In the process of developing a human rights policy a FI [financial institution] should: - Identify its human rights risk profile, including critical business lines, clients, geographic exposures, etc. - Develop human rights categorical exclusion criteria - Develop stringent basic and detailed due diligence procedures - Develop procedures to engage with clients of concern - Consult with civil society, human rights experts and relevant human rights committees - Publish a clear human rights policy with human rights standards, policies and procedures - Create a comprehensive and transparent management system to implement the policies and procedures