Human Rights Policy Development Process

We developed our Human Rights Policy by following the process outlined below:

 

Major Human Rights Issues in the Finance Sector

We have classified below human rights issues by type of business activity after identifying the primary human rights issues in the finance industry as well as all other industries based on internationally recognized guidelines and cases of human rights abuse.

Provision of financial services	Customer privacy Access to financial services Discriminatory expressions in communications Impact on community
	Impact on human rights through our business operations Impact on community Impact on employees Rights of indigenous peoples
Employment	Issues in working conditions and environment Employee privacy Freedom of association Discrimination against employees and other persons
Procurement	Impacts related to employees of suppliers Impact on society through procurement

Stakeholder Dialogues

We requested human rights experts and various stakeholders to provide us with advice via conference calls or written responses in September and October 2017, which included UNEP FI, Shift—a non–profit organization focusing on human rights, and Citigroup.

Their feedback focused on:

1. Content of the draft Human Rights Policy;
2. Salient human rights issues; and
   Stakeholders' expectations regarding implementation of the Human Rights Policy.