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Human Rights Policy

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We recognize that businesses have a responsibility to respect internationally recognized human rights. The human rights in question address social, workforce, economic, cultural, civil, and political concerns. Orion Resource Partners (USA) LP (Orion) is committed to respecting human rights in accordance with and striving to align to the UN Guiding Principles on Business and Human Rights and the UN Global Compact principles on Human Rights and Labour Standards[1], to the extent practicable[2]. Orion’s Human Rights Policy is part of our commitment to act responsibly by respecting and avoiding any infringement upon the human rights of others.


The scope of this Orion Human Rights Policy applies across the organization except for the investment process as is defined herein the “Orion Investments Funds” section and relevant procedures[3]. It sets out the company’s commitment to respect human rights and the expectations we set for our own people around the globe. It applies to all Orion employees, direct contractors, and activities.

Our Employees

Our people are at the heart of our business. We promote fair reward, diversity, inclusion, equal opportunities, freedom of association, and other human rights through our interactions with our employees and in our decisions on hiring, remuneration, training, and promotion. Diversity and inclusion are key to Orion being a responsible and successful business.

The Orion Resource Partners (USA) Employee Handbook (Employee Handbook) prohibits any form of discrimination based on actual or perceived race, creed, color, religion, alienage or national origin, ancestry, citizenship status, age, disability or handicap, sex, marital status, veteran status, sexual orientation, genetic information, arrest record, or any other characteristic protected by applicable federal, state, or local laws. We value the views of our employees and promote a collaborative, open and transparent communications environment which helps us maintain a healthy, inclusive, and strong workplace. We maintain an anonymous comment line for employees to use for concerns and complaints including harassment and discrimination. Our progress toward creating diversity is monitored and disclosed on an ongoing basis, including engaging with third party experts to review programs and provide recommendations.

Developing our people remains central to the work we do. We are committed to providing an environment which is safe and secure and supportive of our people’s health and wellbeing. Our health and safety programs are described in our Employee Handbook. We place importance on creating a culture that promotes high standards of ethical behavior as well as human rights. All our employees are expected to meet the highest standards of ethical behavior and to act in accordance with the Orion Compliance Manual and Code of Ethics (Code of Ethics), which they must attest to every year. We encourage a good work-life balance and offer flexible working arrangements where appropriate, and we support our employees’ rights to trade union membership and collective bargaining.

Orion Investors

We seek to respect the rights of our investors and to treat them fairly, acting with integrity and considering what impact any decisions we take will have on them. We consider the interests of all our customers. Our investors’ needs are the basis on which we design our products and services. Our communications strive to be clear, fair, not misleading, and clearly articulate any risks alongside the benefits. We are committed to providing products that are accessible and we listen to feedback from investors, including regarding any human rights considerations. We adapt our products, services, and processes accordingly. These commitments are contained in Orion’s Code of Ethics. We have a duty to protect our investors’ data and to be clear and transparent about the way this data is used. Orion’s Written Information Security Program (WISP) provides guidance and requirements for our cybersecurity and business continuity. The WISP outlines: i) the way in which we keep data safe and secure, ii) the way we carry out our fiduciary duty towards our investors, and iii) how we use it to improve our products and services.

Orion Investment Funds

We are committed to investing our money and our customers’ money in a responsible manner and working to avoid involvement in activities that may cause or contribute to human rights violations. This Policy is to be applied in conjunction with the Orion Responsible Investment Practice and Policy and Orion Mine Finance (OMF) and Orion Resource Royalties (ORR) Responsible Investment Procedure and a similar procedure for Orion Resource Equities (ORE) and Orion Industrial Ventures (OIV). Other funds where Orion has less influence or control, we rely on other approaches to consider human rights including exchange requirements and public reporting.

We maintain a deep conviction that environmental, social, and governance factors can have a material impact on investment returns and client outcomes. We believe that being a responsible financial actor means our investment approach must support, and not undermine, the long-term sustainability of capital markets, economies, and society. As such, Orion is committed to continuing to integrate human rights into investment analysis and decisions for OMF, ORR, ORE, and OIV.


Orion believes that controversial weapons including cluster munitions, anti-personnel mines and chemical and biological weapons pose risks to human rights, and as such excludes investments in any companies which derive prescribed levels of revenue from the manufacture of such weapons. Orion considers human rights risks as part of its due diligence and Environmental and Social Impact Assessment (ESIA) process requirements for OMF and ORR investments. For all new investments made under OMFIV and ORRII, Orion requests that the Assessment Documentation include assessment of human rights risks in line with the UN Guiding Principles on Business and Human Rights, as specified by the Equator Principles 4 (EP4)[4]. This includes differentiated assessment of vulnerable geographies and stakeholder groups and consultation with potentially affected groups where feasible and appropriate. Where salient human rights risks are identified, they will be addressed in the investment’s Equator Principles Action Plan (EPAP) or Environmental and Social Action Plan (ESAP).


Through active ownership, Orion engages with OMF IV and ORR II portfolio companies on human rights issues as part of evaluating a company’s management of its employees, supply chains, customers, broader community impacts, and reputational risk. Where it possesses the influence and contractual leverage to do so, Orion collects monitoring data on various social factors (including situations of social unrest or human rights concerns) from portfolio companies. Orion focuses its more targeted portfolio company engagement on the highest risk companies and where there have been allegations of serious violations. Such engagements also range depending on Orion’s level of influence and contractual authority. Where serious human rights concerns have been identified, Orion will exercise the extent of its leverage as an investor in a given situation to appropriately address and remedy said concerns. We recognize that some human rights issues are market failures and therefore need addressing through government and regulatory action. We support policy action to tackle these challenges, such as through disclosures and human rights due diligence.


Orion has a set of policies, business standards, and internal procedures that support the delivery of our commitment to human rights and the prevention of modern slavery in our operations and supply chains. We integrate human rights considerations into our existing policies and processes. Our global risk management function monitors compliance with our business standards. We recognize that senior-level participation is paramount. As such, Orion’s ESG Committee and a cross-functional team of specialists are involved in our corporate human rights due diligence and compliance processes.

Our human rights work, including our efforts to tackle modern slavery in our operations and supply chain are sponsored by our Management Committee, Chief Risk Officer, General Counsel, Chief Compliance Officer, and ESG Committee. We are committed to adequately and transparently reporting our performance with respect to human rights in accordance with suitable benchmarks and frameworks for financial services. We are committed to investigating and addressing concerns relating to human rights which are raised. We remain committed to continuously assessing and improving our business processes, training, communication, and management systems and to continue integrating human rights considerations into our existing risk management processes across all our activities.

We recognize the importance of promoting an effective remedy when violations of human rights occur and continuing to monitor and assess both our operations and supply chain, building awareness internally, and working with our suppliers regarding respect for human rights. We encourage employees and suppliers to report any human rights concerns, including via our speak-up helpline and are determined to continue our work towards effectively identifying and addressing any concerns.

This policy is approved by Orion leadership and reviewed annually by the ESG Committee. Compliance is managed by the Chief Risk Officer. Date last revised: September 2023.

  1. See “The Ten Principles | UN Global Compact”https://www.unglobalcompact.org/what-is-gc/mission/principles.
  2. Orion manages certain types of investments and funds which we have no influence over actions, such as commodities. Thus, we have more effective influence over mine finance, royalty, equities, and industrial ventures investment.
  3. This policy only applies to Orion’s direct activities. The specific responsible investment procedures specify how individual funds evaluate human rights for pre-investment diligence and post-investment monitoring. This is done to recognize the different level of control over the assets by fund.
  4. For earlier funds, Orion required alignment to IFC Performance Standards for project in non-Designated Countries.