How to meet expectations?

Standards help clarify human rights expectations for businesses. They can serve as a basis for harmonization within and across industries. However, many standards lack operational guidance, and their voluntary nature creates risks for inconsistent implementation and greenwashing.

Foundational normative standards

Three key international frameworks set out baseline expectations for how companies should respect human rights: the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the ILO Core Labour Conventions. For a more in-depth discussion, see section 1.

While the UNGPs explain what companies are expected to do, they provide limited detail on how to do it. The OECD Due Diligence Guidance for Responsible Business Conduct, especially its sector-specific versions, provides more operational detail. Still, many companies—particularly smaller ones—find it complex to understand, let alone apply. To bridge this gap, a growing body of practical guidance has emerged that can help businesses implement due diligence (see Section 6).

Voluntary Sustainability Standards (VSS)

Voluntary Sustainability Standards translate broad expectations into specific principles and criteria that companies can follow. Over time, many of these standards have integrated explicit human rights (due diligence) requirements. While not legally binding, VSS are widely used by companies to showcase their own commitments to human rights, and to communicate expectations to business partners.

Standards set out what is expected from companies—but businesses also need tools to identify where risks exist, and to verify if the expectations they are setting internally and towards business partners are being met in practice.

Social audits

Social audits remain the most common method for assessing human rights compliance in global value chains. They usually involve on-site inspections of workplaces, focusing on issues like working conditions, health and safety, and working hours. Audits are often used to check compliance with supplier codes of conduct or with VSS. However, as discussed in Section XX, audits face growing criticism. They can miss serious and systemic problems—such as discrimination, harassment, or freedom of association violations—that are harder to detect through short, checklist-based inspections.

Worker-driven monitoring

In response to the shortcomings of conventional audits, a number of initiatives have developed under the banner of worker-driven monitoring or worker-driven social responsibility (WSR). These initiatives put workers—or their legitimate representatives—at the center of the monitoring process. While still relatively few in number, they provide valuable lessons for the future of due diligence: effective verification cannot rely solely on standardized, top-down procedures, but must also empower rights-holders and ensure independent oversight.

Benchmarks

Benchmarks assess and compare companies' human rights performance based on publicly available information. They typically operate at the company level, creating reputational incentives for businesses to improve. They are also used by investors, civil society, regulators, and public buyers to identify leaders and laggards.

Digital solutions

An ever-widening range of digital solutions promise fast, data-driven insights into human rights risks. These tools use technologies like mobile worker surveys, geospatial analysis, AI-driven risk scoring, and data mining. In some cases, they can complement traditional audits. In others, they claim to remove the need for auditing.

Two factors help distinguish between different types of digital solutions:

• Value chain scope: ranging from full value chain to direct business partners.
• Type of data: ranging from exclusive reliance on external, third-party data (outside-in) to an exclusive reliance on information collected directly from companies and workers (inside-out).

Based on these factors, we can identify four main types (see figure XX):

• Type I: Macro-level risk screening (outside-in, full value chain). Can help companies identify and prioritise high-risk products or geographies by analysing global datasets, indices, and media sources; but do not provide supplier-specific insights.
• Type II: Supplier screening (outside-in, direct business partners). Provides ratings or alerts on specific business partners. Often used to avoid reputational or legal risks.
• Type III: Transparency and traceability solutions (inside-out, full value chain). Focus on mapping supply chains across multiple tiers, sometimes using technologies like satellite data or blockchain.
• Type IV: Supplier monitoring (inside-out, direct business partners). Often integrated into procurement systems, and typically rely on self-assessments by suppliers. Sometimes paired with corrective action tracking or grievance reporting.

While digital solutions can certainly help companies to identify and track risks, and to organize data management at scale, they cannot replace the contextual understanding that comes from human judgement, nor replace the engagement and information rights of rights-holders and their representative structures. Without human interpretation, data can mislead—particularly because datasets are partial, uneven in quality, and prone to bias. Moreover, every solution has shortcomings, so effective use would still require cross-checking multiple data sources, validating with those affected, and ensuring findings are interpreted in light of local realities.

Industry initiatives and multi-stakeholder initiatives are collaborative platforms where companies, civil society, and sometimes governments work together to address human rights risks. While participation is largely voluntary, many of these initiatives influence entire sectors through the development of shared frameworks, and by building leverage and capacity to implement them.

Key differences between initiatives include:

• Scope: Some focus narrowly on specific human rights risks (e.g. child labour, health and safety), while others address a broader set of rights. Initiatives may be sector-specific or cross-sectoral.
• Governance: Industry initiatives are typically led and funded by companies. Multi-stakeholder initiatives have more balanced governance, involving NGOs, trade unions, and sometimes governments.
• Standards: Some initiatives are built around formal standards or codes of conduct, while others focus more on guidance and joint action without requiring adherence to a formal standard.
• Activities: Can range from training and capacity building, to problem-solving, advocacy, benchmarking, or maintaining grievance mechanisms.
• Verification: Some rely on self-assessments, while others use independent third-party verification.
• Stakeholder engagement: most initiatives rely on some form of external stakeholder engagement. Yet the depth of this engagement may vary from active involvement in decision-making to limited advisory roles.

Social dialogue is an established, formal and institutionalized process that is rooted in the relationship between employers and employees. It refers to discussions, negotiations, and information exchanges between employers and workers (often represented through trade unions). It can take place at different levels —workplace, sectoral, national, or international— and is recognized by the ILO as a key means of promoting decent work.

Social dialogue and due diligence can act as mutually reinforcing processes essential for responsible business conduct. Both due diligence and social dialogue are process-oriented, preventive, and based on continuous consultation. Effective due diligence requires meaningful consultation with affected groups across the value chain, with a key role for workers' organizations, as emphasized in the ILO MNE Declaration (Paragraph 10 (e)). Social dialogue can enable companies to gather crucial insights on human rights risks and solutions, making due diligence more robust and participatory. In turn, due diligence has the potential to strengthen social dialogue by encouraging companies to assess whether rights like freedom of association and collective bargaining are upheld, and by supporting ongoing stakeholder engagement.

Bipartite social dialogue and HRDD

Several European trade unions are establishing links between existing social dialogue structures and future due diligence obligations at company level. The Dutch trade union CNV International developed a measurement tool, the Fair Work Monitor, to obtain insights in the working conditions in global value chains. They then try to establish a dialogue with the suppliers on the findings of these studies, also engaging the international buyers in this sector. In a number of cases this has resulted in action plans that are developed with the companies to improve the situation on the ground, covering themes such as occupational safety and health, social dialogue and collective bargaining. German trade unions are using the German Supply Chain Act to promote social dialogue in low-income countries.

Global Framework Agreements (GFA)

A Global Framework Agreement is a specific form of cross-border social dialogue. It is negotiated directly between a multinational company and one or more global union federations. It commits the company to respecting core labour rights (cf the ILO standards) across all of its operations and, in many cases, across its supply chain.

Unlike MSIs, GFAs create a direct and formal relationship between the company management and workers' representatives. They draw on trade unions' legal mandate to represent workers, are often linked to grievance and dispute-resolution mechanisms, and typically include joint monitoring mechanisms such as workplace visits or review committees.

While GFAs can strengthen labour rights protection, their effectiveness depends on trade union capacity, company commitments, and local enforcement capacity. Coverage is often limited to a subset of the workforce, and implementation may be weaker in contexts with restrictive labour laws or limited worker organization.