link]
Actions on tax avoidance & revenue transparency
Actions on indigenous peoples
How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?
BG Group communicates internally and externally about its human rights commitments through a variety of channels, including the BG Group website and internal web-portal. Our business principles include an explicit commitment to human rights, and our human rights policy is one of nine BG Group policies, which all employees are required to follow. This requirement is communicated to all new employees.
Human rights commitments are also integrated into a range of policies and standards, which govern employee conduct. For instance, our Employee Support Standard and Resourcing Standard outline our commitment to non-discrimination in workplace related decisions such as recruitment and selection, training and development, opportunities for promotion, pay and benefits, conduct at work, disciplinary and grievance procedures and termination of employment.
BG Group reports publicly on our approach and performance relating to Human Rights through the Group Sustainability Report, Annual Report and through the BG Group website. For instance, see [link].
BG Group is open to engagement with civil society on human rights concerns. For instance, in 2014 BG Group participated in several mediation meetings hosted by the UK National Contact Point for the OECD Guidelines for Multinational Enterprises, in relation to a complaint filed against KPO, a joint-venture co- operated by BG Group. See our 2013 Sustainability Report for more information. BG Group also responds to questionnaires from socially responsible investors on human rights issues.
What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?
BG Group’s approach is to provide access to remedy for grievances related to our business activity through operational grievance mechanisms, and through our employee hotline ‘Speak Up.’
Our Social Performance Standard sets out our commitment to establish operational level grievance mechanisms where communities or other social groups are directly or indirectly affected by our activities. The scale and type of our operational grievance mechanisms may differ, as they are fit-for-purpose to the types of risks or impacts and proportionate to the scale and type of business activity. BG Group grievance mechanisms are free to use, and follow understandable, transparent and culturally appropriate processes. Grievances can be submitted anonymously, and do not impede complainants from accessing other forms of remedy – judicial or otherwise.
Our Assets ensure that potential users are fully informed about the grievance mechanism through stakeholder consultation activities. All our operational grievance mechanisms are reviewed on an annual basis to ensure consistency with our Social Performance Standard.
Our Speak Up (Duty to Report) Policy outlines our requirement for personnel working for BG Group to report any suspected breaches of our Business Principles, Policies or Standards. Speak Up is available to all employees, contractors and others – for instance it can be used by families of workers or members of the public. Concerns can be reported via telephone or through a web-based form. Speak Up is run by an external organisation, which allows complainants to raise concerns anonymously, if desired. All allegations are investigated, and BG commits to ensuring that no complainant will be retaliated against when reporting a concern in good faith.
Australia: A landholder phoned their QGC land access consultant to report that a cow fell into a pipeline trench and had to be put down. QGC investigated the matter and found that QGC was responsible. The landholder was compensated for the loss of the cow and fencing was erected around the section of trench where cattle passed.
Kenya: A fisherman reported through our local grievance hotline that his net became entangled in a drilling ship. An investigation was conducted, which determined that BG Group was the cause of the grievance. As a result, the fisherman was compensated for the loss of equipm ent and for loss of income during the period when the damaged equipment affected his catch (2014).
Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?
We are a member of IPIECA, the global oil and gas industry association for environmental and social issues. BG Group is a member of IPIECA’s Human Rights Taskforce, which seeks to share and promote good practice across the industry on human rights issues. BG Group co-chairs IPIECA’s grievance mechanism working group, which is developing a series of tools and guidance for the industry on grievance mechanisms, which are part of a broader system of ‘access to remedy’ for aggrieved persons to seek remedy for potential infringements of their rights.
Extractive Industries Transparency Initiative (EITI)
We support transparency of payments to governments, which are an important part of our contribution to host countries and local economies. Transparency supports an informed public debate about natural resource extraction and the use of revenues. We have supported EITI since its inception and have interests in ten EITI implementing countries: Colombia, Honduras, Kazakhstan, Madagascar, Myanmar, Norway, Tanzania, Trinidad and Tobago, UK, and USA. We are working towards reporting in 2016 on all payments to government that are eligible under the UK regulations that implement Chapter 10 of the EU Accounting Directive. Chapter 10 requires all extractive sector companies registered in EU member states to report on payments to governments worldwide, on a project-by-project basis.
Institute for Human Rights and Business & Myanmar Centre for Responsible Business
We shared our initial human rights impact assessment of Myanmar with the Institute for Human Rights and Business and the Myanmar Centre for Responsible Business, an organization it co-founded. We provided an industry perspective on impact assessments to support their development of a sector-wide impact assessment for the oil and gas industry in Myanmar. The sector-wide impact assessment, published in 2014, provides an aggregated assessment of the impact of the industry in Myanmar and is a resource for governments, businesses, civil society and development partners to support responsible business practice.
In Kenya, we work with the Nairobi Process, an initiative developed by the Institute for Human Rights and Business in collaboration with the Kenya National Commission on Human Rights. The Nairobi Process aims to embed the UN Guiding Principles on Business and Human Rights into the emerging oil and gas
We are participating in the FPIC Solutions Partnership, a multi-sector dialogue on Free Prior and Informed Consent (FPIC) community processes relating to mining, oil and gas projects convened by RESOLVE, a public policy and dispute resolution NGO based in Washington DC. The dialogue, composed of representatives from civil society and companies, aims to conduct research and share lessons in order to develop practical guidance around FPIC implementation for mining, oil and gas projects.
In 2014, and as part of the FPIC Solutions Partnership, RESOLVE and BG Group collaborated on a project to assess trends and practices around compensation and benefit sharing agreements between companies and Indigenous communities. This research project focused on Latin America where BG has a growing footprint and where there are evolving trends around these types of greements. The research will be shared with the FPIC Solutions Partnership and other stakeholders.
UN Global Compact
BG Group is a signatory to the UN Global Compact, a strategic policy initiative for businesses that are committed to aligning their operations and strategies with ten universally accepted principles in the areas of human rights, labour, environment, and anti-corruption. BG Group is a member of the Global Compact UK Network.
Voluntary Principles on Security and Human Rights
We are a signatory to the Voluntary Principles on Security and Human Rights (VPSHR) which guide companies in maintaining the safety and security of their operations within an operating framework that ensures respect for human rights. Our Security Standard and Social Performance Standard govern how we implement the Voluntary Principles in our business. There are very few occasions when we use armed security to protect our assets. This only done when deemed strictly necessary, and it requires executive level approval. Where there is credible risk of security related human rights abuse, our businesses must go beyond a traditional security assessment and complete a VPSHR risk assessment. Our internal VPSHR guideline, which is aligned to the industry guidance, provides a detailed framework for conducting the assessment. Our businesses create plans which outline the actions to be taken to manage any identified risk of human rights abuse by public and/or private security providers.
Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.
In 2011, BG Group established a human rights taskforce, to formalise and strengthen its approach to human rights due diligence, in response to the UN Guiding Principles.
BG Group takes a cross-functional approach to assessing and managing human rights risks. Relevant functions, including Human Resources, Contracts and Procurement, Security, Ethical Conduct, Environment, Legal and Social Performance identify and manage the human rights issues related to their functional area. The human rights taskforce was established in 2011 to provide additional assurance that potential human rights impacts are systematically identified, documented and addressed through existing functional controls.
The taskforce, composed of senior representatives from the relevant functions, meets twice yearly. Relevant functions submit reports tracking compliance with the Human Rights Policy and detail any reported human rights incidents relating to their function. The taskforce also makes recommendations for strengthening internal controls, where necessary. The minutes from these meetings are circulated to the EVP Policy and Corporate Affairs, who can escalate any issues, if necessary.
In addition, we provide an annual update to the Board Sustainability Committee on human rights risks and how we manage human rights through the company.
What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?
- When a company is a non-operator or a minority partner without an operational mandate in a joint venture, the company is limited in what it can do to implement its human rights commitments.
- Integrating human rights commitments throughout the entire oil & gas supply chain can be challenging, particularly further down the supply chain where it is difficult for the company to have oversight.
- Often the NGO community advocates for human rights impact assessments to be made public. However this could cause negative repercussions on victims of human rights abuses, and also compromise the company’s ability to engage with government constructively on these issues.
- Engaging with host governments on human rights issues can be challenging and needs to be managed with sensitivity.
Suggestions to help strengthen company approaches to human rights:
- It would be useful to get some external advice on what oil & gas companies can practicability be expected to do to manage human rights risks throughout the supply chain, and to get support for implementation.
- In many cases, it is very difficult a company to address human rights challenges on its own, so building and strengthening multi-stakeholder groups to address human rights challenges can assist companies to implement their human rights commitments. The Voluntary Principles on Security and Human Rights is an example of an initiative that has been useful in this regard.