Human Rights Impact Assessments: A Critical Component of Human Rights Due Diligence
Demand for Human Rights Impact Assessments (HRIAs), together with holistic Human Rights and Environmental Due Diligence, is increasing as companies come under growing pressure from investors and need to satisfy additional regulatory requirements. Our clients recognize that they need to obtain nuanced information about current and future risk to prepare for enhanced regulations that require supply chain human rights and environmental due diligence.
HRIAs enable identification of potential risks, differing from a compliance approach, and allow companies to determine how to dedicate resources more effectively based on the outcomes. A key differentiation from a typical compliance approach is a recognition that risks and underlying root causes tend to be systemic – addressing those risks can be complex.
Unveiling hidden supply chain risks
LRQA has developed an HRIA methodology informed by our technical expertise in human rights, “boots on the ground” knowledge of supply chains, and our data insights from our EiQ platform. Operating in more than 180 countries, our HRIAs benefit from our global network of supply chain researchers who spend time at representative sites and use LRQA’s suite of data-driven human rights investigatory tools designed to identify risks that are often hidden such as forced labor, harassment, dangerous working conditions, child labor, sexual abuse and harassment, and others. We use the results to develop action plans that manage current and emerging risks all the way down to the farm and factory levels.
We deliver a diverse body of HRIAs bespoke to the context. Our researchers have arrived by motorbike and by foot at fisheries in rural India and interviewed farmworkers in English and Spanish in the United States, spending time in communities, at worksites, and with management. Trained to create a safe, comfortable environment for direct conversations with workers and benefiting from their local experience, our HRIA researchers have identified issues such as potential forced labor and the risk of heatstroke for farmworkers given changing weather patterns. In most cases, our researchers supplement in person insights with anonymous worker surveys, which have been found to be 7-9 times more likely to uncover sensitive issues than interviews alone.
Strategic steps for effective HRIA
To conduct a successful HRIA, it is critical to first identify the highest risk in a company’s value chain to be sure that this intensive process is a risk-based one. It is also essential to consider the variety of types of suppliers and where the client has leverage for any remediation. Clients need to understand where in the value chain would be the most strategic to focus resources and respond to any risks identified. Our proprietary data analytics platform, EiQ, combines tens of thousands of data points on geographic and commodity risk from audits, and is often used for this step. It is also important to bring real engagement to this process using local researchers who understand the nuances of the human rights situation on the ground. An HRIA is only useful insofar as rightsholders feel that they can be honest in sharing risks that they perceive. Considerable engagement is necessary before and after site visits to ensure a ‘do no harm’ approach and that companies are communicating their human rights actions effectively, as set out in the United Nations Guiding Principles (UNGPs). Remediation systems can vary, but it is essential that the closure of an HRIA is really just a beginning, with a clear action plan and roadmap for next steps to prevent, mitigate, and respond to potential rights infractions.
In short, our pragmatic, action orientated approach includes:
- Data informed: Our work is informed by our EiQ geography and product risk insights that we bring to all engagements.
- Expert Team: The dedicated and experienced human rights due diligence team practiced in performing HRIAs always includes human rights experts and supply chain experts with industry and geographic expertise.
- Local Field Researchers: HRIA field researchers receive customized human rights and industry training prior to each assessment, including on gender sensitivity, enhanced understanding of human rights in the context, and the customized tools for the HRIA. Fluency in the relevant languages and local customs and training in the relevant sector enables them access to information that is nearly impossible to obtain without actual on the ground presence. In addition to researchers, LRQA has regionally-located offices that coordinate and manage all site visits in the relevant local languages and time zones and to handle any urgent findings expeditiously, communicating with clients through global offices.
- Tailored Tools: Tools are customized to the commodity and geography for the most nuanced possible information for clients. Farm or factory site visits include quantitative and qualitative tools that obtain the best possible data. Anonymous worker online surveys, and on-site questionnaires are supplemented with deep dive interviews, focus group discussions, and community sessions, providing a holistic view of potential risks in these hard-to-reach, last-mile locations.
- Rightsholder Engagement: LRQA’s approach emphasizes speaking to all rightsholders – including local community members, workers, and workers’ families – about the full impact of the business, including on local health, education, and economy.
- The HRIA Action Plan: A final HRIA report includes feedback from internal stakeholders across the business, expert stakeholder input, key findings from on-site work and rightsholder interviews, and most importantly, an action plan of next steps to address each finding based on its salience.
In addition to the above, LRQA successfully brings companies together who are working on the same commodities and regions. The ability to influence change and have impact in a region often goes beyond what one company can accomplish on their own, and/or has the resources to accomplish. We understand that identifying and mitigating human rights risks associated with business is critical.
For more information on how LRQA performs HRIAs or how an HRIA can support your work, please contact our HRIA team.
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