WH Smith - Strengthening risk assessment through ETI’s HRDD approach

At ETI, company members gain access to regular, interactive HRDD workshops on specific topics and issues impacting human rights in supply chains including identifying risks, developing strategy and remediating supply chain issues. ETI invites company, NGO and trade union members to speak on their areas of expertise and share examples of good practice, with opportunities for all participants to engage and share their learning. This case study captures the impact these workshops have had for company member WH Smith. 

Driving change through collaboration

When Sarah Davis joined WH Smith as Ethical Trade Manager, it was seen as an opportune moment to review and strengthen the company’s human rights risk assessment process. This coincided with ETI providing targeted support through its deep dive on human rights risk assessment, creating the ideal opportunity to align internal improvements with external good practice.

With WH Smith expanding sourcing into new regions, the team recognised the need for a risk assessment process that could adapt to an evolving supply chain while meeting external commitments, including ETI’s transparency requirements and the UN Global Compact. As with all global brands, the challenges lay in translating complex, wide-ranging risks into a consistent and practical framework for action.

From insight to action

Through ETI’s HRDD workshops, Sarah and her team gained access to practical tools, real-world examples, and peer learning opportunities that helped them make meaningful improvements to their risk assessment process.

“ETI does a fantastic job of showing what good looks like through practical examples,” Sarah explains. “The HRDD workshops are a safe space for honest conversations, it’s helpful to hear how others have overcome similar challenges.”

Inspired by these insights, WH Smith conducted a comprehensive review of salient human rights risks across its business, from stores and joint ventures to deeper tiers of the supply chain. 

Using a severity and likelihood matrix, the team systematically prioritised risks, building a more transparent and defensible rationale for where to focus action. The process and findings were presented to senior management, securing top-level engagement and embedding due diligence more firmly within the business.

Tangible impact

The improved approach has enabled WH Smith to target relevant resources where they can make the most difference. For example, gender equality in China. In response, the business joined ETI’s collaborative working group on gender-responsive occupational health and safety and began collecting better-quality data on gender and related factors such as dormitory facilities which has provided better visibility on the factors at play.

This also strengthened work on worker representation, with WH Smith doubling the number of suppliers participating in its Worker Representation Initiative and seeking to increase women’s participation among worker representatives.

Learning through the network

ETI’s HRDD workshop environment created space for reflection and peer exchange that accelerated progress. The combination of practical tools, real-world examples, and safe peer dialogue helped WH Smith translate guidance into tangible business practice.

Three key lessons stand out:

• Bring others in early. Involve colleagues from buying and risk teams to build internal buy-in.
• Stay connected. Use ETI’s network to exchange ideas and approaches, collaboration speeds up learning.
• Keep it active. Review risks regularly and link them to KPIs to maintain momentum and accountability.

Looking ahead, WH Smith plans to strengthen its approach further by integrating worker voice more directly into the risk assessment process and ensuring that buying teams play a stronger role in regular risk reviews. The team will also continue to engage with ETI’s human rights due diligence workshops to keep learning and evolving.