It has been six years since the United Nations (UN) Human Rights Council unanimously endorsed the UN Guiding Principles on Business and Human Rights (UNGPs). The UNGPs have been accepted by international organisations and companies across different sectors as the universal standard for identifying and managing human rights risks related to business. International standards and frameworks have been updated to ensure alignment with the UNGPs, including the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the UN Global Compact, the International Standards Organisation (ISO) 26000 Guidance on Social Responsibility, the International Finance Corporation (IFC) Environmental and Social Performance Standards and the Food and Agriculture Organisation of the UN's Voluntary Guidelines on Responsible Governance of Tenure of Land, Fisheries and Forests.

Despite the rapid uptake of the UNGPs as a normative standard, implementation of the UNGPs has been slower. The Corporate Human Rights Benchmark (CHRB) assessed the human rights performance of 98 of the world's largest publicly traded companies in three sectors and found significant gaps in implementation of the UNGPs. According to the CHRB, of the 98 companies assessed in 2016:

• one third do not have a publicly disclosed human rights policy;
• half do not indicate how their board considers human rights in decision making;
• three quarters have no provisions on access to remedy; and
• only one third identify human rights risks, of which only half indicated how they mitigate such risks.

Of the 98 companies benchmarked by the CHRB, only six received a score of above 50 per cent and only three companies (two of which were extractive sector companies), scored above 60 per cent. The average score across the sample was approximately 30 per cent.

Against this backdrop, we ask questions about why, how, and to what extent the UNGPs can be integrated into corporate policy frameworks, and operationalised in practice. The paper responds to these questions. It draws on our collective experience of working for BG Group, when we were tasked with establishing the Social Performance and Human Rights function as part of a company-wide change management program.