September 2025

Key findings:

• ...A business is expected to account for impacts it causes directly and those it contributes to or is directly linked to through its business relationships. Businesses that are ‘directly linked to’ a harm are expected to exercise their leverage to affect change, but where there is a risk of a severe threat, the business must be able to affect change quickly or they risk moving along the continuum of responsibility and ‘contributing to’ the harm, triggering their remedial responsibilities.
• When applying the severity threshold to the Russian invasion of Ukraine, it is possible to expect divestment by foreign businesses from Russia due to the widespread and systematic nature of the violations of international human rights law (IHRL) and international humanitarian law (IHL).
• Any assessment of responsibility on the basis of ‘mere presence’ raises significant concerns about how finding mere presence as a contribution could undermine the rights of Russian civilians. However, the report finds that there are situations when staying in an economy can be a contribution despite certain mitigating factors...
• It is crucial for businesses to assess, as part of their hHRDD, whether and to what extent their actions or omissions are assisting in the maintenance and prolonging of the illegal situation created by the Russian state in the context of its invasion of Ukraine...
• Businesses should not assume that payment of taxes is a neutral act in contexts like this and take seriously the possibility that its contributions to the war economy outweigh the contributions to the realisation of rights.
• Staying in Russia for an extended period of time may move the business from ‘directly linked to’ to ‘contributing to’ the harm, incurring a responsibility to remediate...
• IHRL offers significant guidance as to what kinds of rights and interests and economic activity are essential to preserve even when economic disengagement is otherwise appropriate. In conducting their hHRDD and assessing responsible exit, businesses should be guided by these principles in weighing retrogression against potential contributions to gross violations of IHRL and IHL.
• Businesses that have stayed in Russia might be liable to provide reparations if it is established that they have caused or contributed to gross IHRL and IHL violations committed in Ukraine.
• As part of a comprehensive and victim-centred reparations programme, it would be appropriate for businesses that stayed in Russia when they should have left to make appropriate contributions.
• Home states of foreign businesses have an obligation to regulate their corporate actors operating in Russia, and to hold them accountable for staying in Russia when they should have left. These home states should be ensuring their businesses are contributing to the Ukrainian national reparations programmes and should adopt legislation to facilitate this if they have not already done so.