EXECUTIVE SUMMARY
Combine worker engagement, management interviews, observation and document checks to understand human-rights risks and their causes. Test differences between written procedures and daily practice, and record uncertainties alongside findings. Agree who will act, what evidence will demonstrate progress and how affected people will be involved in follow-up. A site visit alone does not establish that a due diligence programme is effective.
For an on-site HRDD assessment, examine how work is carried out as well as the policies and procedures that govern it.
What on-site assessment adds
Desk reviews show what policies, procedures and records say. Fieldwork tests how they work in practice. It combines four sources of evidence:
Direct worker and contractor engagement that reveals lived experience behind KPIs
Management interviews that show how policies translate into practice
Process and documentation testing that identifies control gaps and weak evidence trails
Observation of day-to-day operations where risks often concentrate
On-site assessment can support the UNGP responsibility to respect human rights by helping identify and address adverse impacts. Its adequacy depends on the quality of stakeholder engagement, risk assessment and follow-up. An on-site visit alone does not establish conformity with the UNGPs.
Three areas to examine on site
1) Worker voice is essential
Talking directly with workers shows how working conditions, supervision and access to help operate in practice. It can confirm good practice, such as clear safety routines and respectful treatment, and identify problems, such as excessive overtime, informal subcontracting and poor complaint systems. Including worker views in Human Rights Risk and Impact Assessments (HRRIAs) helps ensure that priorities and responses reflect the experience of those most affected.
Going further, invite workers to help design solutions as well as identify problems. Their input can show whether a proposed action is workable on site and whether it addresses the cause. Record how their views shaped the action plan.
2) Managers decide how policy is applied
Policies and procedures take effect through the managers who apply them. When managers understand the purpose and the process, they can spot risks early and agree workable responses. Their objectives, performance reviews and bonus criteria should support these responsibilities. The UN Guiding Principles ask companies to strive for coherence between their responsibility to respect human rights and the policies that set financial and other performance incentives for personnel.
Choose measures that reward the quality of the response. For example, site managers might be assessed on closing priority actions with evidence, the quality and timeliness of remedy, and workers’ confidence in the reporting channels. A target to reduce the number of grievances can discourage reporting. A grievance mechanism works only if the people it serves trust it and can use it. Without management support and clear accountability, HRDD stays within the sustainability team. When accountability is part of management objectives, due diligence can inform how resources are used, suppliers are chosen, projects are planned and performance is managed.
3) Everyday practices are where risks manifest
Human rights risks often sit in routine moments:
How shifts are assigned and changed
How productivity pressure is managed
How PPE is distributed and enforced
How supervisors handle complaints and conflicts
How recruitment and onboarding are managed in contractor chains
These everyday actions determine whether people are treated with dignity and kept safe, or whether harm becomes routine. An on-site assessment examines these practices directly and helps identify their causes.
The business case for HRDD
Respecting human rights requires resources for prevention, monitoring and remedy. Assess these costs against the organisation’s specific exposure to disruption, legal claims and other adverse consequences, without assuming a fixed financial return from an HRDD programme.
Operational disruption (work stoppages, supplier failure, project delays)
Regulatory and legal exposure under applicable due diligence and labour laws
Reputational damage and loss of customer or community trust
Use evidence from HRDD to explain identified risks, actions and unresolved issues to investors, lenders and business partners. Evaluate any financing or commercial benefit against the terms of the specific transaction. Do not assume that an HRDD programme will secure lower-cost capital.
We recommend ending each assessment with a clear account of the issues identified, the evidence supporting them and the decisions required. Distinguish immediate protective action from changes that need wider management involvement. Agree how workers will receive feedback and how progress will be checked.
The companion article, A practical HRDD uplift: from findings to accountable action, develops the programme needed to carry that work forward.

