Our approach
Stakeholder engagement
Who we engage, on what basis, and how what is raised is recorded and acted on.
What engagement is for
Engagement is a source of information about risk. Its purpose is to establish, before a decision is taken, what the people affected by that decision understand, expect and object to, and to reflect that in how the activity is designed. Engagement that does not change anything is not engagement, and the framework treats a record of what was raised, and of what followed it, as the test of whether it took place.
Engagement is required across the lifecycle of an activity, from the earliest stage of work through to closure and beyond it. It is not confined to the periods in which the law requires a formal process.
Key facts
We record engagement: who took part, what was raised, what followed.
Grievance mechanisms are open to verbal, written and anonymous submission.
Where a matter falls to the State, we participate and supply information; we do not conduct the process.
We maintain engagement records so that consistent reporting is possible at any time.
Who is engaged
How engagement is conducted
We identify stakeholders for each activity, including groups vulnerable to its effects, and we choose the method of engagement so that it is accessible to the people concerned: language, literacy, distance, and the seasonal pattern of agricultural and pastoral work are all relevant to whether a meeting can in fact be attended. We record engagement: who took part, what was raised, and what followed.
Where a matter is raised that we cannot address, we say so and give the reason, rather than leaving it unanswered. Where a matter falls to the State, our role is to provide the information the process requires and to participate in it.
Grievances
Grievance mechanisms are accessible, transparent and compatible with the effectiveness criteria in the UN Guiding Principles on Business and Human Rights. They are non-judicial, culturally appropriate, free from retaliation, and open to verbal, written and anonymous submission. We log a grievance with the date received and the matter raised, investigate it for cause, mitigate where we establish a cause, and communicate the outcome to the person who raised it. We record the time taken and the outcome.
We review grievance trends for systemic issues. We escalate a systemic or unresolved issue to executive management and, where appropriate, to the competent authorities.
Reporting on engagement
Where an activity generates them, aggregate statistics on engagement volumes and grievance outcomes are published, and the records behind them are maintained so that the information is prepared on a consistent basis.