Not from a general ESG rating, a controversy alert or an industry-wide report alone. To find out what a particular investment manager knows about a particular fund or mandate, clients need to ask how the manager identifies human-rights risks in its investments, what it does about them, and what evidence it can disclose. Even then, evidence of an investment connection is not, by itself, proof that a client knowingly funded or was complicit in a violation.
What should an investment manager know and do?
Responsible-investment guidance treats respect for human rights as an ongoing management process, not a one-time screen or a promise that a portfolio has no adverse impacts. The UN Guiding Principles on Business and Human Rights (UNGPs) describe the responsibilities through three connected elements: a policy commitment, human-rights due diligence, and access to remedy where appropriate. Principles for Responsible Investment (PRI) and OECD guidance apply related due-diligence concepts to investors and investment portfolios.
- Set a policy commitment. The manager should explain which internationally recognized human rights its policy covers and whether that policy applies to the specific fund or mandate the client owns.
- Identify and assess impacts. It should look for actual and potential adverse impacts connected to investee companies, including relevant parts of their value chains, and prioritize the most severe risks. Assessment should account for sector, geography, asset class and the circumstances of affected people.
- Prevent or mitigate harm. The manager should describe what it has done to influence investees or otherwise address identified impacts, rather than treating a risk flag as a completed response.
- Track actions and outcomes. It should assess whether its response is being implemented and whether it is effective, while acknowledging gaps or uncertainty in the available evidence.
- Communicate and address remedy. It should explain relevant actions and outcomes to clients and beneficiaries, and use an appropriate process to provide or enable access to remedy when its connection to harm creates that responsibility.
For private-market investors, PRI says due diligence should inform decisions throughout the investment process. It can shape investment selection, shareholder-agreement terms and post-transaction plans. Engagement with investees and stakeholders, building leverage, and corrective action may all be relevant. Divestment is a contextual option, not an automatic answer: if a manager is constrained from selling, it should be able to explain why it remains invested and what it is doing instead.
What do industry figures say—and what can’t they tell you?
PRI signatory reporting offers a view of reported industry practices, not a record of what any one client’s portfolio holds or whether a particular harm occurred. The figures below refer to different reporting populations and periods; they should not be combined as if they shared a denominator.
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| Reported practice | Figure | Source and scope |
|---|---|---|
| Signatories taking action on all pillars of the UNGPs | 8%, with combined assets under management (AUM) of US$13.6 trillion | PRI, 2025 reporting data. This describes reported practice, not independently verified portfolio outcomes. |
| Signatories conducting human-rights due diligence | 32% | PRI, 2025 reporting data. It does not establish the quality or results of a particular manager’s process. |
| Signatories enabling access to remedy | 11% | PRI, 2025 reporting data. It is a reported practice figure, not evidence that remedy was provided in a specific case. |
| Asset owners and investment managers reporting use of the UNGPs and/or OECD Guidelines | 36% of asset owners; 30% of investment managers | PRI, 2023 reporting cycle, as reported in 2024. The frameworks were applied to USD 13.2 trillion of asset-owner AUM and USD 61.8 trillion of investment-manager AUM. |
| Signatories explicitly linking responsible-investment activity to fiduciary duties in policies | Around 75% | PRI’s responsible-investment introduction page, summarizing 2025 reporting data. |
These are self-reported signatory figures. They do not prove that a named manager has a particular exposure, that due diligence prevented harm, or that a client’s money financed a specific violation. They are useful context for questions, not a substitute for fund- or mandate-specific disclosure.
Why a risk score or headline is not proof
Portfolio data is incomplete and can point in different directions. PRI notes that ESG-rating providers can disagree and that risk profiles change over time. A single score should not be treated as conclusive evidence of a company’s human-rights performance—or as proof that a manager has met its responsibilities.
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A controversy alert, investment in a high-risk country or sector, or ownership of a security may be a reason to investigate. None alone establishes that a human-rights violation occurred, that a particular client knowingly funded it, or that the investor caused or contributed to it. The answer depends on evidence about the underlying impact, the investment relationship and the investor’s connection to the harm. General reporting about institutional practice cannot establish those facts for an individual account.
Scale also matters: an investor may have thousands of investees or applicants to assess. The OECD identifies land rights, displacement and forced relocation as risks in some investment contexts. These examples show why a manager’s analysis needs to reflect the relevant sector, geography, asset class and value chain; they are not evidence that a particular portfolio is connected to those outcomes.
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PRI puts the data challenge plainly: “Acknowledging that data availability is imperfect and that inconsistencies exist between environmental, social and governance (ESG) ratings from data providers, it is vital that investors take a methodological approach when assessing human rights risks to ensure that the most salient risks are identified.” — Principles for Responsible Investment, How to identify human rights risks: A practical guide in due diligence, 5 June 2023.
Questions to put to your manager
Ask about the fund or mandate you actually own, and request evidence or examples where the manager can provide them. Clear answers should identify the method, scope, actions and reporting cadence—not just state that the firm takes human rights seriously.
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- Which public human-rights policy applies to my fund or mandate, and what investments or business relationships does it cover?
- How do you identify actual and potential impacts in current and prospective investments, including relevant value-chain impacts?
- How do you prioritize severe risks? Which data sources do you use, and how do you handle gaps or disagreements among providers?
- What actions have you taken in response to identified impacts, and how do you assess whether those actions worked?
- How do you engage investee companies and affected stakeholders? What circumstances lead you to escalate, change investment terms or consider an exit?
- What information about actions and outcomes do you report to clients and beneficiaries, and how often?
- If an investment is connected to harm, what process do you use to provide or enable access to remedy?
Evaluate the answers against the manager’s published policy, methodology, records and portfolio-specific evidence. A confident response is not proof on its own; the useful test is whether the manager can explain how its stated process applies to the investment and what it has done.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to compare managers or funds
Use the same questions for each candidate and compare what applies to your specific mandate. These are process criteria derived from PRI and OECD guidance, not a third-party ranking or guarantee of outcomes.
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| What to compare | What to look for |
|---|---|
| Policy coverage | Whether the policy addresses internationally recognized human rights and clearly applies to your fund or mandate. |
| Risk identification | How the manager assesses actual and potential impacts, selects data sources, prioritizes severity and handles uncertainty. |
| Response | Evidence of prevention, mitigation, engagement, escalation and a contextual approach to any exit decision. |
| Tracking and communication | How the manager follows actions and outcomes and what it reports to clients, beneficiaries and, where appropriate, affected stakeholders. |
| Remedy | A process for providing or enabling access to remedy where the investor’s connection to harm makes that relevant. |
What a client can reasonably conclude
You can ask a manager to account for its policy, due diligence, response, tracking, communication and remedy processes. Those answers can help establish what the manager says it knows and how it acts. Whether a particular client’s money was connected to a specific serious violation requires investment- and impact-specific evidence; it cannot be settled by an industry statistic or a generic ESG label. The legal obligations of a particular manager also depend on jurisdiction and facts.
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