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What does it take for a farmer in Kenya or a tea estate worker in India to have their voice genuinely heard by the company buying their products?
At the Ethical Trading Initiative (ETI), we believe this is at the heart of effective human rights due diligence (HRDD). Genuine dialogue with workers and rightsholders isn’t just a box to tick, it’s the only way to understand the realities they face and identify actions that will make a real difference.
For years, this idea has been embedded in soft law and in our tripartite approach. But, a new term has been gaining prominence: ‘meaningful stakeholder engagement’ (MSE). This is, in part, due to the welcome importance attributed to it within the EU Corporate Sustainability Due Diligence Directive (CSDDD).
As a member of the STITCH Partnership, ETI co-developed and launched the Meaningful Stakeholder Engagement Framework earlier this year, which sets out five key principles: legitimacy, accessibility, safety, equitability and respect.
Last month, we ran a workshop to bring these principles to life through examples of engagement from across our diverse membership. At ETI, we support our company members to continuously improve their human rights approach through a series of practical workshops on the most challenging aspects of HRDD. Guiding companies to build MSE into every aspect of the HRDD cycle is a significant part of this work.
From addressing barriers for marginalised workers to creating feedback loops that lead to tangible change, together our members shared how they are embedding MSE throughout the HRDD cycle, discussed the opportunities and challenges they face day-to-day and defined next steps for strengthening their own approach.
Principles in action - key insights from our speakers
Accessibility: Addressing barriers to participation
Stakeholders often face barriers to engaging with companies. From obvious impediments such as language, to more insidious social barriers that can prevent marginalised groups from having the opportunity to speak. This principle clarifies the need for companies to address these barriers to ensure that all stakeholders can express themselves.
Sabita Banerji, CEO of THIRST (The International Roundtable for Sustainable Tea), illustrated how she’s witnessed accessibility play out in practice. THIRST recently held workshops with tea estate workers, smallholder tea farmers, and young people in Kenya and India.
Sabita emphasised the importance of understanding the specific accessibility barriers in any given workplace or location. She stressed the value of partnering with local organisations – with deep knowledge of the social and economic context – who can help uncover and address challenges outsiders might miss.
She noted management nervousness about providing access to workers, generational and gender power imbalances and the limited free time of workers as some of the crucial barriers to meaningful engagement in this context.
To overcome these barriers, a key first step was building trust with management through transparent communication about the purpose of the engagement. It was also fundamental for THIRST to unpack the power dynamics at play to ensure that workers were in groups where they were able to speak freely (to avoid women being less comfortable to speak in front of men, workers in front of managers, or younger workers in front of older colleagues). They negotiated carefully with both management and workers about the timings of the workshops, to ensure that work time wasn’t being interrupted but also workers’ very limited free time wasn’t unduly taken up.
These workshops sought to understand participants’ vision for the future of the tea sector and their role within it, as experts within the field who so often get overlooked. Read THIRST’s full report from this process in Kenya, which includes guidance for buyers on how to use this to inform HRDD.
Safety: Creating a safe environment for engagement
Engaging with companies is not without risk for stakeholders. These risks can range from retaliation by an employer to the psychological implications of reliving trauma. To ensure meaningful engagement, companies should proactively identify and mitigate any risks prior to engagement, recognising that higher-risk contexts or particularly sensitive topics may require stronger safeguards.
FLEX (Focus on Labour Exploitation) is a UK-based organisation working to end labour abuse and exploitation through research, policy, and engagement with workers and businesses. They recently piloted a worker engagement framework in the UK’s cleaning sector, a high-risk environment that is outsourced, feminised, and heavily reliant on migrant and ethnic minority labour.
Ana-Sofia Baillet, Business and Workers’ Rights Manager at FLEX, provided insight into how they prioritised participant safety in this pilot. She emphasised the importance of preparation in creating a safe environment: identifying risks, planning support needs and defining safeguarding boundaries. The pilot highlighted the need for a sector-specific lens on potential risks, to understand how those risks could play out in certain contexts and effectively mitigate them. For example, when we hear retaliation, we may commonly think of physical violence or job loss, but in the cleaning sector this may come in the form of changes to hours, duties or day-to-day treatment.
Reducing the risk of psychological harm was a central focus of the pilot. FLEX tested questions on sensitive topics, such as sexual harassment, with a small number of workers and adapted their approach to meet the participants needs. They followed a worker-informed safeguarding model, guided by principles including Do No Harm, Informed Consent, Confidentiality, Non-Retaliation, Accessibility, and Internal Validation. This model informed every stage of engagement, from preparation and building rapport, to allowing workers to share their experiences freely, and providing closure and post-engagement wellbeing support, ensuring participants could share safely while minimising emotional risk of sharing sensitive experiences.
You can find more information about FLEX’s worker informed HRDD pilot here.
Respect: Turning dialogue into action
Respectful stakeholder engagement is conducted in good faith, which means acting on the information shared and implementing effective solutions. The views of stakeholders must not disappear into a vacuum as companies gather information on adverse impacts, but be treated as part of ongoing, two-way engagement that leads to action.
Janet Kabaya, Head of Legal, Gender and Human Rights at Kakuzi PLC (part of Eastern Produce Regional Services, an agricultural company member operating in East Africa), shared how the respect principle is embedded in their human rights due diligence. For Kakuzi, ongoing engagement with a broad range of stakeholders - from workers to faith-based community groups - has been central to the design and development of their approach.
A dedicated community relations manager plays a key role in Kakuzi’s ability to carry-out two-way engagement, ensuring dialogue is continuous and not a one off. Crucially, this engagement influences outcomes. When designing their operational grievance mechanism, Kakuzi sought input from workers and other local stakeholders through several community meetings.
Feedback included things like making the grievance mechanism accessible to all stakeholders (e.g., community members as well as workers) and encouraging open dialogue. Kakuzi were able to put these things into action, helping to ensure the mechanism actually works for those it is designed for. In practice, open dialogue means having regular meetings with community-based organizations who raise concerns, conducting joint fact-finding missions to establish the issues raised, keeping any complainants updated on the status of their cases and communicating the company’s decisions.
Trade union engagement also forms a key part of their HRDD approach. Each estate, be it producing blueberries, macadamia or avocados, holds monthly meetings with union representatives to discuss issues and solutions, demonstrating an ongoing commitment to two-way communication through these relations.
ETI members can find out much more about Kakuzi’s approach here.
ETI and our partners within the STITCH consortium are developing a practical toolkit which integrates the principles of the MSE framework within HRDD processes for companies within the apparel and textiles industry. Look out for its release in the autumn, which will be followed by a similar toolkit for food, farming and fisheries later in the year.