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To check whether a bank or investment fund is connected to human-rights abuses, identify the exact financial relationship, inspect the institution’s current disclosures, and compare them with credible reporting and independent assessments. A policy gap, an investment holding, or an allegation alone does not prove that an institution caused or contributed to a specific harm. Keep the evidence—and its limits—clear.
Start by identifying the financial relationship
“My bank finances this company” can mean several different things. A bank may lend to a business, underwrite securities, finance a project, or invest on its own account. An investment fund holds assets chosen by its manager. A deposit account, a bank’s lending activity, and a fund in a pension portfolio are separate relationships; establish which one you are investigating before drawing conclusions.
Record the exact bank or investment manager and, where possible, its legal entity and country. For a fund, note the full fund name, share class or ticker, and the date of the latest portfolio disclosure. OECD guidance treats institutional investment, project and asset finance, and general corporate lending and securities underwriting as distinct due-diligence contexts. OECD Due Diligence Guidance for Responsible Business Conduct
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Search the bank or manager’s website for its human-rights policy, responsible-business-conduct or human-rights due-diligence material, sector policies, sustainability or stewardship reports, voting and engagement reports, grievance channels, and statements responding to particular allegations.
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For a fund, compare the latest holdings disclosure with the company or issuer named in the concern; note the date the holdings represent, because a portfolio can change. For bank financing, look for project-finance disclosures, company reports, bond prospectuses, or other public evidence of a transaction. Confidentiality can limit what a bank discloses, and the public information that is available may be incomplete. The BankTrack guide on financial institutions and human rights discusses ways public records and client consent can help clarify relationships.
Check whether a policy is put into practice
A pledge is a starting point, not proof of effective due diligence. Use these questions to assess whether the institution explains how it identifies and responds to risks to people:
- Does its policy cover the relevant service or investment, as well as the business relationships involved?
- Does it assess potential impacts on people, rather than focusing only on risks to its own finances?
- Does it explain how it prioritizes serious impacts, takes action, tracks results, and communicates what happened?
- Does it describe how it uses influence over a client or portfolio company, including what it does if engagement fails?
- Can affected people or their representatives raise concerns through a credible channel, and does the institution explain its approach to remedy?
- Does it consult affected people or credible local sources when direct engagement is not possible?
The UNEP FI Human Rights Guidance Tool for the Financial Sector organizes guidance around policy commitments, human-rights due diligence, and remedy, with stakeholder engagement as a cross-cutting theme. The UN Guiding Principles Reporting Framework provides questions that can help readers assess a company’s disclosures. These are scrutiny tools, not substitutes for case-specific evidence.
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Check independent assessments and the specific case
For commercial banks
Use BankTrack’s Global Human Rights Benchmark and its Response Tracking as independent sources of scrutiny. The benchmark assesses banks’ implementation of the UN Guiding Principles; response tracking records responses to civil-society requests concerning alleged impacts linked to finance. In its 2024 benchmark, BankTrack assessed 50 large commercial banks, ranked two as leaders, and reported that no bank in the sample fully met the UN Guiding Principles. That result describes the 2024 assessment and its bank sample; it does not establish responsibility for a particular transaction, cover every bank, or assess investment funds.
For investment funds
Compare the manager’s dated portfolio disclosures with credible reporting and information from the relevant issuer. OECD investor guidance treats due diligence as an ongoing process across the investment value chain and asset classes, rather than a one-time check before investing. OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and related guidance provide a framework for responsible business conduct. A past holdings list cannot, by itself, show the fund’s current exposure or what its manager did after learning of a concern.
For project or asset finance and other bank services
For project and asset finance, the OECD’s guidance on due diligence for responsible corporate lending and securities underwriting and its paper on responsible project and asset finance address different financing contexts. The project-finance paper includes practical recommendations on stakeholder engagement, client confidentiality, and contributing to or providing for remediation. Match the guidance to the service at issue rather than treating all financing as the same.
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Distinguish an allegation, a link, and responsibility
Record each concern separately, and label a claim “alleged” unless a credible finding establishes it. Keep these questions distinct: Did harm occur? Is there evidence of a financial relationship with the company, project, or issuer? What did the institution know and do? What conclusion, if any, has a credible source reached about its role?
The UN Guiding Principles distinguish between an institution causing harm, contributing to it, or being directly linked to it through a financial relationship. Direct linkage is not automatically the same as causing or contributing. Expectations differ: an institution directly linked to an impact is expected to use its leverage, while causing or contributing can entail responsibility to support remedy. The OECD’s due diligence guidance explains this risk-based approach.
For each case, keep a short evidence record containing:
- The alleged harm and the people or rights-holders affected.
- The company, project, or issuer involved.
- The financial relationship and its date, with the source supporting it.
- The source of the allegation and whether it reports an allegation, a finding, or both.
- The institution’s response and any steps described to prevent, mitigate, or remedy harm.
- What remains unknown or cannot be confirmed from public information.
Compare banks or funds using the same criteria
If you are choosing between institutions, assess each against the same evidence rather than relying on a sustainability label or a single score.
| Criterion | What to examine |
|---|---|
| Coverage | Whether policies cover the relevant lending, underwriting, project finance, investment, or asset class. |
| Due-diligence process | Whether the institution identifies impacts on people and explains action, follow-up, and communication. |
| Transparency | Whether holdings, financing relationships, policies, and case responses are specific and current enough to evaluate. |
| Engagement and leverage | How it uses influence and what escalation follows if engagement does not work. |
| Grievances and remedy | Whether channels are accessible and the institution explains its role in addressing harm. |
| Case record | How it responds to credible allegations and independent scrutiny. |
Use the OECD spotlight on responsible-business-conduct disclosure for context: the OECD notes that disclosures about adverse impacts are uneven, partial, and biased. A thin record therefore signals uncertainty, not proof that no exposure exists.
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Ask the institution for an explanation
If public information does not answer the question, contact the bank or fund manager. Identify the company, project, or issuer and the concern; ask what relationship it can disclose, what due diligence and response it undertook, and how affected people can raise concerns. The institution may cite client confidentiality. Public company reports, prospectuses, other disclosures, or client consent may help clarify a relationship, as described in the BankTrack guide.
For an actual complaint, the appropriate regulator, national contact point, or other route depends on the country, institution, financial relationship, and facts. There is no single complaint channel that applies in every jurisdiction.
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