Human Rights Policy
- Purpose
Fluvio is committed to respecting Human Rights[1] across all aspects of its operations.
This Human Rights Policy establishes how Fluvio identifies, assesses, and manages potential negative human rights impacts associated with our clients and suppliers.
It is aligned to the United Nations (2011) Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework.
It is approved at the most senior level (i.e. Directors).
The purpose of this Human Rights Policy is to:
- Ensure that human rights considerations are embedded in business decision-making;
- Reduce the risk of contributing to human rights harm, including indirect impacts such as greenwashing or misrepresentation;
- Provide a consistent framework for assessing and mitigating risks;
- Promote transparency and accountability in client and supplier selection.
This Human Rights Policy prohibits material sales or purchases from high-risk industries that are known to have caused, contributed towards, or have linkages with human rights abuses and/or environmental issues. This prohibition is a form of screening that is carried out before deciding to bid for a project for a particular client or make a purchase of goods or services from a supplier. The industries that Fluvio screens-out include:
- Fossil fuels:Companies primarily involved in the production of fossil fuels (including coal, oil, and gas).
- Weapons/defence: Companies primarily involved in the production of weapons/arms.
- Prison industry and labour: Companies that manage or operate prisons, as well as firms in the US and Canada that support prisons or utilize prison labour, are entirely ineligible.
- Tobacco: Producers and marketers of tobacco, including all nicotine products.
- Pornography: Companies involved in the production or distribution of adult content.
- Gambling: Companies with significant, direct involvement in operating casinos or gambling, although some charity lotteries may be considered.
- Certain financial services:Companies that operate in specific, high-risk, non-transparent tax havens.
2. Scope
This Policy applies to:
- All clients and suppliers, including businesses, government organisations and non-governmental organisations;
- All projects undertaken or considered by Fluvio;
- All Directors, employees, contractors and other parties linked to its operations, products or services.
3. Commitment
Fluvio aligns its approach with internationally recognised human rights standards, including the United Nations (2011) Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework. Fluvio seeks to:
- Avoid causing or contributing to adverse human rights impacts;
- Mitigate risks where potential impacts are identified;
- Use its influence to encourage responsible practices among clients and suppliers;
- Remediate impacts where they are caused.
4. Human rights impact assessment (HRIA)
Fluvio conducts a structured assessment of potential negative human rights impacts for clients and suppliers. The HRIA is designed to help Fluvio to understand the risk of our clients or suppliers not meeting their responsibilities to respect human rights[2]. Fluvio does not have the capacity to investigate individual organisations to ascertain if there have been, or currently are, any instances of non-compliance. However, we will draw on external expertise on this matter from organisations such as the Business and Human Rights Centre (using their search function).
4.1 Identification of most material clients or suppliers
For Fluvio’s first year of operation, the HRIAs were conducted retrospectively on our three most material clients and five most material suppliers of goods and services. Materiality was determined by the value of revenue generated from clients and expenditure spent on suppliers in the year of operation of interest.
However, going forward, Fluvio will conduct prospective HRIAs on all client revenue > £10,000 ex VAT in one year requires prospective HRIA, supplier spend > £5,000 ex VAT in one year requires prospective HRIA (unless they are a B Corp).
4.2 Assessment Criteria
- Commitment to Humans Rights
In order to meet their responsibility to respect Human Rights, organisations should have in place policies and processes appropriate to their size and circumstances. Fluvio assess this with the following criteria:
(i) Does the organisation have a policy commitment to meet their responsibility to respect Human Rights?
(a) Is the policy approved at the most senior level of the business enterprise;
(b) Is the policy informed by relevant internal and/or external expertise?
(c) Does the policy stipulate the organisation’s Human Rights expectations of personnel, business partners and other parties directly linked to its operations, products or services?
(d) Is the policy publicly available and communicated internally and externally to all personnel, and other relevant parties?
(e) Is the policy reflected in operational policies and procedures necessary to embed it throughout the organisation?
(ii) Does the organisation have a Human Rights due diligence process to identify, prevent, mitigate and account for how they address their impacts on human rights?
(a) The process should cover adverse Human Rights impacts that the organisation may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its relationships? The process should be ongoing, recognizing that the Human Rights risks may change over time as the organisation’s operations and operating context evolve.
(iii) Does the organisation have processes to enable the remediation of any adverse Human Rights impacts they cause or to which they contribute?
- Severity of impact
In addition to assessing an organisation’s commitment to Human Rights (Section 4.2 A). Fluvio recognises that not all organisations currently have made these commitments. As such, we assess the potential severity of impact of the organisation, assessed based on the following dimensions:
- Scale: The seriousness of the potential impact, i.e. does it limit basic freedoms (speech, movement, privacy) or does it threaten life or physical safety (e.g., torture, forced labour)?
- Scope: The number of people who could be affected, i.e. does the violation affect one or two people, or thousands of people?
- Ease of remediation: The degree of difficulty in remedying the harm, i.e. temporary restrictions (e.g., short-term detention) can be fully remedied, whereas the loss of life or permanent disability is irreversible.
Severity is judged by combining these three factors:
- High severity = large-scale, widespread, irreversible harm
- Moderate severity = limited group, partially reversible harm
- Low severity = minor, temporary, easily remedied harm.
- Likelihood of impact
Likelihood considers:
- The probability of the impact occurring; and
- The expected frequency of occurrence.
Fluvio’s approach aligns with the UN framework, whereby severity outweighs likelihood. Even if something is unlikely, if the potential harm is extreme (e.g., risk of death), it must be prioritised.
Additional factors considered:
- Vulnerability of affected groups (children, refugees, marginalized communities)
- Systemic vs. isolated impact (is it part of a pattern?)
- Duration (short-term vs. ongoing harm)
- Intent and negligence (deliberate abuse vs. unintended consequence)
4.3 Assessment process
For each relevant client or project, Fluvio will:
- Conduct due diligence
- Review publicly available information (Business and Human Rights Centre);
- Analyse the client’s sector, geography, and operational practices;
- Identify links to known human rights risks (e.g. labour rights, environmental harm, data privacy, community impacts).
- Identify salient Human Rights issues
- Determine which human rights are most at risk in the context of the client or supplier.
- Evaluate severity and likelihood
- Apply the criteria outlined above;
- Prioritise risks based on severity.
- Document findings
- Record identified risks, assessment rationale, and initial conclusions.
5. Mitigation actions
Where potential negative human rights impacts are identified, Fluvio will take appropriate mitigation actions, which may include:
5.1 Engagement and influence
- Raising concerns with the client/supplier;
- Encouraging improved practices or safeguards;
- Requesting additional information or transparency.
5.2 Project design adjustments
- Modifying project scope or methodology to reduce risks;
- Incorporating human rights safeguards into deliverables;
- Avoiding outputs that could enable harm or misrepresentation.
5.3 Contractual measures
- Including clauses related to ethical conduct and responsible use of outputs;
- Setting expectations for compliance with human rights standards.
5.4 Internal controls
- Escalating high-risk cases to senior leadership;
- Requiring additional approvals for engagement;
- Increasing monitoring during project delivery.
5.5 Declining or withdrawing engagement (if necessary)
- Where risks cannot be adequately mitigated, Fluvio may decline to proceed with a client or supplier.
Fluvio will record its mitigation action, if its assessments identified any potential or actual negative impacts, and will, within 12 months record the effectiveness of its mitigation actions.
6. Recording and transparency
Fluvio maintains records of its human rights assessments for the three most material clients and five most material suppliers for each year.
These records include:
- The basis for determining materiality;
- Identified human rights risks;
- Assessment of severity and likelihood;
- Mitigation actions considered and implemented;
- Final decisions and outcomes.
Records are reviewed annually and used to inform continuous improvement of the Policy and processes.
7. Governance and responsibility
- Responsibility for implementation of this Policy sits with Fluvio’s leadership team.
- Employees involved in client selection and project delivery are responsible for applying this framework.
- Significant risks and decisions are escalated to senior management.
8. Review
This Policy is reviewed annually to ensure it remains effective, aligned with best practices, and responsive to emerging human rights risks.
9. Continuous improvement
Fluvio recognises that human rights due diligence is an ongoing process. The company is committed to:
- Learning from past assessments;
- Updating methodologies;
- Strengthening its ability to identify and mitigate risks over time.
Effective Date: 17/04/2026
Approved By: Gary Bilotta (Director) and Matt Turley (Director)
[1] Human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.
[2] Human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.