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23 Mar 2022

Russian invasion of Ukraine: What companies have to say about their human rights due diligence

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Anti-war rally in Vancouver, Canada, Feb 26th 2022

UPDATED 9:00 GMT 21 November 2022

Since Russia’s invasion of Ukraine on 24 February 2022, the Business & Human Rights Resource Centre has been closely monitoring company activity and the private sector response to the rapidly changing situation.

Under the United Nations Guiding Principles on Business and Human Rights (UNGPs), in situations of armed conflict business should conduct enhanced human rights due diligence to identify, prevent, and mitigate heightened risks and adopt a conflict-sensitive approach. Companies need to do so because of the severe risk of gross human rights abuses. Businesses must also avoid contributing to violations of international humanitarian law.

For this reason, we invited 400 companies operating or investing in Ukraine and/or Russia to respond to questions about human rights due diligence. The purpose of the survey is to increase transparency of business human rights due diligence practices related to the Russian invasion of Ukraine, including gaps and examples of good practice. We provided companies two weeks to respond to the survey and will post their responses to this dedicated story.

Companies invited to respond

How have the companies responded so far?

We heard back from 115 companies, 29% of those approached. Just 43 companies provided full or partial responses to the questions about their human rights due diligence in response to the Russian invasion. Sixty companies sent general statements condemning the violence, expressing concerns, and sharing information about their donations in support of Ukraine. Ten companies either asked for extension or said they were working on responses to the questionnaire. Two companies declined to provide answers.

The 43 companies that provided responses to our questions include Accor, BASF, Booking Holdings, Bosch, Carlsberg, CCC, Chevron, Clifford Chance, Credit Suisse, Engie, Eni, Ericsson, Fenzi, Fortum, Gunvor, HeidelbergCement, Hewlett Packard Enterprise, Hewlett Packard Inc., Henkel, Hitachi, Hoffmann Group, illycaffè, Kinross Gold, LG Electronics, Maersk, Marks & Spencer, Michelin, Novartis, Novo Nordisk, Ørsted, Philips, Pirelli, Raiffeisen Bank, SAP, Shell, Siemens, Tchibo, Twitter, Uber, Unilever, Uniper, Vitol and Wintershall Dea. This includes ten companies in the tech sector, five companies in both oil & gas and energy, two companies in both clothing & textile and food & beverage sector. The responses vary greatly in content and detail. Some companies simply listed the human rights policies, guidelines, and standards they have in place without indicating any specific, concrete measures they are taking in response to the Russian invasion of Ukraine. Others explained what steps they are taking to conduct enhanced human rights due diligence.

What have they had to say?

In its response, Uber noted it established a steering committee several weeks prior to the invasion to identify risks, take mitigating action, and plan for potential further escalation. According to Uber, “This steering committee meets on at least a daily basis, but also more frequently as necessary. Among the first steps, Uber began regular outreach and consultation with employees, business partners, and both local and national government officials in Ukraine to better understand the fast-evolving situation on the ground in Ukraine and the priority needs of our stakeholders. Uber also engaged with humanitarian organizations to identify how the company could best contribute to future relief efforts and heightened its cyberthreat monitoring to further ensure the protection of users’ data and privacy.”

In addition to ensuring the health, safety, and well-being of its staff and contractors and contributing to humanitarian and aid organisations, Shell is committed to "stop all spot purchases of Russian crude oil" and "withdraw from its involvement in all Russian hydrocarbons, including crude oil, petroleum products, gas and liquefied natural gas (LNG) in a phased manner." However, Shell also notes that in the context of its operation in Russia, "...there may be circumstances in which our teams may have no choice but to supply military transport. This could be if armed troops demanded fuel or, indeed, if there was a legal obligation under martial law."

Ericsson has integrated human rights due diligence into its sales process through the Sensitive Business Framework for the purpose of assessing, preventing, and mitigating potential misuse of Ericsson’s technology. According to the company, “The Sensitive Business Framework evaluates sales opportunities from a human rights risk perspective. Risks are identified based on the parameters of the Sensitive Business risk methodology (country, customer, product and purpose). As a result of these due diligence measures, Ericsson decides how to proceed with the opportunity and how to mitigate identified risks. The decision can be to approve, with or without conditions, or to reject the sales engagement.”

What next?

Companies can and must do much more. Whether they choose to do so remains to be seen. We are following up with the companies that did not provide any response and will continue updating this page with new company responses as we receive them. We encourage all those who have not yet responded to do so.