You can investigate whether a bank or investment fund is connected to alleged human-rights abuses by tracing the specific financial relationship, checking what the institution says it does about human-rights risks, and comparing that account with credible independent evidence. A policy gap, an investment holding, or an allegation alone does not prove that the institution caused or contributed to an abuse.
Start by identifying the financial relationship
First write down exactly what you want to assess: the bank and its legal entity, the country and product involved, or the fund’s full name, share class or ticker, and manager. A personal bank account is not the same thing as the bank’s lending or underwriting activity. Likewise, a fund in a pension portfolio may hold shares in a company, but that does not by itself establish that the bank providing your account financed that company.
Financial institutions can be connected to businesses through different activities: a bank may lend to a company, underwrite securities, or finance a project; an investment manager may hold securities in a portfolio. The relationship affects what evidence to look for and what due diligence is expected. The OECD distinguishes investment from project and asset finance, as well as general corporate lending and securities underwriting; see its responsible-business-conduct guidance and the relevant sector guidance below.
Gather the institution’s disclosures and outside evidence
Check what the institution publishes
Search the bank or fund manager’s website for its human-rights policy, responsible-business-conduct or human-rights due-diligence disclosures, relevant sector policies, sustainability or stewardship reports, voting and engagement records, grievance channel, and statements about the specific concern. For a fund, obtain its latest holdings disclosure and note the date it represents. For bank financing, look for public project-finance disclosures, company reports, bond prospectuses, or other transaction evidence.
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Public information may not reveal every relationship. Confidentiality can limit what a bank discloses, and company reporting about adverse impacts is often uneven, partial, and biased, as the OECD notes in its spotlight on responsible business conduct and ESG disclosure. Missing public evidence is uncertainty—not proof that exposure does not exist.
Compare disclosures with independent material
For commercial banks, BankTrack’s Global Human Rights Benchmark and its response tracking offer independent scrutiny of banks’ implementation of the UN Guiding Principles on Business and Human Rights (UNGPs) and responses to civil-society concerns about finance-linked impacts. The benchmark is not an exhaustive transaction database and does not determine legal responsibility.
For investment funds, compare current portfolio disclosures with credible reporting and information about the companies or issuers involved. The OECD’s guidance for institutional investors treats due diligence as an ongoing process across investment value chains and asset classes; a one-time pre-investment screen cannot show whether an investor identifies and responds to adverse impacts over time.
For project or asset finance, consult the OECD’s 2022 guidance on project and asset finance, which addresses stakeholder engagement, client confidentiality, and remediation. For general corporate lending or securities underwriting, the OECD provides separate financial-sector guidance.
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A public commitment is a starting point, not evidence on its own that risks are being managed. The UNEP FI human-rights toolkit for financial institutions organizes its guidance around policy commitments, human-rights due diligence, and remedy, with stakeholder engagement running through the process. Use these questions to assess a bank or fund manager’s disclosures:
- Does the policy cover the particular service or investment activity and the relevant business relationships?
- Does the institution assess impacts on people, rather than looking only at risks to its own finances?
- Does it explain how it prioritizes serious impacts, acts on them, tracks results, and communicates what happened?
- Does it describe how it uses influence over clients or portfolio companies—and what it does if that influence fails?
- Can affected people or their representatives raise concerns through an accessible, credible channel? Is the approach to remedy explained?
- Does the institution meaningfully engage affected people or credible local sources when direct engagement is not possible?
The UNGP Reporting Framework offers questions that can help readers assess an organization’s account of its human-rights practices. Disclosure can help show what the institution claims to do; it does not, by itself, establish how a particular case was handled.
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Separate an allegation, a financial link, and responsibility for harm
Keep distinct questions distinct: Was harm alleged, and who was affected? Is there evidence of a financial relationship with the company, project, or issuer? What did the bank or manager know and do? Has a credible finding established the harm or the institution’s role? Attribute allegations and use “alleged” unless a credible finding supports a firmer description.
The UNGPs and OECD guidance distinguish between an institution causing an impact, contributing to it, or being directly linked to it through a business relationship. Direct linkage is not automatically the same as causing or contributing. Expectations differ by relationship: an institution directly linked to an impact is expected to use its leverage to prevent or mitigate it, while causing or contributing to an impact can entail responsibility to support remedy. BankTrack’s complaints guide reproduces the UNGP statement: “Where business enterprises identify that they have caused or contributed to adverse impacts, they should provide for or cooperate in their remediation through legitimate processes.”
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For each concern, make a short evidence record containing:
- The alleged harm and the people or rights-holders affected.
- The company, project, or issuer involved.
- The institution’s financial relationship and its date, if established.
- The source of the allegation and any credible findings.
- The institution’s response, including steps to prevent, mitigate, or remedy harm.
- What remains unknown or disputed.
Compare institutions using the same criteria
If you have alternatives, compare them on evidence that applies to the same financial activity and period. A bank benchmark and a fund’s holdings report are not interchangeable measures.
| What to compare | Evidence to look for |
|---|---|
| Coverage | Whether the policy covers the relevant lending, underwriting, project finance, investment, or asset class. |
| Due diligence | Whether the institution identifies impacts on people and describes action, tracking, and communication. |
| Transparency | Whether holdings, financing relationships, policies, and case responses are specific and current enough to assess. |
| Engagement and leverage | How the institution says it uses influence and what escalation follows if engagement fails. |
| Grievances and remedy | Whether channels are accessible and responsibilities for addressing harm are explained. |
| Case record | How the institution responds to credible allegations and independent scrutiny. |
As one dated benchmark example, BankTrack’s 2024 Global Human Rights Benchmark assessed 50 large commercial banks, ranked two as leaders, and reported that no bank in that sample fully met the UNGPs. Those findings describe that 2024 assessment and its bank sample; they do not decide whether a specific transaction caused a particular abuse, and they do not cover every bank or investment fund.
Ask the institution for an explanation
Contact the bank or fund manager with a focused request. Identify the company, project, or issuer and the alleged impact; ask what relationship the institution can disclose, what due diligence and response it undertook, how it uses leverage, and how affected people can raise concerns. Client confidentiality may restrict an answer. BankTrack’s complaints guide notes that public company reports, bond prospectuses, other disclosures, or client consent may help clarify a relationship.
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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallComplaint options depend on the country, institution, financial relationship, and facts. There is no single route that applies everywhere; identify the appropriate regulator, national contact point, or other channel for your jurisdiction before filing.
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