7 A UK STRATEGY ON BUSINESS
AND HUMAN RIGHTS?
164. One of the governance gaps identified by Professor
Ruggie was a lack of coherence within national Governments on
the relationship between their work with businesses and their
human rights obligations and related policies. He told us:
that directly shape
business practices, whether it is securities regulations or whether
it is trade, commerce or investment, are off doing their thing,
the human rights people are off somewhere else and the twain rarely
The UK Government approach
165. Responsibility for Government policy on business
and human rights straddles at least four major departments:
- The Ministry of Justice, the Foreign and Commonwealth
Office (FCO) and the Department for International Development
(DFID) share responsibility for Government policy on human rights.
Their responsibilities vary according to domestic or international
boundaries, and whether the policy involved relates to human rights
issues in developing countries;
- BIS has responsibility for business policy in
the broader sense. It has lead responsibility for corporate responsibility,
the operation of the OECD Guidelines and anti-corruption issues.
BIS is "fully engaged" in any human rights initiatives
which are taken forward by other departments which have an impact
on UK businesses, consumers and employees; 
- A number of departments play additional roles:
- DFID leads on a number of voluntary multi-stakeholder
initiatives which the Government supports, including the Ethical
Trading Initiative (ETI), the extractives industry mechanisms
and other natural resource and conflict issues. DFID also provided
funding for the establishment of the International Institute of
Business and Human Rights, a body led by former UN Commissioner
for Human Rights Mary Robinson, which is designed to build on
the work of the Business Leaders Initiative on Human Rights;
- The FCO provides the UK lead on the work of the
UN Special Representative. It runs the Government Diamond Office
which works on the Kimberley Process. Working with the US, the
FCO was responsible for establishing the Voluntary Principles
on Security and Human Rights in the extractive industry. It also
led on the creation of the Extractives Industry Transparency Initiative;
- The Export Credit Guarantees Department, together
with BIS, DFID and the FCO sits on the Steering Board of the
UK NCP for the OECD Guidelines;
- The Department for Environment, Food and Rural
Affairs (DEFRA) has responsibility for environmental reporting
by businesses and "skills for corporate responsibility";
- The Department for Work and Pensions has responsibility
for Government policy on ethical pension fund management and socially
responsible investment, UK relations with the International Labour
Organisation (ILO) and liaison with trade unions in the workplace;
- Other Departments may work on individual projects,
for example, the Department of Health is currently working with
the Ministry of Justice on its Private Sector and Human Rights
project, which we consider, below.
166. Witnesses had three criticisms of Government
policy in this area:
- Undue priority was given to voluntary initiatives
in the Government's approach;
- Government policy lacked coherence;
- The Government had failed to provide a clear
167. We consider each of these criticisms in relation
to the following recent Government initiatives:
- The Corporate Responsibility Report, published
by the then Department for Business, Enterprise and Regulatory
Reform, in February 2009.
- The Ministry of Justice's new private sector
project, designed to inform Government work on the relevance of
human rights for the domestic UK private sector ("the Private
Sector and Human Rights Project");
- The FCO Toolkit for its overseas posts, focusing
on the issue of business and human rights. The final version
of this Toolkit was published in October 2009. ("the FCO
- The draft Bribery Bill, published for pre-legislative
scrutiny in March 2009.
Government Corporate Responsibility Report 2009
168. The Corporate Responsibility Report sets out
the Government's vision for corporate responsibility. It states:
Today's nations face a global challenge- we
want everyone to satisfy their basic needs and enjoy a better
quality of life but to do so without compromising the quality
of life for future generations. [
] Everybody has obligations
to act responsibly in order to achieve these goals, individuals,
groups, businesses and Government.
169. The Report sets out the business case for corporate
social responsibility and explains that the Government intends
to create a policy framework which sets minimum levels of performance
in health and safety and environmental and employment practices
and helps businesses to take voluntary measures aimed at encouraging
responsible behaviour. The Report recognises that while much
of the impetus behind the Corporate Responsibility agenda has
come from environmental issues, customers, employees and other
stakeholders are increasingly "demanding ethical trading
policies, fair employment practices and the safeguarding of human
rights". It outlines a number of Government initiatives
both at home and abroad to foster corporate responsibility.
170. The work of the UN Special Representative
is highlighted as one of a number of initiatives supported by
Government. The Report outlines the 'protect, respect, remedy'
framework in brief but provides no explanation of what the business
responsibility to respect means or of the due diligence measures
recommended by the UN Special Representative to meet that responsibility.
171. Although the document sets out a range of measures
which support corporate responsibility - and positive steps being
taken by the Government to that end - there is no clear statement
on which measures the Government consider to be effective or what
steps the Government recommends or expects businesses to take
next. The Government's latest Corporate Responsibility Report
presents a positive overview of the steps which the Government
is taking to implement its existing policy. While we commend
the steps taken by the Government to promote the business case
for corporate responsibility, we regret that the Report does not
clearly connect this business case to the responsibility to respect
human rights recognised by the UN Special Representative in his
work. The language of 'encouragement' found in the Corporate
Responsibility Report, while positive, seems out of kilter with
the conclusion of Professor Ruggie that many of the steps taken
by business to address their human rights impacts are incorrectly
viewed as purely voluntary measures. Equally, the Report does
not clearly identify that existing compliance and regulatory steps
required of business - for example in respect of health and safety,
the environment and equality - are designed to meet the human
rights obligations of the UK. This suggests that the Government's
corporate responsibility strategy is unduly focused on voluntary
measures and underestimates the extent to which businesses have
human rights responsibilities.
The Private Sector and Human Rights Project
172. The Ministry of Justice is currently working
with the Department of Health on a Private Sector and Human
Rights Project. This has involved establishing a private
sector working group, running an online survey and conducting
a series of interviews with businesses from a variety of sectors.
The project: "aims to establish an understanding of the
engagement of UK businesses with human rights within their domestic
operations and will consider whether a need for further guidance
for businesses with human rights within their domestic operations
whether a need for further guidance for businesses
exists on how to embed human rights within their UK practices".
173. The project seems to us to demonstrate a number
of limitations and shortcomings. First, it focuses solely on
the domestic activities of UK businesses. Secondly, is principally
concerned with the view of UK businesses on whether they need
guidance, not on wider issues surrounding the impacts of UK business
on human rights. The consultation appears to have focused principally
on private sector and business bodies and organisations. It does
not appear to have canvassed the wider views of consumers, NGOs
or other stakeholders.
174. The Ministry of Justice submitted a supplementary
memorandum dealing principally with the preliminary findings of
the project. These included that the majority of business respondents
"clearly understood" human rights applying to all individuals.
The majority of companies understood the concept of human rights,
but these companies perceived that human rights issues were largely
confined to employment matters. UK businesses surveyed had a
"significant desire" for practical guidance on "how
to integrate human rights within their policies". Importantly,
companies surveyed did not often use the term 'human rights' beyond
the enclave of corporate social responsibility. Businesses surveyed
typically saw 'human rights' as "mainly applicable to their
wider operations only when they operate overseas, particularly
in the least developed countries".
175. The Government launched the report of its scoping
study after the conclusion of this inquiry, on 12 November 2009.
The findings of the report broadly reflect the initial findings
set out above. In addition, the study recognises that its sample
is likely to be dominated by companies who were inclined to express
a positive interest in human rights issues. It acknowledges that
a "vociferous yet small number of negative responses"
were likely to be significantly underrepresented. This group
is characterised as the "Human rights are not for us"
or "Get out of my hair" cohort in the study.
176. The study raises a number of key questions for
the Government to consider and encourages the Government to engage
with business leaders in taking this discussion forward:
The initiation of dialogue between the UK government,
the private sector and other interested organisations is in its
early stages. There is clearly interest in the subject amongst
the business community, which gives government an opportunity
to enhance the understanding of the issues and promote business
177. The Government told us that the findings of
the study would inform the next steps of the project and its overall
scope. In his
foreword to the report of the study, the Minister for Human Rights,
Michael Wills MP called it an initial "outreach" to
guide "further engagement with the UK private sector".
However, he also made clear that the project has provided "initial
momentum" which the Government hopes will be taken forward
by the EHRC.
178. It was initially unclear why the scope of this
project had not been widened to include the overseas activities
of UK businesses. In oral evidence, Michael Wills MP, the Minister
for Human Rights, told us that the FCO was not part of the steering
group for the project, although it had been "copied in".
The Government has since said that the FCO has begun to attend
project steering group meetings.
179. We commend the decision of the Government
to initiate its Private Sector and Human Rights Project. It seeks
informed answers to many of the questions posed by this inquiry,
including whether there are gaps in existing guidance and legal
and regulatory frameworks relating to businesses in the UK which
need to be addressed. However, we are concerned that the project
appears to have been limited to gathering the views of UK businesses
about their domestic activities. It is unfortunate that other
Government departments, including BIS, DFID and the FCO, which
are more familiar with the Government's corporate responsibility
agenda, have not been more heavily involved. Their experience
of the international debate on the cross border impacts of companies
could have usefully informed the scoping study. We recommend
that any policy options pursued as a result of the Private Sector
and Human Rights Project are subject to wider consultation with
consumers, employees, NGOs and other stakeholders.
180. At present, there are no planned next steps
for the Government Private Sector and Human Rights Project, other
than to recommend action by the Equality and Human Rights Commission.
We are concerned that this approach appears to indicate a lack
of leadership and commitment to taking this debate forward.
We make some positive recommendations for further action, below.
The FCO Toolkit on Business and Human Rights
181. The FCO Toolkit has been distributed to all
overseas FCO and UK Trade and Industry posts. The 20 page Toolkit
explains that its purpose is to give guidance to political, economic,
commercial and development officers in overseas missions on how
to "promote good conduct for UK companies overseas".
It focuses principally on the implementation of the OECD Guidelines,
but gives guidance to staff on how to promote human rights. It
provides basic further information on other mechanisms for the
protection of human rights, including the Voluntary Principles
on Security and Human Rights, the Extractives Industries Transparency
Initiative and the work of the Special Representative. The Toolkit
sets out the Government's support of the work of the Special Representative
and the OECD Guidelines and stresses that the UK is "committed
to promoting responsible corporate behaviour amongst UK companies
operating (or considering potential opportunities for operating)
overseas". It expressly states that:
An important part of overseas missions' work
is to promote human rights
with host government representatives.
Missions should therefore be aware of allegations of concern
arising from the operations of UK companies or their subsidiaries
overseas. Where possible, facilitate and lobby for discussion
and resolution of these issues.
182. In addition to this lobbying and promotional
work, the Toolkit identified a number of possible actions for
FCO posts. For example, staff who become aware of acts of bribery
committed by UK nationals or companies, should report immediately
to the Serious Fraud Office. Staff must inform companies about
human rights risks, particularly in conflict zones. If a complaint
arises against a UK company, staff should inform relevant bodies
including the EU, the UN, and the International Monetary Fund.
Any information relevant to a complaint - irrespective of whether
it supports or undermines the allegations against the UK company
- should be communicated to the UK NCP.
183. Some witnesses argued that promotion of UK businesses
overseas should be linked to their human rights performance.
Others argued that the UK Government had taken steps to promote
UK businesses in ways which would be inconsistent with local law
and the international human rights commitments of the host state.
Gavin Hayman, for Global Witness said:
[A UK Ambassador in a South Asian country] was
effectively taking a British biofuels company to a plantation
to encourage them to invest with inward investment, but effectively
that plantation was completely illegal under the laws of the land.
] This is the kind of thing where a sense of not simply
promoting business but helping business manage risks could be
a very sensible approach.
184. We asked the Minister for further information
on the guidance and support provided by UK posts overseas to business
and others on human rights issues. The Minister for Regulation,
Ian Lucas MP, told us that Government wanted human rights to be
at the "front of the minds" of UK businesses working
overseas and that this was "very high" on the list of
priorities for UK missions.
We also asked whether the FCO and UK Trade and Investment (UKTI)
took a consistent approach. The Minister explained:
There is a perception of difference, for example,
in the UKTI and perhaps the Foreign Office, from outside, but
what we are trying to do is ensure that for UKTI human rights
are just as much on their agenda as they are for the Foreign Office.
185. The Government subsequently provided us with
further information on the role of UKTI. This information makes
clear that the objectives of the UKTI - to promote UK enterprise
overseas - are
There are no specific references to human rights
principles in the objectives of the UKTI. However through the
commitments of its parent departments BIS and FCO, UKTI is bound
to consider human rights principles in its efforts to achieve
186. We discussed the promotion of human rights with
a number of FCO personnel overseas. We recognise from our discussions
that a more proactive role for UK posts could require significant
additional resources and the need for more training in human rights
particularly in relation to the private sector.
187. Lord Malloch-Brown, then Minister for UN and
Africa, explained that all posts currently receive generic human
rights training. It is unclear what further training staff will
receive on the issues in the Toolkit. In June 2009, the Government
explained that it intended after publication of the Business and
Human Rights Toolkit to disseminate it to posts and make it available
on the FCO website.
188. We welcome the Government's Toolkit on Business
and Human Rights and commend the aim of providing accessible information
and recommendations to overseas posts on issues which might arise
about business and human rights. We particularly welcome the
specific directions given to posts about how they might promote
human rights and respond to allegations against UK companies.
There are, however, limits to what this short document can achieve.
Without promotion and adequate training for relevant staff in
what human rights mean for business, there is a risk that the
Toolkit will gather dust in embassy in-trays.
189. We recommend that the FCO monitors the use
of the Toolkit in practice to assess its value. At present, the
Toolkit does not provide a UK contact for posts to consult for
further guidance. We recommend that the Government considers
how knowledge and expertise on business and human rights issues
can be developed centrally, with a view to ensuring best practice
is shared within the FCO and across Whitehall.
The draft Bribery Bill
190. The draft Bribery Bill was introduced by the
Government in March 2009 for pre-legislative scrutiny. The Joint
Committee on the draft Bribery Bill reported in July 2009. It
welcomed the draft Bill and made a number of detailed recommendations.
At the request of the Chairman of the Joint Committee, we wrote
to indicate our view that in so far as the Bill was designed to
meet both domestic and cross border corruption, in our view it
was a human rights enhancing measure.
Anti-corruption measures address human rights issues. In the
2004 foreword to the UN Convention, the then UN Secretary
General, Kofi Annan explained:
Corruption is an insidious plague that has a
wide range of corrosive effects on societies. It undermines democracy
and the rule of law, leads to violations of human rights, distorts
markets, erodes the quality of life and allows organised crime,
terrorism and other threats to human security to flourish.
191. In the past, the Government has been criticised
for a lack of leadership on bribery and corruption issues, facing
accusations that the international obligations of the UK suffer
at the expense of short term economic interests.
We hope that the publication and enactment of the Bribery
Bill during this Parliamentary session will mean that such concerns
are a thing of the past. We look forward to scrutinising this
measure. In so far as it is designed to reduce bribery and corruption
in the UK and abroad, we consider that it is a human rights enhancing
measure. We recommend that Parliamentary time be made available
to allow this Bill to gain Royal Assent before the end of this
The need for a UK strategy on
business and human rights
192. We are concerned that a number of the weaknesses
highlighted by Professor Ruggie in his reports are apparent in
the Government's current strategy for business and human rights.
No clear message appears from the Government's evidence on these
issues, other than encouragement to businesses to take a responsible
approach to their human rights impacts. Peter Frankental, of
Amnesty International told us that:
A good starting point would be for the UK to
have an overarching strategy on business and human rights, which
does not exist at the moment. If it is left to individual government
departments to try to address these issues, the human rights impacts
of business will always be subsumed within other departmental
193. The Institute for Business and Human Rights
said that greater coordination on this issue was needed nationally
and could be provided by either the Government or the national
human rights institutions in the UK:
Several countries have taken steps to ensure
greater policy coherence between different government departments
with regard to business and human rights. Some governments have
appointed ministers responsible for cross-department information
sharing and coordination; others; such as France and Sweden have
appointed ambassadors to foster greater integration of human rights
principles and standards between government departments: including
those addressing business and other trade and economic related
issues. In some countries, like Kenya and South Africa, it is
the National Human Rights Institution that has played this coordinating
role. In the UK, there is a great need and great opportunity
for one or both of these approaches to be harnessed.
194. We asked Ministers how the Government achieved
consistency and coherence in its approach when its policy straddled
the responsibilities of so many Departments and agencies. The
Minister for Human Rights, Michael Wills MP, explained that the
Government hoped to learn from its Private Sector and Human Rights
Project. He accepted that there may "need to be changes
to the machinery of Government to ensure better coordination and
better certainty for business" and that the project was highlighting
the need to "join the dots".
Government policy on business and human rights lacks the coherence
called for by the UN Special Representative. We recommend that
the Government reviews its approach to business and human rights
to develop a more consistent strategy with a clearer message.
The forthcoming review of the OECD Guidelines provides a good
opportunity for the Government to step back and look not just
at the Government position on the Guidelines but at its broader
approach to the human rights impacts of business both in the UK
195. One approach would be to broaden the cross-Government
steering group on the UK NCP so that it could inform and coordinate
Government strategy on business and human rights issues. While
this steering group includes external members, it also provides
an example of a coalition of relevant Government departments not
currently duplicated on other issues. We recommend that the Government
consider this option.
What would a UK strategy look
196. There are many facets of the Government's existing
policy which are to be commended, not least its financial support
for multi-stakeholder initiatives and capacity building in nations
where governance is weak.
However, there are limits to the Government's current approach.
197. On voluntary mechanisms, Professor Ruggie told
us that policies limited to advocating voluntary approaches to
corporate responsibility for business "often differ very
little from laissez faire":
They are not really policies at all; they are
just words on paper
Even if the government advocates voluntary corporate responsibility
in a programme or a policy, it needs to signal what that means,
it needs to signal what the expectations are, otherwise it is
not a policy
at a minimum a policy needs to signal what
is expected and then you go up from there, if you will, on a regulatory
198. The limits of capacity building are illustrated
in the recent work of the House of Commons International Development
Committee on Nigeria. The Committee counselled against increased
aid until corruption in Nigeria had been reduced and its governance
mechanisms improved. It considered the impact of the operations
of Royal Dutch Shell in Nigeria and concluded that legislation
might be necessary in addition to capacity building measures:
Violence and instability in the Niger Delta are
having a serious impact on Nigeria's oil industry and therefore
on its economic situation. The people of the region suffer poverty
and live in fear, despite the wealth being generated in the region.
The causes are complex and reflect the interaction between oil,
politics, crime and corruption in Nigeria which have to be tackled
in a co-ordinated and integrated approach. We believe DFID must
do more to support the Nigerian authorities to meet their responsibility
to provide this response. This should include the adoption where
necessary of stronger legislation to compel oil companies to honour
the rights of local people.
199. Witnesses identified a number of themes which
could be addressed in a new UK strategy on business and human
- A consistent approach across their domestic and
- Capacity building and enhancing human rights
protection in host states
- Proactive engagement with business and human
rights issues by the UK at an international or intergovernmental
200. Professor Ruggie has been clear that the most
effective approach is a proactive one, where Governments integrate
a human rights based approach into all aspects of their activities
relating to business:
The human rights policies of states in relation
to business need to be pushed beyond their narrow institutional
confines. Governments need actively to promote a corporate culture
respectful of human rights at home and abroad.
201. There are a number of proactive steps which
Professor Ruggie and others told us the UK could consider taking
to support and reinforce the 'protect, respect, remedy' framework.
- Clearer guidance and support for business on
human rights issues;
- A strategy on human rights in public procurement
and public investment;
- Reforms to the Government's approach to Export
- Revisiting the Companies Act 2006; and
- A change in approach to investment.
202. The Government and business witnesses tended
to argue against such measures and we assess their arguments,
203. Some witnesses suggested that the UK could use
domestic law to make parent companies directly responsible for
their actions overseas, the actions of their subsidiaries, or
actions in their supply chain, where human rights abuses cannot
be remedied in the countries where they happen.
However, the IoD argued that the adoption of this approach "serves
to weaken the sovereignty of other national governments",
lacks legitimacy and can be criticised as an exercise in "cultural
The CBI was cautious about the involvement of the home state
in any extraterritorial activities of business:
If you are looking at state duty, the state as
the primary duty bearer has its own jurisdictions to undertake
the obligations which are placed upon it. When you begin to look
at the home-host country dynamic, one of the areas that you get
into which does cause business some concern is extraterritoriality
does not feel comfortable with the extraterritorial application
but it is important to look at ways to explore
the home-host state nexus.
204. The Government opposes such extraterritorial
action. Lord Malloch-Brown said he had concerns about how firms'
behaviour overseas could be monitored from the UK and about determining
the relevant standard that should be applied to UK businesses.
Professor Ruggie told us that home-state regulation applied to
the activities of the parent company was not unreasonable and
should be explored, despite its potential extraterritorial effects:
states are generally permitted to do more than
they are currently doing. One of the things that states are permitted
to do, which relatively few do, is what we call parent-based regulation,
Government requires [a] parent company
to exercise oversight of its own subsidiaries, and it holds the
parent company responsible, as opposed to directly reaching out
into another country and legislating directly for the subsidiary.
Developing countries in particular get all huffed up when confronted
with extraterritorial jurisdiction by Western countries in particular.
If you propose a major intervention in their jurisdiction, you
would not get very far in most UN bodies, for example, but parent-based
regulation or requirements are perfectly acceptable under current
205. We accept that there are legitimate concerns
to be addressed in respect of direct application of extraterritorial
standards overseas. We are not persuaded that the same degree
of concern applies to all forms of regulation which may have some
extraterritorial effects. We consider that the application of
conditions to a parent company based in the UK, for the purposes
of regulating their relationship with the UK Government or its
shareholders in the UK, has a very different degree of extraterritorial
effect to the direct application of the jurisdiction of the UK
courts to breaches of the human rights obligations of the UK overseas.
We recommend that the Government considers which standards it
expects UK companies to meet in respect of its own contacts with
and support for those businesses.
INTERNATIONAL STANDARDS AND LEGAL
206. Standards can be defined and applied in a number
of ways to affect how businesses respect human rights. In the
Netherlands, certain forms of support will not be provided to
companies who cannot prove that they comply with the OECD Guidelines.
In Norway, statutory ethical standards are applied to certain
actions of public bodies, for example in relation to pubic investment.
A third possibility is to introduce a clear reporting mechanism
which allows the Government, consumers and other stakeholders
to test business performance against voluntarily accepted business
The Government should not rule out setting clear standards
for business to meet where it considers these standards are necessary
to meet its human rights obligations. There is merit in considering
whether existing standards supported by both businesses and the
UK Government could be used to reinforce the responsibility of
business to respect human rights in practice.
COMPETITIVENESS AND THE PLAYING
207. The last of the key arguments against further
action by the UK Government is that by taking action unilaterally,
the UK will undermine the competitiveness of its companies and
harm the economy. Gary Campkin, for the CBI, told us that caution
must be exercised when looking at the competitiveness of UK businesses:
That is not to say that we downgrade human rights
or we downgrade anti-bribery or what have you, but it has to be
done in a way which is principled but also which does not put
British companies at a disadvantage.
208. We asked Professor Ruggie about this argument
and he told us:
Your companies will be at an advantage because
they are going to stay out of trouble, and the Chinese companies,
or whatever they may be, who do not have the backing of a government
to provide them with effective assistance and enhanced risk management
concerns will be in deeper trouble. It is not an imposition,
it is not a competitive disadvantage. It helps companies stay
out of trouble because in the current environment, as we saw with
the financial sector meltdown, when incentives are fundamentally
misaligned the market does not automatically produce optimal outcomes.
There has to be some signalling device, there has to be assistance
209. Arguments based on anti-competitiveness are
difficult to square with the understanding that all responsible
companies should already be performing due diligence in respect
of their human rights impacts. For the home state to take action
to incentivise or reward behaviour which is accepted good practice
would seem logically to have little impact upon the competitiveness
of UK companies. We are not persuaded that unilateral steps
by the UK would undermine the competitiveness of UK businesses.
210. We recommend that any new Government strategy
should build on the work of the Special Representative and the
'protect, respect, remedy' framework. It should also seek to
address the criticisms raised by witnesses to this inquiry. In
particular, Government policy must be clearer and more coherent.
The principal purposes of the strategy should be to meet the
Government's duty to protect human rights and to support UK businesses
in meeting their responsibility to respect the human rights of
others, both within the UK and abroad. Its key aim should be
to set out clearly for businesses, consumers and the wider community
what the UK expects of UK business. The international human rights
obligations of the UK and UK Government policy on human rights
should inform its policies for the private sector both within
the UK and overseas. The strategy should present a clear and
coherent connecting thread between domestic policy, foreign policy
and the UK's international diplomacy, including at the EU, the
OECD and the UN.
230 Q1 Back
Ev 96 Back
Ev 85 Back
See for example, Ev 138, Ev 209 Back
See for example, Ev 139, Ev 172, Ev 207, Ev 218, Ev 271 Back
See for example, Ev 279, Q 63 - 64, Q113 - 114 Back
Corporate Responsibility Report 2009, page 5. Back
Ev 85 Back
Ev 85 and Ev 89.Compare Ev 99 - 100 Back
Ev 89 Back
Twenty-Fifty Ltd, The Private Sector and Human Rights in the UK,
October 2009, pages 23 - 24. Back
Ibid, page 8 Back
Ev 100 Back
Twenty-Fifty Ltd, The Private Sector and Human Rights in the UK,
October 2009 Back
Ev 100 Back
Ev 231 Back
For further information on the objectives of UKTI, see: https://www.uktradeinvest.gov.uk/ukti/appmanager/ukti/aboutus?_nfpb=true&_pageLabel=aims_objectives&_nfls=false Back
Ev 99 Back
HC Deb 18 June 2009, Col 43`1W Back
Joint Committee on the Draft Bribery Bill, First Report of Session
2008-09, The Draft Bribery Bill, HL Paper 115/HC 430. Back
Ibid, Ev 328 Back
See for example, OECD Working Group on Bribery, United Kingdom:
Phase 2bis, October 2008; R (Corner House) v Secretary of State
for Industry  EWCA Civ 192, at paras 100-114; R (Corner
House) v Serious Fraud Office  UKHL 60.See also , for example,
The Independent, Britain rebuked for dropping bribe inquiry, 19
January 2007. Back
Q64. See also Ev 189, Ev 205, para 4.2 Back
Ev 270, para 2 Back
See for example, QQ 359 - 360 Back
Eighth Report of 2008-09, DFID Programme in Nigeria, HC 840, para
Ev 268, paras 1-3 Back
Ev 205, para 4.2 Back
Speech of Professor John Ruggie, Third Annual Responsible Investment
Forum, New York, 12 Jan 2009. See also Ev 297. Back
See for example, Ev 106, Ev 166 Back
Ev 108, paras 18-19 Back
See for example, Ev 289 Back
See for example, Ev 228, Ev 238, Ev 274, Ev 292 Back