Walk Free+Human Rights investment policy (sector specific)+Vanguard Asset Management Limited+2022+Discussion

It is not referred to as a policy, but it is a process:

p.1: In addition, Vanguard actively engages with portfolio companies and their boards to discuss material risks, ranging from business and operational risks to environmental and social risks. Vanguard’sinvestment stewardship activities encourageboards to properly oversee such material risks. We have established a formal procedure to identify and monitor portfolio companies whose direct involvement in crimes against humanity or patterns of egregious abuses of human rights would warrant engagement.We will continue to build outour monitoringof business practices and engage with companies where we believe that action is required.Vanguard is also a signatory to the UK Stewardship Code 2020, whichcomprises a set of principles and guidance for asset managers to promotetransparency and integrity in businessas part of stewardship activities: Vanguard’s report can be found here. Further information on Vanguard’s investment stewardship programme, detailing the approach to engagement and case studies, can be found here.

The procedure refers to the identification of companies that have to be engaged with on human rights issues, but it it not a blueprint for investment.