Having a grievance mechanism is not the same as having one that works

It is a natural assumption that receiving few grievances is a good thing – evidence that things are running smoothly and that you have a happy workforce. But complaints are a normal part of working life, and very few grievances should prompt a different question: why aren’t people raising concerns?

Over the past few years, AIM-Progress, Ethical Trading Initiative (ETI) and Oxfam Business Advisory Service* have worked with companies, suppliers, trade unions, and workers on grievance mechanisms across different sectors and countries. These insights will be published on 4 November in our new joint paper, Designed with and for workers: Joint Lessons from AIM-Progress, Ethical Trading Initiative and Oxfam Business Advisory Service on worker-led grievance mechanisms. We will also be launching the publication during a live webinar on 4 November, and we invite all readers to join the discussion – register here. 

Spanning 9 projects, 14 engaged global brands, and hands-on advice for 29 suppliers across 21 countries (plus 202 suppliers upskilled through training), our work shows that this approach doesn't just need to happen – it actually works. Early outcomes reveal increased worker awareness, growing confidence, and a fundamental shift in management perspective, paving the way for more inclusive, trusted systems aligned with the UNGPs. As a worker representative at Company X noted:

“Participation before was difficult because there was no structure. Now there is a structure, and it is easier.”

The initiatives examined in the paper supported suppliers dealing directly with global brands to establish more effective grievance mechanisms that respect workers’ rights. Although most suppliers already had grievance channels – suggestion boxes, supervisors, HR open-door policies – these were rarely used due to low trust, fear of retaliation, limited clarity, and barriers faced by marginalised groups.  Across our collective experience, one lesson has been remarkably consistent: having a grievance mechanism is not the same as having one that works. 

Effective mechanisms are built with the people expected to use them, especially those who are most vulnerable or hardest to reach, and are continuously tested and improved based on their experience.

Why receiving no complaints isn't necessarily good news

The absence of complaints does not necessarily mean the absence of problems. It may tell us more about whether people know how to raise a concern, feel safe doing so, and trust that something will happen if they do.

A project working with migrant workers and growers in Spain and Italy illustrated the gap between paper policies and lived realities. Many workers were unaware of available channels or how to use them. Language, literacy, immigration status, dependence on employers, fear of repercussions, and trust all affected whether they felt able to speak up. A grievance mechanism that works may therefore produce more grievances, not fewer.

The process matters as much as the mechanism

Our experience revealed that how a grievance mechanism is developed matters as much as the mechanism itself. In many of the settings, workers and their representatives had little say in design or execution, limiting accessibility and trust. Workers cannot simply be users of a system designed by others; they must be actively involved from the start.

The experience in Spain brought home just how difficult this can be. At two growers, grievance mechanism taskforces brought together workers and management to assess existing mechanisms and design improvements. Yet field workers could easily be missing from meetings due to production schedules and release challenges.

These practical challenges are precisely why meaningful participation needs to be deliberately enabled, ensuring that workers facing the greatest barriers are not absent from the process intended to help them. Meaningful participation takes time, translation, paid time away from work, management commitment, and attention to diverse representation. This is vital where mechanisms integrate into existing worker representative structures and social dialogue.

A grievance mechanism is not a hotline, an app or a box

This work reinforces the need to stop viewing grievance mechanisms primarily as objects. A hotline, an app, a complaints box, or an email address are merely channels within a wider system.

What makes a grievance mechanism effective is everything around the channel: whether workers understand and trust it, feel safe speaking up, receive meaningful remedy, and whether the organisation learns from what it is told. They are ongoing processes and organisational commitments, not tick-box solutions.

This requires a shift in mindset: from seeing grievances as problems to be minimised to seeing them as valuable insights and opportunities to improve relationships with workers. A grievance may tell a company where policies are failing, identify emerging human rights risks before they escalate, or reveal structural issues that an audit missed. Furthermore, a worker raising a difficult concern may signal that they trust the mechanism enough to speak.

Instead of asking, "How many grievances did this supplier receive?" buyers should ask: Who is using the mechanism? Who isn't? What concerns are raised? Do workers know what happens next? Are grievances resolved fairly? And what do workers say about whether it works?

That requires a very different conversation between buyers and suppliers, and one that is often easier to have collectively, with trade unions and civil society at the table.

From a mechanism to an ecosystem

Operational mechanisms cannot carry the entire burden of providing remedy. As outlined in the recent Oxfam briefing “Navigating Grievance Mechanisms: A Pathway to Robust Accountability for Rightsholders,” we need a connected grievance ecosystem where operational, buyer, and multi-stakeholder mechanisms play complementary roles. Rightsholders should be able to choose the safest route; suppliers should resolve local issues; buyers should identify patterns and use leverage; and sector actors should address systemic risks.

Our new joint paper Designed with and for workers: Joint Lessons from AIM-Progress, Ethical Trading Initiative and Oxfam Business Advisory Service on worker-led grievance mechanisms, launching on 4 November, builds on this broader conversation by bringing together practical experiences from AIM-Progress, ETI, and Oxfam Business Advisory Service. At its centre is a worker-led approach that starts with the people most directly affected.

Start with the people who need to use it

The UN Guiding Principles set out clear effectiveness criteria, but companies have perhaps spent too much time asking whether channels exist.

The more useful questions are: would the people most affected know where to go, feel safe enough to speak, and trust what happens next? Those questions cannot be answered by looking at a policy or counting complaints; they can only be answered by the people the grievance mechanism is supposed to serve.

Our new paper, Designed with and for workers: Joint Lessons from AIM-Progress, Ethical Trading Initiative and Oxfam Business Advisory Service on worker-led grievance mechanisms, sets out the practical lessons from these initiatives for companies, suppliers and supporting organisations. If you are designing or reviewing a grievance mechanism, or supporting others to do so, we welcome the conversation —starting with our upcoming webinar launch on 4 November (register here).

*Oxfam Business Advisory Service was a subsidiary of Oxfam GB that closed in December 2025.

By Sara Petersson and Monica Romis

Sara Petersson is an independent consultant specialising in human rights due diligence and responsible supply chains, formerly with the Ethical Trading Initiative (ETI). Monica Romis is an independent consultant specialising in business and human rights and former member of Oxfam Business Advisory Service (OBAS). Both worked on initiatives exploring how to meaningfully engage workers in the design and assessment of effective grievance mechanisms.