Establishing the facts of the incident
Because they will almost always hear about the incident from a third party, works council, or from the affected business unit, the incident management (IM) team will generally have a head start over other stakeholders in human rights cases.
An investigation will almost certainly follow in the coming weeks and months. However, it is important for the IM team to be able to decide on immediate next steps. This means moving fast to establish an accurate picture from the outset, regardless of the source of the original allegation.
Key actions should include:
- making contact with the affected business unit to establish the true position on the ground, whatever the source of the original allegation
- if it is based in the affected country, the IM team should try to make direct contact with operators to establish what has happened
- if it is not, the IM team should be extended to include a locally-based senior manager or director of the subsidiary; the team can then work closely with that manager, explaining what needs to be done on the ground
Key questions during these communications could include:
- have any potential violations occurred?
- where have the potential violations occurred?
- how many victims are there?
- have employees suffered?
- have employees taken part in the potential violation?
- which employees were involved?
- were any third parties involved?
- has the potential violation stopped?
- how did the potential violation come to light?
- is this a systemic issue or a one-off incident?
