“Start somewhere”…“It is important to keep on improving” – Interviewees
HRDD in supply chains is a new and developing area, and companies are at different stages in terms of the maturity of their programmes. None of the interviewees indicated that they have accomplished everything they would still like to do.
An analysis of those organisations which are perceived as having the most advanced HRDD processes reveals that not all started in the same place. Some companies with established programmes, for example, began by first addressing specific risk areas such as occupational health and safety, before adapting those processes to other human rights issues. By contrast, an organisation which is just beginning its journey may be best advised to follow a strategy which reflects the methodology in the UNGPs, beginning with an assessment of actual or potential human rights impacts in the supply chain. In all cases, it is important to have a coherent strategy which informs a credible, defensible methodology implemented by individuals with appropriate expertise and resources.
In light of our research, the following recommendations are made.
- HRDD has to be a robust, substantive and ongoing process. It should take into account all human rights which the company may possibly impact, and not just those covered by limited regulatory reporting requirements, or human rights risks which are frequently associated with a specific sector.
- Companies should use a unified and cross-functional internal approach. For example, a company which spends extensive resources on addressing human rights impacts through HRDD in one business area should ensure these efforts are not contradicted by its buying practices in another (where the occurrence of human rights issues may be less well understood).
- Comprehensive HRDD requires governance commitments at the most senior level of the company, including board and CEO engagement. These commitments ought to be underpinned by coherent governance structures which ensure decisions that engage human rights issues are taken by personnel and committees with appropriate authority, experience and appreciation of the issues and associated risks
- Internal translation of the importance of HRDD is more likely to be successful if supply chain HRDD is understood as a key component of the company’s commercial goals which include ensuring a quality, stable and sustainable supply chain.
- All companies engaged in the movement of materials and products should ensure that their supply chain HRDD includes transportation and distribution suppliers. This appears to be an area which has received limited attention from companies to date, whereas the potential for human rights issues associated with the shipping sector (for example) has been well documented by NGOs.
- Those charged with designing and carrying out auditing processes to test adherence to existing human rights standards and policies by suppliers should have appropriate human rights-related experience, working with external experts as appropriate.
- Companies should proactively involve local stakeholders, including rights-holders and local civil society organisations, in information-gathering and decision-making processes.
- Companies should partake in industry and other multi-stakeholder initiatives in the form of collective action, including those which facilitate the vetting and training of suppliers, in part to assist suppliers in managing the resource demands of participating in customer HRDD exercises.
- The use of technology should be explored for the purposes of traceability, identification of human rights impacts, stakeholder engagements, grievance mechanisms and certification. Technology used for HRDD should be developed in consultation with human rights experts to be effective and to ensure that the technology does not inadvertently infringe human rights.
- Companies should explore ways of ensuring effective HRDD beyond the first tier, including through industry collective action, partnerships with local civil society organisations and human rights experts, operational-level grievance mechanisms for those affected by supply chains, and by encouraging open and honest dialogue with first tier suppliers to increase supply chain transparency.
- Companies should participate in consultative processes for regulatory reforms, in order to add to the process’ legitimacy and to ensure that enacted laws are realistic and effective. This could be done individually or through industry bodies or other representatives.
Recognising that supply chain HRDD is a new and developing area, those companies with less-advanced processes, particularly SMEs, should not to be daunted (e.g. when engaging with “leading” companies). It is important to “start somewhere”. As one interviewee commented: “Let’s just start asking the questions. These are the kind of questions that we started asking in health and safety years ago.”