In July 2025, the International Sustainability Standards Board (ISSB) opened a public consultation seeking feedback on its Proposed Amendments to the SASB Standards. Rights CoLab submitted a comment letter highlighting ways the ISSB can better integrate human rights due diligence across prioritized industry standards. The letter appears below and is also available on the ISSB website here. 

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Thank you for this opportunity to submit these comments on the proposed amendments to the SASB Standards.

Founded in 2018, Rights CoLab incubates outside-of-the-box solutions to systemic problems that strengthen civil society and leverage markets to fortify human rights. Rights CoLab has been engaged with the SASB Standards since 2020 when it became a knowledge partner to SASB Standards/Value Reporting Foundation (VRF) to support the research team in its work on a  human capital management framework and, subsequently, updating the SASB human capital standards.¹ Following the convergence of VRF into the ISSB in 2022, we have responded to the ISSB public consultations in 2022 and 2023, and this year provided input into the Processed Foods Standard revision and the draft analytical approach to the human capital project. Cofounder Paul Rissman is a member of the ISSB Sustainability Reference Group and Rights CoLab is also a co-founder of the Taskforce on Inequality- and Social-related Financial Disclosures (TISFD).

Over the past 18 months, Rights CoLab has been working on two research projects designed to support the technical team in the development of the ISSB standards.² The first is an examination of how to integrate human rights due diligence (HRDD) – a financially material topic – into the ISSB Standards. This research resulted in the report, A Roadmap for Integrating Human Rights into ISSB Standards, published in September. The second report, “What’s the Matter with DEI? A Reset” provides a roadmap for navigating the politically fraught environment around diversity, equity, and inclusion (DEI), and will be released in early 2026.³

Our comments draw from the recommendations of the September report. Specifically, we focus on the amendments that can enhance integration of human rights due diligence into the nine industry standards that the ISSB prioritized (all eight industries in the Extractives & Minerals Processing sector and the Processed Foods industry) and opportunities for further improvements. Although IFRS S1 is not the focus of this consultation, it is important to address areas for IFRS S1 improvements since they form the foundation for the use of the SASB Standards in the entities’ materiality assessments.

Why should the ISSB place a priority on integrating HRDD into the Standards?

There is abundant evidence that HRDD is financially material. Without comprehensive duediligence, corporate management cannot reliably identify which impacts may evolve into material entity-level risks, making effective reporting on material risks and opportunities challenging. States have recognized this imperative, resulting in mandatory due diligence legislation developments in the EU, as well as Asia and Latin America.

Investors also demonstrate strong interest in HRDD: two-thirds of the members of the ISSB Investor Advisory Group (IAG) – 66 investors representing $74 trillion in assets under management – have a human rights policy statement, most of which refer to the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Responsible Business Conduct, the authoritative standards on business and human rights. In its most recent responsible investment report, IAG member Norges Bank Investment Management (NBIM) reported that since 2012, risk-based divestments from portfolio companies deemed to have insufficient risk management of human rights have increased the cumulative return on equity by 0.16 percentage points.⁴ Another IAG member, State Street Global Advisors (SSGA), published its expectation for companies to carry out human rights due diligence as part of its 2025 Sustainability Stewardship Service Proxy Voting and Engagement Policy.⁵ The ISSB’s own research reinforces this finding. A February 2025 ISSB staff report outlines human capital-related investor information needs based on interviews with investors globally states:

Furthermore, recent financial media reporting suggests that large pension funds and other asset owners are showing increasing interest in HRDD.⁷

Recommended Amendments to IFRS S1

The present ISSB consultation is not soliciting comments on IFRS S1. However, because the SASB Standards offer industry-level guidance for entities on how to align with IFRS S1 sustainability disclosure requirements and specific metrics for addressing social topics, the changes we recommend in relation to the human rights elements of the proposed SASB Standards revisions will be incomplete without amendments to IFRS S1 itself. 

In our report, we examined IFRS S1 against the six HRDD steps outlined in the OECD Due Diligence Guidance for Responsible Business Conduct (OECD Guidance) and found that while capturing double materiality is not the objective of the ISSB, both IFRS S1 and the SASB Standards significantly overlap with impact materiality. As HRDD is an impact management process, this overlap offers a foundation for advancing more explicit HRDD disclosure requirements in ISSB Standards.  

While the groundwork is laid in the Objective Statement and Conceptual Foundations of IFRS S1, there is considerable room for improvement in how the Core Content areas of IFRS S1 capture HRDD. This is documented in Table 4 of the report. For example, in the Risk Management section, three OECD due diligence steps – Step 1: Integrate RBC in Policies, Step 2: Identify and Assess Adverse Impacts, and Step 4: Track Efforts to Address Adverse Impacts – are reflected but not Step 3 of the OECD Guidance: Cease, Prevent, or Mitigate Adverse Impact. As a result, Risk Management concerns how companies monitor risks, but not how they actually respond to or mitigate them. This gap can be easily addressed by requiring explicit disclosure of actions taken under Risk Management.

Future amendments to the Standards should emphasize disclosing information on all six steps of HRDD as outlined in the OECD Guidance, including remedy which is currently not reflected at all in IFRS S1. Doing so will help reconcile the tension between HRDD frameworks that emphasize impact materiality and IFRS S1’s focus on financial materiality, while also aligning with the expectations of major asset managers.

Of particular relevance to the SASB Standards is the need to improve the focus on HRDD policies in IFRS S1. Currently, among the Core Content areas, Governance contains a consideration of policies, which not only calls for developing a policy commitment to addressing sustainability issues, but also embedding these policies into management and operations systems. However, both references to policies focus primarily on risks and opportunities rather than impacts, making them a limited reflection of Step 1. As set forth in the OECD Guidance, Step 1: Integrate Responsible Business Conduct in Policies calls for a specific, company-wide commitment to assessing human rights risks in company operations and throughout the value chain, including a broad scope impact and saliency assessment to identify and prioritize the most significant risks, based on meaningful stakeholder engagement. Lacking a commitment to a broad-scoped risk assessment may produce blind spots, rendering the materiality assessment using the SASB Standards incomplete. Moreover, an update to IFRS S1 should consciously incorporate the 11 due diligence characteristics of the OECD Guidance  to ensure that reported information enables investors to accurately evaluate the quality of HRDD efforts.

Comments on the Proposed SASB Standards Amendments

We begin our comments with our assessment of the only HRDD metrics, and the technical protocol that explains them, that currently (pre-revision) sit within 4 of the 77 SASB industry standards. Three of these four industry standards are the subject of this consultation: Oil & Gas–Exploration & Production (metric EM-EP-210a.3); Metals & Mining (metric EM-MM-210a.3); and Coal Operations (metric EM-CO-210a.2).⁸ After summarizing our findings from our report, we examine the proposed changes to the due diligence metrics with a focus on Coal Operations, and point to areas in need of further improvement.  In addition to the changes in the explicit due diligence metrics, we discuss the proposed amendments in two important areas for HRDD: 1) the requirements for meaningful stakeholder engagement, which sit at the heart of robust HRDD; and 2) Conflict and high risk areas (CAHRAs), where heightened due diligence is essential.

In the Roadmap report, we take note of the fact of the presence of an HRDD metric in each of four industry standards.  While these metrics each refer to international standards, they do so unevenly. For example, the Coal Operations standard only refers to ILO 169, the Indigenous and Tribal Peoples Convention of 1989, and not the UNGPs. The Metals and Mining and Oil & Gas E&P Standard refers additionally to other ILO conventions, including freedom of association (No. 87), collective bargaining (No. 98), forced labour (No. 29 and No. 105), child labour (No. 138 and No. 182), fair wages (No. 100), and discrimination (No. 111). These two standards also refer to the UNGPs, but with one shortcoming: they only reference UNGP 17 on human rights due diligence. By specifying this single guiding principle, it leaves out UNGP 16, the requirement for a human rights policy.  As noted above, a human rights policy (which is part of the OECD Guidance due diligence steps but not a part of UNGP 17 is key to ensuring human rights risks and opportunities are not overlooked in materiality assessments. As the Metals and Mining Standard refers also to the Five Step Framework outlined in the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas, we can say that a human rights policy commitment is covered in this standard. For this reason, in our report we recommend that the ISSB use the Metals and Mining standard as the basis for the development of due diligence disclosure metrics across all standards.

Turning to the Exposure Draft we examine  the Coal Operations standard to demonstrate where the Exposure Draft is lacking and would benefit from improvements., The topic that the due diligence metric currently appears in, “Rights of Indigenous Peoples,” is no longer a standalone topic and instead is merged with the Community Relations topic. This change introduces the opportunity to extend due diligence processes to all rights holders, including those that are not indigenous.

In terms of Community relations, the technical protocol of the metric on “the processes used to manage risks and opportunities associated with community rights and interests” (EM-CO-210b.1) adds language for a new provision that covers due diligence to an extent:

2.The entity shall disclose information about… 2.3 how the entity identifies, assesses, prioritises and monitors the risks and opportunities associated with community rights and interests, including whether and how those processes are integrated into and inform the entity’s overall risk management process;

Yet, as with IFRS S1 as discussed above, OECD Due Diligence Step 3 Cease, Prevent, or Mitigate Adverse Impact, is missing from the technical protocol for this metric, and needs to be added. (Note that it is addressed in paragraph 6 of the technical protocol, but insufficiently, as we discuss below.)  Moreover, in paragraph 3, the description of what constitutes community-related risks is incomplete:

Community-related risks and opportunities include: corruption, non-technical delays, legal and regulatory complexities, local community employment, availability of skilled labour, purchases of local goods and services, availability of local goods and services, quality of and access to adequate infrastructure (for example, ports, roads, bridges, or shipping channels), resettlement and access to land and social licence to operate (p. 66).

Missing are community health harms. Communities near mines and coal plants show higher rates of respiratory and cardiovascular diseases, cancers, kidney problems, and adverse birth outcomes and premature mortality linked to air pollution and contaminated water and soil.​ Furthermore, private security contracted to protect the mine are known to be linked to human rights abuses, including gender based violence and harassment.⁹ Moreover, land acquisition and resulting environmental degradation often undermine agriculture, fisheries, and other local livelihoods, and in some cases involve displacement or loss of access to customary lands and resources. There is also a history of project activities destroying cultural heritage, particularly on Indigenous lands.¹⁰ Finally, there are numerous civil society and media reports showing that the mining sector (including coal) is consistently among the industries most frequently associated with attacks on land and environmental defenders, including killings, disappearances, threats, and strategic lawsuits.¹¹ An example of a coal-linked incident is In South Africa, where members of the Mfolozi Community Environmental Justice Organisation opposing the expansion of the Tendele coal mine at Somkhele faced threats, harassment, and violence; one prominent activist, Fikile Ntshangase, was shot dead in her home in 2022, and other community members have reported shootings and intimidation linked to their stance on the mine.¹²

These gaps are addressed to an extent in paragraph 4 of the Exposure Draft, which asks entities to disclose whether the processes are aligned with IFC Performance Standards (PF) of 2012, including IFC PF 4 on Community Health, Safety, and Security; IFC PF 5, Land Acquisition and Involuntary Resettlement; and IFC PS 8, Cultural Heritage. Yet, these standards are also incomplete – for example, they fail to address the attacks on human rights defenders. They are also outdated, and the IFC is currently undergoing a process of revision and review that is slated to continue over the next two years.¹³ Therefore, there is still room for improvement in terms of their ability to capture risks and opportunities in the industry. Just as stakeholders are calling on the IFC to more fully integrate HRDD into the forthcoming revised IFC Sustainability Framework, the ISSB should likewise reintroduce the requirement that entities disclose whether they are undertaking comprehensive due diligence.

Paragraph 6 of the technical protocol for this metric  has the potential to address HRDD Step 3 Cease, Prevent, or Mitigate, which as noted above is missing from paragraph 2.  However, it is also lacking. It reads:

Besides the fact that a human rights impact assessment (HRIA) is more thorough and a social impact assessment,¹⁴ paragraph 6 is positive from the perspective of its focus on engagement with affected rights holders, which is essential to robust human rights due diligence. However, several of the elements of meaningful stakeholder engagement, as defined by the OECD Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, are missing.

Turning to Indigenous Peoples, the Exposure Draft includes a redrafted due diligence metric:  Description of engagement processes and due diligence practices related to upholding Indigenous Peoples’ rights (EM-CO-210b.4). A positive aspect of the metric, as elaborated in the technical protocol, is its implied intention to engage with stakeholders at the project inception stage of a project (paragraph1) as well as  project development (paragraph 2). While the references to ILO Convention 169 (1989) and the United Nations Declaration on the Rights of Indigenous Peoples (2007), to make explicit that stakeholder engagement should occur throughout the project lifecycle and to signal that all HRDD steps should be undertaken as part of an entity’s risk management processes, we recommend that the ISSB also reference the OECD Guidance for Meaningful Stakeholder Engagement in the Extractive Sector here. 

Furthermore, for filling the gaps in both EM-CO-210b.1 and EM-CO-210b.4 so that the Standard can better capture risks and opportunities in the industry, we recommend that the ISSB refer to our Stakeholder Engagement Guide, launched in June of this year as part of the Investor HREDD Precision Tools. Designed for investors to help them discern the quality of HRDD of their portfolio companies, the tool lays out seven effectiveness criteria across four stages of engagement with affected stakeholders.¹⁵

A significant improvement to the Coal Industry Standard in relation to HRDD is the introduction of the topic on “Operations in Conflict Areas” (pp 70-71) and in particular the new metric, “Description of engagement processes and due diligence practices related to operating in conflict-affected and high-risk areas” (EM-CO-210c.2). Importantly, this metric refers to the Five-Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain outlined in Annex I of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (2016), which defines the concept of Conflict-affected and High Risk Areas, or CAHRAs, according to the Guidance and indicates that entities should disclose whether they uphold the principles of the Guidance. We recommend that the metric be revised to include Step 6, Provide for or Cooperate in Remediation Where Appropriate.¹⁶

In Conclusion

In this comment, we have summarized the case we presented in the Rights CoLab report, “A Roadmap for Integrating Human Rights into ISSB Standards,” on the importance of ensuring that HRDD is explicitly and fully present in the standards. Doing so is a means of ensuring that entities undertake their materiality assessments in a fulsome manner and accurately disclose their risks and opportunities. We also highlighted the need for amendments to IFRS S1 to make HRDD requirements explicit. Focusing on the proposed revisions to the Coal Standard, we highlighted the strengths as well as remaining weaknesses of the standard in relation to HRDD. We hope that this discussion will help the ISSB to apply the lessons to the other eight industry standards in the Exposure Draft.

As noted in our introduction at the start of this letter, we provided early feedback on the  Processed Foods Industry Standard and in the Exposure Draft see scope for improvement. Moreover, in focusing on specific elements of HRDD in the Coal Standard, we did not provide in this letter our comments on the human capital topics – Labor Practices and Workforce Health and Safety –  across the nine industry standards. We welcome the opportunity to provide further feedback to the ISSB on these topics as it finalizes the industry standards and proceeds with standard setting on Human Capital. 

1. In 2021, Rights CoLab signed an MOU with the Value Reporting Foundation.  ↩︎
2. This work is funded by a generous grant from the Tipping Point Fund for Impact Investing, Humanity United, and Generation Foundation. ↩︎
3. This report builds off our 2022 report, “What is DEI? Market Signals of Diversity, Equity, and Inclusion,” which mapped 429 DEI metrics across 21 influential frameworks to reveal both common core understandings of DEI and significant differences in how DEI is conceptualized, measured, and managed. This report was written to support the SASB research team in its research on DEI, a priority topic at the time. See: https://rightscolab.org/what-is-dei-market-signals-of-diversity-equity-and-inclusion/ ↩︎
4. Norges Bank Investment Management, “Responsible Investment: Government Pension Fund,” 
   https://www.nbim.no/en/news-and-insights/reports/2024/responsible-investment-2024/web-reportresponsible-investment-2024/  ↩︎
5. Human Rights, General Expectations” in State Street Global Advisors (SSGA), 2025
   Sustainability Stewardship Service Proxy Voting and Engagement Policy, 2025, 10-11. https://
   www.ssga.com/library-content/assets/pdf/global/asset-stewardship/sustainability-stewardshipservice-proxy-voting-and-engagement-policy.pdf ↩︎
6. IFRS Foundation, Research Project – Human Capital: Analysis of Evidence of Investor Interest in
   Human Capital-Related Information, Staff Paper, Agenda Reference 4B (International Sustainability
   Standards Board, February 2025), para. 35, https://www.ifrs.org/content/dam/ifrs/meetings/2025/
   february/issb/ap4b-analysis-evidence-investor-interest.pdf   ↩︎
7. Vicky Meek, “The Rise of Human Rights Due Diligence,” New Private Markets, February 3, 2025, 
   https://www.privateequityinternational.com/the-rise-of-human-rights-due-diligence/  ↩︎
8. The fourth metric is from the Forest Management Standard (metric RR-FM-210a.2). The analysis of these metrics can be found on pp 29-30 of our report and in Appendix B.  ↩︎
9. Earth Rights International, “Security Guards for World’s Largest Gold Mining Company Rape and Kill Locals in Papua New Guinea,” https://earthrights.org/case/barrick/  ↩︎
10. Antar, “Rio Tinto’s Destruction of the Juukan Gorge,” updated May 22, 2025 https://antar.org.au/issues/cultural-heritage/the-destruction-of-juukan-gorge/  ↩︎
11. Global Witness, “Missing voices: The violent erasure of land and environmental defenders,” 10 September 2024 https://globalwitness.org/en/campaigns/land-and-environmental-defenders/missing-voices/  ↩︎
12. Lerator Musila, “We are being hunted, say SA’s human rights defenders amid rising attacks,” Daily Maverick, October 27,2025 https://www.dailymaverick.co.za/article/2025-10-27-we-are-being-hunted-say-sas-human-rights-defenders-amid-rising-attacks/  ↩︎
13. International Finance Corporation, “Update of IFC’s Sustainability Framework,” https://www.ifc.org/en/what-we-do/sector-expertise/sustainability/policies-and-standards/update-of-ifc-s-sustainability-framework  ↩︎
14. An SIA looks broadly at social consequences (employment, migration, local services, social cohesion, etc.) and often treats “human rights” as one category within that broader social field. It is usually framed using flexible social-science benchmarks and a strong planning/development orientation. An HRIA, by contrast, is anchored explicitly in international human rights law and principles, grounded in the rights of specific rights‑holders and the corresponding duties of states and responsibilities of companies.  ↩︎
15. Stakeholder Engagement Guide (Beta Version), part of the Investor HREDD Precision Tools, https://www.investorhreddtools.org/main-page2.html ↩︎
16. In 2026, the Investor HREDD Precision Tools project will launch a Remedy Guide, which will present the case for the financial materiality of remedy. ↩︎

Photo by Giammarco Boscaro on Unsplash