Pakistan – Non-financial reporting

By Daniel Morris | 7. February 2022

CHAPTER 3: National Action Plan Priority Areas and Proposed Actions

3.1. General Proposed Actions

  • Federal and Provincial (pages 16-17)

‘5. Issue and disseminate BHR guidelines for business enterprises in line with the NAP—its priority areas, proposed actions and State expectations of business enterprises—and with regards to non-financial reporting on corporate human rights policies, human rights due diligence, and remedial mechanisms.

Performance indicator(s): (i) Development of Guidelines; (ii) Number of businesses to which Guidelines are disseminated

UN Guiding Principle(s): 1, 2, 3

Relevant SDG(s): Goal 5 – Gender Equality; Goal 8 – Decent Work and Economic Growth; Goal 16 – Peace, Justice and Strong Institutions’

This information is also covered under Appendix 1: Implementation Plan, Proposed Action 5 designating the Ministry of Human Rights; Ministry of Industries & Production; Ministry of Commerce as Leading Entities, and designating the Ministry of Law & Justice; Ministry of Interior; Provincial Human Rights Departments; Securities and Exchange Commission of Pakistan; Ministry of Overseas Pakistanis and Human Resource Development; National Commission for Child Welfare and Development; National Commission on the Rights of the Child as Additional Entities (page 45).

 

3.2. NAP Priority Areas

3.2.3. Human Rights Due Diligence

Proposed Actions

  • Federal (page 26)

‘32. Conduct feasibility study of human rights certification and provision of market incentives for businesses which demonstrate respect for human rights across their operations, including conducting human rights due diligence and publicising their efforts.

Performance indicator(s): (i) Feasibility study report

UN Guiding Principle(s): 1, 2, 3, 8

Relevant SDG(s): Goal 8 – Decent Work and Economic Growth; Goal 10 – Reduced Inequalities; Goal 12 – Responsible Consumption and Production; Goal 16 – Peace, Justice and Strong Institutions’

This information is also covered under Appendix 1: Implementation Plan, Proposed Action 32 designating the Ministry of Commerce and the Ministry of Industries and Production as Leading Entities (page 55).

  • Federal and Provincial (page 27)

‘35. Develop and launch a Human Rights Due Diligence Partnership Project with the private sector, for the purpose of establishing a framework and standards for human rights due diligence reporting.

Performance indicator(s): (i) Launch of Partnership Project

UN Guiding Principle(s): 2, 3, 11, 12, 15, 17, 23

Relevant SDG(s): Goal 5 – Gender Equality; Goal 8 – Decent Work and Economic Growth; Goal 10 – Reduced Inequalities; Goal 12 – Responsible Consumption and Production; Goal 16 – Peace, Justice and Strong Institutions’

This information is also covered under Appendix 1: Implementation Plan, Proposed Action 35 designating the Federal & Provincial Governments, the Ministry of Human Rights, the Provincial Human Rights Departments as Leading Entities, and designating the Ministry of Climate Change; Ministry of Commerce and Textile; Provincial Commerce Departments; Ministry of Communications; Provincial Communications Departments; Ministry of Energy; Provincial Energy Departments; Ministry of Finance, Revenue and Economic Affairs; Ministry of Industries & Production; Ministry of Law & Justice; Provincial Law Departments; Ministry of Inter-Provincial Coordination, Pakistan Environmental Protection Agency; Ministry of Health; Provincial Health Departments; Federal and Provincial Ombudspersons as Additional Entities (page 57).

‘36. Establish voluntary and common standards for conducting and reporting human rights due diligence in business activity, applicable to both the direct operations and across the value chains of public and private enterprises.

Performance indicator(s): (i) Development and dissemination of voluntary standards in line with international best practices

UN Guiding Principle(s): 1, 2, 3, 11, 12, 15, 17, 23

Relevant SDG(s): Goal 5 – Gender Equality; Goal 8 – Decent Work and Economic Growth; Goal 10 – Reduced Inequalities; Goal 12 – Responsible Consumption and Production; Goal 16 – Peace, Justice and Strong Institutions’

This information is also covered under Appendix 1: Implementation Plan, Proposed Action 36 designating the Provincial Governments and the Ministry of Human Rights as Leading Entities, and designating the Ministry of Law and Justice; Ministry of Industries and Production; Ministry of Commerce; Provincial Human Rights Departments; Provincial Law Departments; Provincial Commerce Departments; Provincial Industries and Commerce as Additional Entities (page 58).

3.2.8 Access to Remedy

Proposed Actions

  • Federal (page 36)

‘63. Conduct a national mapping exercise to identify existing reporting procedures for human rights violations occurring from business activity, and make recommendations for improved effectiveness.

Performance indicator(s): (i) Mapping exercise report

UN Guiding Principle(s): 1, 25

Relevant SDG(s): Goal 8 – Decent Work and Economic Growth; Goal 10 – Reduced Inequalities; Goal 16 – Peace, Justice and Strong Institutions’

This information is also covered under Appendix 1: Implementation Plan, Proposed Action 63 designating the Ministry of Human Rights, the Provincial Human Rights Departments and the National Commission on Human Rights as Leading Entities, and designating the NHRIs and CSOs at Federal and Provincial Levels as Additional Entities (page 69).

 

CHAPTER 4: State Expectations of Business Enterprises (pages 38-39)

‘To facilitate and guide business enterprises in ensuring compliance with and supporting the effective implementation of the NAP priority areas and the UNGPs, the State of Pakistan expects business enterprises to:

1. Evaluate their compliance with all applicable domestic laws relevant to the respect for human rights in business activity, and provision of corrective or remedial action in response to potential, ongoing, or past human rights violations resulting directly from their activity or through their business relationships across their value chains.

2. Ensure the elimination of child labour, forced or bonded labour, and all forms of modern slavery from their business operations and supply chains. This may be expedited through the utilisation of effective and thorough human rights due diligence.

[…]

6. Establish adequate human rights due diligence mechanisms to identify, prevent, and remedy human rights impacts. Human rights due diligence should consider both internal risks that stem directly from business operations as well as external risks, which relate to all other entities that the business work with across their operations or are linked with through their value chains. Human rights due diligence should be carried out before commercial operations and business activities, proportionate to the size and scope of the enterprise and the scale and complexity of its potential human rights impacts, and on a continuous basis to ensure that integrated findings from impact assessments shape future business decisions. Businesses should also ensure that the risks identified through due diligence and corrective actions taken are adequately reported and communicated to stakeholders, preferably in the form of an annual human rights due diligence report.

[…]

8. Develop key performance indicators corresponding to the achievement of human rights goals and routinely review and update them to reflect national legislative and policy changes.’

 

ANNEX II | Actions Already Undertaken by Pakistan

A | General Measures Relevant to Business and Human Rights (pages 72-73)

‘The Securities and Exchange Commission of Pakistan (SECP) has provided guidelines on CSR, whereby public companies must report on how their activities protect and promote human rights.

[…]

Protection from environmental degradation is also a priority for Pakistan. Under the State Bank Guidelines for Infrastructure Project Financing, companies must draft a description of environmental impact assessments and must report on health and safety issues to provide information as to the compliance of the project with relevant laws.’

B | Measures Relevant to NAP Priority Areas

iii. Human Rights Due Diligence (page 80)

‘The State Bank has developed guidelines which provide that as a pre-requisite companies must draft a description of environmental impact assessments and must report on health and safety issues to provide information as to the compliance of the project with relevant laws.

In the sustainability reports of businesses within Pakistan, corporate social responsibility (CSR) is a major component. This mostly covers health, safety, and environmental policies.’