I was...pleased to see that the Financial Reporting Council (“FRC”) has issued draft guidance to help companies implement the strategic report requirements under the revised UK Companies Act....[T]he inclusion of human rights will be new for many companies. I would therefore respectfully urge that the final FRC guidance give clear and practical guidance to companies in this regard. In particular, I would encourage the drafters to: [1] avoid introducing the concept of materiality with regard to human rights reporting: this does not feature in the underlying legislation and risks encouraging narrow and short-term assessments of the relevance of human rights reporting; and [2] indicate to companies how the UN Guiding Principles can assist them in understanding how best to frame their reporting on human rights. Doing so would help meet the FRC’s very legitimate aim of achieving more concise and relevant reporting, without resort to a purely valuation-based definition of materiality.