How to implement human rights due diligence in your company

Implementing human rights due diligence (HRDD) requires more than a policy commitment. It involves building a practical system that identifies risks to people, takes action to address them, and improves over time. 

For many companies, the challenge is not understanding the concept — but translating it into day-to-day decisions across procurement, sourcing, and supplier relationships. 

This guide sets out a step-by-step approach to implementing HRDD in line with the UN Guiding Principles on Business and Human Rights (UNGPs), with a focus on practical application. 

If you are new to HRDD, start here: 
What is Human Rights Due Diligence?

A practical framework for implementation 

HRDD is best understood as a continuous cycle of five core steps: 

1. Embed responsible business conduct
2. Identify and assess risks
3. Prevent and mitigate impacts
4. Track effectiveness
5. Communicate and enable remedy 

These steps are not linear. In practice, they overlap and evolve as risks change. 

Many organisations find it helpful to start small — piloting HRDD in a specific supply chain or risk area — before scaling across the business. 

Step 1: embed responsible business conduct 

Effective implementation starts with governance and internal alignment. 

This includes: 

• Adopting a clear human rights policy aligned with international standards
• Assigning senior accountability and board oversight
• Defining roles across procurement, legal, compliance, and sustainability teams
• Integrating expectations into supplier codes and contracts 

In practice, the most common gap is not policy — it is alignment. 

Where procurement targets, pricing decisions, or timelines conflict with human rights commitments, due diligence systems quickly become ineffective. 

Tip: Focus early on aligning internal incentives and decision-making processes, not just external commitments. 

Step 2: identify and assess human rights risks 

Risk assessment is the foundation of HRDD. 

Companies should: 

• Map their operations and supply chains
• Identify salient risks — those posing the greatest risk of severe harm
• Analyse country, sector, and product-level risks
• Engage workers and stakeholders to understand real conditions 

Prioritisation is critical. Attempting to assess everything at once can slow progress and dilute focus. 

Organisations that build in worker and stakeholder insight at this stage tend to identify more accurate and actionable risks. 

For more detailed guidance, see: 
HRDD risk assessment for supply chains

Step 3: prevent and mitigate adverse impacts 

Once risks are identified, companies need to take action. 

This often includes: 

• Reviewing purchasing practices that may contribute to labour risks
• Strengthening supplier expectations and management systems
• Supporting supplier capacity-building
• Collaborating with peers and stakeholders 

In many cases, the root causes of risk are commercial — such as pricing, lead times, or last-minute order changes. 

Addressing these issues is often more effective than increasing audit activity. 

In practice: companies that move beyond audit-driven approaches and invest in supplier relationships tend to see more sustainable improvements. 

For more on this, see: 
Supplier engagement and HRDD 

Embedding HRDD in procurement and sourcing 

Procurement decisions have a direct impact on working conditions. 

To align procurement with HRDD: 

• Include human rights criteria in supplier selection
• Set realistic lead times and pricing structures
• Avoid last-minute changes that create pressure on suppliers
• Build longer-term relationships with key suppliers
• Align buyer incentives with responsible sourcing goals 

This is often where HRDD succeeds or fails in practice. 

If procurement is not aligned, due diligence remains theoretical. 

Step 4: track effectiveness 

Monitoring ensures that actions lead to real improvements. 

Companies should: 

• Define indicators linked to priority risks
• Combine audit data with worker feedback and grievance data
• Conduct regular internal reviews
• Adjust strategies based on findings 

Traditional audits can provide useful information, but they rarely capture the full picture. 

Stronger approaches combine multiple data sources — particularly worker voice — to understand whether conditions are actually improving. 

Step 5: communicate and enable remedy 

Transparency and accountability are essential. 

Companies should: 

• Report on risks, actions, and progress
• Be open about challenges
• Provide accessible grievance mechanisms
• Ensure remediation processes are effective 

Where harm occurs, the response matters. 

Effective remediation builds trust and strengthens systems over time. 

Where companies often get stuck 

In practice, many organisations face similar challenges: 

• Treating HRDD as a reporting exercise rather than a management system
• Over-reliance on audits without addressing root causes
• Misalignment between procurement practices and human rights commitments
• Limited engagement with workers
• Fragmented internal ownership 

Recognising these early can help avoid investing in systems that look strong on paper but deliver limited impact. 

Getting started: practical next steps 

If your organisation is at an early stage, a practical approach is to: 

1. Review existing policies and governance structures
2. Map your supply chain and identify priority risks
3. Pilot HRDD in a specific country, product, or supplier group
4. Build internal awareness across teams
5. Develop a roadmap for scaling implementation 

A phased, risk-based approach is often more effective than trying to implement everything at once. 

Support and practical guidance 

Many companies benefit from external frameworks, peer learning, and structured guidance when implementing HRDD. 

Approaches that tend to be most effective include: 

• Combining internal systems with external expertise
• Engaging with stakeholders, including workers and their representatives
• Learning from sector-specific experience
• Collaborating with other companies facing similar challenges 

ETI’s work with companies, trade unions, and civil society organisations highlights the value of collaborative approaches in strengthening due diligence systems and addressing systemic risks. 

Continue building your HRDD approach 

To go further: 
Human rights due diligence: a complete guide for business
HRDD risk assessment for supply chains
Supplier engagement and HRDD 

These resources provide deeper guidance on specific elements of implementation. 

Moving from commitment to practice 

Implementing human rights due diligence is about moving from policy commitments to practical action. 

Companies that build structured, risk-based systems — and align them with day-to-day decision-making — are better equipped to manage risk, meet regulatory expectations, and improve outcomes for workers. 

The most effective approaches combine: 

• Clear governance
• Practical tools
• Ongoing engagement with suppliers and stakeholders 

This is where due diligence moves from theory into impact.