BRIEFING NOTE 5 - COMMUNICATE

Communicate to stakeholders about human rights impacts identified and progress in addressing them

IIIIIIIIII 1 Concept of communication
IIIIIIIIII 2 What to communicate? – Content
IIIIIIIIII 3 Whom to communicate to? – Target audience
IIIIIIIIII 4 When to communicate (report)? – Timing
IIIIIIIIII 5 How to communicate? – Requirements
IIIIIIIIII 6 Where to communicate? – Mechanisms
IIIIIIIIII 7 Considerations about vulnerable groups
IIIIIIIIII 8 Challenges and recommendations
IIIIIIIIII 9 Checklist
IIIIIIIIII 10 Library of Tools

Objective of the briefing note

This briefing note provides information on how to communicate to stakeholders about the human rights risks and impacts identified in the company’s own operations and supply chain, and the actions taken to address these issues. The briefing note provides guidance on what to communicate, to whom, when, how and where.

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Concept of communication

The communication stage involves conveying to consumers, investors, buyers, rights holders, and other stakeholders about the human rights impacts and risks identified, the measures being taken to prevent, mitigate, and remedy them, and how effective these measures have been in addressing the root cause of the impacts identified. Some stakeholder groups may be more important than others for a company, depending on its position in the supply chain.

The company's transparency in its communication involves providing complete, objective, valid, and reliable information. In addition, it must be freely accessible, easy to understand and shared through channels that are completely open to the target audience.

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What to communicate? – Content

It is recommended that the material to be communicated includes the following information:

The company’s approach and process in place to respect human rights in its own operations and supply chain

Results achieved in implementing the action plans, focusing mainly on the effectiveness of the actions

The methodology adopted and main results of the identification of adverse human rights impacts and risks in their own operations and supply chain

Grievances received and how they were dealt with (if applicable)

Actions taken to prevent, mitigate, and remediate the identified impacts

Future actions and commitments

Communication can include the main results and progress in addressing human rights impacts for specific vulnerable groups. For example, the company can report on the measures it has taken to increase the number of women in leadership positions, to ensure pay equity between different genders, or to increase their participation in important decision-making processes.

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Whom to communicate to? – Target audience

The target audience can vary depending on the content and objectives of the communication and the company's position in the supply chain. Given the proximity of sugarcane mills to potentially affected rights holders, there is a greater need to include mechanisms for communicating directly with them about actions taken to reduce the occurrence of risks to them.

Examples of target audiences for a sugarcane mill could be:

their own workers (permanent, temporary, and contracted)
the communities surrounding the mill's operations
their suppliers
their buyers
their investors (if applicable)

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When to communicate ? – Timing

It is recommended that, at least once a year, the company communicates to stakeholders, and especially to affected parties, about the impacts identified in its operations and supply chain and how they are being addressed.

Specific cases may require more frequent or one-off communication. For example, in cases of complaints received through the company's grievance mechanism, it may be necessary to maintain more frequent communication with the whistleblower(s) in order to keep them informed of progress in resolving the issue. Similarly, communication with your own workers needs to be two-way and frequent to allow for healthy labour relations dynamics and to consider feedback from workers to improve their working conditions.

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How to communicate? – Requirements

The communication tools and formats chosen can vary. The choice of the most appropriate communication mechanism will depend on the objective, the target audience and the content to be communicated. In some cases, it is interesting to communicate aggregated and more summarized data through sustainability reports or online publications.

In other cases, there may be a need to develop a tailored communication mechanism for specific groups of actors. For example, creating oral communication channels accessible to illiterate workers and creating communication materials in the official language of immigrant workers. In specific situations, a one-off report addressing the issue and the action taken to deal with it can be issued by the company.

The chosen means of communication will also depend on the size of the mill and its relationship with human rights holders. A small mill may not have a sustainability report to communicate aggregated data and will rely on simpler mechanisms such as newsletters on the website, press releases, or presentations to relevant stakeholders, among others.

In general, the following criteria are considered when designing communication pieces:

Use existing reporting tools
Comply with legal requirements for reporting on human rights issues, where applicable.
Make it publicly available to all stakeholders
- Example: make it publicly available on the company's website indicating the target audience
Provide sufficient and relevant information
- Example: report on measures aimed at the Health and Safety of workers, including the results of key performance indicators (preferably disaggregated by gender and other relevant groups)
Do not put rights holders at risk
- Example: have a grievance mechanism established to guarantee the anonymity of the reporting parties, and do not disclose information that could lead to the identification of the complainants
Communicate to rights-holders in a culturally sensitive way and in a language they can understand
- Example: publish a sustainability report for the general public on the company's website, and communicate the most relevant information in face-to-face meetings with illiterate workers
- Example: provide a report with the most relevant information in the official language of immigrant workers
- Example: use drawings and icons if there are illiterate workers

Seek the opinion of local rights-holders or Civil Society Organizations (CSOs) on the appropriate communication approach
- Example: before publishing a notice, consult with the workers' association and a local NGO to identify whether the website is accessible to the target audience in question or whether there would be a more suitable communication channel
Reiterate the commitment to existing human rights policy.

Communication helps to foster a positive relationship with workers, communities, and other local actors and, therefore, it is important to consider how inclusive and appropriate this communication is, assessing the accessibility of information, platforms, and meetings in order to reach the target audience effectively. For example, a face-to-face meeting with the local community needs to be held at a place and time that is accessible to this audience. In addition, in order to promote broader representativeness, the needs of specific groups, such as women, need to be taken into account, offering a space and caregivers for young children, if necessary.

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Where to communicate? – Mechanisms

There are various types of mechanisms that can be used to deliver information to the target audience:

Direct communication mechanisms with workers, local communities, and suppliers, internal company programmes.
Example: letter by post; posters in the town hall; WhatsApp message.
The spaces for dialogue and face-to-face meetings allow for greater interaction with the affected actors, with the potential inclusion of consultations in the other stages of due diligence, such as the identification of impacts and the definition of action and monitoring plans.
Example: Face-to-face meeting at the town hall; face-to-face meeting at the company; Daily Safety Dialogues (DSD) [1] or similar; online meetings

Periodic sustainability reports, with specific content on human rights actions, in order to inform the public of the main risks related to the company’s operations and supply chain and how the problems identified are addressed. Second- or third-party verification of human rights reports strengthens their content and credibility.
Example: Sustainability Report Bevap2019
Communications or reports in specific cases of human rights violations
Example: public notice issued by the company, ensuring that the notice reaches the affected parties in an appropriate manner

Communication about grievances raised and the process of analysis and resolution
Example: public ethics channel reporting in detail the process of analysis and resolution of the case

Companies at the start of the supply chain, such as sugarcane mills, due to their proximity to the production level, have direct communication channels with raw material producers and other direct suppliers (of other materials, services, etc.). They are also closer to individuals or groups of actors affected or at risk (such as workers, women, local communities, etc.). Therefore, they are well placed to take advantage of existing spaces for dialogue or, where necessary, create new spaces for communication with these actors, in order to involve them in the process of identifying human rights risks and impacts and co-developing action and monitoring plans.

Below are some examples of possible spaces for dialogue:

For workers: meetings with workers' unions; boxes for anonymous complaints and suggestions; having an employee dedicated to listening to their demands at pre-established times and places.
Surrounding communities: periodic meetings or specific company’s events for the community; known and accessible channels for complaints and suggestions.
Direct suppliers: technical visits by the agricultural team with professionals trained to address human rights issues; meetings before, during, and after the harvest; taking advantage of technical training moments to raise awareness on specific human rights issues.

Real examples of communications in the sugarcane sector

Zilor announcements on actions taken to promote gender equality and traffic safety (access here and here).

Page on Copersucar's website about the actions implemented against the coronavirus (access here).

[1] Daily Safety Dialogues are moments in companies where day-to-day issues are discussed and that can be used to communicate with and listen to workers.

Raizen’s Sustainability Report 2022-2023, in addition to making operational actions visible with engagement, impact assessments and development programmes aimed at the local community, including KPIs, are communicating for the first time the identification of sectoral human rights risks together with mitigation and monitoring actions (access here).

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Considerations about vulnerable groups

It is necessary to reiterate the vulnerability of certain groups at the communication stage. Firstly, by not disclosing information that could lead to the identification of the complainants (people or communities). This could entail a direct risk for human rights defenders. This precaution should not only be taken in external communication but also internally.

In addition, it is important to assess whether the communication material is comprehensible in terms of language. It should be assessed whether all target groups have access to the means of communication. For example, in rural areas, it may not be common to have a telephone or internet access. Therefore, it is advisable to diversify the channels of communication, for example, through individual written bulletins or posted in high-traffic places (such as cafeterias, rest areas, elevators, or stairwells).

Consider using an inclusive language that involves all people, without specifying gender and without changing the spelling of words; or a neutral language that avoids the binarity between male and female genders.

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Challenges and recommendations

Concern of companies regarding reporting on human rights issues

It is understandable that public disclosures about involvement in human rights issues are sensitive content for companies. Any association with human rights abuses can lead to reputational, legal, and financial risks, and commercial consequences. However, it is much more appropriate for a company to acknowledge that it is aware of the impact and to discuss what actions are being implemented to address it, while still allowing relevant stakeholders, such as civil society organizations and affected actors, to follow the progress and effectiveness in addressing the impact. Transparency on human rights issues is the best way forward, always ensuring, of course, the safety of affected actors from possible retaliation or other harm.

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Checklist

✓  Does the company communicate about its human rights impacts and actions at least annually?   

✓  Does the company assess the target audience for each communication and adjust the content and delivery method accordingly?   

✓  Does the company assess the accessibility of information for affected rights holders and other stakeholders?   

✓  Is the information communicated complete, specific, and relevant?   

✓  Does the company protect rights holders by maintaining confidentiality?   

✓  Does the company reiterate in its communication its approach to respecting internationally recognized human rights?   

✓  For specific cases of human rights violations or complaints, does the company maintain frequent and effective communication with the complainant and/or affected parties?