Context
Migrant agricultural workers in Southern Europe play an essential role in supplying the fresh produce relied upon by businesses and consumers across Europe. Yet many face heightened risks of exploitation, limited access to rights, and few safe avenues to raise concerns. Although companies and governments have responsibilities under the UN Guiding Principles (UNGPs) to respect human rights and provide remedy, significant gaps remain in how these duties are carried out in practice. Grievance mechanisms are one of several tools intended to support effective remediation and strengthen future prevention. However, ETI’s research shows that current grievance pathways—whether national helplines, retailer hotlines, or workplace channels—are often ineffective for most migrant workers. A combination of powerful barriers, including lack of knowledge about their labour rights, fear of reprisals and lack of language skills to access existing channels and communicate complaints effectively, prevent most workers from reporting problems and issues they face in the workplace
Aims & outcomes
In January 2023, ETI launched a two-year project to improve access to grievance mechanisms for vulnerable workers in selected agricultural supply chains of ETI members. This includes a two-pronged approach:
- Piloting a process to establish effective operational grievance mechanisms at grower level in Spain and Italy. This approach focuses on facilitating workplace dialogue between workers and employers.
- Establishing and supporting a network of civil society organisations in selected countries of origin and transit for migrant workers (Côte d'Ivoire, Tunisia and Morocco) to share and disseminate accurate information on labour rights and the risk of labour exploitation in agricultural supply chains in Southern Europe.
Membership, partners & funding
This work was funded by the UK Government through the third phase of the Modern Slavery Innovation Fund. The project formed a work group consisting of 20 retail and supplier members from ETI, Ethical Trade Norway and Sweden and Food Network for Ethical Trade (FNET) that provided oversight to the initiative and facilitated access to growers and suppliers in the countries of production.
ETI worked with Partner Africa to facilitate the creation of the network to prevent modern slavery in countries of origin and transit in West and North Africa. The project also worked with Oxfam Business Advisory Service (OBAS) as a technical partner to design the implementation model for the grievance mechanism pilot and worked with the Ethical Trade Forum (Asociación Foros de Comercio Ético) in Spain to pilot grower-level grievance mechanisms.
Key project outputs
- Developed and piloted a process to establish worker-centred grievance mechanisms through representative site-level Grievance Mechanism Task Forces at two grower sites in Spain, engaging over 100 workers and managers with training and multilingual tools to improve access and trust.
- Strengthened Italy’s existing grievance system Helpdesk Anti-Caporalato by integrating business engagement into its approach to reach workers.
- Launched Digniwork, the first cross-national civil society network connecting 18 organisations across Morocco, Tunisia, Côte d’Ivoire, Spain and Italy to support migrant workers along migration routes.
- Conducted research on access to grievance mechanisms among migrant workers in selected areas of Spain and Italy, based on 122 interviews and 8 focus groups, with actionable recommendations for businesses.
- Engaged stakeholders in Foggia, Italy, bringing together 35+ stakeholders, including growers, cooperatives, trade unions and NGOs to address heat-stress risks for agricultural workers and agree practical prevention measures such as improved hydration access and multilingual safety materials.
Key learnings
- Trust takes time – building relationships with growers, workers, and local partners is essential for sustainable change.
- Worker involvement is critical – grievance systems are most effective when co-designed and led by workers, including the most vulnerable groups. To engage the most vulnerable workers, including migrants, additional stakeholder engagement and trust building is key.
- Business buy-in drives success – engaging senior management early and aligning mechanisms with growers’ incentives (e.g. productivity, compliance, worker welfare) increases uptake. To facilitate buy-in, it is crucial that the language used is tailored to business needs.
- Soft outcomes matter – improvements in worker confidence, dialogue, and collaboration are as important as formal systems.
- Practicality is key – accessible, multilingual, and clearly communicated grievance tools help make rights tangible on the ground.
Anchoring initiatives in real supply chain journeys increases business relevance – while the Digniwork network made strong progress on cross-border coordination, closer alignment with a clearly defined migration corridor (e.g. Morocco–Spain) could have strengthened traction with business actors.
Key challenges
- Grower engagement – limited participation, particularly in Italy, due to audit fatigue and low trust in external initiatives influenced by sensitivity around exposure, increased external scrutiny, and uncertainty about measurable business outcomes.
- Time constraints – the project’s two-year timeframe, combined with delays in initial research and supply chain mapping, meant that full piloting and follow-up evaluation were compressed. While this limited the opportunity to observe long-term results, we focused efforts on capacity building, tool development, and securing post-project commitments to carry the work forward.
- Climate disruptions – extreme weather events, such as heatwaves and floods, delayed fieldwork and engagement activities.
Variable company participation – differing capacity and priorities among businesses led to uneven engagement in the work group.
Limited trade union involvement – often due to capacity constraints as trade union representatives are already operating at full workload, with minimal ability to reallocate or add resources for new initiatives on short notice. Their role in worker protection is critical. Future efforts should secure union engagement during the proposal stage, not after implementation begins.
Key recommendations
Strategic Level
- Reframe grievance mechanisms as tools for empowerment, dialogue, and continuous improvement — not just compliance.
- Embed grievance systems into company culture, securing senior management buy-in and integrating them into everyday operations.
- Support suppliers’ ownership by providing sustained guidance, resources, and access to practical tools such as the OBAS Grievance Mechanism Toolkit.
Worker-Centred Design
- Involve workers from the start through trade unions, joint taskforces, grievance committees, and worker-appointed grievance officers.
- Ensure diverse representation – including women, migrants, and temporary workers – via transparent and democratic selection.
- Build trust and safety by ensuring grievance systems are confidential, accessible, and clearly communicated in multiple languages.
Practical Implementation
- Conduct participatory gap analyses to assess and strengthen existing mechanisms.
- Offer multiple reporting channels (verbal, written, anonymous, digital) to suit different literacy and comfort levels.
- Deliver targeted training for workers and managers on rights, reporting processes, and protection from retaliation.
- Adopt gender-sensitive practices, such as appointing female grievance officers and creating private spaces for sensitive disclosures.
Monitoring, Learning & Adaptation
- Establish measurable KPIs to track grievance types, response times, and resolution rates.
- Review and adapt mechanisms regularly, incorporating worker feedback into continuous improvement.
- Share outcomes transparently to build credibility and reinforce worker confidence.
- Include workers in evaluations to ensure accountability and shared ownership of results.
Ecosystem & Stakeholder Engagement
- Engage local civil society and trade unions in both the design and implementation processes to strengthen credibility and trust.
- Work through trusted local partners who understand the legal and cultural context.
- Foster multi-stakeholder collaboration, using established platforms when available, to align approaches and share learning across sectors.
