Publications of the Ministry of Economic A�airs and Employment Energy • 2021:17 Status of Human Rights Performance of Finnish Companies (SIHTI) Project Report on the status of human rights performance in Finnish companies Status of Human Rights Performance of Finnish Companies (SIHTI) Project Report on the status of human rights performance in Finnish companies Ministry of Economic Affairs and Employment of Finland Helsinki 2021 Publications of the Ministry of Economic Affairs and Employment 2021:17 Ministry of Economic Affairs and Employment of Finland © 2021 Authors and Ministry of Economic Affairs and Employment of Finland Author’s organisation: Elina Tran-Nguyen (FIANT Consulting Oy), Suvi Halttula (3bility Consulting), Jaana Vormisto (FIANT Consulting Oy), Lotta Aho (Aalto University/Hanken), Nikodemus Solitander (Hanken/Centre for Corporate Responsibility), Sirpa Rautio (Human Rights Centre) and Susan Villa (Human Rights Centre) ISBN pdf: 978-952-327-737-3 ISSN pdf: 1797-3562 Layout: Government Administration Department, Publications Helsinki 2021 Finland Publication distribution Institutional Repository for the Government of Finland Valto julkaisut.valtioneuvosto.fi Publication sale Online bookstore of the Finnish Government vnjulkaisumyynti.fi https://julkaisut.valtioneuvosto.fi/ https://vnjulkaisumyynti.fi/ Description sheet 16 March 2021 Status of the Human Rights Performance of Finnish Companies SIHTI-project report Publications of the Ministry of Economic Affairs and Employment 2021:17 Subject Enterprises Publisher Ministry of Economic Affairs and Employment of Finland Authors Elina Tran-Nguyen, Suvi Halttula, Jaana Vormisto, Lotta Aho, Nikodemus Solitander, Sirpa Rautio and Susan Villa Language English Pages 104 Abstract The main objective of the Status of Human Rights Performance of Finnish Companies (SIHTI) project was to obtain a comprehensive and in-depth overview of how Finnish companies are fulfilling their human rights responsibility, i.e., how they have implemented the expectations set in the UN Guiding Principles on Business and Human Rights (UNGPs). The methodology developed by Corporate Human Rights Benchmark (CHRB) was used to assess the companies’ human rights performance. The study included 78 Finnish companies, of which 29 were assessed using CHRB's comprehensive industry-specific methodology, and 49 using the Core UNGP Indicators methodology. During the project, 20 company representatives were also interviewed about challenges companies face in disclosing information related to human rights responsibility. The results of the study show that although Finnish companies are, at least on a general level, quite widely committed to respecting human rights, the practical integration of human rights responsibility and related monitoring into the core activities of companies, is still largely at an early stage. Finnish companies also publish relatively little information related to their human rights responsibilities. However, the status of the human rights performance of Finnish companies is approximately on the same level as the results of CHRB's global assessments. The study shows that the Core UNGP Indicators developed by CHRB would be well suited for regular monitoring of the human rights performance of Finnish companies, as the indicators can be widely used to assess companies of different sizes and from different industries and they focus on the key aspects of the UN Guiding Principles. Keywords enterprises, assessment, corporates, corporate responsibility, human rights ISBN PDF 978-952-327-737-3 ISSN PDF 1797-3562 URN address http://urn.fi/URN:ISBN:978-952-327-737-3 http:// Kuvailulehti 16.3.2021 Suomalaisyritysten ihmisoikeussuoriutumisen tila (SIHTI) -hanke Selvitys suomalaisyritysten ihmisoikeussuoriutumisen tilasta Työ- ja elinkeinoministeriön julkaisuja 2021:17 Teema Yritykset Julkaisija Työ- ja elinkeinoministeriö Tekijä/t Elina Tran-Nguyen, Suvi Halttula, Jaana Vormisto, Lotta Aho, Nikodemus Solitander, Sirpa Rautio ja Susan Villa Kieli englanti Sivumäärä 104 Tiivistelmä Suomalaisyritysten ihmisoikeussuoriutumisen tila (SIHTI) -hankkeen päätavoitteena oli tuottaa kattavaa ja syvällistä tietoa suomalaisyritysten ihmisoikeusvastuun toteutumisesta suhteessa YK:n yrityksiä ja ihmisoikeuksia koskevissa ohjaavissa periaatteissa (UNGP:t) yrityksille asetettuihin odotuksiin. Hankkeessa yritysten ihmisoikeusvastuun toteutumisen arviointiin käytettiin Corporate Human Rights Benchmarkin (CHRB:n) kehittämää metodologiaa. Selvitykseen sisällytettiin 78 suomalaisyritystä, joista 29 arvioitiin CHRB:n laajalla toimialakohtaisella metodologialla, ja 49 keskeisten UNGP-mittareiden avulla. Hankkeen aikana haastateltiin myös 20 yritysten edustajaa ihmisoikeusvastuuseen liittyvän tiedon viestimisen haasteista. Selvityksen tulokset osoittavat, että vaikka suomalaisyritykset ovat varsin laajasti ainakin yleisellä tasolla sitoutuneet ihmisoikeuksien kunnioittamiseen, käytännön tasolla ihmisoikeusvastuun ja sen seurannan järjestelmällinen integrointi osaksi yritysten ydintoimintoja on suurelta osin vielä varhaisessa vaiheessa. Suomalaisyritykset myös julkaisevat verrattain niukasti ihmisoikeusvastuunsa toteutumiseen liittyvää tietoa. Suomalaisyritysten ihmisoikeusvastuun toteutumisen tila on kuitenkin pitkälti samalla tasolla CHRB:n globaalien arviointien tulosten kanssa. Selvitys osoittaa, että CHRB:n kehittämät keskeiset UNGP-mittarit soveltuisivat hyvin suomalaisyritysten ihmisoikeusvastuun toteutumisen säännölliseen seurantaan, sillä mittaristo keskittyy YK:n ohjaavien periaatteiden keskeisiin asioihin ja sitä voi käyttää laajasti eri toimialojen ja eri kokoisten yritysten arviointiin. Asiasanat yritykset, arviointi, ihmisoikeudet, yritysvastuu ISBN PDF 978-952-327-737-3 ISSN PDF 1797-3562 Julkaisun osoite http://urn.fi/URN:ISBN:978-952-327-737-3 http:// Presentationsblad 16.3.2021 Utredning av tillståndet för mänskliga rättigheter bland finländska företag (SIHTI) (Selvitys suomalaisyritysten ihmisoikeussuoriutumisen tilasta) Arbets- och näringsministeriets publikationer 2021:17 Tema Företag Utgivare Arbets- och näringsministeriet Författare Elina Tran-Nguyen, Suvi Halttula, Jaana Vormisto, Lotta Aho, Nikodemus Solitander, Sirpa Rautio och Susan Villa Språk engelska Sidantal 104 Referat Det övergripande målet med utredningsprojektet var att skapa djupare och mera omfattande kunskap om hur finländska företag lever upp till de förväntningar som FN:s vägledande principer för företag och mänskliga rättigheter (UNGP) skapar. Som grund för denna utvärdering användes en metodologi utarbetad av Corporate Human Rights Benchmark (CHRB). I utredningsprojektet ingick 78 finländska företag, varav 29 företag utvärderades användandes av CHRBs sk. omfattande sektorspecifika metodologi, samt 49 företag utvärderades med de s.k. centrala UNGP indikatorerna. I utredningen ingick även intervjuer med 20 företagsrepresentanter angående utmaningar att publicera information om mänskliga rättigheter. Utredningens resultat visar att fastän finländska företag rätt så väl på ett allmänt bland förbundit sig till att respektera mänskliga rättigheter, så finns det utmaningar kring den systematiska integrationen av människorättsansvaret och dess uppföljning till delar av företagets kärnfunktioner. De finländska företagen publicerar även relativt sparsamt information om hur de förverkligar sitt ansvar kring mänskliga rättigheter. Dock konstaterar utredningen att dessa resultat stort sett är i linje med CHRBs egna globala utredningsresultat. Utredningen visar även att den metodologi som CHRB utvecklat som bygger på den centrala UNGP-indikatorerna skulle lämpa sig väl för en regelbunden uppföljning av hur människorättsansvar förverkligas av finländska företag, detta på grund av att de använda indikatorerna fokuserar på de centrala punkterna i FN:s vägledande principer för företag och mänskliga rättigheter samt på grund av att de dessa indikatorer kan användas för att utvärdera företag av olika storlek och inom olika sektorer. Nyckelord företag, utvärdering, mänskliga rättigheter, företagens samhällsansvar ISBN PDF 978-952-327-737-3 ISSN PDF 1797-3562 URN-adress http://urn.fi/URN:ISBN:978-952-327-737-3 http:// Contents Summary.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1 Introduction.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 2 Key concepts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 3 Project methodology.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 3.1 Assessment of the corporate human rights performance using the CHRB methodology.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 3.1.1 Background of the CHRB methodology.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 3.1.2 Sample.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.1.3 Material used. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 3.1.4 Interaction with the companies.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 3.1.5 Assessment process.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 3.1.6 On the content of the CHRB methodology’s indicators.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 3.1.7 Comparison with other studies using the CHRB methodology.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 3.2 Interview study on disclosing information on the companies’ human rights responsibility.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 4 The level of human rights performance in Finnish companies.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 4.1 Results of sectoral assessments.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 4.1.1 Agricultural products sector. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 4.1.2 Forest sector. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 4.1.3 Extractives sector.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 4.1.4 Apparel sector. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 4.1.5 ICT sector.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 4.1.6 Cross-sectoral comparison. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 4.2 Results for the Core UNGP Indicators .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 4.2.1 Results of the assessment conducted with the Core UNGP Indicators.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 4.2.2 Results of the Core UNGP Indicators across the full project sample. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 4.2.3 Significance of ownership base and revenue in assessment results.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73 4.3 Overall analysis of the results and conclusions.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 4.3.1 The level of human rights performance in Finnish companies.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 4.3.2 Factors affecting the human rights performance of Finnish companies.. . . . . . . . . . . . . . . . . . . . . . . . . . . 79 5 Why do the companies not disclose information on their human rights responsibility?.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 6 Suitability of the CHRB methodology as a monitoring tool in Finland. . . . . . . . . . . . . . . . . . 88 7 Conclusion.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93 Appendices.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96 8 Publications of the Ministry of Economic Affairs and Employment 2021:17 S U M M A RY In June 2011, the UN Human Rights Council adopted the UN Guiding Principles for Business and Human Rights (UNGPs) as the first global standard for corporate human rights responsibility. Applying to all countries and all businesses, the purpose of the principles is to prevent and address the adverse effects of business activities on human rights. At the same time, they clarify the related roles, responsibilities and obligations of states and businesses. Although states have a primary duty to protect human rights, private sector actors are expected to take appropriate measures to prevent, mitigate and remedy their adverse human rights impacts.  Objective of the study The main objective of this project (Status of Human Rights Performance of Finnish companies, SIHTI) was to produce comprehensive and in-depth information on the human rights performance of Finnish companies in relation to the expectations and standards concerning their policies, processes, practices and responses to harmful human rights impacts, set for companies in the UN Guiding Principles.  The aim was that the information produced in the project will support the implementation of the elements related to responsible business operations in the Prime Minister Marin’s Government Programme, such information on Finnish companies’ human rights performance having not been available previously. The project was divided into three areas, with the following research questions: 1. What is the status of the human rights responsibility among the Finnish companies under review? 2. What are the main challenges companies face in publishing information related to the fulfilment of their human rights responsibilities? 3. How suitable is the CHRB methodology as a monitoring tool in the Finnish context? 9 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Methodology and sample The project used the methodology developed by Corporate Human Rights Benchmark (CHRB), in accordance with the call for proposals by the Prime Minister’s Office, to assess the implementation of the human rights performance of Finnish companies. The broad industry-specific methodology developed by the CHRB for companies in the agricultural products, apparel, extractives, and ICT sectors is based on international and sectoral standards for human rights and responsible business. In addition, CHRB’s more concise Core UNGP Indicators -methodology is suitable for all sectors and covers the key elements of the UN Guiding Principles. Both of these methodologies were used in the project. A total of 78 Finnish companies were included in the sample, 29 of which were assessed using CHRB’s sectoral methodology and 49 with the Core UNGP Indicators. Companies with their head office in Finland were considered as Finnish companies. 1 SMEs were excluded from the sample because the CHRB methodology has been developed to assess in particular larger companies. The TE500 list, published annually by Talouselämä, comprising 500 companies with the largest revenue in Finland, was used to determine the sample. In accordance with the CHRB methodology, the implementation of corporate human rights responsibility was assessed in the report based on publicly available information. This approach is based on the strong emphasis on the principle of transparency in the UN Guiding Principles, which require companies to communicate openly and actively about their commitment to human rights, their human rights risks and impacts, and the related actions. Key sources of information used in the assessment included the companies’ own websites, financial and non-financial reports, other public documents and statements, such as policy commitments (e.g. Code of Conduct, Supplier Code of Conduct), values, guidelines and other relevant documents. In accordance with the CHRB methodology, the 29 companies involved in the sectoral assessment were invited to publish any additional information or documents related to their human rights performance at the beginning of the assessment process and once they received their tentative assessment results for review. This additional information that could be published either on the company’s own website or on the SIHTI project website was also taken into account in the assessment. The companies involved in the sector- specific assessment could also discuss their tentative assessment results with a member of the research team. The narrower assessment conducted with the Core UNGP Indicators did not include an engagement phase with the companies, the assumption being that, 1 Three foreign companies with significant mining activities in Finland were also included in the sectoral assessment of the extractive sector. 10 Publications of the Ministry of Economic Affairs and Employment 2021:17 since these indicators measure the fundamentals of the implementation of UN Guiding Principles in business processes and transactions, the data should be available in public materials. Both CHRB’s sectoral and the Core UNGP Indicators methodologies include a number of indicators, which are grouped under different measurement themes. To ensure consistent interpretation and scoring of indicators and related criteria, the project team invested strongly in quality assurance. This was particularly important because the terminology used by companies in their communications does not always correspond to the language of human rights documents and the UN Guiding Principles. In addition to assessing the human rights performance, the project studied also the views and experiences of Finnish companies in relation to publicly disclosing information related to their human rights responsibility. A total of 20 companies involved in the sectoral assessment or in the Core UNGP Indicators assessment were interviewed on the companies’ experiences and challenges in publishing information and on ways to support companies in publishing more information related to their human rights responsibility. The level of implementation of corporate human rights responsibility The results of the assessment show that although Finnish companies are quite widely, at least on a general level, committed to respecting human rights, the systematic integration of human rights responsibility and its monitoring into their core activities is still largely at an early stage. This is clearly reflected in the results of the Core UNGP Indicator assessment focusing on issues fundamental for the implementation of the UN Guiding Principles, with an average of 27.2% across the whole sample (max. 100%). Although there is significant dispersion in the results of the 78 companies assessed, a clear majority of the companies (49/78) remain at less than 30% of the maximum score in their overall results. Five companies receive a zero score in the assessment, while only one company reaches the best score range (90–100%). The overall results of the five more comprehensive sector-specific assessments confirm the conclusion that although companies have started to integrate human rights responsibility into their sustainability work, this work has not yet progressed very far. The average of the total score of the 29 companies assessed is 24.8%, which is very close to the average of the 2019 global assessment carried out by the CHRB2. Although there are differences in the results between the sectors and there is a significant dispersion in the results of the whole 2 Corporate Human Rights Benchmark (CHRB) has assessed the human rights performance of large companies in its sectoral assessments. In 2019, 200 companies from around the world participated in the assessment. 11 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 sample, almost half of the companies assessed are quite close to the average and more than a quarter are well below the average. Commitment to respecting human rights: What can be considered a positive result is that the majority of Finnish companies are generally committed to respecting human rights, and the majority are also committed to respecting the ILO Fundamental Principles and Rights at Work. At the same time, however, there are still several companies that are not explicitly committed to these rights in their own business and supply chains. It should also be noted that only a small proportion of Finnish companies are publicly committed to remedy in situations where they find that they have caused or contributed to adverse human rights impacts. This can be seen as reflecting the fact that companies are still at an early stage in concretising their human rights responsibilities and in understanding what the commitment means in practice.   The human rights due diligence is a key process in the implementation of a company’s human rights responsibility. 3 It enables the company to identify, prevent, mitigate and address the adverse human rights impacts of its activities. The results of the study show that for the majority of Finnish companies, this process has not yet been fully started (41/78) or it is at a very initial stage (16/78). Few companies have regularly identified the key human rights risks and impacts of their activities, conducted related human rights impact assessments and integrated the assessment results into their internal functions and processes. However, there are also forerunners among Finnish companies. Although companies that have progressed furthest in the implementation of human rights due diligence are often large companies, there are also smaller companies that have actively tackled human rights risks that are relevant to their businesses, both in supply chains and in their domestic operations.  Grievance mechanisms and remedy: The UN Guiding Principles expect companies to put in place effective operational-level grievance mechanisms as channels through which all people and communities potentially affected by business-related human rights impacts can report their concerns and claim their rights. Most of the companies assessed (68/78) have at least some channels for reporting human rights concerns and abuses. However, there were considerably fewer grievance channels open to all stakeholders potentially affected by companies’ human rights impacts (39/78). The results of the study highlight the need to develop the companies’ grievance channels especially so that they are accesible to vulnerable stakeholders. They also clearly show that companies do not yet 3 In this report, we use the term human rights due diligence to refer to the corresponding concept in the UN Guiding principles. In this context, the term does not refer to the statutory obligations of companies. 12 Publications of the Ministry of Economic Affairs and Employment 2021:17 have a clear approach to remedy in general. Information on the processes and approach to remedy was found from only one company in the whole sample (78 companies). The discussion on the human rights responsibilities of companies is strongly and rightly focused on so-called high-risk countries. However, there are also increasing human rights risks in Finland. The results of the sector-specific assessment brought up an important issue related to ignoring the so-called self-evident issues in the monitoring and reporting of human rights risks in companies. Such self-evident issues include, for example, a living wage, appropriate wage payment practices, or the fact that the company does not use child labour or forced labour. As the operating environment evolves, it is increasingly important to discuss to what extent these issues can be taken for granted in Finland or other low-risk countries.  The UN’s Guiding Principles require companies to go beyond the requirements of national legislation in situations where the legislation does not comply with human rights standards. However, the report showed that many companies have not yet considered what their active role could and should be in respecting human rights in these more challenging country contexts. A concrete example of this is related to the freedom of association and the right to collective bargaining, which are excluded from the rights of workers in certain countries in which Finnish companies operate, manufacture and/ or source. In the case of these countries, companies’ commitments may contain separate references to take into account the limitations of local legislation regarding freedom of association and collective bargaining. At the same time, there are also companies that have developed approaches and practices to ensure respect for these rights also in challenging country contexts. Challenges in disclosing information on human rights responsibility The UN Guiding Principles strongly emphasise the importance of transparency. Companies are expected to communicate openly about the management of their human rights risks. The results of the study show that Finnish companies publish relatively little information on their human rights responsibilities and related performance. This is partly because companies find it difficult to report on human rights issues, and there is a need for both clear recommendations how the reporting should be done, as well as more resources. Additionally, companies perceive that there is not enough demand for such information. The conducted interviews also revealed that lack of commitment by senior management makes transparent reporting more difficult.  13 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Monitoring the implementation of corporate human rights responsibility The annual assessments carried out by the CHRB have shown that regular monitoring encourages companies to improve processes, mechanisms and practices related to their human rights responsibility. Given that Finnish companies are largely still in an early stage in the implementation of the UN’s Guiding Principles, it is important to consider how regular monitoring at the national level could be used to promote the implementation of the human rights responsibility in Finnish companies.  CHRB’s Core UNGP Indicators are well suited to assess the realisation of human rights responsibilities of Finnish companies, as they focus on the fundamental elements of the UN Guiding Principles and are suitable for different industries and also for companies of all sizes. With these indicators, it would be relatively easy and efficient to monitor, for example, annually how Finnish companies progress in these matters. On the other hand, a more comprehensive sector-specific assessment carried out every few years, would enable more comprehensive information on the implementation of corporate human rights responsibility. The results of the study indicate that the state of human rights performance of Finnish companies is largely at the same level as the results in the global assessments of the CHRB. Regular monitoring could, for its part, contribute to encouraging Finnish companies to make active progress in their human rights performance in accordance with the UN’s Guiding Principles.  14 Publications of the Ministry of Economic Affairs and Employment 2021:17 Results of the study in a nutshell: • Finnish companies are largely committed to respecting human rights, at least on a general level. However, the practical implementation of the commitments is still largely at an early stage. • For most of the companies, the development of the human rights due diligence process has not yet started at all or is at a very early stage. • A large proportion of the companies have some channels for reporting human rights concerns and abuses. However, there is an apparent need for developing the grievance channels that are accessible to vulnerable groups, especially channels that are open to external parties. Moreover, companies generally do not yet have a clear approach to remedy. • Discussions on the corporate human rights responsibility are strongly and rightly focused on high-risk countries. However, as the operating environment is continuously changing, it is increasingly important to take into consideration the business related human rights risks also in Finland or other low-risk countries.  • The status of human rights performance of Finnish companies is largely at the same level as the results in the global CHRB assessments. Regular monitoring could encourage companies to actively progress in their human rights responsibilities in accordance with the UN’s Guiding Principles. 15 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 1 Introduction In June 2011, the UN Human Rights Council adopted the UN Guiding Principles for Business and Human Rights (UNGPs) as the first global standard for corporate human rights responsibility. Applying to all countries and all businesses, the purpose of the 31 principles is to prevent and address the adverse effects of business activities on human rights. At the same time, they clarify the roles, responsibilities and obligations of states and businesses. Although states have a primary duty to protect human rights, private sector actors are expected to take appropriate measures to prevent, mitigate and remedy their adverse human rights impacts.  Prime Minister Marin’s Government Programme includes three entries related to responsible business: 1. In cooperation with the business sector, Finland will develop a binding regulatory framework on corporate responsibility as a part of the reform work under way in the UN and the OECD; 2. the possibility to legislate at European level on corporate social responsibility based on due diligence, which takes into account companies of different sizes and international value chains, will be investigated; and 3. a report aiming to enact a corporate social responsibility act will be prepared. Information on how Finnish companies are currently implementing their human rights responsibilities is needed to support the implementation of these entries. Such information has not, however, been available. In recent years, information has been produced quite regularly on the evolution and priorities of the corporate responsibility of Finnish companies. For example, the results4 of the Corporate Responsibility survey and the latest results of the Corporate Responsibility Pulse study5 focusing on large companies published by FIBS have revealed a strong increase in the significance of corporate responsibility. According to PwC’s 2018 Corporate Responsibility Barometer6, more detailed human rights reporting has increased, especially among large companies. However, the purpose of the above noted reports has not been 4 FIBS 2019: Corporate Responsibility 2019 survey. Key findings. https://www.fibsry.fi/wpcontent/ uploads/2019/05/Yritysvastuu2019_Tiivistelma-1.pdf. Thematic reports: https://www.fibsry.fi/ajankohtaista/ yritysvastuu-2019-teemakohtaiset-raportit/ 5 FIBS 2020: FIBS Corporate Responsibility Pulse. Questionnaire summary 19 November 2020. https://www.fibsry. fi/wp-content/uploads/2020/11/FIBS_yritysvastuupulssi_pilottikyselyn-yhteenveto_11_2020.pdf 6 PwC 2018. Corporate Responsibility Barometer 2018. https://www.pwc.fi/fi/julkaisut/ yritysvastuubarometri-2018.html 16 Publications of the Ministry of Economic Affairs and Employment 2021:17 to assess how companies perform in relation to the expectations of the UN Guiding Principles, but to more generally describe the state of responsible business in Finland. The first pilot study7, carried out by FIANT Consulting Oy and 3bility Consulting, focusing on the implementation of human rights responsibilities of Finnish companies, was published at the end of 2019. It examined the implementation of human rights responsibility by Finnish listed companies using the Core UNGP Indicators of the Corporate Human Rights Benchmark (CHRB) methodology. The main objective of the Status of Human Rights Performance of Finnish companies (SIHTI) project, implemented under the Government of Finland’s research, analysis and assessment activities, was to produce comprehensive and in-depth information on the realisation of human rights responsibility of Finnish companies in relation to the expectations and standards concerning their policy, processes, practices and response to harmful human rights impacts, set for companies in the UN Guiding Principles.  The aim was that the information produced will support the implementation of the entries related to corporate social responsibility set in the current Government Programme. At the same time, the information produced is also valuable for other stakeholders, such as research and expert institutions, parties focusing on responsible investment and civil society actors. The project’s main objective was divided into three areas, with the following research questions: 1. What is the status of the human rights responsibility among the Finnish companies under review? 2. What are the main challenges companies face in publishing information related to the fulfilment of their human rights responsibilities? 3. How suitable is the CHRB methodology as a monitoring tool in the Finnish context? The project used the methodology developed by Corporate Human Rights Benchmark (CHRB), as specified in the thematic descriptions in the call for proposals by the Prime Minister’s Office, to assess the implementation of the human rights responsibility of Finnish companies. The sector-specific methodology developed by the CHRB is based on international and sectoral standards for human rights and responsible business. In addition, the methodology applied by CHRB to all sectors covers the core elements of the UN Guiding Principles. Both methodologies were used, i.e., companies were assessed 7 FIANT Consulting Oy & 3bility Consulting 2019: Words to Deeds. Report on the implementation of the UN Guiding Principles on Business and Human rights in Finnish listed companies. 17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 on the basis of publicly available information, either by the broad, sector-specific CHRB methodology developed in particular for agricultural products, apparel, extractives, and information and communication technology companies (ICT) or by CHRB’s narrower Core UNGP Indicators methodology suitable for all sectors. A total of 78 Finnish companies were included in the project sample, 29 of which were assessed using CHRB’s sectoral methodology and 49 with the Core UNGP Indicators. Companies’ views on the publishing information related to the realisation of their human rights responsibility were collected through an interview study with a sample of 20 companies. The project was implemented in 2020, when the COVID-19 pandemic started. Although the pandemic had a wide range of impacts on the everyday lives of people and businesses, it did not have a significant impact on the study itself. The publicly available data used for the assessment as per the CHRB methodology (e.g., various reports for 2017–2019) had already been largely completed and published before the pandemic started. Furthermore, the pandemic did not seem to influence the engagement with the companies involved in the sectoral assessment. The SIHTI project was implemented by Hanken School of Economics’ and the University of Helsinki’s joint research and development institute, Centre for Corporate Responsibility, the Human Rights Centre, FIANT Consulting Oy and 3bility Consulting. The project lead was Nikodemus Solitander (PhD, Centre for Corporate Responsibility, CCR, director), the project coordinators (until the end of October) were Marie-Lou Manca (MSc (Econ. & Bus. Adm.), CCR/Hanken) and Greta Steenworden (MSc, CCR/Hanken), the project’s researchers were Elina Tran-Nguyen (MA, FIANT Consulting Oy), Jaana Vormisto (PhD, FIANT Consulting Oy), Suvi Halttula (M.Soc.Sc., 3bility Consulting) and Lotta Aho (LL.M, PhD, Aalto University/Hanken), and the project’s experts were Sirpa Rautio (LL.M, PhD, Human Rights Centre), Susan Villa (MSc, Human Rights Centre) and Dorothée Cambou (LL.D, University of Helsinki). Emma Borg (LL.M) and Julia Koskinen (BSc) acted as project assistants. In order to ensure the quality of the project, in particular coherent interpretation of the CHRB indicators and related criteria, and the consistency of scoring, the project team held several internal quality assurance meetings during the assessment process. The project also relied on two external experts, Lenita Toivakka from the Global Compact Finland network and Anna Hyrske from Finland’s Sustainable Investment Forum, FINSIF. The steering group of the project consisted of experts from the Ministry of Economic Affairs and Employment, the Ministry for Foreign Affairs and the Prime Minister’s Office.  The SIHTI project began in April 2020, and the project’s Finnish report was completed in December 2020. The report was published and translated into English at the beginning of 2021. The different phases of the project are summarised in Figure 1 below. 18 Publications of the Ministry of Economic Affairs and Employment 2021:17 Figure 1:  SIHTI project phases Chapter 2 of this report discusses key concepts relevant to the study, and chapter 3 presents in more detail the methodology and sample of the assessment, as well as the assessment process. Chapter 4 presents the results of both the sectoral and the Core UNGP Indicators assessments, and provides an overall analysis of the results. At the end of the chapter, the first research question will also be answered: What is the status of human rights responsibility of Finnish companies, and what kind of underlying factors influence it? Chapter 5 focuses on the results of the interview study on the companies’ views and experiences of disclosing information related to human rights responsibility and discusses the challenges involved. Chapter 6 of the report responds to the third research question: What is the suitability of the CHRB methodology as a monitoring tool in the context of Finland? The applicability of both the broad sector-specific methodology and the narrower Core UNGP Indicators methodology are assessed. Finally, Chapter 7 of the report summarises the overall results of the SIHTI project. The SIHTI project team would like to warmly thank the steering group members Linda Piirto, Kent Wilska, Sami Pirkkala and Alva Bruun for their valuable expert discussions and good guidance, the companies involved in the sectoral assessment for their active participation in the process, as well as the CHRB experts Angus Sargent and Camille Le Pors for their support in answering methodological questions. January–February 2021: publication of the report and translation into English June–July 2020: introductory webinars for companies subject to sector-speci�c assessment and launch of research work November–December 2020: writing and �nalising the report August–September 2020: preliminary results for comments and complementing by companies in sectoral assessment, implementation of UNGP Core Indicators assessment September–October 2020: interview study on challenges related to publishing human rights responsibility information, implementation of UNGP Core Indicators assessment, writing the report April–May 2020: project inception phase 19 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 2 Key concepts The report examines the level of implementation of human rights responsibility in Finnish companies. The reference framework for this review is the UN Guiding Principles on Business and Human Rights (UNGPs) adopted by the UN Human Rights Council in 20118 The UN’s Guiding Principles are seen as a global standard for business and human rights, which all countries and businesses are required to comply with. Although the document is not legally binding, the Guiding Principles specify the content and consequences of existing standards and practices for both states and businesses. The Principles have been drawn up for the implementation of the 2008 “Protect, respect and remedy” framework presented by the UN Special Representative. They contain 31 principles that summarise the measures that countries can take to help companies respect human rights. For companies, they offer an operating model for managing risks related to the adverse human rights impacts, and, for stakeholders, the criteria with which they can assess respect for human rights in business activities.9 The following concepts define the processes by which companies are expected to implement their human rights responsibilities in accordance with the UN’s Guiding Principles and are therefore at the core of this study: Human rights due diligence is an ongoing risk management process through which a company’s commitment to human rights is implemented in practice and the stages of which are defined in the UN Guiding Principles.10 These stages include identifying and assessing the potential and actual human rights impacts of business activities, integrating and acting on the basis of assessment results, monitoring the effectiveness of the actions taken and transparent communication on how the impacts are addressed (see Figure 2).11 8 https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf 9 United Nations, The Corporate Responsibility to Respect Human Rights, An Interpretive Guide, 2012 https:// www.ohchr.org/Documents/Issues/Business/RtRInterpretativeGuide.pdf 10 In this report, we use the term human rights due diligence to refer to the corresponding concept in the UN Guiding Principles. In this context, the term does not refer to the statutory obligations of companies. 11 United Nations, The Corporate Responsibility to Respect Human Rights, An Interpretive Guide, 2012 https:// www.ohchr.org/Documents/Issues/Business/RtRInterpretativeGuide.pdf FIANT Consulting Oy & 3bility Consulting, Words to Deeds – Study on Operationalization of the UN Guiding Principles on Business and Human Rights among Listed Companies in Finland, 2019, https://www. ihmisoikeuskeskus.fi/@Bin/8444383/Words+to+Deeds.pdf. 20 Publications of the Ministry of Economic Affairs and Employment 2021:17 The primary purpose of human rights due diligence is to prevent a company’s adverse direct and indirect human rights impacts. However, it also plays an important role in mitigating the adverse effects that have been realised, preventing their recurrence and, if necessary, remedying them.12 Remediation /remedy refers both to processes of providing remedy for adverse human rights impacts and to solutions to address the adverse impact. The means of resolution may take different forms, such as an apology, restoration of control or value, financial or other compensation, criminal or administrative penalties (such as a fine), and prevention of harm in the future, for example by means of a precautionary measure or an assurance of cessation of the adverse activities.13 Grievance mechanisms: The UN Guiding Principles expect companies to put in place effective operational-level grievance mechanisms. Effective grievance mechanisms are channels through which all people and communities potentially affected by human rights impacts of business operations can report their concerns and claim their rights. They are an important source of information for businesses to learn about and to intervene in their human rights impacts and to use this information for learning within the organisation.14 12 OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, http://mneguidelines.oecd.org/ OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf 13 United Nations, The Corporate Responsibility to Respect Human Rights, An Interpretive Guide, 2012 https:// www.ohchr.org/Documents/Issues/Business/RtRInterpretativeGuide.pdf 14 FIANT Consulting Oy & 3bility Consulting, Words to Deeds – Study on Operationalization of the UN Guiding Principles on Business and Human Rights among Listed Companies in Finland, 2019, https://www. ihmisoikeuskeskus.fi/@Bin/8444383/Words+to+Deeds.pdf. 21 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Figure 2:  Human rights due diligence process (Figure adapted from Figure 1 in OECD Due Diligence Guidance for Responsible Business Conduct, 2018) Embed responsible business conduct into policies & management systems Identify and assess adverse human rights impacts in operations, supply chains and business relationships Track implementation and results Remedy and grievance mechanisms Cease, prevent or mitigate adverse human rights impacts Communicate how impacts are addressed 22 Publications of the Ministry of Economic Affairs and Employment 2021:17 3 Project methodology The methodology developed by Corporate Human Rights Benchmark (CHRB) was used, as specified in the call for proposals by the Prime Minister’s Office, to assess the implementation of the human rights responsibility in Finnish companies. The majority of the analyses and results of the study are based on this methodology. In addition, a structured key informant interview method was used to study company’s views and perspectives on their human rights performance related communication. This chapter describes the main characteristics of the CHRB methodology, while more detailed information can be found in the CHRB methodology publications15. 3.1 Assessment of the corporate human rights performance using the CHRB methodology 3.1.1 Background of the CHRB methodology The methodology developed by the CHRB is based on the UN’s Guiding Principles and other international and sectoral standards for human rights and responsible business. The first pilot version of the methodology was published in 2016, and feedback was collected from a wide range of stakeholders, including companies, government representatives, NGOs, researchers and legal experts. In 2017, the CHRB used the methodology to assess the human rights performance of 100 large global companies in the agricultural products, apparel, and extractives industries. Since then, the CHRB has further developed its methodology and published an updated version of it on an annual basis. In addition, in 2018, the CHRB also developed an assessment methodology for ICT companies. The assessment carried out by the CHRB in 2019 already included a total of 200 companies from the agricultural products, apparel, extractives and information and communication technologies sectors. The sectoral assessment of the SIHTI project has used the latest version of the CHRB methodology, published in January 2020. 15 1) Corporate Human Rights Benchmark Methodology 2020 for the Agricultural Products, Apparel and Extractives Industries; 2) Corporate Human Rights Benchmark Methodology 2020 for the Information and Communications Technology Manufacturing Industry; 3) CHRB Core UNGP Indicator Assessment for Companies in All Sectors. 23 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 In addition to the sectoral methodology, the CHRB developed a narrower methodology in 2019 for all sectors, focusing on the key issues of the UN Guiding Principles (Core UNGP Indicators). This methodology has been used by parties other than the CHRB in Ireland and Germany (and Finland) in 2019.16 In 2020, it has been used in Belgium, Ireland, Denmark, Germany and Scotland.17 In addition, in November 2020, the CHRB published its own global assessment in accordance with this methodology.18 In addition to the sector-specific methodology, this Core UNGP Indicators methodology was also used in the SIHTI project. 3.1.2 Sample The CHRB’s sectoral methodology has been developed and used in particular to assess the implementation of human rights responsibilities by large companies. The methodology focuses in particular on the production of raw materials and the manufacturing of products (see Table 1 below). The majority of Finland’s largest companies operate in sectors other than agricultural products, apparel, extractives and information and communication technology. In order to obtain a sufficient sample and thus an overall picture of the level of implementation of the human rights responsibility in Finnish companies, companies from other sectors were included in the SIHTI project sample by using the CHRB’s Core UNGP Indicators. A total of 78 Finnish companies were included in the sample, 29 of which were assessed using CHRB’s sectoral methodology and 49 with Core UNGP Indicators. Based on discussions with the steering group in the early stages of the project, SMEs were excluded from the sample, as the CHRB methodology has been developed in particular for the assessment of larger companies. Furthermore, it would have been difficult to compare the results obtained by SMEs with those of larger companies. The TE500 list, published annually by Talouselämä, comprising 500 companies with the largest revenue in Finland, was used to determine the sample. Companies with their headquarters in Finland were included in the sample from the 2019 TE500 list. 16 Hogan, F.B, Rhodes, ML., Murphy, S.P. & Lawlor, M.2019: Irish Business & Human Rights: Benchmarking compliance with the UN Guiding Principles. Trinity College Dublin, The University of Dublin. School of Management and Law & Business & Human Rights Resource Centre 2019: Respect for Human Rights. A Snapshot of the Largest German Companies. FIANT Consulting Oy & 3bility Consulting, Words to Deeds - Study on Operationalization of the UN Guiding Principles on Business and Human Rights among Listed Companies in Finland, 2019. https://www. ihmisoikeuskeskus.fi/@Bin/8444383/Words+to+Deeds.pdf 17 So far, only the Danish study has been published: The Danish Institute for Human Rights 2020: Documenting Business Respect for Human Rights. A Snapshot of Large Danish Companies. 18 https://www.worldbenchmarkingalliance.org/publication/chrb/ 24 Publications of the Ministry of Economic Affairs and Employment 2021:17 Of the 12 companies included in the sample from the agricultural product sector, five were food stuff companies, three were retails companies and four were forest sector companies. In the global review of the CHRB, companies in the forest sector have not been included, but it was decided to include them in the sample of the SIHTI project, as they represent a significant group of companies in the Finnish corporate context with respect to both revenue and direct human rights impacts (in Finland and globally). Based on the preliminary analysis carried out before the actual assessment, the methodology developed for the agricultural product sector was deemed to be largely suitable also for the assessment of companies in the forest sector. It was decided to include in the sample not only Finnish extractives companies but also foreign companies operating in Finland. The importance of the extractives sector in Finland has grown in recent years (e.g., excavation volumes have increased in the last three consecutive years). In addition, mining activities and their environmental impacts, as well as risks and challenges related to human rights, have also been discussed in public in Finland. A total of six extractives companies were included in the study. Six companies from the apparel sector were included in the sample. In Finland, there are very few apparel companies as defined by the CHRB whose business in this sector would constitute a significant part of the business. For this reason, the sample includes all companies in the sector on the TE500 list. Five companies were included in the sample from the ICT sector. In line with the CHRB definition, production and manufacturing of various ICT products form an integral part of the assessed companies’ businesses. Nokia was not included in this study, as it has been and will continue to be assessed as part of the global assessment of the CHRB19. The sample of the assessment using the Core UNGP Indicators included the 49 largest companies on the TE500 list, excluding the companies included in the sectoral review, financial and insurance companies, as well as the Finnish subsidiaries of foreign groups that focus on the marketing and sales of group products in Finland. Financial and insurance actors were not included in the sample, as it would have required a more in-depth assessment of how well the indicators take into account, for example, the complexity of value chains in these sectors. It was not possible to carry out this assessment and potentially modify the methodology to suit these areas within the scope of this study. 19 CHRB’s ICT sector assessment report 2019: https://www.corporatebenchmark.org/sites/default/files/2019-11/ CHRB2019KeyFindingsReport.pdf. The results of the CHRB’s narrower assessment implemented with core UNGP indicators in 2020 are available at https://www.worldbenchmarkingalliance.org/publication/chrb/. 25 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Table 1:  Sectors covered by CHRB methodologies and the project’s sample size Sector as defined by the CHRB Sample size Notes a) Agricultural products sector: raw material production and processing, including related supply chains. 12 companies c) Extractives sector: exploration, development, production, decommissioning and closure. 6 companies The CHRB methodology does not cover processing, refining, marketing or end-use of extractive resources. b) Apparel sector: material production and manufacture of apparel products, including related supply chains. 6 companies The CHRB methodology does not cover the distribution or retailing of apparel products. d) ICT sector: production and manufacturing of ICT products and the related supply chains. 5 companies The CHRB methodology does not cover the distribution and retailing of ICT equipment and software or other information technology services. e) Other sectors: The 49 largest companies on the TE500 list, excluding the companies included in the sectoral review, financial and insurance companies and the Finnish subsidiaries of foreign groups that focus on the marketing and sales of group products in Finland. 49 companies Assessment with the CHRB Core UNGP Indicators that measure the implementation of the UN Guiding Principles 3.1.3 Material used In accordance with the CHRB methodology, the implementation of corporate human rights responsibility was assessed in the report on the basis of publicly available information. This policy is based on the principle of transparency contained in the UN Guiding Principles requiring companies to communicate openly and actively about their commitment to human rights, their human rights risks and impacts, and related actions. Basing the assessment on publicly available information also enables a more comprehensive sample compared to methodologies involving companies more extensively. Key sources of information included the companies’ own websites, financial and non-financial reports, other public documents and statements, such as policy commitment documents (e.g. Codes of Conduct, Supplier Codes of Conduct), values, guidelines and other relevant documents. In line with the CHRB methodology, the data contained reports relevant to indicators, such as annual reports, sustainability reports and human rights related reports for the last three years. 26 Publications of the Ministry of Economic Affairs and Employment 2021:17 In the sectoral assessment, the companies were able to publish documents related to their human rights performance at the beginning of the assessment process and at the data completion stage, either on their own website or on the SIHTI project website. This additional published information was also taken into account in the assessment. The analysis of the report also utilised the information on revenue, ownership base and industry classification provided by the TE500 list (data concerning 2019). In addition to these, information was collected on company memberships in various global and national corporate responsibility networks. With respect to global business networks, a list of memberships compiled by the CHRB was used, totalling 19 memberships, such as UN Global Compact, ICMM (International Council on Mining and Metals), WBCSD (World Business Council for Sustainable Development) and RSPO (Roundtable on Sustainable Palm Oil) (see appendix 1 to the report). The list of global memberships was also supplemented by checking whether the companies are members of the Better Cotton Initiative, Amfori BSCI or Fair Wear. In relation to national responsibility networks, it was verified whether the company was a member of FIBS or the Finnish Network for Sustainable Mining. 3.1.4 Interaction with the companies The sector-specific methodology of the CHRB also includes an engagement process with the assessed companies. Information about the SIHTI project was sent to the 29 companies that participated in the sector-specific assessments. In addition, the companies received an invitation to webinars in Finnish and English, held in June, where the objectives, methodology and schedule of the SIHTI project were presented. The webinars, followed by a message sent to companies, indicated that the company had the opportunity to supplement information related to its human rights performance on its own website or on the project’s disclosure platform within a period of one month. Company-specific tentative assessment results were sent to each company at the end of August. The companies had the opportunity to discuss the results with a member of the project’s research team, and at this stage they also had the opportunity to publish additional information for approximately one month. The additional information was used to finalise the assessment results. The narrower assessment that used the Core UNGP Indicators did not include an engagement phase with companies. These core indicators measure the fundamentals of the implementation of UN Guiding Principles in business processes and transactions. Therefore, the methodology assumes that the information is available in public materials and no additional information is requested separately from the companies. 27 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 3.1.5 Assessment process Both in the CHRB’s sectoral and the narrower methodologies the assessments were conducted with a number of indicators, grouped under different measurement themes against which the publicly available information on the company’s human rights performance was analysed (see section 3.1.6 on the content of the indicators). Each indicator consisted of levels 1 and 2, for which specific criteria had been defined. The maximum score for one indicator was 2 points. Based on the assessment, indicator-specific weighted and thematic total scores were calculated for the companies, which were converted to percentage points. A more detailed description of the scoring principles and their calculation models can be found in the CHRB Methodology documents. The final company-specific assessment results were sent to the companies before this report was published. In order to ensure coherence in the interpretation of the CHRB indicators and the related criteria, and in scoring, the researcher team held numerous internal quality assurance meetings during the assessment process. The project team experts also played an important role in quality assurance and in ensuring coherent interpretation of indicators. In some questions, the researcher team also consulted with the CHRB to ensure that the results of the assessment would be as consistent as possible with the assessments carried out by the CHRB. In order to ensure the consistency of the interpretations and the quality of the results, the researcher team paid particular attention to the systematic documentation of the interpretation of indicators and criteria and the justifications for the scores given. This strong emphasis on quality assurance was essential particularly because the terminology used by companies in their communications does not always correspond to the language of human rights documents and the UN Guiding Principles. 28 Publications of the Ministry of Economic Affairs and Employment 2021:17 3.1.6 On the content of the CHRB methodology’s indicators A) Indicators used in the sectoral assessment The indicators of the sectoral assessment of the CHRB are grouped under six different measurement themes. Table 2:  Structure of the CHRB’s sectoral assessment Theme Focus Number of indicators Maximum proportion of total score (%) A Governance and policy commitments 9–10 10 B Embedding respect and human rights due diligence 14 25 C Remedies and grievance mechanisms 7 15 D Company human rights practices 8–21 20 E Response to serious allegations 3 20 F Transparency 3 10 Theme A. Governance and policy commitments The theme was divided into two sub-themes, of which A.1 focused on the company’s operative policy commitments and A.2 on how the implementation of the commitments is managed. With regard to the commitments, it was assessed, for example, whether the company is committed to respecting human rights including human rights of workers, to engaging with its stakeholders, including potentially and actually affected stakeholders and/or their legitimate representatives, and to remedying adverse human rights impacts. In addition to indicators common to all sectors, the theme included sector-specific indicators that assessed how the company is committed to: y respecting the rights of children, women and migrant workers (agricultural, apparel and ICT sectors) y respecting land, natural resources and water rights (agricultural products sector) y respecting security and safety related human rights (extractives sector) y respecting the rights of indigenous peoples (extractives sector) y responsible mineral procurement (ICT sector) In managing the implementation of the commitments, the commitment of the top management of the company was assessed: for example, whether the company’s policies 29 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 were approved by the board of directors, how responsibilities related to human rights issues were divided among senior management, how senior management handle human rights issues and whether human rights issues are taken into account in the incentive schemes of senior management. The number of indicators for theme A varied by industry. There were 9 in the extractives and apparel sectors and 10 in the agricultural products and ICT sectors. Theme B. Embedding respect and human rights due diligence Theme B was also divided into two sub-themes: Embedding respect for human rights in company culture and management systems (B.1) and human rights due diligence (B.2). In embedding human rights responsibility, it was assessed how human rights issues have been integrated into the company’s internal systems and processes. The indicators were used to assess, for example, whether the company has described how responsibilities related to human rights issues have been divided at the senior management level, how the day-to-day management of human rights issues has been divided across the company’s various functions, how human rights risks have been integrated into the company’s risk management, how human rights policies are communicated to the company’s employees and other parties, and how the implementation of policies related to human rights is monitored. In the second sub-theme, i.e., human rights due diligence, the focus was on how the company recognises and assesses its human rights risks and impacts, how the results of the human rights impact assessments have been integrated into the company’s operations and processes, how the effectiveness of measures related to human rights risks and impacts is monitored and assessed, and how the company communicates its measures related to human rights risks and impacts to third parties and those affected. The focus of the assessment is on system-level processes with which the company ensures that it is aware of its human rights risks and impacts and takes up-to-date action to minimise them. Theme C. Remedies and grievance mechanisms Theme C assessed the extent to which the company offers remedying measures to address the harm caused by human rights impacts. The purpose of the indicators was to assess the extent to which the company has appropriate processes to address grievances and concerns in a timely manner. The indicators assessed, for example, what types of grievance mechanisms or channels the company has in place for its employees and external stakeholders, how accessible these channels are from the viewpoint of the 30 Publications of the Ministry of Economic Affairs and Employment 2021:17 users, how willing the company is to participate in other grievance mechanisms and what approach it has to taking remedying measures. Theme D. Company human rights practices Theme D focused on certain sector-specific practices involving human rights. The focus was particularly on practices aimed at proactively preventing typical sector-specific human rights risks and their adverse impacts. The indicators were used to assess, for example, whether employees are paid a living wage, how the company’s supply chains have been mapped and disclosed, how the use of child labour is prevented (e.g. age verification), how the company communicates about its occupational health and safety related incidents and targets, and how land ownership issues are assessed and processed. In the extractives sector, the thematic indicators focused on the companies’ own mining activities (including joint venturess). For the agricultural products, apparel, and ICT sectors separate indicators were used to assess the company’s own operations and to assess the practices related to the supply chain. In these sectors the supply chain practices were assessed for all companies20, while the company’s own operations were assessed if the company had production or manufacturing of its own. The number of indicators under theme D in different sectors was as follows: y In the extractives sector, a total of 8 indicators. y In the agricultural products sector, a total of 11 indicators, if the company was assessed only for practices related to supply chains. If the company’s own operations were also assessed, the total number of indicators was 20. y In the apparel sector, a total of 10 indicators, if the company was assessed only for practices related to supply chains. If the company’s own operations were also assessed, the total number of indicators was 18. y In the ICT sector, a total of 13 indicators, if the company was assessed only for practices related to supply chains. If the company’s own operations were also assessed, the total number of indicators was 21. 20 According to the guidelines submitted by the CHRB to the researchers of the SIHTI project on 14 April 2020, the basic assumption for the methodology is that all companies have a supply chain. 31 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Theme E. Response to serious allegations Theme E investigated how the company responded to serious allegations from external sources in which the company was said to have or suspected to have caused serious adverse human rights impacts. In accordance with the CHRB criteria, serious adverse effects may be related to, for example, child labour, forced labour, discrimination, freedom of association, collective bargaining, working hours, indigenous rights, etc. The indicators assessed, for example, whether the company has publicly responded to the allegations and whether it has taken the necessary steps to eliminate the adverse effects. The CHRB methodology uses databases provided by Vigeo Eiris, RepRisk and the Business and Human Rights Resource Center (BHRRC) as the source of information for the allegations. The latter of these is the only publicly accessible database. In the SIHTI project, accusations were sought from the BHRRC database, Finnwatch reports and other public sources. The theme E included three indicators. If the company did not have any allegations for the preceding three years, the indicators were not used in the assessment, and the company was scored for this theme based on the average of the four previous themes (A–D). Theme F. Transparency In theme F, companies were given credit for openly sharing information related to human rights. The indicators took into account the scores received by the company in the preceding themes (A–E) and weighted some previous indicators (for example, an indicator where the company gave examples of human rights issues discussed in the company’s board of directors, or an indicator where the company gave a practical example of its remedying actions). Scores were given also if the company applied an internationally recognised reporting practice (Global Reporting Initiative, Sustainability Accounting Standards Board or UN Guiding Principle Reporting Framework). b) Core UNGP indicators The core UNGP indicators include three measurement themes and a total of 13 indicators (see Table 3). All of the indicators are also included in the sectoral methodology presented above. 32 Publications of the Ministry of Economic Affairs and Employment 2021:17 Table 3:  Structure of the Core UNGP Indicators assessment Theme Focus Number of indicators A Governance and policy commitments 4 B Embedding respect and human rights due diligence 6 C Remedies and grievance mechanisms 3 Theme A assessed the companies’ commitment to respecting human rights and human rights of workers, commitment to stakeholder engagement and commitment to remedy. Theme B focused on how the companies have implemented the different stages of the human rights due diligence process. The indicators assessed the processes companies have in place for identifying human rights risks and impacts, assessing the risks and impacts identified, integrating assessment results and taking action, monitoring and evaluating effectiveness of measures taken related to human rights risks and impacts, and reporting on different stages. One indicator assessed the human rights related share of roles and responsibilities at the level of the company’s senior management as well as between the different functions within the organisation. Theme C focused on the types of grievance channels or mechanisms the companies have in place for employees and external stakeholders and communities. The third indicator focused on remedying the adverse impacts. 3.1.7 Comparison with other studies using the CHRB methodology The results of the sectoral assessment have been compared to some extent with the results of the 2019 CHRB assessment. However, this comparison has been affected by some limitations. In the SIHTI sample the number of companies per sector was quite small, and therefore the comparison is only indicative. At the same time, the sector- specific sample of this study could not have been increased further, as the companies that met the sector-specific criteria of the CHRB on the TE500 list in Finland were all included in the sample. 33 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 To date, assessments using the Core UNGP indicators have been published for Germany (2019), Ireland (2019) and Denmark (2020).21 Other reports completed in 2020 were still to be published when this report was written. Only very limited comparison was made with these assessments. This was because the sample of these assessments was based on different types of criteria. For example, companies have been selected not only on the basis of revenue, but also on the basis of their supply chains (companies with supply chains in low and middle-income countries). There have also been differences in approaches. For example, the Danish assessment also included an engagement phase with companies while, in this assessment, the engagement phase was used in accordance with the CHRB methodology only for the sectoral assessment. 3.2 Interview study on disclosing information on the companies’ human rights responsibility In addition to assessing the implementation of human rights responsibility in Finnish companies, the SIHTI project examined the views of the companies on publishing information related to their human rights performance. This was done through structured telephone interviews, which lasted 15–20 minutes. The interviews focused on the companies’ experiences and challenges in publishing information and on ways to support companies in publishing more information related to their human rights responsibilities. Both companies involved in the sectoral assessment and companies assessed with the Core UNGP Indicators were included in the interview study sample. This was to ensure that the sample would represent different sectors as diversely as possible. In addition, the tentative assessment results of the companies were taken into account when determining the sample. Based on the tentative results, the companies were divided into three categories: an assessment score higher than average, an average assessment score, and lower than the average. Companies from all categories were included in the sample, with a weighting on companies with below-average and average scores. Representatives of a total of 20 companies were interviewed. The aim was to reach the company’s director in charge of responsibility matters for the interview. In two interviews, there was another person present in addition to the main interviewee. The interviews were mainly conducted in Finnish, except one in English. More detailed information on the interview study can be found in Appendix 2. 21 Hogan, F.B, Rhodes, ML., Murphy, S.P. & Lawlor, M.2019: Irish Business & Human Rights: Benchmarking compliance with the UN Guiding Principles. Trinity College Dublin, The University of Dublin. School of Management and Law & Business & Human Rights Resource Centre 2019: Respect for Human Rights. A Snapshot of the Largest German Companies. The Danish Institute for Human Rights 2020: Documenting Business Respect for Human Rights. A Snapshot of Large Danish Companies. 34 Publications of the Ministry of Economic Affairs and Employment 2021:17 4 The level of human rights performance in Finnish companies 4.1 Results of sectoral assessments 4.1.1 Agricultural products sector a) Sample The CHRB’s agricultural products indicators focus on the production and processing of raw materials for agricultural products as well as on the related supply chains22. The indicators do not cover the distribution or sale of agricultural products. The report examined eight companies in the agricultural products sector. Five of these were foodstuff companies and they were assessed both from the perspective of their own operations and supply chains of agricultural products. The remaining three were retail companies which were assessed only for their supply chains of agricultural products. The companies included in the review are quite large in Finland’s context, but their revenue varies significantly, from the smallest company’s 2019 revenue of 921 million euros to the largest one’s 10.7 billion euros23. Although most of the assessed companies have a strong business focus in Finland, all companies except one also have own operations in other countries (see Table 4). The assessed companies participate in various international and/or national responsibility initiatives. Two of the companies are members of the UN Global Compact, two are members of the Consumer Goods Forum, two are committed to the Better Cotton Initiative, while six are involved in the Roundtable for Sustainable Palm Oil. In addition, four companies are members of the amfori BSCI. All companies except for one in the sample are also members of the Finnish corporate responsibility network FIBS. In line with the CHRB methodology, the assessed companies had the opportunity to discuss their tentative results with the researcher and to submit existing public information or to publish additional information to support the assessment. Seven of the companies in the agricultural products sector discussed their tentative results with 22 https://www.corporatebenchmark.org/sites/default/files/CHRB%202020%20Methodology%20AGAPEX%20 28Jan2020.pdf 23 The TE500 list published in June 2020 as the source 35 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 a researcher. Five companies published additional information on the SIHTI project’s disclosure platform, and two companies submitted information already published to support the report. In the SIHTI project, four forest sector companies were also assessed using the agricultural product indicators. However, the results of these companies have been analysed separately, since their business activities differ significantly from those of the other companies assessed with the agricultural products indicators. The decision to analyse the results of the forest sector companies as a separate group was also based on the significance of this sector in the Finnish business environment (see chapter 3.1.2 of the report). Table 4:  Information on the companies included in the sectoral assessment of the agricultural products sector Company Sector Ownership Revenue (EUR million) Location of the company’s operations Object of assessment Alko Oy Trade Government 1144 Finland Supply chain of agricultural products Atria Oyj Food Listed 1451 Finland, Sweden, Denmark, Estonia, Russia Own operations and supply chain Fazer Group Food Family- owned company 1097 Finland, Sweden, Russia, Estonia, Latvia, Lithuania Own operations and supply chain HKScan Oyj Food Listed 1744 Finland, Sweden, Denmark, Estonia Lithuania, Latvia Own operations and supply chain Kesko Oyj Trade Listed 10720 Finland, Sweden, Norway, Estonia, Latvia, Lithuania, Poland, Belarus Supply chain of agricultural products Paulig Group Food Family- owned company 921 Belgium, Sweden, Finland Own operations and supply chain SOK-yhtymä Trade Cooperative 7496 Finland, Estonia, Russia Supply chain of agricultural products Valio Oy Food Cooperative 1787 Finland, Russia, Baltic countries, Sweden, USA, China Own operations and supply chain 36 Publications of the Ministry of Economic Affairs and Employment 2021:17 b) Results The average of the total score of the agricultural products sector is 26.7%. However, the overall score per company varies significantly, with the highest result being 40.8% and the lowest 12.3% (see Table 5). Looking at the average scores, the highest thematic results were in theme A, which assesses human rights policy commitments and Board level accountability, and in theme B, which assesses embedding respect in the operations of the company and human rights due diligence . The weakest overall results were related to grievance mechanisms and remedy (theme C). Table 5:  Measurement theme performance of the agricultural products sector Measurement themes and thematic maximum percentage scores % scores Alko Atria Fazer HK Scan Kesko Paulig SOK Valio Average Theme A as a whole (max. 10%) 3.1 1.8 3.1 2.9 2.7 2.0 4.4 3.7 3.0 A.1. Policy commitments (max. 5%) 1.4 1.4 2.7 2.5 2.3 1.6 3.1 3.3 2.3 A.2. Board level accountability (max. 5%) 1.7 0.4 0.4 0.4 0.4 0.4 1.3 0.4 0.7 Theme B as a whole (max. 25%) 8.6 2.7 4.5 3.6 11.8 7.6 13.6 7.6 7.5 B.1. Embedding respect for human rights in company culture and management systems (max. 10%) 3.6 2.7 3.9 3.6 6.8 4.5 5.5 3.2 4.2 B.2. Human rights due diligence (max. 15%) 5.0 0.0 0.6 0.0 5.0 3.1 8.1 4.4 3.3 C. Remedies and grievance mechanisms (max. 15%) 0.8 0.8 4.2 4.2 2.5 1.7 3.3 2.1 2.4 D. Company human rights practices (max. 20%) 5.3 1.5 3.0 4.3 5.5 5.0 6.5 6.5 4.7 E. Response to serious allegations (max. 20%) 4.9 2.5 4.7 5.1 6.8 5.2 8.1 5.0 5.3 F. Transparency (max. 10%) 4.0 3.0 1.8 4.0 4.5 4.1 4.9 4.5 3.9 Total score (max. 100%) 26.7 12.3 21.2 24.1 33.9 25.6 40.8 29.3 26.7 37 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Commitment to human rights and board level accountability The average score of the agricultural products companies on Theme A (Policy commitment and Board level accountability) is 3.0%, the maximum score being 10%. The companies’ overall level of commitment to respecting human rights is quite good, but the commitment to respecting workers’ rights varies from one company to another, the most common shortcoming being explicit commitment to respecting the workers’ right to collective bargaining. However, the assessed companies are relatively large in terms of number of employees and their personnel is divided across several countries. This makes the commitment to respecting workers’ rights an important indicator in addition to the general respect for human rights. Respect for the rights of vulnerable groups specific to the sector, including children, women and migrant workers, and respect for the human rights related to land ownership, natural resources and water, was fairly weak throughout the sample. The commitments and/or actions related to stakeholder engagement have, on the other hand, been fairly well or well taken into account the assessed companies. On the other hand, it is also worth noting that none of the companies in the sample expresses its commitment to remedying the adverse effects according to the CHRB criteria, and only one company is committed to respecting the rights of human rights defenders. When assessing the Board level commitment to the realisation of human rights policy commitments, the average of the results was 0.7% (max. 5%). In all of the companies, human rights policy commitments have been approved by the Board or the CEO, but only in one company a board level public statement regarding respect for human rights in their business had been made. Furthermore, only in one company the board of directors discusses human rights responsibility related issues on a regular basis. None of the companies, on the other hand, clearly link the remuneration system of the members of the board of directors to the performance indicators related to the implementation of human rights responsibility. Embedding respect and human rights due diligence Theme B assesses the company’s way of embedding human rights responsibility in internal systems and processes (sub-theme B.1) and the realisation of the company’s human rights due diligence. The average of the overall score of the theme is 7.5% (max. 25%). The results were relatively better in indicators related to embedding human rights responsibility compared to indicators related to the implementation of human rights due diligence. The average of the scores in subtheme B.1 is 4.2% (max. 10%). Company-specific results show that the two largest companies in the sample meet the subtheme’s indicator criteria 38 Publications of the Ministry of Economic Affairs and Employment 2021:17 best. The large volume and extent of the business requires robust internal processes, strong risk management and supply chain management, which is also reflected in the results of the theme. Looking at individual indicators reveals that the companies in the sample score better across the board for communicating human rights commitments to suppliers and business partners and for taking these commitments into account in business relationships compared to internal stakeholders. This raises the question of the extent to which human rights responsibility issues are considered to be mainly related to supply chains in companies rather than to their own operations. It is also noteworthy that none of the assessed companies met the indicator criteria concerning management’s remuneration system. Theme B.2 assesses the implementation of human rights due diligence. The average score in the sub-theme is 3.3% (max. 15%), but there are significant differences between company-specific results. Three of the companies are still in a very early stage or have not yet begun to implement human rights due diligence systematically. However, there are also companies that already have a systematic process for identifying and assessing human rights risks, but the integration of the results of the assessments into the company’s operations or the monitoring of these activities has not yet begun. Remedies and grievance mechanisms In the theme assessing the companies’ approach to remedy and grievance mechanisms, the average score was 2.4%, the maximum score being 15%. Based on the results, all of the assessed companies have grievance channels for internal stakeholders, but there are significant differences between the companies in whether a grievance channel is available to external stakeholders or whether it is accesible, especially from the perspective of vulnerable stakeholders. For example, none of the companies in the sample has involved vulnerable stakeholders in the design or monitoring of grievance channels. In addition, none of the companies shared information about their cooperation with state-based grievance mechanisms or explained their approach to remedy. Human rights practices Theme D assesses human rights risks critical to the sector and what steps the company has taken to minimise the actualisation of these risks in its own practices. The average score of the assessed companies was 4.7%. However, there is again dispersion in the company-specific scores in the theme. When looking at the results, it should also be noted that in this theme, five food stuff companies have been assessed from the perspective of both their own operations and the supply chain, while three retail companies have been assessed only from the perspective of the supply chain only. 39 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Six out of eight companies provide some information on the supply chain of agricultural products (e.g. origin of the raw material). On the other hand, all the assessed companies have committed themselves to prohibit child labour, but only one company is committed to verify the age of job applicants in its own operations. Only four companies have some practices in place to prevent forced labour in line with the CHRB criteria. On the other hand, all the assessed companies have fairly well taken into account aspects related to occupational health and safety in the supplier requirements. However, the transparency of reporting on cases of supplier injury or death is still weak. None of the assessed companies met the indicator criteria for the implementation of land rights, but the companies are considerably further along in identifying and taking into account the risks associated with water use. Food stuff companies (5) were assessed from the perspective of both their own operations and supply chains. The criteria for indicators related to the companies’ own operations raised questions and comments during the assessment process. Some companies’ felt that the indicators assess statutory self-evident issues, which is why matters related to the provision of payslips or freedom of association, for example, have not been considered in the ethical principles of companies or other policies or guidelines. These country-context- related perspectives are discussed in more detail in chapter 4.3 of the report. Response to serious allegations In accordance with the CHRB criteria, serious adverse impacts may be related to, for example, child labour, forced labour, discrimination, freedom of association, collective bargaining, working hours, or the rights of indigenous peoples. In the last three years, a serious allegation, as per the CHRB criteria, has been made against only one of the assessed agricultural products companies. This allegation was related to the realisation of workers’ rights. The indicators in the theme assess, for example, whether the company has publicly responded to the allegations and whether the company has taken the necessary steps to eliminate the adverse impacts. For the other seven companies, the score for this measurement theme has been calculated on the basis of the results of the previous themes. The average of the scores is 5.3%, with a maximum of 20%. Transparency In this theme, companies are given credit based on the transparency shown in previous themes and for using internationally recognised reporting frameworks. The average of the scores of the agricultural products sector actors is 3.9%, with a maximum of 10%. c) Comparison with the results of the global CHRB assessment In its global assessments, the CHRB has assessed companies from the agricultural products sector three times since 2017. In 2019, the CHRB assessment included 57 companies in the agricultural products sector, with an overall average score of 24.2%. Although the 40 Publications of the Ministry of Economic Affairs and Employment 2021:17 companies included in the SIHTI project sample were assessed for the first time using the CHRB methodology, the average of the total scores (26.7%) is slightly higher than for the companies involved in the international comparison24. Companies being assessed by CHRB for the first time have generally achieved significantly lower scores than those who have been assessed previously. In 2019, the average of the scores of the agricultural products companies included in CHRB’s assessment for the first time was 13%. When comparing the theme level results with the results of the 2019 CHRB global assessment, the average of the scores related to the human rights commitments of Finnish agricultural products companies and the board level accountability (theme A) is fully in line with the global average. In the embedding of human rights responsibility and human rights due diligence (theme B), Finnish companies are slightly ahead of the global level, while when assessing grievance mechanisms and remedy (theme C), they are slightly behind the global average. Human rights practices (theme D) are fairly close to the results of global assessment. The results related to the transparency of reporting (theme F) are also very similar to the results of the global assessment. It is not feasible to compare the results of the global assessment with the results of theme E on responding to serious allegations, as only some companies have a serious allegation that meets the criteria over the last three years, and the scores of the other companies have been calculated on the basis of the CHRB calculation formula. 4.1.2 Forest sector a) Sample The project assessed the human rights performance of four forest sector companies with the CHRB agricultural products indicators25. As explained in the previous chapter, the indicators focus on raw material production and processing of agricultural products as well as related supply chains. The indicators do not cover the distribution or sale of agricultural products. Although forest sector actors have not previously been included in CHRB’s global assessments, it was decided in the SIHTI project to include forest sector actors in the sample, as they represent a significant group of companies in the Finnish corporate context with respect to both revenue and direct human rights impacts (in Finland and globally). Consequently, taking them into account was considered important in order to realise the project’s objective of obtaining an overall picture of the level of implementation of human rights responsibility of Finnish companies. 24 https://www.corporatebenchmark.org/sites/default/files/2019-11/CHRB2019KeyFindingsReport.pdf 25 https://www.corporatebenchmark.org/sites/default/files/CHRB%202020%20Methodology%20AGAPEX%20 28Jan2020.pdf 41 Publications of the Ministry of Economic Affairs and Employment 2021:17 Publications of the Ministry of Economic Affairs and Employment 2021:17 Although the same methodology was used for the agricultural products sector and the forest sector, the results of the latter have been analysed separately in order to enable meaningful comparaison within the sector, as there are significant differences between the forest sector and the other companies assessed with the agricultural products indicators, especially from a business perspective. The assessed forest sector companies are among Finland’s largest companies, with annual revenue ranging from EUR 2.9 billion to EUR 10.2 billion26. As shown in the table below (Table 6), all the companies have a strong global presence. All of the forest sector companies were assessed from the perspective of both their own operations and the supply chains of agricultural products. The assessed forest sector companies participate in various international and/or national responsibility initiatives. They are all members of the UN Global Compact, and three of them have signed the CEO Water Mandate. In addition, one of the companies is also a member of the World Business Council for Sustainable Development and the Global Business Initiative. All companies are also members of the Finnish corporate responsibility network FIBS. In line with the CHRB methodology, the assessed companies have the opportunity to discuss their tentative results with the researcher and to submit existing public information or to publish additional information to support the assessment. Three of the forest sector companies discussed preliminary results with a researcher. In addition, two companies published additional information on the SIHTI project’s disclosure platform, and one company shared already published information to support the assessment. 26 The TE500 list published in June 2020 as the source 42 Publications of the Ministry of Economic Affairs and Employment 2021:17 Table 6:  Information on the companies included in the sectoral assessment of the forest sector Company name Ownership Revenue in Finland (EUR million) Location of the company’s operations Ahlstrom-Munksjö Oyj Listed, family enterprise 2916 14 countries, including USA, France, Sweden, Brazil, Germany Metsä Group Cooperative 5473 Finland, Sweden, Poland, Germany, Slovakia, Russia, Estonia, UK Stora Enso Oyj Listed, state 10055 17 countries, including Finland, Sweden, China, Poland, Germany, Russia, Brazil, Uruguay, USA UPM-Kymmene Oyj Listed 10238 12 countries, including Finland, Germany, China, USA, Uruguay b) Results The average total score in the forest sector is 41.9%. However, there is a significant dispersion in the overall score per company (see Table 7), with the best overall result at 63.0% and the weakest at 20.1%. The highest scores are awarded to large companies with many global functions of their own as well as global supply chains. In relative terms, the highest thematic results were obtained in the theme on embedding human rights responsibility in the company’s operations and the implementation of huma