How human rights shape our investment decisions

For over 40 years, our Ethical Charter has guided us to restrict⁺ investments that contribute to human rights harm. We back this up with a clear, consistent way of assessing companies - looking at where they may be exposed to human rights risks, and whether there have been human rights concerns or controversies in the past. Where risks or issues are identified, we take a closer look to decide whether a company meets our standards for inclusion, or whether it should be excluded.

Ethical investing today for human rights means looking beyond what a company does directly. It's not just products that can be used in harmful ways. Business relationships can expose people and communities to risk. Global operations and supply chains span legal systems with very different protections. All of this makes human rights impacts harder to see, and potentially easier to ignore. 

That’s why we look at both the good a company delivers and the most serious human rights risks it’s linked to. Where we identify risk, we only invest where we assess companies are taking responsibility for those risks. If they’re not, we don't invest in them, no matter what else the company does well. 

Human rights are the basic protections everyone deserves. They apply to all people and are there to uphold dignity, fairness and respect. 

Some human rights risks aren't easy to see. Modern slavery is one of them.  

Modern slavery includes forced labour, debt bondage and situations where people can’t leave or refuse work without penalty. It can be hidden behind subcontracting, labour hire arrangements, recruitment fees, passport confiscation, unsafe accommodation or wages being withheld. These risks tend to show up where people have the least power, which can be deep within supply chains, in insecure work, or where protections and oversight are weak. 

When we assess human rights, we’re talking about issues like: 

Safe and fair work

• Fair pay, safe conditions and freedom of association 
• No forced labour, child labour or coercive recruitment 

Freedom and dignity

• Protection from intimidation, abuse or arbitrary detention 
• Respect for privacy, expression and personal security 

Community and land rights

• Respect for Indigenous peoples, consent over land and resources 
• No extraction or development that relies on rights being ignored 

When companies fall short, they fall outside of our investable universe

The below examples show what active assessment and exclusion look like in practice: 

Siemens Gamesa Renewable Energy	Community and land rights
Wind turbine manufacturer In 2021, following direct engagement, we divested from Siemens Gamesa over concerns about use of the company’s wind turbines to supply energy for the extraction of natural resources by Morocco in the occupied territory of Western Sahara without the consent of the Saharawi people, contrary to international law.
BYD	Safe and fair work
Electric vehicle & battery manufacturer We excluded BYD in 2025 following severe allegations related to forced labour conditions at a factory construction site in Brazil, and very weak human rights governance and supply chain transparency based on independent assessments and available reporting.
Halozyme Therapeutics	Safe and fair work
Biotechnology company While not operating in a traditionally high-risk sector, Halozyme has supply chain exposure that warrants a clear human rights approach. We excluded the company in 2025 after direct engagement confirmed no human rights policies or practices, including no supplier due diligence.
Hutchison Port Holdings	Safe and fair work
Port operator and infrastructure owner Ports and maritime infrastructure operate in high-risk environments, with vulnerable workforces and complex supply chains. In 2025, we excluded Hutchison Port Holdings because we found no credible evidence of effective human rights due diligence, collaboration, or grievance and remediation mechanisms.
Harvey Norman	Safe and fair work
Australian electronics and furniture retailer In 2022 we assessed that Harvey Norman did not meet our human rights expectations. In a sector with known modern slavery risks, sourcing from high-risk jurisdictions, we found the company fell short of what we expect from a business of its scale – including no publicly available modern slavery policy, limited supplier due diligence, limited evidence of preparedness to respond to any issues identified in the due diligence process and no evidence of collaboration with NGOs or industry to help address risks. We have not since reassessed Harvey Norman to see if it has improved its policies and practices but note that in its latest research, the Monash Business School gave the company the lowest rating for its modern slavery reporting, putting the company at the bottom of the ASX100.1

These decisions aren’t about headlines. They’re about whether a company meets our standards as guided by our Ethical Charter to manage serious human rights risk. 
 

When companies meet the bar, they can be investable

High risk doesn’t automatically mean exclusion. How a company responds to address these risks matters, as the following inclusion examples show:

The Berkeley Group	Safe and fair work
UK property developer Construction is a high-risk industry, particularly where contractors and temporary labour are involved. Berkeley identifies those risks and backs that awareness with practical controls — including site level responsibility, modern slavery training, tender and factory checks, and collaboration through industry anti-slavery initiatives.
CATL	Safe and fair work
Chinese battery manufacturer Battery and critical mineral supply chains carry heightened human rights risk. CATL shows evidence of supplier standards, due diligence programs, audit activity and corrective action processes, alongside participation in industry initiatives focused on responsible minerals. We also recognise the limits of assurance in some jurisdictions, which is why this remains an area we monitor as new information emerges.

 
These inclusions reflect the same discipline as our exclusions: the risks are assessed, and companies are included where their responses and plans for action meet our standards. 

Responsibility is the test

Human rights issues don’t always mean a company will not form a part of our investable universe. In complex businesses, problems can surface despite genuine efforts to prevent them. And the absence of reported issues doesn’t automatically mean everything is fine. 

When we assess responsibility, we look for clear signals, including whether: 

• leaders are aware of the risks and acting on them 
• the company is transparent, rather than making harm harder to see 
• there is real effort to fix what’s broken and stop it happening again 

In parts of the economy where human rights risks are well known, the bar is higher to be a part of our investable universe. These are areas where poor practices can cause serious harm, so we expect: 

• stronger oversight and accountability 
• evidence that commitments are being put into practice, not just written down 

We’re not looking for perfection. We’re looking for responsibility - and proof that a company’s actions match what it claims to stand for. Where that responsibility and action is missing, it’s a red flag. 
 

Review, divestment and accountability

Company behaviour changes. Our assessments of companies within our investable universe are revisited periodically or as material new information emerges. 

Where issues are identified, we often engage the company being clear about our expectations. If the company no longer meets our standards, we divest. 

Learn more about our Ethical Charter and Modern Slavery Statement and share what you’ve learned with someone who cares where their money is invested.