Pluto advisory
CORPORATE RESPONSIBILITY · PUBLIC POLICY
For decisions that aren't straightforward.
We work where business, human rights, geopolitics and public policy meet — helping organisations navigate difficult decisions and shape the frameworks that govern them.
From policy to practice — and from analysis to decision.
WHAT WE DO
Where principles meet real decisions
The hardest business and human rights questions rarely have straightforward answers. We combine policy expertise, practical experience and independent judgement to help organisations understand what matters and make decisions they can defend.
What should a company do when there is credible evidence of severe harm but incomplete information?
How should an investor act when leverage is limited?
What does responsible business conduct require in conflict?
When should an organisation stay, engage, escalate or leave?
And how should policymakers respond when markets, technologies and geopolitical realities evolve faster than the frameworks meant to govern them?
These are the questions Pluto works on.
where we come in
Advise.
Assess.
Shape.
Think.
ADVISE
Navigate hard decisions
We advise boards, executives, investors, governments and international organisations where human rights, commercial, legal, political and operational considerations intersect: severe impacts, complex business relationships, limited leverage, political uncertainty, crises and contested operating environments. This includes readiness for mandatory due diligence requirements — the CSDDD as amended, the German Supply Chain Act, the EU Forced Labour Regulation — and what they demand of operations in high-risk contexts.
Our role is not to explain what standards say. It is to help determine what they mean for the decision at hand.
Strategic business and human rights advisory · Conflict and fragile contexts · Responsible investment
ASSESS
Understand impacts, risks and relationships
We conduct human rights due diligence, impact assessments and targeted reviews across operations, projects, value chains, investments and business relationships. We identify impacts on people, examine how organisations may cause, contribute to or be directly linked to them, and assess severity, context, leverage and available responses. In conflict-affected environments this means heightened due diligence, conflict analysis, scenario analysis, escalation frameworks, and what exposure under international humanitarian and international criminal law means for governance, decisions and risk — working alongside legal counsel where legal advice is required.
An assessment that changes nothing is a document. Ours are built to end in a decision.
Human rights due diligence and impact · Heightened due diligence · Stakeholder engagement and remedy
SHAPE
Develop policy that works in practice
We work with governments, international organisations, businesses and investors to develop policies, standards, guidance and governance approaches for responsible business conduct. Because our experience spans both development and implementation, we can test emerging approaches against institutional reality and identify where apparently straightforward rules produce difficult consequences on the ground.
A requirement nobody can meet produces compliance, not change.
Public policy and standard setting · Guidance development · Independent review and evaluation
THINK
Work on the questions that come next
We research, convene and contribute new thinking on emerging issues at the intersection of business, human rights, conflict, investment, technology and public policy.
Some of the most important questions do not yet have established answers. Those are the ones worth working on now.
Research · Convening · Emerging issues
HOW WE WORK
Principled. Pragmatic. Independent.
Grounded in international standards, focused on the decisions they are meant to inform.
01
Severity first
We focus attention where it matters most: on impacts that are severe, potentially irreversible or insufficiently understood.
From analysis to decision
02
Analysis is useful only if it improves decisions. We translate findings into choices, escalation thresholds, governance triggers and practical courses of action.
Policy and practice
03
We know how standards are developed and what happens when organisations have to implement them. We bring business realities into policy discussions and policy developments into organisational decision-making.
Diverse perspectives
04
Good decisions require more than one institutional viewpoint. We bring the experience and concerns of affected people, civil society, business, investors, governments and international institutions into our analysis.
Built for scrutiny
05
Our advice is designed to withstand regulatory, legal, investor, stakeholder and public scrutiny — without allowing compliance or reputation to substitute for addressing impacts on people.
WHO WE WORK WITH
Pluto works across institutional boundaries because many of today's most difficult business and human rights problems cannot be understood from a single perspective.
Companies — Senior leadership working on both systems and individual decisions, particularly where impacts may be severe, information incomplete and the available options imperfect.
Investors and lenders — Human rights impacts across portfolios and transactions, and how responsibility, leverage, engagement, escalation and investment decisions should respond.
Governments and International organisations — Policy development, guidance, research, implementation and the evolution of international approaches to responsible business conduct.
Civil society — Research, accountability, policy development and engagement with business and public institutions.
Different institutions. Same hard questions.
SELECTED WORK
Some of the questions we have been asked to work on, described in general terms. Most of our work stays between us and our clients.
ADVISORY · SUPPLY CHAIN
THE QUESTION
How a global industrial company should approach human rights when a new supply chain spans jurisdictions with very different regulatory, political and human rights risks.
WHAT WE DID
Translated international standards and incoming European requirements into the policies, governance and decision processes of a new strategic supply chain, examining where responsibility travelled beyond direct suppliers and what different relationships required.
WHAT WE DELIVERED
A responsible sourcing architecture connecting policy commitments to supplier requirements, due diligence, escalation and decision-making.
ADVISORY · ALLEGATION RESPONSE
THE QUESTION
A published investigation alleged serious harm connected to a company's operations. The company's own systems had not identified it. What had actually happened, and what should follow?
WHAT WE DID
An independent review of the allegation, the operations concerned and the systems that failed to surface them, engaging directly with affected people and with the organisations that raised the matter.
WHAT WE DELIVERED
Findings the company could act on and defend, and the changes required to the systems that had missed it.
ADVISORY · RESPONSIBLE DISENGAGEMENT
THE QUESTION
A company had decided to leave a market where conditions had deteriorated. What would responsible departure require, and what obligations would survive it?
WHAT WE DID
Assessed impacts caused or contributed to, what would transfer with the assets, who would succeed the company and on what terms, and whether leverage had genuinely been exhausted or merely become inconvenient.
WHAT WE DELIVERED
A disengagement plan with obligations that continued after departure, and a record of how the decision was reached.
PUBLIC POLICY · GLOBAL
THE QUESTION
What companies and investors should be required to do differently in conflict-affected contexts, and how to express it so it could be implemented.
WHAT WE DID
Led development of guidance for the UN Development Programme and the UN Working Group on Business and Human Rights, tested against operating realities with companies, investors and civil society.
WHAT WE DELIVERED
The reference text now used by companies, investors, states and development finance institutions.
ADVISORY · MANDATORY DUE DILIGENCE · NON-EU
THE QUESTION
Whether a company headquartered outside the Europe could meet incoming EU due diligence requirements, and what would have to change on the ground if not.
WHAT WE DID
Assessed the company's existing control systems against the requirement as it would apply in practice, identified where obligations would land.
WHAT WE DELIVERED
A detailed analysis of where the systems would hold, where they would not, and what had to change before the requirement bit.
INVESTMENT · CONFLICT-AFFECTED CONTEXTS
THE QUESTION
An investor holds positions in companies operating in conflict-affected contexts. ESG screening returns nothing unusual. What is it missing, and what should change if it were seen?
WHAT WE DID
Translated heightened human rights due diligence into the investment process: how an investor is connected to impacts it did not cause, what leverage exists across a diversified holding, and how deteriorating conditions should change a position that was defensible when it was taken.
WHAT WE DELIVERED
When heightened due diligence is required, what to ask of a holding, and how the answers should change engagement, escalation and the decision to remain invested.
ABOUT us
Pluto Advisory is a strategic advisory firm operating at the intersection of geopolitics, public policy and corporate responsibility. Our work is defined by a clear principle: from policy to practice and from analysis to decision.
Independent advice for difficult decisions
Experience behind the frameworks
Pluto Advisory works where commercial realities, public policy and societal expectations intersect.
The question we are most often asked is not what the standards require. It is what they require here, given what is known, what is not, and what can realistically be changed.
Companies come to us when a decision has to be defensible: entering a market where the risk is severe, staying as conditions deteriorate, responding to an allegation, or leaving without leaving harm behind.
Governments and international organisations come to us at different moments. Before an instrument is finalised, when a draft requirement needs testing against operational reality, or when the text itself needs writing. During implementation, when a framework is not producing the change it was designed for. And afterwards, when what it produced needs assessing honestly. We have drafted guidance, standards and policy instruments as well as advised on them, including for the United Nations.
Some organisations reach us before a decision is taken, when the options are still open. Others reach us once something has already happened: an allegation, an investigation, a lender's question, a context that has deteriorated faster than the analysis behind it. We are used to being brought in late, and to working while the facts are still changing.
Because we work on both sides of the same standards, we can say which readings will hold when they are tested, and which requirements will fail in the field however well they are drafted. That is difficult to get from a firm that only advises companies, or
Pluto Advisory is led by Gerald Pachoud, who has helped design some of the initiatives and frameworks that have shaped responsible business over the past two decades.
As Special Adviser to Professor John Ruggie under the UN Secretary-General's Special Representative mandate on business and human rights, Gerald contributed to the development of the UN Guiding Principles on Business and Human Rights, and to the international process that led to their endorsement in 2011. More recently, he was lead author of the UNDP and UN Working Group guidance on heightened human rights due diligence in conflict-affected contexts, translating the UNGPs into practical guidance for companies and investors .
Before that, Gerald started and led the programme on business and human security at the Swiss Federal Department of Foreign Affairs, where he worked on initiatives that anticipated some of the major developments in responsible business. He was among those who conceived and launched the IFC/UN Global Compact initiative behind Who Cares Wins, the 2004 report that brought leading financial institutions together around environmental, social and governance considerations in investment analysis, laying the foundations for the mainstreaming of ESG. He also conceived and launched the Swiss initiative on private security that led to the International Code of Conduct for Private Security Service Providers.
Following the Ruggie mandate, Gerald served as Principal Officer in the Executive Office of the UN Secretary-General, working on strategy, partnerships and private-sector engagement, including in fragile and conflict-affected contexts. He founded Pluto in 2015.
In parallel to his work at Pluto, Gerald is Professor of Practice at SOAS School of Law, University of London, and Special Adviser to the Geneva Peacebuilding Platform. He sits on the human rights advisory board of BASF, and has previously served on the board of the Pharmaceutical Supply Chain Initiative, the SRI Advisory Board of Candriam and the Governing Board of the ACCESS Facility.
Independent by design, we bring together a small team of senior practitioners required, tailored to each mandate , working across sectors, disciplines and geographies without the constraints of a large consulting structure.
IN MEMORIAM
John G. Ruggie, 1944–2021
Pluto exists because of him. Gerald joined him in 2005, at the opening of the mandate that produced the UN Guiding Principles on Business and Human Rights, and worked alongside him through to their adoption.
What we took from that period was not a framework but a way of working: start from the harm, prioritise by severity, and insist that analysis end in a decision someone has to take.
INSIGHTS
Some of our public writing and contributions
On business and human rights, responsible investment, conflict and public policy.
ISSUE PAPER · FEB 2026
Why businesses ignore international criminal law — and why they shouldn't.
Why international criminal law belongs inside corporate governance and human rights due diligence in conflict-affected and high-risk contexts.
Gerald Pachoud · Global Business Initiative on Human Rights
01 · JUN 2022
02 · OCT 2024
Analysis of systems to combat child labour in Côte d'Ivoire in the context of European Union regulations
03 · MAR 2026
04 · MAR 2022
The Future of Business and Human Rights