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Blog | Tuesday September 9, 2025

Partnering with Suppliers to Advance Human Rights Due Diligence

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As regulatory frameworks and stakeholder expectations on business and human rights continue to evolve, companies are increasingly expected not only to assess and manage their own impacts, but also to work collaboratively with suppliers to do the same.  

Evolving Expectations for Supplier Engagement 

While the UN Guiding Principles on Business and Human Rights (UNGPs) do not set out explicit expectations for companies to support or partner with their suppliers on due diligence, they set out broader responsibilities. Principles 13 and 19, for example, emphasize that companies should seek to prevent or mitigate adverse impacts they are linked to through business relationships, and to take appropriate action based on their relation to the impact. 

Traditionally, the core attributes of supply chain management have included the following:  

Strategy and governance, including clear supply chain commitments and defined roles and responsibilities; standards and policies (validated through engagement of cross-functional leaders); audits and enforcement (protocols informed by resources, risk, and influence); goals and enablers (in the form of financial and non-financial incentives); and capacity-building for buyers, suppliers, and other stakeholders. 

However, this approach is evolving as companies are increasingly moving beyond one-size-fits-all compliance mechanisms towards partnership-based supply chain management. Rather than a top-down imposition of expectations, best practice emphasizes dialogue between buyers and suppliers, leveraging suppliers’ supply chain expertise for a more strategic approach to managing human rights issues. A good example of this comes from the palm oil sector, where buyers and suppliers have worked closely together to address the devastating effects of deforestation and human rights impacts like child and forced labor through collaboration, joint initiatives, and mutual ambition-setting, rather than expectations being dictated from the bottom of the supply chain up. 

Tools for Supplier Engagement 

Buyers can actively support their suppliers in enhancing their human rights management practices through targeted collaboration and tailored support initiatives. This may require focusing on strategic suppliers first to develop partnership models, but like due diligence, this approach should extend across the supply chain. 

There is a vast ecosystem of resources available to help companies and suppliers collaborate on human rights due diligence. Key engagement tools include: 

• Policy and Commitment Support: Providing frameworks and best practices to help suppliers establish strong internal policies and public commitments to human rights. 
• Due Diligence Tools: Supplier self-assessment questionnaires (SAQs) and other due diligence tools to enable systematic identification, monitoring, and management of human rights risks. 
• Joint Initiatives: Collaborating on Human Rights Impact Assessments (HRIAs) to combine expertise, pinpoint potential impacts, and develop joint action plans to address identified risks. 
• Training and Capacity Building: Offering educational resources and training sessions that empower supplier teams to manage and improve human rights practices. 
• Worker Engagement Mechanisms: Facilitating effective worker feedback through tools such as anonymous reporting systems and regular communication channels. 

These tools are most effective when introduced through collaboration rather than imposition. Before initiating programs, companies should talk to their suppliers to understand what tools they are already using and consider which initiatives might work best based on the suppliers’ respective profiles. Understanding this context fosters trust and enables more effective implementation. 

Case Study 1: Designing and Scaling a Supplier Engagement Program for a Global Apparel Brand 

In 2024, BSR partnered with a leading global apparel brand and six strategic suppliers to create and roll out a worker engagement program aimed at tackling systemic labor rights issues in the supply chain—specifically around fair recruitment, wages, and working hours. 

The program was designed to foster joint action between the brand and those suppliers, with a focus on addressing the root causes of the issues. Eventually, factories would be empowered to establish and maintain robust management systems, ensuring ongoing respect, protection, and advancement of human and labor rights within their facilities. 

BSR partnered with the brand, the strategic suppliers, and a global technology platform to develop two worker engagement modules and tailor them with input from the suppliers and their employees. These were jointly administered between the parties, and the remediation and mitigation of identified root causes will be jointly run by the brand and suppliers. 

Key actions included: 

• Conducting factory-level management system assessments on fair recruitment, working hours, and wages 
• Providing practical resources aligned with identified improvement areas to elevate supplier practices 
• Tracking and evaluating progressive improvements along a maturity curve 
• Integrating worker perspectives to gauge the effectiveness of management actions, highlight remaining gaps, and guide ongoing remediation 
• Providing suppliers with a maturity assessment and access to a range of tools to help them remedy any issues, following completion of the modules. 

The assessments and worker surveys strengthened suppliers’ knowledge and capacity on priority issues and helped them gain insight into root causes through direct worker feedback. The result was a replicable framework for scaling supplier engagement across geographies, and a partnership model between buyers and suppliers to tackle identified root cause issues. 

Case Study 2: A Collaborative Approach via Action for Sustainable Derivatives (ASD) 

The Action for Sustainable Derivatives (ASD) initiative offers another compelling example of a partnership model in practice. In 2024, ASD launched its human rights strategy, identifying high-risk issues in palm supply chains, including land rights violations, forced labor, and gender-based violence, based on a previously conducted collective Human Rights Impact Assessment (HRIA). Building on the findings of the HRIA, ASD translated the findings into targeted collective activities, prioritizing the most salient impacts where members have influence and leverage. 

Key elements of ASD’s approach include: 

• Collaboration between buyers and suppliers 
• Deployment of an operational grievance mechanism (OGM), funded collaboratively  
• Prioritization of a few key issues based on a collective HRIA, followed by collective and collaborative action to address these 

This model illustrates how cross-company collaboration, underpinned by a shared vision for responsible sourcing, can achieve greater transparency and impact than unilateral efforts. 

Advancing Partnership-Based Due Diligence 

As companies work to operationalize human rights due diligence, it is essential to move from a compliance mindset to a partnership mindset. 

However, challenges remain: many suppliers are resource-constrained, wary of external monitoring, or skeptical of buyer intentions. Yet through dialogue, co-design, and mutual accountability, companies can foster trust and long-term impact. 

At BSR, we partner with companies in developing innovative, context-specific strategies for supplier engagement. Please reach out to our team to find out more about how we can support you in advancing your supply chain management. 

Blog | Wednesday September 3, 2025

What’s Next? Building on a Corporate-Level Human Rights Assessment

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Completing a corporate-level human rights assessment (HRA) is a significant milestone. It provides clarity on a company’s salient human rights risks across its entire value chain, helps to address stakeholder expectations, and grounds a company’s policy commitments in credible evidence. While the scope and depth of a corporate-level HRA vary depending on objectives, its value is consistent: it simplifies a complex landscape into a clear roadmap for action. It also offers a defensible rationale for prioritizing where to focus deeper due diligence, aligning with the growing expectations of investors, regulators, civil society, and human rights benchmarks. 

However, an HRA is not the finish line. It is the beginning of a process to transform insights into an ongoing due diligence cycle that delivers meaningful outcomes for people and measurable results for the business. Leading companies distinguish themselves not by completing a single assessment, but by building on it—focusing on the most severe risks, designing operating models that scale, measuring progress against defined indicators, and using grievance and remedy mechanisms as engines for continuous learning. 

This approach is increasingly codified in global standards and regulation. The UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises emphasize that due diligence must be continuous. Emerging regulations, including what was formerly referred to as the EU Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD) formalize this expectation, requiring companies to identify and assess impacts, take action, track effectiveness, and report results on an ongoing basis. 

From a Corporate-Level HRA to Action: Six Key Workstreams 

There is no single formula for what comes after a corporate-level HRA. However, based on BSR’s experience supporting companies to design and deliver robust assessments as part of broader human rights due diligence, six priority workstreams consistently emerge. These workstreams show how companies can move from a one-time assessment to a fully embedded, ongoing due diligence process—one that not only manages risk but also delivers sustained impact for people and the business. 

1. Deep-Dive Human Rights Impact Assessments (HRIA) Where it Matters Most: A corporate-level HRA helps identify where risks are most severe in the value chain, guiding targeted deep dives—by site (a country or facility), issue (e.g., forced labor, freedom of association), product/customer (high-leverage relationships), or moment in time (market entry, acquisition, supply shocks). HRIAs are carried out from the perspective of rightsholders, providing real-time insights that strengthen mitigation strategies and support effective remediation planning in line with the expectations set by the UNGPs, OECD Guidelines, and various regulatory requirements. 
2. Strategy Development: Corporate-level HRAs establish a company’s overall risk and impact profile, highlighting salient issues and management gaps. Acting on these findings requires developing a clear strategy for managing and integrating human rights into business operations, supported by short-, medium-, and long-term goals. A well-defined strategy aligns priorities, ensures sustained action to mitigate and remediate impacts, embeds changes into the business model, and builds the capacity needed to address human rights challenges effectively. 
3. Monitoring and Reporting: Following a corporate-level HRA, define goals and KPIs that align with both stakeholder and regulatory expectations. Stakeholder pressure on reporting after assessments and due diligence is growing, from regulators, investors, and beyond. Companies should therefore prepare for increased disclosure of human rights assessment outcomes, more issue-specific reports for well-defined audiences on the most severe impacts, and where appropriate, full publication of HRIAs. Those that move beyond one-off assessments to adopt a transparent, continuous due diligence approach will be best placed to meet growing reporting expectations from stakeholders and regulators alike. 
4. Integration: The findings from a corporate-level HRA should not remain on the shelf—they need to be embedded into the company’s daily operations. This means updating relevant policies, procedures, and practices, and developing targeted mitigation and remedy action plans. Beyond this, socializing these concepts and changes with relevant teams and focusing on integrating human rights considerations into day-to-day activities is a critical step for successful, long-term change. Integration turns the HRA from a one-off exercise into a living process, improving visibility over human rights risks, strengthening management, and enabling progress tracking. 
5. Training: To maximize impact, employees need the skills and knowledge to understand salient human rights impacts, identify potential issues in their daily work, and adapt to updated processes. Targeted, role-specific training raises awareness, builds capability, and ensures timely and effective responses when risks arise. 
6. Corporate-Level HRA Refresh: Plan a refresh every 4-5 years, or sooner, when there are material changes to the business that can impact the company’s footprint and risk profile.  

A corporate-level HRA is the starting point of a journey, not its end. The months after completing the assessment are critical for building momentum—continuing to engage team members that were interviewed or consulted as part of the HRA process, embedding findings into operations, establishing clear strategies, training teams, and more. This is how companies shift from a snapshot in time to a continuous, credible human rights due diligence process. 

The steps outlined above—deep-diving HRIAs, strategy development, monitoring and reporting, integration, training, and periodic refresh—are proven ways to transform insight into action. Taken together, they help companies strengthen risk management, meet rising stakeholder and regulatory expectations, and most importantly, deliver positive outcomes for people affected by business activities. 

BSR supports companies at every stage of this process. From conducting the initial corporate-level HRA to building the governance structures, tools, and capabilities needed for ongoing due diligence, BSR brings sector expertise, a global perspective, and a practical focus on solutions that teams can implement and sustain. 

For companies ready to move beyond assessment into sustained action, now is the time to set the tone, align leadership, and embed human rights due diligence into everyday business. BSR can help make that transition clear, strategic, and impactful.  

If you are considering launching a corporate-level HRA or deciding what should come next, we encourage you to reach out to BSR’s Human Rights team.

Blog | Tuesday August 26, 2025

Mining and the Just Transition: Putting People at the Center of the Energy Transition

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The mining industry plays a dual role in climate change: while the industry contributes 4 to 7 percent of global greenhouse gas (GHG) emissions, it is also an essential enabler of the clean energy transition, supplying the minerals needed for renewable energy technologies and low-carbon infrastructure. These transition minerals will play a pivotal role in supporting the global transition to a low-carbon economy because renewable energy technologies (e.g., solar panels, wind turbines, batteries, etc.), rely on copper, lithium, nickel, cobalt, and rare earth elements. While the recycling of transition minerals should be prioritized wherever possible, it will be insufficient to meet skyrocketing demand in the short to medium term given limited supply of recyclable materials, making the development of new and expanded mines necessary. However, any new or expanded mines must be developed only under the strictest ecological safeguards and with full respect for human rights, to avoid repeating the environmental destruction, social conflict, and rights violations that have too often accompanied mining in the past. 

Among governments, civil society, Indigenous leaders, multilateral institutions like the ILO, as well as industry coalitions such as the ICMM, there is a growing consensus that the mining industry must undergo a just transition to address its dual role as both a driver of climate harm and an enabler of climate solutions. At its core, a just transition in the mining industry means that the benefits and burdens of the global energy shift are shared fairly, and that mining companies proactively uphold human rights and justice as they adapt to a decarbonizing economy and expand operations to meet growing demand. A just transition requires mining operations to become far cleaner and safer than in the past, treating environmental protection and respect for human rights as non-negotiable priorities. 

For mining companies, action on just transition falls into three areas: in their own operations, in their supply chains, and in the communities in which they operate. Their just transition actions should be built upon an unwavering goal of reaching net zero by 2050 and commitment to respecting human rights. Meeting these goals would involve conducting ongoing environmental and human rights due diligence, upholding the highest standards, and considering, mitigating, and remedying the impacts to people in their decarbonization efforts and beyond.  

BSR recommends that responsible mining companies focus on: 

• Climate Action with a Human Lens: Integrate social impacts into climate mitigation and adaptation efforts to ensure people, not just emissions and impacts to infastructure, are considered in transition plans and climate action. Mitigate harms to people, and where harms do occur, provide remedy. Consider those actions caused and contributed to by the company, as well as those linked to the company through business relationships. 
• Environmental Responsibility: Minimize impacts on nature and the environment, and safeguard against worker and community harm through responsible land, water, waste, and pollution management. Limit impacts to biodiversity, land disturbance, water use, waste, and pollution. 
• Respect for Workers and Just Labor Practices: Uphold labor and human rights, including fair wages, safe working conditions, freedom of association, and collective bargaining. Manage mine closures, automation, and changes to the workforce and production through transparent social dialogue (e.g., negotiation and consultation between workers, employers, and sometimes governments), reskilling, compensation, and worker-inclusive transition planning to ensure no one is left behind from decarbonization efforts. 
• Responsible Supply Chains: Apply environmental, human rights, and just transition standards across procurement of equipment, materials, and services. Use due diligence to ensure suppliers meet ethical and sustainability expectations, and set clear expectations for just labor practices around decarbonization and expectations on respecting human rights to suppliers. 
• Stakeholder Engagement and Social Dialogue: Foster inclusive, transparent, and continuous engagement with key stakeholders that will be impacted by the transition, especially workers (through social dialogue) and communities (including Indigenous people), to inform decision-making and build mutual trust. Establish formal mechanisms for dialogue, engagement, grievances, and participation to ensure voices are heard and incorporated throughout the transition process. 
• Community Rights, Consent, and Inclusion: With over 50 percent of known reserves of transition minerals like copper, lithium, and others located on or near Indigenous and agrarian community lands, respect for Free, Prior, and Informed Consent (FPIC) is critical. Recognize and integrate Indigenous Peoples Principles and Protocols for Just Transition into company approaches. 
• Benefit-Sharing and Local Development: Ensure communities share in the value created through royalties, equity, local hiring, and infrastructure investment. Go beyond impact mitigation to build long-term regional resilience, trust, and partnership. Rely on co-creation to ensure that mining is carried out with the community, not just in the community.  

The mining sector bears a responsibility to implement a just transition that addresses its distinctive challenges. Mining companies can become champions of a just transition by transforming the way they do business: cutting emissions, innovating cleaner processes, upholding labor and human rights, and sharing benefits with local communities. Through honest engagement, benefit-sharing, rights protection, and long-term investment in regional well-being, mining companies can provide a foundation built on social trust and consent, allowing for the energy transition to be just, equitable, and inclusive.  

Interested in learning more about just transition or taking action across your mining operations, supply chains, and communities? Connect with BSR’s Energy and Extractives team to learn how we can support. 

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Blog | Thursday August 14, 2025

Developing Integrated Approaches to Human Rights, Climate, and Nature

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In July 2025, the International Court of Justice affirmed that all nations have a binding duty to protect the climate, recognizing a clean, healthy, and sustainable environment as a fundamental human right. It warned that inaction or harmful conduct—such as fossil fuel production and subsidies—may require reparations, including through ecosystem restoration and financial compensation. These obligations remedy both human welfare and biodiversity harms, underscoring the inseparable link between environmental protection and human rights.

This decision, alongside ambitious regulations like the Corporate Sustainability Due Diligence Directive (CSDDD) and Corporate Sustainability Reporting Directive (CSRD) and rising litigation on climate- and nature-related human rights impacts, reflects growing recognition of the need to address the triple planetary crisis of climate change, pollution, and biodiversity loss while upholding human rights.

For business, this is an opportunity to integrate environmental and social strategies, as impacts on climate, deforestation, land degradation, and pollution are often tied to human rights harms—and vice versa. And while business efforts to mitigate climate change are urgently needed, climate action that ignores people can lead to job dislocation and community displacement.

Many companies, however, struggle with effective human rights and environmental due diligence (HREDD) due to fragmented regulations, siloed internal systems, and limited guidance, slowing progress toward integrated, impactful action.

Key Challenges

Siloed Operational Frameworks

The OECD Guidelines for Multinational Enterprises’ risk-based due diligence approach sets consistent expectations for businesses seeking to address their impacts on climate, nature, and human rights. However, this approach is inconsistently reflected across operational frameworks in these fields. These operational frameworks are intended to guide impact identification, assessment, and action on internationally recognized human rights standards and global environmental goals and targets (e.g., UN Guiding Principles on Business and Human Rights, Science-Based Targets initiative, Science-Based Targets for Nature), hindering integrated HREDD. Differences in terminology, methodologies, and stakeholder expectations of each persist, making it harder for teams within companies to coordinate. Some frameworks prioritize outward impact management, others financial materiality, and a few integrate both, complicating alignment.

Different Data Sets, Varying Methodologies

One challenge for companies in delivering effective HREDD lies in the data. Environmental assessments typically rely on quantitative metrics, e.g., carbon emissions, energy use, or water consumption. Human rights assessments are largely qualitative, requiring stakeholder input, contextual nuance, and narrative disclosure. The ease of quantifying environmental data and performance can lead companies to prioritize environmental over social initiatives.

Integrating qualitative and quantitative data is essential for a complete risk picture. Scientific indicators provide critical metrics, but combining them with local knowledge and cultural context can uncover issues that numbers alone miss. This approach strengthens decision-making when data are incomplete and helps identify cumulative impacts where different risks intersect and amplify each other. For institutional investors (or universal owners, such as pension funds and sovereign wealth funds), this is critical, as systemic risks from the interaction between climate change, biodiversity loss, and inequality pose a far greater threat to portfolios than the performance of any single company.

Some sectors, like oil, gas, and mining, have incorporated social considerations into Environmental Impact Assessments (EIAs), producing Environmental and Social Impact Assessments (ESIAs). However, the primary purpose of such assessments is not to assess a company’s broader impacts against internationally agreed environmental conventions. Rather, ESIAs are project-specific tools designed to identify, predict, evaluate, and mitigate potential environmental and social impacts before a project proceeds and in compliance with domestic laws and permitting requirements, which may differ from international standards.

Limited Guidance on Interaction and Synergies between EU-Wide Sustainability Laws

The EU’s sustainability laws were developed by different Commission bodies on separate timelines, with limited guidance on how requirements are meant to work together. This raises practical questions, including:

• How should high-level due diligence under CSDDD support compliance with more prescriptive regulation, e.g., EU Deforestation Regulation (EUDR), EU Batteries Regulation?
• Can EUDR risk assessments be leveraged to support compliance with other requirements, e.g., EU Forced Labour Regulation?
• How can integrated HREDD, including in the context of climate transition plans under CSDDD, inform CSRD reporting on intersecting environmental and social impacts?

These and other factors can contribute to siloed compliance approaches, where legal teams may lead on CSDDD; environment, health, and safety departments on environmental impacts; and finance teams on non-financial reporting of HREDD under CSRD. While dedicated teams, systems, and resources can be valuable for managing business impacts on people and the environment, working in silos can create fragmented cultures, poor information sharing, and duplicative processes that fail to build on existing, well-established approaches. This can undermine a coherent strategic direction and weaken leadership buy-in.

The Path Forward: Building Bridges Across Fields and Business Functions

An integrated approach to climate, nature, and human rights is essential to long-term business value. While geopolitical tensions may slow regulatory momentum, expectations are rising for companies to holistically address their impact on people and the planet.

Some companies are already moving in this direction. For example, Unilever’s People and Nature Policy connects deforestation, regenerative agriculture, and human rights, including land rights and the protection of human rights defenders. A food and beverage company is tackling emissions, waste and pollution, and human rights by adopting a circular economy model developed with local governments to support and protect informal waste workers. 

How BSR Can Help

To support companies, BSR is undertaking initiatives that provide clarity on coherently implementing standards:

• Multi-stakeholder engagement to bring key organizations together, including standard setters, to develop a shared understanding of what good looks like when integrating human rights and environmental impacts into one due diligence process
• Building a platform on people-centered climate action in private capital markets to support private equity and venture capital investors on advancing a just transition
• Supporting members on integrated human rights and environmental due diligence in line with OECD Guidelines
• Creating collaborative spaces for companies to advance in this area, including through the Human Rights Working Group, Climate and Nature Working Group, and Impactful Sustainability Due Diligence Roundtable Series
• Developing insights, including on how to take an integrated approach to climate and human rights under CSDDD and across regulatory compliance efforts

Interested in implementing effective HREDD in your company? Reach out to BSR’s Human Rights team.