Symposium on business and human rights

1. BCCI Symposium on Business and Human Rights
By Dr Vidya Tikoo

2. 2 Agenda
International and National Frameworks on Human
Rights
Aditya Birla Group Sustainable Business Framework
Human Rights within the ABG Sustainable Business
Framework

3. International and National Frameworks on Human Rights

4. 4 Universal Declaration on Human Rights, 1948
Article 1 - All human beings are born free and equal in dignity and rights. Equality
Article 2 –Rights and freedom without distinction of any kind, such as race, colour, sex,
language, religion, political or other opinion, national or social origin, property, birth or
other status. – Non discrimination
Article 3 - Everyone has the right to life, liberty and security of person.
Article 4 - No one shall be held in slavery or servitude. – Bonded labour
Article 5 - No one shall be subjected to torture or to cruel, inhuman or degrading
treatment or punishment.
Article 6 - Everyone has the right to recognition everywhere as a person before the law.
Article 7 - All are equal before the law and are entitled without any discrimination to equal
protection of the law.
Article 8 - Everyone has the right to an effective remedy by the competent national
tribunals for acts violating the fundamental rights granted him by the constitution or by law.
Grievance management
Article 9 - No one shall be subjected to arbitrary arrest, detention or exile.
Article 10 - Everyone is entitled in full equality to a fair and public hearing by an
independent and impartial tribunal, in the determination of his rights and obligations and of
any criminal charge against him. Freedom of Association
Article 11 - Everyone charged with a penal offence has the right to be presumed innocent
until proved guilty.
Article 12 - No one shall be subjected to arbitrary interference with his privacy, family,
home or correspondence, nor to attacks upon his honour and reputation.

5. 5 Universal Declaration on Human Rights, 1948 (contd.)
Article 13 - Everyone has the right to freedom of movement and residence within the
borders of each State. Everyone has the right to leave any country, including his own, and
to return to his country.
Article 14 - Everyone has the right to seek and to enjoy in other countries asylum from
persecution.
Article 15 - Everyone has the right to a nationality.
Article 16 - Men and women of full age, without any limitation due to race, nationality or
religion, have the right to marry and to found a family.
Article 17 - Everyone has the right to own property alone as well as in association with
others.
Article 18 - Everyone has the right to freedom of thought, conscience and religion; this
right includes freedom to change his religion or belief.
Article 19 - Everyone has the right to freedom of opinion and expression.
Article 20 - Everyone has the right to freedom of peaceful assembly and association.
Article 21 - Everyone has the right to take part in the government of his country, directly
or through freely chosen representatives.
Article 22 - Everyone, as a member of society, has the right to social security.
Article 23 - Everyone has the right to work, to free choice of employment, to just and
favourable conditions of work, to protection against unemployment, to equal pay and
equal work, to form and to join trade unions for the protection of his interests. Non
discrimination in wages, freedom of association

6. 6 Universal Declaration on Human Rights, 1948 (contd.)
Article 24 - Everyone has the right to rest and leisure, including reasonable limitation
of working hours and periodic holidays with pay.
Article 25 - Everyone has the right to a standard of living adequate for the health and
well-being of himself and of his family, including food, clothing, housing and medical care
and necessary social services, and the right to security in the event of unemployment,
sickness, disability, widowhood, old age or other lack of livelihood in circumstances
beyond his control.
Article 26 - Everyone has the right to education.
Article 27 - Everyone has the right to freely participate in the cultural life of the
community.
Article 28 - Everyone is entitled to a social and international order in which the rights and
freedoms set forth in this Declaration can be fully realized.
Article 29 - Everyone has duties to the community in which alone the free and full
development of his personality is possible.
Article 30 - Nothing in this Declaration may be interpreted as implying for any State,
group or person any right to engage in any activity or to perform any act aimed at the
destruction of any of the rights and freedoms set forth herein.

7. 7 United Nations Global Compact
The UN Global Compact was launched in July 26, 2000 with nine Principles. On
June 24, 2004, during the first Global Compact Leaders Summit, Kofi Annan
announced the addition of the tenth principle against corruption.
The principles are derived from the Universal Declaration of Human Rights,
the International Labour Organization’s Declaration on Fundamental Principles
and Rights at Work, the Rio Declaration on Environment and Development, and
the United Nations Convention against Corruption.
Human Rights
Principle 1: Businesses should support and respect the protection of
internationally proclaimed human rights; and
Principle 2: make sure that they are not complicit in human rights abuses.
Labour
Principle 3: Businesses should uphold the freedom of association and the
effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labour;
Principle 5: the effective abolition of child labour; and
Principle 6: the elimination of discrimination in respect of employment and
occupation.

8. 8 Social Accountability 8000:2014
• Child Labour
• Forced Labour
• Health and Safety
• Freedom of Association and Right to Collective Bargaining
• Discrimination
• Disciplinary Practices
• Working Hours
• Remuneration
• Management Systems
• Policies, procedures and records
• Social performance team
• Identification and assessment of risks
• Monitoring
• Internal involvement and communication
• Complaint management and resolution
• External verification and stakeholder engagement
• Corrective and preventive actions
• Training and capacity building
• Management of suppliers and contractors

9. 9 Guiding Principles on Business and Human Rights, 2011
The Protect, Respect and Remedy Framework of United Nations
I. THE STATE DUTY TO PROTECT HUMAN RIGHTS
II. THE CORPORATE RESPONSIBILITY TO RESPECT HUMAN RIGHTS
III. ACCESS TO REMEDY
These Guiding Principles are grounded in recognition of:
(a) States’ existing obligations to respect, protect and fulfil human rights and
fundamental freedoms;
(b) The role of business enterprises as specialized organs of society
performing specialized functions, required to comply with all applicable laws
and to respect human rights;
(c) The need for rights and obligations to be matched to appropriate and
effective remedies when breached.

10. 10 Global Reporting Initiative Standards, 2016

11. 11 National Voluntary Guidelines, 2011
The Government of India, through the National Voluntary Guidelines want
companies to:
• Give back something to the society;
• Be responsible;
• Be accountable for its actions; and
• Be sustainable in itself and in the environment it operates in.
Securities and Exchange Board of India (SEBI) as a part of its circular on
13th August 2012, made it mandatory for top 100 BSE and NSE listed
companies (as on March 2012) to disclose their Business Responsibility
Practices through a report (Business Responsibility Report, BRR) adhering
to the NVG framework.

12. 12 National Voluntary Guidelines, 2011
Principle No. Aspects Principle Description
1 Ethics, transparency
and accountability
Businesses should conduct and govern themselves with
ethics, transparency and accountability
2 Product life cycle Businesses should provide goods and services that are
safe and contribute to sustainability throughout their
life cycle
3 Employee’s
wellbeing
Businesses should promote the wellbeing of all
employees
4 Stakeholder
engagement
Businesses should respect the interests of, and
be responsive towards all stakeholders,
especially those who are disadvantaged,
vulnerable and marginalised
5 Human rights Businesses should respect and promote human
rights
6 Environment Businesses should respect, protect, and make efforts to
restore the environment
7 Policy advocacy Businesses, when engaged in influencing public and
regulatory policy, should do so in a responsible manner
8 Inclusive growth Businesses should support inclusive growth and
equitable development
9 Customer value Businesses should engage with and provide value to
their customers and consumers in a responsible
manner

13. Aditya Birla Group Sustainable Business Framework

14. 1 Aditya Birla Group Sustainability Vision
December 2012
By 2017, the Aditya Birla Group endeavours to become the leading
Indian conglomerate for sustainable business practices across its global
operations.
Formation of Apex Sustainability Committee
Aditya Birla Group Sustainability Model

15. Legal Standards
Today
Following local laws,
gives business a
relatively large space
to operate in.
Legal Limits / Tolerance

16. Legal Standards
Today
Following local laws,
gives business a
relatively large space
to operate in.
More Demanding Legal
Standards by 2030
By 2030, to be on the road
to a sustainable planet,
businesses will have to
perform better than ever.
Legal
Standards
needed for a
Sustainable
World 2050
By 2050, only the
best managed
business, with
highest
performance will
be able to survive.
Legal Limits / Tolerance

17. International
Standards Today
Operating voluntarily to international
standards requires a systematic approach
and higher levels of control and performance
i.e. a constricted operating space.
Legal Standards
Today
Following local laws,
gives business a
relatively large space
to operate in.
More Demanding Legal
Standards by 2030
By 2030, to be on the road
to a sustainable planet,
businesses will have to
perform better than ever.
Legal
Standards
needed for a
Sustainable
World 2050
By 2050, only the
best managed
business, with
highest
performance will
be able to survive.
Legal Limits / Tolerance
ABG Control Limits / Int’l Stds

18. International
Standards Today
Operating voluntarily to international
standards requires a systematic approach
and higher levels of control and performance
i.e. a constricted operating space.
Legal Standards
Today
Following local laws,
gives business a
relatively large space
to operate in.
Best Practice
Today
Companies operating at
best practice levels are
normally driven by
visionary leaders.
More Demanding Legal
Standards by 2030
By 2030, to be on the road
to a sustainable planet,
businesses will have to
perform better than ever.
Legal
Standards
needed for a
Sustainable
World 2050
By 2050, only the
best managed
business, with
highest
performance will
be able to survive.
Legal Limits / Tolerance
ABG Control Limits / Int’l Stds

19. Responsible Stewardship
Create a framework to move
us towards international
standards and mitigate our
impact on ‘Externalities’.
International
Standards Today
Operating voluntarily to international
standards requires a systematic approach
and higher levels of control and performance
i.e. a constricted operating space.
Legal Standards
Today
Following local laws,
gives business a
relatively large space
to operate in.
Best Practice
Today
Companies operating at
best practice levels are
normally driven by
visionary leaders.
More Demanding Legal
Standards by 2030
By 2030, to be on the road
to a sustainable planet,
businesses will have to
perform better than ever.
Legal
Standards
needed for a
Sustainable
World 2050
By 2050, only the
best managed
business, with
highest
performance will
be able to survive.
Legal Limits / Tolerance
ABG Control Limits / Int’l Stds

20. Stakeholder Engagement
Gain knowledge to understand
how fast 'External Factors' will
change and when disruptions
will occur.
Responsible Stewardship
Create a framework to move
us towards international
standards and mitigate our
impact on ‘Externalities’.
International
Standards Today
Operating voluntarily to international
standards requires a systematic approach
and higher levels of control and performance
i.e. a constricted operating space.
Legal Standards
Today
Following local laws,
gives business a
relatively large space
to operate in.
Best Practice
Today
Companies operating at
best practice levels are
normally driven by
visionary leaders.
More Demanding Legal
Standards by 2030
By 2030, to be on the road
to a sustainable planet,
businesses will have to
perform better than ever.
Legal
Standards
needed for a
Sustainable
World 2050
By 2050, only the
best managed
business, with
highest
performance will
be able to survive.

21. Future-Proofing Including Our
Supply Chain
Modify our strategic business plan to
include additional mitigation and
adaption to changes in ‘External Factors’.
Stakeholder Engagement
Gain knowledge to understand
how fast 'External Factors' will
change and when disruptions
will occur.
Responsible Stewardship
Create a framework to move
us towards international
standards and mitigate our
impact on ‘Externalities’.
International
Standards Today
Operating voluntarily to international
standards requires a systematic approach
and higher levels of control and performance
i.e. a constricted operating space.
Legal Standards
Today
Following local laws,
gives business a
relatively large space
to operate in.
Best Practice
Today
Companies operating at
best practice levels are
normally driven by
visionary leaders.
More Demanding Legal
Standards by 2030
By 2030, to be on the road
to a sustainable planet,
businesses will have to
perform better than ever.
Legal
Standards
needed for a
Sustainable
World 2050
By 2050, only the
best managed
business, with
highest
performance will
be able to survive.

22. 2 The Three Steps to Building Sustainable Business
Responsible Stewardship
Stakeholder Engagement
Future Proofing
by
Creating & Sharing
Value

23. 3 Responsible Stewardship
Energy and
Carbon
Health
Security
Transport
Safety Human Rights
MANAGING CURRENT OPERATIONS TO INTERNATIONAL STANDARDS
Resource
Conservation
Air
Contaminated
Site
Noise
Waste
Water
Biodiversity Supply Chain
Product
Stewardship
Contractor
Sustainable
Infrastructure

24. 4 Stakeholder Engagement
Stakeholder
UNDERSTANDING THE SUSTAINABILITY TRENDS AND PLANETARY
LIMITS
Business
Stakeholders
Strategic
Experts
• Banks and
Shareholders
• Employees
• Community
• Suppliers and
Contractors
• NGOs
• Authorities
• Industry
Associations
• SMEs for Energy,
Climate Change,
Water, Human
Rights, etc.
• Think Tanks
• Legal authorities

25. 5 Future Proofing
Future Proofing our Businesses
IMPLEMENTING SUSTAINABILITY ISSUES INTO FUTURE BUSINESS
STRATEGY
Acquisition, Divestment and
Joint Venture
Crisis Management
Projects Development and
Life Cycle management
Decommissioning, Demolition
and Decontamination

26. ABG Sustainable Business Framework Documents6
Policy
Position
Statements
Management
Standards
Technical
Standards
Guidance Notes
Group’s
overall
intent
Group’s
position on a
global issue
Mandatory
requirements
applicable to
all areas of
the
framework
Mandatory
requirements
applicable to
one policy
Guidance to
implement the
requirements
of the
Standards

27. Human Rights within the ABG Sustainable Business
Framework

28. 28
Human Rights within the ABG Sustainable Business
Framework
Integrated Structure for
Sustainable Business
Indigenous
Peoples
Management
Good Faith
Negotiation and
Consent Process
Cultural
Heritage
Management
Human
Rights
Human Rights
Management Plan
Land
Acquisition
Stakeholder
Engagement
Stakeholder
Engagement Plan
External
Grievance
Management
Implementing
the Resettlement
Action Plan and
Livelihood
Restoration Plan
H
u
m
a
n
R
i
g
h
t
s
P
o
li
c
y

29. 29 Process Flow for Human Rights Management
Yes
No
Risk and Impact
Assessment
(Section 4.2.1;
Annexure B)
Establish Terms
of Reference
(Section 4.2.2)
Undertake
Assessment
Put in place
appropriate
remedy
(Section
4.5)
Management
Plan
(Section
4.3;
Annexure C)
Monitor the
management
plan
(Section 9.1)
Prepare
Management
Plan
Update
management
plan based
on the
monitoring
results
Put in place
appropriate
remedy
(Section 4.5)
Yes
No
Put in place
appropriate
remedy
(Section 4.5)
Existing
Operations
Screening
(Section 4.1;
Annexure A)
New Project
Merger or
Acquisition
Expansion or
other change
Do potential
risks exist?
No risks identified
Put in place
appropriate remedy
(Section 4.5)
Notify CEO
(Section 4.4)
Risks deemed
unavoidable
Risks identified
and are likely
Risks identified but not
likely to occur
Risks and
impacts
identified?
Is additional
management
required?

30. 30 Outcome of Human Rights Screening Exercise
SCREENING
OUTCOME: No risk identified
If the screening process indicates that there are no human rights risks, the
site shall ensure that an effective grievance mechanism (i.e. remedy) is in
place for rights holders (i.e. community members potentially impacted by
the site’s activities and the site’s employees and contractors).
OUTCOME: Risks identified, but risks not considered likely
If the screening process identifies that potential human rights risks exist,
but are not considered likely to occur, appropriate management shall be
identified to mitigate the risks and the site will need to ensure that an
effective grievance mechanism is in place for rights holders. The
management measures shall be captured in the screening tool and reflected
in a HRMP.
OUTCOME: Risks identified and are considered likely to
occur
If the screening process identified potential human rights risks that are
likely to occur, further due diligence shall be required in the form of a HRIA.
However, the scope and scale of the HRIA shall be dependent on the
potential risks. It may be that the HRIA focuses on a specific risk or topic
(e.g. relating to suppliers or business relationships) or may look at a range
of risks
OUTCOME: Risks deemed unavoidable
If the screening process identifies potential human rights risk is
unavoidable, the Company CEO shall be notified. It will then be the
responsibility of the CEO along with the appropriate functions to determine
how to proceed.

31. 31 Chance Find Procedure and Cultural Heritage Management
Operating
Sites
Greenfield
Projects/
Expansion
Merger &
Acquisition
Change in
Protection
Status or Law
regarding CH
Sites
Self-Assessment
(Annex-A)
Screening (Annex-
B)
Preparation of ToR for
CHIA (Annex C)
Preserve the
filled Annex-A
CHIA Process
(Section 4.3)
Selection of Qualified
Third Party
Third Party conducts
CHIA as per TS (Section
4.3.3 and Annex-D)
CHMP Preparation
(Annex-E)
CHMP
Implementation/
Monitoring Process
ExternalStakeholder
Engagement
(Section6.0)
IfCHimpactsNot
ScreenedNeitherCHImpact
NorExcavationis
Anticipated
No CH Impact
But Excavation
Anticipated
NoCHImpact
ButExcavation
Anticipated
Preserve the filled
Annex-B
NoCHImpact
NeitherExcavation
Required
IfAntiquitiesfound
duringExcavation
If CH impacts identified
Chance Find Procedure
(Section 4.2)

32. 32 Indigenous Peoples Issues at Operating Sites
Supplementary
Management Plan for
Gaps Identified
No
No
Yes
Yes
Continuing
Implementation
End-Term Evaluation
Screening of Impact on
IPs (Annex B)
Are there
significant
Impacts on IPs?
Annex B is preserved
as Documentation
IPP/IPDP Implementation
Continuing or Completed in
in Recent Past (5 Years)
IP- Due Diligence
Closure of Management
Plans
Implementation
Completed

33. 33 Indigenous Peoples Issues at New Projects
Are there Potential
Impacts on IPs?
Are Natural Resources/Critical
Heritage sites of IPs affected?
Yes
No
Preparation of Management Plans
IP-IA with Informed Consultation and
Participation (ICP)
Prepare a FPIC Plan for ESIA
AnnexCispreservedas
Documentation
IP-IA with FPIC
Review ESIA/ IPDP
Mid-Term Evaluation
End-Term Evaluation
Closure of Management Plans
Screening of Impact on
IPs (Annex C)
No
Yes & ESIA
not done
Is Impact
Assessment of IPs
in ESIA
systematic and
comprehensive
and Action Plans
Adequate?
Yes
No

34. 34 Land Acquisition Impacts
• Relocation or loss of shelter – IFC PS 5
• Physical displacement of people, loss of
shelter, or other non-resource assets –
World Bank
Physical Displacement
• Loss of assets or access to assets that leads
to loss of income sources or means of
livelihood – IFC PS5
Economic Displacement

35. 35 Land Acquisition Mitigation
• Payment in cash or in kind for an asset or a resource that is
acquired or affected by a project at the time the asset needs
to be replaced – IFC handbook for preparation of
resettlement action plan
• Compensation money or payment in kind to which the
people affected are entitled in order to replace the lost
asset, resource or income – ADB handbook on resettlement
Compensation
• Resettlement packages and assistance such as
transportation, food, shelter and social services provided to
affected people during relocation. Assistance may include
cash allowances that compensate for the inconvenience
associated with resettlement and cover transition expenses
such as moving expenses and lost workdays - IFC
• Rebuilding of housing assets including productive land and
public infrastructure in another location - ADB
Resettlement
• Measure taken for income restoration or economic recovery
so that the affected population can improve or at least
restore its previous standard of living - ADB
Livelihood Restoration

36. 36 Special Considerations for Land Acquisition
Legality of land
ownership
Vulnerable groups Gender
considerations
Cultural property
Indigenous
peoples
Distress selling
Government land Forced evictions

37. 37 Preference of Approach for Undertaking Land Acquisition
Privately
owned land
1. Willing buyer
willing seller
arrangements
2. Negotiated
settlements
3. Government
led land
acquisition
Government
owned land
with no claims
1. Land transfer
by government
Government
owned land
with claims
1. Negotiated
settlement
2. Government
led land
acquisition

38. 38 ABG Process for Land Purchase
Identification of Land Owners (Section 4.2.4.1)
Establish of Market Value of Assets (Section 4.2.4.1)
Establish Replacement Cost (Section 4.2.4.1)
Disclosure of Information to Land Owners about the Land Purchase and its
Purpose (Section 4.2.4.1)
Purchase of Land based on Informed Consent(Section 4.2.4.1)
Provision for Additional Support for Special Considerations (Section 4.2.4.1)
Documentation (Section 4.2.4.2)

39. 39 ABG Process for Land Acquisition
Land Acquisition -Involuntary
(Section 4.2.5)
Government led Land Acquisition
Government led- Regulatory Land
Acquisition Process
Gap Assessment (Section 4.2.7.1)
Engagement with Government
(Section 4.2.7.2)
Formulation of Action to address
identified gaps (Section 4.2.7.3)
Disclosure of Action Plan to Affected
Population (Section 4.27.4)
Implementation of Action Plan
(Section 4.2.6)
ABG led Land Acquisition (including
negotiated settlements)
Identification of Affected Population
Establishment of Socio-Economic Baseline
(Section 4.2.5.1)
Establishment of Impacts and Losses from
Land Acquisition (Section 4.2.5.2)
Identification of Entitlements and Formulation
of Management Plans (Section 4.2.5.3)
Disclosure of Entitlement Framework to
Affected Population (Section 4.2.5.6
Agreement and Consent from Affected
Population (Section 4.2.5.7)
Implementation of Management
Plans (Section 4.2.6)

40. 40 Stakeholder Engagement
Review of
existing
stakeholder
engagement
process
(Section 4.3)
Appoint
Internal
Task Force
(Section 4.1)
Train &
Orientate
Task Force
Members
(Section 4.2)
Identificatio
n of
Stakeholder
s and Issues
(Section 4.4)
Analysis and
Prioritizatio
n of
Stakeholder
s and Issues
(Section 4.5)
Developme
nt of
Stakeholder
Engagement
Plan
(Section 4.6)

41. 41 Grievance Management
Yes
No
No
No
Yes
Yes
Grievance
Source*
(Section
4.2.1)
Central
Grievance
Management
Channel
(Section 4.1
& 4.2)
Send acknowledgement after receiving a
grievance (Section 4.2.1)
Communicate timeline for grievance
resolution (Section 4.2.3)
Forwarded to
Concerned
Department
Define Timeline and
mode of engagement
(Section 4.2.2 &
4.2.3)
Option to resubmit or use an alternate
mode of resolution (Section 4.2.4)Grievance closed
Internal
Escalation
(Section
4.2, Annex
E)
Communicate
timeline,
Action Plan
and Monitor
the status of
Grievance
(Section
4.2.4 &
4.2.5)
Receive Grievance (Section
4.2.1)
Record
Grievances
in the
Grievance
Log
Grievance closed
with formal sign
off
Alternate mode of
resolution
(Section 4.2.4)
Grievance closed
through alternate
mode
Categorize
(Section 4.2.2
& Annex E)
Within
Scope
(Section
4.2.2)
Grievance
closed?
Action Plan
(Section
4.2.4)
Process Alternate mode of resolution and interaction with ‘Source’ Decisions Dotted Arrows- Parallel Process

42. 42
Establishing Sustainability Expectations in the
Supply Chain
Environment
1. Material toxicity and chemicals
2. Raw material use
3. Recyclability and end of life of
products
4. Greenhouse gas emissions
5. Energy use
6. Water use and wastewater
treatment
7. Air pollution
8. Biodiversity
Anti-corruption
1. Conflict of interest
2. Gifts, meals and entertainment
3. Bribery and kickbacks
4. Accounting and business
records
5. Protecting information
6. Reporting misconduct
Human Rights and Labour
1. Forced labour
2. Child labour
3. Working hours
4. Wages and benefits
5. Humane treatment
6. Nondiscrimination
7. Freedom of association and
collective bargaining
8. Occupational safety
9. Emergency preparedness
10. Occupational injury and illness
11. Fire safety
12. Industrial hygiene
13. Physically demanding work
14. Machine safeguarding
SUPPLIER CODE OF CONDUCT / CONTRACT AGREEMENT

43. 43
Establishing Human Rights Expectations in Security
Management
1. Behaviour during riots/ bandhs or any unrest
2. Tresspassing
3. Use of force
4. Rules of engagement
HUMAN RIGHTS POLICY AND CONTRACTUAL AGREEMENT
SECURITY POLICY

44. 44 Assessing Conformance to the Framework
• Answers on an IT platform
• Allows to upload evidence and validate the answers
• Scores are generated
• Action plans to be prepared for non-conformance
Self Assessment
Questionnaire
•< 60% - Unacceptable, SMEs to help the site/
business
•> 60% to < 80% - Satisfactory, remote validation of
questionnaire
•> 80% to < 95% - Good, Group or Business
assurance team to do on-site verification
•> 95% - Excellent, More detailed on site verification
Scoring
• Dash boards presented in Business Review meetings
Senior management
review

45. THANK YOU
45