EXECUTIVE SUMMARY
Start with the human-rights issues the organisation needs to address and the decisions preventing progress. Assign responsibilities across procurement, operations, HR, legal and risk. Prioritise impacts according to their severity, engage affected people and translate findings into funded actions. Track implementation alongside worker experience, access to remedy and recurrence. Extend assessment beyond direct suppliers where the risk assessment warrants it. The aim is a programme that explains what has changed, what remains unresolved and who has authority to respond.
From an assessment to a programme
An assessment may identify excessive working hours, recruitment fees, unsafe conditions or weaknesses in handling complaints. Each finding raises further questions. Who can change the practice? Does the proposed response address its cause? What resources are needed? How will affected people know whether their concerns have been addressed?
We suggest using these questions to define the uplift. A broad policy rewrite may be useful, but an organisation may first need to resolve a specific gap in purchasing decisions, contractor oversight or case handling.
The seven areas below provide a practical structure. They connect with the policy, assessment, action, tracking, communication and remediation processes described in the OECD due diligence guidance. The work should be proportionate to the organisation’s circumstances and the risks involved.
1. Give governance an operational purpose
A human-rights policy needs a clear route into decisions. Identify where the organisation approves suppliers, sets production schedules, recruits workers, appoints contractors and responds to complaints. For each decision, specify the responsible role, the evidence required and the circumstances that trigger escalation.
Procurement may need authority to challenge delivery terms. HR may need resources to investigate recruitment practices. Operations may need a process for stopping unsafe work. Legal and risk teams can help define the applicable obligations and decision boundaries.
We recommend recording these responsibilities in a short operating framework. Include who can approve corrective actions, commit resources and accept the closure of a finding. Senior oversight should address material unresolved issues and resource decisions, with day-to-day implementation assigned to management.
2. Prioritise impacts with reasons that can be examined
A human rights risk and impact assessment should explain how priorities were reached. Consider the people affected, the gravity and extent of the harm, and the difficulty of restoring their circumstances. Where action must be prioritised, the UNGPs emphasise the most severe impacts and those that could become irremediable through delay. UN Guiding Principles, Principle 24.
Record the evidence, uncertainties and reasoning behind each priority. Avoid ranking issues solely by their visibility, the ease of obtaining information or the convenience of a proposed fix. An overtime concern should not automatically outrank a safety issue, or vice versa.
Translate the assessment into decisions. Each priority needs an action, an accountable owner, resources, a follow-up date and a way to judge the result. Where evidence is incomplete, specify what must be established and whether protective action is needed while that work continues.
3. Make engagement part of the response
Worker interviews and stakeholder meetings should inform decisions throughout the programme. Consider who may be missing from the discussion, including temporary workers, agency workers, migrant workers and people employed through contractors.
Choose engagement methods that allow people to speak safely and understand what will happen to the information they provide. Explain confidentiality arrangements and their limits. Plan how concerns about retaliation will be handled.
We suggest involving affected people in developing and reviewing responses where appropriate. A revised shift arrangement, for example, should be assessed against workers’ circumstances as well as operational requirements.
Close the feedback loop. Explain what action has been agreed, what remains under investigation and how people can raise further concerns. Attendance and interview counts can describe activity; they do not establish that engagement has influenced the outcome.
4. Build capability around real decisions
Training is most useful when it prepares people for the situations they encounter. A procurement team may need to recognise when purchasing terms create pressure on working hours. Supervisors may need to respond to a complaint without exposing the worker to retaliation. Investigators may need support with evidence assessment and interviewing.
Define the decisions each role should be able to make, then design training and practical support around them. Use realistic cases, clear escalation routes and accessible guidance.
Evaluate capability through practice. Review the quality of investigations, action plans and follow-up records. Ask workers whether they know how to raise concerns and whether they trust the response. A lower number of complaints, by itself, does not demonstrate improvement. Examine access to channels, the nature of cases and evidence of recurrence before drawing conclusions.
5. Keep a usable record of action and outcomes
The programme should allow a reviewer to follow an issue from identification through to the response and its outcome. Keep the supporting evidence, assessment, decision, responsible roles, actions and follow-up together.
Distinguish an action being completed from its intended result being achieved. A supplier may have issued a revised policy or completed training while the underlying working practice remains unchanged. Closure should therefore depend on evidence appropriate to the issue, including affected people’s experience where relevant.
Assess legal, contractual and reporting requirements separately. Information gathered for due diligence may support disclosures, but the relevant scope and reporting rules still need to be checked.
We recommend a concise management view of overdue actions, recurring issues, unresolved concerns and decisions requiring escalation. Supporting detail should remain available without making the management record difficult to use.
6. Measure changes in people’s circumstances
Select measures that help answer whether the response is working. Depending on the issue, these might include repayment of recruitment fees, correction of wages, changes in working hours, access to protective equipment or the quality and timeliness of remedy.
Establish the starting position and the period being assessed. Combine records with worker feedback and other relevant evidence. Where turnover or absenteeism changes, examine other influences before attributing the result to one intervention.
Include unintended effects. A measure introduced to reduce overtime could affect earnings or shift pressure to another group of workers. Ask who benefits, who may face a new burden and whether the original concern has moved elsewhere.
Use the findings to revise the response. Measurement should support decisions about continuing, changing or escalating an intervention.
7. Follow risk through business relationships
Direct suppliers provide an important starting point, but the assessment should consider where impacts may arise through other business relationships. Recruitment intermediaries, subcontractors and lower-tier production can require closer examination.
Map the relationships relevant to the identified risk. Record what is known, where visibility is limited and which information is needed next. Avoid assuming that every lower-tier relationship carries the same risk or that a contractual assurance resolves the issue.
Consider the organisation’s involvement and available influence when deciding how to respond. This may involve changing its own practices, working with a business partner or coordinating with others. Responsibilities for remediation depend on the circumstances; the UNGPs distinguish causing or contributing to harm from direct linkage through a business relationship. UN Guiding Principles, Principles 13, 19 and 22.
Start with a defined uplift
We recommend selecting a manageable set of priority issues and agreeing the decisions, resources and evidence needed to address them. Establish a baseline, assign accountable owners and set review points that reflect the seriousness of the issues and the work involved.
At each review, ask what has changed for affected people, which evidence supports that conclusion and what remains unresolved. Escalate gaps in authority or resources rather than repeatedly extending actions without a decision.
Our human rights and supply chain due diligence work can support this process through risk assessment, worker engagement, supplier and contractor controls, corrective action and follow-up.