We benchmarked 45 of the largest banks globally against a set of 12 criteria, based on the requirements of the UN Guiding Principles. These criteria are grouped into four categories: policies, due diligence commitments, reporting and access to remedy. Our key findings are that:

• Most banks are less than half way towards full implementation of the Guiding Principles.
• Many laggards; no true leaders.
• Banks are making progress, but slowly.
• There are three alarming gaps in implementation by even the front runners.
• The link between good policies and good implementation appears to be weak.