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Annual impact report 2022/23

Our year in business and human rights: A letter from Phil Bloomer and Chris Jochnick

2022 was a year of opportunity and challenge for our work. Corporate theft of lands of Maasai communities in Kenya for solar farms; sexual harassment of women garment workers to ‘discipline’ them to accept long hours on poverty wages; intrusive surveillance of concerned journalists and citizens caring for their community and society; and attacks on community leaders seeking fair negotiations over land, water, pollution and jobs when big investment arrives. These are just a few of the 1,000 grassroots allegations of abuse we have taken up with companies in the last year. Responsible companies and investors have responded to end abuse in their supply chains. But too many still demonstrate a sense of impunity in tolerating supply chain abuse as part of their business model.

Yet, after years of evidence, persuasion and pressing by our diverse movement, we are detecting a potential sea-change in business environments. In response to the ‘polycrisis’ of unsustainable inequality, ecological breakdown, and attacks on democracy, diverse governments are asserting markets must work for shared prosperity and climate security. Illustrations include the EU draft due diligence directive, new green industrial policies of the US and EU that also insist on worker and community empowerment, Brazil’s new plan to protect the Amazon’s forests and peoples, and Sierra Leone’s Mines and Mineral Development Act that enshrines community consent and women’s land rights.

Equally, encouraged by our movement’s evidence of their powerful role, responsible investors are concerned about the mounting legal and reputational risks of laggard companies they invest in. Responsible investors increasingly insist companies address abuse and pollution and build relations with worker- and community-organisations. But this is all against a backdrop of attacks on responsible ‘ESG’ investment in the USA, and scandal of mis-selling some funds as ESG when they are just business as usual.

In 2022, our own work, alongside allies around the world, sought to enhance each of these trends. We have pressed for a just energy transition to promote shared prosperity, corporate duty of care (due diligence) and fair negotiations. We have helped create supply-chain-wide initiatives where exploitation and sexual harassment of women workers in clothing factories was addressed by suppliers and brands with trade unions. We helped insist the IT sector address its enormous human rights risks (from AI to social media to surveillance) by subjecting them to human rights due diligence laws. And we have worked in solidarity with grassroots communities to protect human and environmental rights defenders, and worked with companies to introduce robust protection policies.

2022 brought important challenges and opportunities to the fore and underscored the vital role played by the Resource Centre and allies.

In the midst of trying times, we hope you take encouragement from the progress reflected in this annual impact report.

Phil Bloomer, Executive Director

Chris Jochnick, Chair of the Board

Business & Human Rights Resource Centre

Who we are

Vision

Our vision is a world where business respects human rights and provides redress for abuse, where people are leaders in shaping a rights-respecting and sustainable future for markets and business, and where shared prosperity through greater equality of power and wealth is enjoyed by all.

Mission

We work to strengthen partners, allies, and movements so that our collective work ensures businesses respect and advance human rights.

We build evidence to influence decision-makers in governments, investors and businesses towards effective laws, regulation and norms that transform exploitative business behaviour into a rights-respecting economic model.

We amplify and support the voices and work of partners, allies and movements to drive accountability for abuse.

BHRRC

BHRRC

The Resource Centre works with partners worldwide to put human rights at the core of companies’ business models; to empower communities and workers to secure their rights and gain accountability for abuse; and to encourage effective regulation – policy and legislation – to facilitate these outcomes. We are a global organisation committed to cooperation with diverse actors in our movement. The organisation comprises a Global Team of more than 80 people based around the world who work with a wide network of human rights advocates.  With our global network of allies, our primary global approaches to deliver this vision are:

  • Work to achieve equality of power in negotiations which further human rights between workers and communities, with business and governments;
  • Use the evidence and data we generate to positively influence decision-makers including business, investors and national and regional governments;
  • Strengthen corporate accountability, due diligence, and effective remedy for abuse; and
  • Build transparency of the advances, challenges, and abuse of human rights in business.

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BHRRC

BHRRC

There is a growing global appetite for increased corporate regulation to hold companies and investors to account for harms caused by their business activities. Even business leaders are recognising voluntary measures alone are not enough, and are adding their voices to affected communities and workers advocating for effective implementation of the UN Guiding Principles for Business and Human Rights. This includes stronger due diligence legislation, the judicious use of import bans and a consistent effort to ensure effective access to remedy for those harmed.

Strategic litigation network in Latin America

In this period, we grew our Strategic Litigation Network (the Network) – a knowledge-sharing network for advocates from the BHR community to share experiences and learn and progress key legal and advocacy strategies – to a membership of 140, including domestic, regional and international civil society organisations, lawyers and academics. During this period the Network ran a number of workshops and exchanges, focused on supporting Indigenous and Afro-descendant communities. Members participate as speakers and experts in our human rights clinics, workshops and internal meetings, propose new topics, present cases they are litigating at the local and regional level, author blogs and reflect on the future of the Network. Members of the Network find it useful to share resources that can support litigation to tackle corporate abuse in their countries and they see it as a key priority to strengthen their capacity for strategic litigation. We published lessons from the experiences of the Network's members in July 2022.

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We have also supported and amplified the cases of individuals and organisations subject to lawsuits which bear the hallmarks of SLAPPs (strategic lawsuits against public participation) in Ecuador, Honduras and Guatemala. This includes supporting seven environmental defenders sued by a poultry company in Honduras by amplifying their human rights work and drawing attention to the repression they experienced. The case was recently dismissed and the defenders were declared innocent.

Hydropower in Eastern Europe & Central Asia

Our research prompts the European Investment Bank to scrutinise hydropower investments

Following the launch of our report Drying up in July 2022, which covers our findings from tracking the environmental and human rights harms caused by hydropower projects in the Caucasus and Central Asia, we approached the investors involved in those projects. Six out of eight responded. Since then, we had a significant breakthrough: our engagement contributed to the European Investment Bank (EIB) adding hydropower projects to its exclusion list. This means bank intermediaries can no longer finance hydropower projects without the EIB directly carrying out detailed project checks itself. The outreach also clarified that the EIB and the European Bank for Reconstruction and Development (EBRD) were not involved in the controversial Rogun Hydropower Project, despite numerous claims to the contrary.

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Monitoring the progress of due diligence regulation in Europe

During this period, we continued to work alongside partners and allies to build evidence and support stakeholders’ voices working to strengthen the development of the EU’s due diligence legislation – the Corporate Sustainability Due Diligence Directive (CSDDD).

This included swiftly tracking reactions to CSDDD proposals, providing objective evidence and analysis, and supporting over 220 organisations calling for an effective law to enhance access to justice for victims of abuse and involvement of rights-holders, strengthen climate obligations on companies, and expand the company, value chain and normative scope.

In parallel, in spring 2023, we brought together MEPs and policymakers with labour rights experts from Cambodia and India to encourage them to require companies to enhance their engagement with workers and their independent unions. This was complemented by a series of workshops held with around 100 labour rights activists in Cambodia, India, Kenya and Uganda, introducing due diligence legislation and exploring how it may be used to protect and promote labour rights.

We have also helped promote the voice of responsible international investors and companies in this debate. They have spoken out for smarter business regulation and incentives that create a more level playing field on human rights and environmental protection.

“The answer to ensuring workers are protected across supply chains is not necessarily a proliferation of more frameworks and initiatives, but rather a focus on implementation”

- Delegate in our Kenya workshop on the EU CSDDD

BHRRC

The climate crisis is making its impact felt, not merely through extreme weather events but also through the race to secure reliable renewable energy sources. This rush encompasses everything from mining essential minerals to procuring land for vast solar and wind farm installations. A fast transition will have to be fair to sustain broad public support, and that of workers and communities. Here, the rights of Indigenous communities become a critical concern, alongside increased attacks against environmental and human rights defenders. The Resource Centre continually generates data and analysis emphasising the importance of an equitable and rapid energy transition and the potential risks if we fail to achieve this.

Supporting the just energy transition

During 2022/23 we sought out opportunities to advocate for an energy transition which is both fast and fair.

The Transition Minerals Tracker is a flagship output for the organisation, updated annually to monitor the human rights implications of mining for six key minerals for renewable energy technologies and batteries: cobalt, copper, lithium, manganese, nickel and zinc. In this year’s edition we incorporated new indicators, including a critical analysis of risks to human rights defenders in transition mineral mining. The Tracker updates build our essential evidence base for the need to uphold human rights as a cornerstone of a just transition and underpinned additional advocacy efforts throughout the year including an opinion pieces in the Financial Times and ESG Investor. Our updated investor guide Investing in renewable energy to power a just transition: a practical guide for investors garnered the most media coverage of our natural resources publications, and resulted in numerous requests for engagement, including with three of the largest transition mineral mining companies. We facilitated direct engagement between investors, companies and frontline defenders by hosting workshops designed to foster open conversation and press for critical thinking about human rights reform. Our annual analysis of attacks on human rights defenders was published in April and found during 2021, 70% of the 615 attacks we tracked were against climate, land and environmental rights defenders.

Africa continues to occupy a central place in the renewable energy value chain: from the extraction of Africa’s transition minerals to the renewable energy installations themselves. The Fast and fair renewable energy for Africa: Lessons from Kenya briefing published in June demonstrates that failure to respect human rights where renewable energy installations are located will slow the transition. These cases provide rich lessons for the rest of Africa on how to achieve fast shifts to renewable energy and avoid delays as a result of irresponsible approaches. The briefing led to a partnership with Swedwatch to support grassroots organisations affected by renewable energy projects and to undertake investor engagement. Moreover, we subsequently used this research in a workshop with investors (in partnership with CERES) in July, as part of our work leading up to COP27. The briefing received good media coverage, including in Bloomberg and Business Day.

In September, we had our biggest turnout for our yearly flagship Mary Robinson speaker series event, with 1,000 registrations and attendees from 60 different countries across all regions. This edition was focused on the challenge of a just transition to clean energy in Africa in the run-up to COP27. Mary Robinson was accompanied by keynote speaker Mali Ole Kaunga, Executive Director of IMPACT (Indigenous Movement for Peace Advancement & Conflict Transformation) and speakers Ikal Angelei founder of the Friends of Lake Turkana, Sierra Leone Minister of State Francess Piagie Alghali, and Hubert Danso, CEO of the Africa Investor Group. We also convened a group of investors (CalPERS, Aviva, APG, and others) and high-level spokespeople (including Mary Robinson and Heidi Hataula, Vice President of the European Parliament) to craft and disseminate key messages and core principles around the opportunity of a just transition including COP27. This included a letter to the leadership of the International Sustainability Standards Board, which pressed to ensure a human rights and just transition focus to this key sustainability reporting framework in development; subsequently, good progress has been made the process, in recognition of the need for a transition to be just and inclusive.

Pre-COP27, we coordinated a letter to the United Nations body tasked with supporting the global response to the threat of climate change. Co-authored with Indigenous Peoples Rights International, the letter, covered in The Guardian and Reuters, was signed by over 200 organisations and called for a human rights-based approach to the energy transition. This breadth of support reflects the respected role our partners and we hold in creating joint messaging and bringing together coalitions.

USA: Residents seek remedy from Sasol for environmental injustice using Resource Centre company engagement tool

We continue to support communities facing systemic abuse by companies in their environs. As one example, we published a blog authored by the Concerned Citizens of Mossville, Louisiana, describing environmental racism as a result of the expansion of a nearby chemical complex owned by Sasol. Mossville, Louisiana is a predominantly Black community founded by formerly enslaved people and forms part of 'Cancer Alley', a stretch of land along the Mississippi River in Louisiana with a large concentration of petrochemical factories and refineries where residents have a higher cancer risk than elsewhere in the United States. The Resource Centre requested Sasol respond to allegations in the blog. Sasol responded and an extensive back and forth between the company and the local community ensued - a prime example of the Resource Centre providing our international platform to bolster the voices and actions of workers and communities, especially those in difficult contexts, and support their assertiveness in their own advocacy for human rights in business.

“We thank the Business & Human Rights Resource Centre for facilitating this dialogue, and we applaud BHRRC for its pathbreaking work to promote corporate social responsibility. We hope Sasol leadership shares our view that Sasol still has an opportunity to do right by those who remain in Mossville.”The Concerned Citizens of Mossville, University of Utah Environmental Justice Clinic, and the Tulane Environmental Law Clinic.

Concerned Citizens of Mossville, University of Utah Environmental Justice Clinic, and Tulane Environmental Law Clinic

Mining companies in South Africa commit to establishing complaint mechanisms

Mining plays a significant role in South Africa’s economy, contributing 8.7% to the country’s GDP in 2021, according to the Minerals Council South Africa. The industry also has numerous human rights and environmental impacts. Platinum and coal are two of South Africa’s leading exports. Together with our partner Southern Africa Resource Watch (SARW), in late 2022 we travelled to Limpopo in Northern South Africa to train communities affected by mining on how to approach companies. In a return trip, we engaged companies operating platinum and coal mines in the region, including Anglo American Platinum and Sefateng Chrome Mine, on operational grievance mechanisms. The companies were open to our engagement and Sefateng Mine made commitments towards establishing operational grievance mechanisms. Anglo American Platinum committed to finding ways to make these mechanisms more accessible and available in local languages, as well as trying to simplify them. We will continue to engage to push more senior decision-makers in the companies to follow through with these commitments.

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Increasing inequality has been a hallmark of recent geopolitical instability. The stark socioeconomic divide and its human consequences, laid bare by the pandemic, may well be forgotten in the pursuit of fast returns to shareholders. While the global economic downturn spares only the most affluent, the dire consequences for society's most impoverished and vulnerable workers often remain unseen, deep in global supply chains. The workers providing society with essential goods are pushed further from a living wage as inflation surges and businesses prioritise financial stability over workers' welfare.

Against this backdrop we worked alongside partners in the sector to gather evidence of abuse linked to big brands to drive action and improve rights protections for workers, especially the most vulnerable, including migrants, women and those at the bottom of the supply chain.

Qatar World Cup 2022

Human rights concerns were prominent as the FIFA World Cup kicked off in Qatar in November 2022. Two million migrants live in the country, comprising 95% of the country’s workforce. Most of the low-wage migrant workers are from South Asia, Southeast Asia and East Africa. These workers were integral to the delivery of the World Cup but faced egregious human rights abuses, including allegations thousands died due to health and safety failures. Other allegations include workers being trapped in jobs, charged recruitment fees, not being paid wages, and suffering racial discrimination.

Our World Cup Parallel Portal brought together relevant information on human rights issues and allegations linked to World Cup-related projects. The Portal contains an allegations tracker highlighting the abuse of workers across Qatar, including those constructing specific stadiums or hosting guests in hotels. It builds on our many years of tracking abuse allegations in the region.

In the six months before kick-off, our corporate engagement focused on hotels, football associations and corporate sponsors, key tournament stakeholders who have either the resources or the platform (or both) needed to effect concrete changes. Outreach consisted of individual outreach to companies seeking responses to allegations of abuse and mini-surveys to 30 hotels, 31 football associations and 19 sponsors, with outputs of one briefing, one commentary and media advisories.

Our database tracking alleged cases of abuse was directly used by numerous media sources, including the Guardian, Al Jazeera, Reuters, the BBC, Sky Sports and the Financial Times Magazine, among others. In total, we had interviews with over 50 media outlets. Alongside other human rights groups, this media coverage helped raise the profile of migrant workers’ rights, and human rights generally, to a level rarely seen before in a major sporting event.

As a result of our engagement with hotels, transparency in the industry has increased. Since our survey was conducted, 14 brands responded (up from seven in 2019 and 11 in 2021); 10 disclosed at least one recruitment agency or labour supplier (up from four in 2021) and four uncovered instances of fee payments (up from two brands in 2021) - small but welcome indications the industry is willing to open itself to scrutiny.

Isobel Archer, Gulf Programme Manager at the Business & Human Rights Resource Centre, says that high-profile sporting events are linked to a rise in violence against women, further increasing the risks facing women hotel workers and anticipates the same happening during the World Cup.

She says that urgent action has to be taken by hotels, which will be packed to capacity with football fans, to protect women and allow them to be able to report abuse safely without fear of repercussions.

“I don’t think we’ve seen any evidence that hotels are doing anything, frankly, [to support women],” she says. “And [the women] simply won’t be able to speak up.”

— "Female migrant workers speak out about harassment in Qatar’s World Cup hotels" - Louise Donovan, Guardian, 17 November 2022

Building the evidence base to reveal labour rights abuse in Asia

Our research and subsequent report, Unpicked: Fashion & Freedom of Association, focused on the impact of the pandemic on workers’ right to freedom of association. Our Labour Rights team interviewed 24 trade union leaders and surveyed 124 union activists and labour advocates in Bangladesh, Cambodia, India, Indonesia and Sri Lanka. Interviews revealed allegations of union busting and related abuse at 13 factories. For the first time in the context of this kind of research, the Resource Centre sought responses from supplier companies in addition to responses from brands and retailers. These factories supply, or have recently supplied, at least 15 global fashion brands and retailers, including adidas, Asda, Benetton Group, BESTSELLER, C&A, Sainsbury’s, ETAM, H&M, HUGO BOSS, J.Crew, OVS SpA, Mango, Next, Primark and Under Armour. Nearly two thirds of survey respondents indicated the situation for freedom of association and collective bargaining had ‘gotten worse’ and over half revealed an increase in wage and severance theft as a result of restrictions on trade union rights. The research highlights not just the impact of the pandemic on freedom of association, but how this in turn led to a more general increase in labour rights abuse; from health and safety to gender-based violence and harassment.

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Technological advances, particularly in surveillance and artificial intelligence (AI), are proceeding at breakneck speed without adequate regulation or pressure to ensure respect for human rights, especially among the most vulnerable. In addition to our ongoing focus on forced labour risks we sought to build relationships with partners holding IT companies to account to strengthen our collective advocacy.

Dismantling the facade: A global south perspective on the state of engagement with tech companies

Information Communication Technologies (ICT) companies have determining effects across personal, professional, social and political facets of our lives. While increased productivity, access to information and efficiency are hallmarks of the expansive ICT sector, so too are the negative consequences of many of its products and services: unchecked proliferation of hate speech, misinformation, intrusive surveillance, manipulative algorithms, discriminatory artificial intelligence (AI) and environmental damage in the form of a growing carbon footprint and dumping of e-waste. Against this background, the role of civil society in calling for corporate accountability and transparency remains both vitally important and uniquely challenging.

Our analysis drew on consultations and interviews with civil society groups and digital rights defenders in the Global South exploring three specific examples from civil society groups demanding tech sector accountability:

  • Myanmar: 13 digital rights organisations push for Meta to address Facebook content linked to Rohingya genocide
  • Chile: Derechos Digitales analyses data protection practices in the telecoms sector
  • Africa: Digital Rights and Inclusion Forum brings together cross-regional voices for critical conversations on digital policy in Africa

These cases, together with reflections from interviews with other activists, informed our recommendations for strengthening the movement for accountability for rights infringements, partly grounded in lessons learned from these case studies.

Andrey Tolkachev, Getty Images via Canva

KnowTheChain ICT Benchmark

KnowTheChain, a Resource Centre project, analysed and scored 60 of the world’s largest ICT companies’ efforts to address supply chain forced labour risks in 2022. It found most companies are not conducting even adequate due diligence or providing appropriate remedy for workers suffering from the worst form of human rights abuse. Worryingly, companies received a median score of just 14/100.

The benchmark page on the KTC website received 13,592 page views, demonstrating the reach of this research. The main launch event attracted 125 attendees. Of those that registered, 27% were investors, 31% companies, Our panellist from Intel closed by saying that benchmark standards and methodology revisions push companies very hard but in a fair way, appreciates the process, and our investor panellist stated that more investors should engage with KTC to understand the nuances of forced labour and how they should be engaging with companies.

We have held follow up calls with a number of companies who are seeking to improve efforts to tackle forced labour ahead of the next benchmark. One of these companies is Cisco, where several members of the manufacturing operations team joined our usual company contacts on a call in 2022, indicating the influence and wide buy-in that KTC has garnered among benchmarked companies. This also demonstrated how companies are using the benchmark to guide both reporting and practical efforts to address forced labour.

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Indonesia: AIIB funded ITDC Mandalika project uproots Indigenous communities despite UN condemnation

A large-scale tourism project in Indonesia’s Lombok Island has become a nightmare for coastal Indigenous Sasak communities. Hundreds of families have been forced by the government and armed security forces to leave their homes for temporary resettlements unfit to support their livelihoods, while others who stand up for their rights to land, a life of traditions and rightful compensation, still face intimidation and reprisals three and a half years after the Asian Infrastructure Investment Bank (AIIB) started financing the Indonesian Tourism Development Corporation’s (ITDC) project. Most problematic was the ITDC’s claim that 93% of the land was clean and clear in the Mandalika area, despite a decades-long history of violent land disputes connected to previous large-scale development projects in Lombok.

From the months preceding the loan approval in 2018 onwards, those who resisted involuntary resettlement in Mandalika have been subject to repeated and repressive intimidation and reprisals by the ITDC and other components of the Indonesia government, according to accounts given by local communities, Indonesia’s human rights body, and the special procedures of the UN Human Rights Council.

We invited AIIB and the ITDC to respond to these allegations – after initial reports were published in August 2022, and again ahead of the AIIB’s annual meeting in October 2022, on foot of a partner report detailing further allegations.

It was a breakthrough to receive such detailed responses from the Asian Infrastructure Development Bank (AIIB) and the Indonesian Tourism Development Corporation.

The rise in geopolitical tension, and authoritarian states leads unscrupulous companies to bad decisions that strengthen totalitarians with no regard for rights. We remain alert to emerging and urgent risks in the field of business and human rights – including areas of conflict like the Russian military aggression against Ukraine, escalating US-China tension, and the continuing fallout from the 2022 military coup in Myanmar.

Business and human rights in conflict

February 2022 marked two sombre anniversaries: the invasion of Ukraine and the coup in Myanmar. We partnered with allies to deliver evidence about the impact of business on the human rights on ordinary people. In Myanmar, we invited 26 companies that announced withdrawal or suspension of operations since the attempted coup to assess whether their actions were or will be conducted in a responsible manner. Through collaboration with partners and allies inside and outside Myanmar, we have been monitoring labour and human rights abuses of garment workers across the country since the military takeover. By the end of February 2023, the Myanmar garment worker allegations tracker documented 212 cases of alleged labour and human rights abuses perpetrated against at least 108,000 garment workers, revealing a stark increase in the number of allegations of abuse.

Meanwhile, we looked back at our year-long efforts calling for heightened human rights due diligence among companies operating or investing in Ukraine and/or Russia. Although we still see a lack of understanding by companies of their responsibilities under international law, our efforts have recently attracted the attention of Western governments. Several, including Germany and the USA, are using data from our survey to monitor companies still operating in Russia and encourage them to conduct heightened human rights due diligence. Our dataset is used as a reference by the OECD and a French Government-backed asset management firm is also using our data and analysis when discussing ways to exit responsibly with its clients still operating in Russia.

Corporate due diligence timeline: Monitoring companies’ human rights practices related to Russian aggression against Ukraine

Kirin's "irresponsible" exit from Myanmar

In June 2022, Kirin announced its exit policy from Myanmar, transferring all shares to Myanmar Brewery Limited (MBL), a joint venture with allegedly military-linked Myanma Economic Holdings Public Company Limited (MEHPCL). The company stated it would take into consideration the impact on local employees, business partners, and others in the local Myanmar communities.

However, Justice for Myanmar described Kirin's exit "irresponsible", saying the exit plan would continue providing revenue to the Myanmar military by placing MEHPCL effectively in control of MBL. Its press release stated the responsible move should be denying funds to the Myanmar military and remedying the harm to workers. It also demanded Kirin disclose their human rights due diligence, and the fate of the dividends that they had been withholding from MEHPCL.

We asked Kirin to respond to Justice for Myanmar, which it did, insisting “The safety and treatment of the remaining employees will be determined before the withdrawal, and we will further fulfil our responsibility by requesting MEHPCL to make its best efforts to ensure the safety and freedom of employment of its employees.”

In a fragile and conflict-affected context like Myanmar, with deteriorating human rights situation and the unfeasibility of undertaking ongoing and heightened human rights due diligence, responsible business disengagement strategies should be considered to abide by international human rights standards.

Our total expenditure in FY 2022-23 increased by 14% (£495k) from £3,469k to £3,964k. This expenditure was funded by income generated in the year. This financial year our total income was £4,288k.

As restrictions brought about by the pandemic have eased, so has activity expenditure picked up as the opportunities to work and travel increase. Expenditure on charitable activities also increased by 15% from £3,315k (FY 2021/22) to £3,825k.

Our charitable expenditure is split between our thematic and regional project work as indicated. 

Staffing levels, which, when we include regional researchers, are about 70% of the costs of the organisation. Having stayed steady over the previous two reporting years, this has started to grow again in line with extra funding and demand on our work.

Our total unrestricted reserve stands at £1,082k (FY 2021/22 £404k). This equates to about 3.5 months of full spend. Our policy is now to have these reserves be within 3 to 6 months of total spend.

Read the full financial report and annual statutory accounts.