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Not from a fund name, ESG rating or general report alone. A client can find out what a manager says it does by reviewing the policy that applies to their fund or mandate, asking how the manager identifies and addresses human-rights risks, and seeking portfolio-specific information and evidence of action. Even then, that information may not establish that a particular client’s money funded a particular violation or that the client or manager was legally responsible for it.
What can a client actually know?
Investment managers can report policies, risk-assessment methods, engagements and responses to identified problems. Those disclosures help clients assess whether a manager is taking human-rights due diligence seriously. They are not the same as tracing an individual client’s contribution to a specific harm.
Many investors hold pooled funds or portfolios containing securities issued by companies with complex operations and value chains. A controversy alert, a high-risk country or sector, an ESG score, or ownership of a security can flag a question for investigation; none alone proves that a client knowingly funded a violation. Establishing a connection requires evidence about the holding, the impact and the investor’s relationship to it. The legal implications also depend on the relevant facts and jurisdiction.
General industry statistics describe reporting institutions and their practices, not the holdings or conduct of the particular fund a client owns. For a meaningful answer, clients need disclosures from their own manager about the applicable mandate, its method and the actions taken.
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What responsible-investment due diligence involves
The Principles for Responsible Investment (PRI) describes three connected elements: a policy commitment to respect internationally recognized human rights, due-diligence processes, and access to remedy. Due diligence is ongoing rather than a one-time screening exercise: managers identify actual and potential adverse impacts connected to investees, work to prevent or mitigate them, track how they are managed, and communicate actions and outcomes to clients, beneficiaries and, where appropriate, affected stakeholders and the public.
Identify and prioritize impacts
A manager should explain how it looks for actual and potential impacts in current and prospective investments, including relevant value-chain risks. It should also say how it prioritizes severe risks and handles gaps or disagreements in its information. Context matters: sector, geography, asset class and business relationships can change which risks are salient. The OECD notes that investment contexts can involve risks such as land-rights impacts, displacement and forced relocation; those examples do not establish that a particular portfolio is connected to such outcomes.
PRI cautions that ESG data is imperfect and provider ratings can be inconsistent. In its 5 June 2023 practical guide, it states: “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.” A rating can be one input, but it is not conclusive proof of a company’s human-rights performance.
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Prevent, mitigate and track
Identification should lead to a response. Ask what the manager did to prevent or mitigate a particular impact, how it engaged with the investee and affected stakeholders, and how it assesses whether its actions worked. A policy or an engagement count, by itself, does not demonstrate that harm was prevented or remedied.
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Communicate and address remedy
Clients should be able to learn what actions the manager took and what outcomes it tracked, with enough detail to understand how the policy is applied to their fund or mandate. Where the investor’s connection to harm creates a responsibility to act, PRI guidance includes providing or enabling access to remedy. A manager should be able to explain the process it uses rather than relying only on a general statement of commitment.
What published figures say—and do not say
PRI reporting gives an indication of what signatories report doing, but it cannot tell a client whether a particular fund holds a particular company or whether a specific impact occurred. These figures come from different reporting populations and periods; they should not be combined into a single measure of all investors.
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| Reported practice | Figure and scope | What it does not establish |
|---|---|---|
| Action across all pillars of the UN Guiding Principles on Business and Human Rights (UNGPs) | In 2025, 8% of PRI signatories, with combined assets under management (AUM) of US$13.6 trillion, reported taking action on all pillars of the UNGPs. | This is a reported practice figure, not proof of portfolio-level outcomes or of a particular client’s exposure. |
| Human-rights due diligence and access to remedy | PRI’s 2025 reporting found that 32% of signatories conducted human-rights due diligence and 11% enabled access to remedy. | These figures do not show whether an individual manager’s methods worked or whether a client’s investments were connected to harm. |
| Use of the UNGPs and/or OECD Guidelines | In PRI’s 2023 reporting cycle, 36% of asset owners and 30% of investment managers reported using one or both frameworks. The 2024 PRI report says the frameworks were applied to USD 13.2 trillion of asset-owner AUM and USD 61.8 trillion of investment-manager AUM. | The reported use of a framework does not establish a specific holding, impact or outcome. |
| Responsible investment linked to fiduciary duties | PRI’s responsible-investment introduction page summarizes its 2025 reporting data as showing that around 75% of signatories explicitly link responsible-investment activity to fiduciary duties in their policies. | This describes policy language among PRI signatories, not a legal conclusion about a specific manager or mandate. |
These are self-reported PRI signatory figures. They are not independent verification of each manager’s portfolio practices, and they should not be treated as representative of every investor.
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Ask for answers that apply to the fund or mandate you own, not just the firm’s broad responsible-investment policy. Specific, documented responses are more informative than a yes-or-no assurance.
- Policy: What public human-rights policy applies to my fund or mandate, and where can I read it?
- Risk identification: How do you identify actual and potential impacts in current and prospective investments, including relevant value chains?
- Prioritization and data: How do you prioritize severe risks? Which data sources do you use, and how do you address gaps or differences among providers?
- Action: What have you done to prevent or mitigate identified impacts, and how do you assess whether those actions were effective?
- Engagement and escalation: How do you engage with investees and affected stakeholders? What circumstances might lead you to escalate your response or consider exiting?
- Reporting: What information about actions and outcomes do you report to clients and beneficiaries, and how often?
- Remedy: If an investment is connected to harm, what process do you use to provide or enable access to remedy?
Follow-up evidence matters. A manager’s affirmative answers describe its claimed process; clients should assess them against the manager’s methodology, records and portfolio-specific disclosures.
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 manager and check whether the answers apply to the investment you own. A useful comparison focuses on process and evidence, rather than treating a single score or label as a ranking.
| Area to compare | What to look for |
|---|---|
| Policy coverage | Whether the policy covers the client’s actual fund or mandate, not only the firm in general. |
| Risk method | How the manager identifies and prioritizes impacts, which data it uses and how it addresses uncertainty. |
| Response | How it prevents or mitigates harm, engages with investees, escalates concerns and considers exit. |
| Tracking and communication | How it checks whether responses are working and what it reports to clients or the public. |
| Remedy | What process applies when the investor’s connection to harm gives rise to a responsibility to act. |
PRI’s 7 June 2023 private-markets guide says: “Human rights due diligence should be used to inform decision-making at all stages of the investment process.” In private markets, that can mean informing investment selection and corrective actions in shareholder agreements or post-transaction plans. PRI also discusses building leverage, ongoing engagement and considering divestment as a last resort in context. There is no universal instruction to sell or hold: a manager may need to explain its reasoning, including when constraints limit its ability to divest.
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