Strengthening HRDD - with Charles Russell Speechlys

30 April

You can’t do human rights due diligence from a desk. Policies and frameworks are important. But the insights that actually tell you what’s happening in your operations and supply chains come from people – workers, communities, suppliers, and those closest to the realities on the ground.

This video is part of a short series featuring Kerry Stares from Charles Russell Speechlys and Louise Herring from Inherently Human on how to do risk-based human rights due diligence.

Stakeholder engagement and grievance mechanisms are often treated as supporting elements of human rights due diligence. In this video, Kerry and Louise make the case that they are foundational. Drawing on the UNGPs and the CSDDD, they explain who businesses need to engage with and why, how to bring worker and community voices into risk assessment and action planning, and what effective grievance mechanisms look like in practice.

They also address what happens when these systems fail, with Rana Plaza as a defining example of the consequences of ignoring worker concerns.

Key themes

Stakeholder engagement is built into the framework, not bolted on. Both the UNGPs and the CSDDD require meaningful consultation with affected people at key stages of the due diligence process. This means direct engagement with workers, communities, and suppliers, not just internal review or desk research.

Three groups, each with distinct value. Internal teams hold practical knowledge about where leverage exists. Suppliers and external partners are closest to the issues and often to the solutions. Workers, unions, and trusted local institutions provide lived experience that no audit or questionnaire can replicate.

Engagement produces better outcomes than enforcement. Building relationships with workers through trusted intermediaries, whether unions, NGOs, or local staff, is more effective than issuing directives from head office. This is especially true for migrant workers in sectors like agriculture, where language, isolation, and power imbalances create particular vulnerabilities.

Grievance mechanisms are an early warning system. When designed well, they surface unsafe conditions, unpaid wages, recruitment fees, and discrimination before they escalate. Rana Plaza is the most cited reminder of what happens when worker concerns go unheard.

An ecosystem of channels is more effective than a single route. Workers need options: onsite channels, collective routes, third-party anonymous reporting, and in some contexts, state or multi-stakeholder hotlines. The right channel depends on the issue, the context, and the level of trust workers have in each option.

Listening is the start; remedy is the goal. Grievance mechanisms only work if concerns lead to action. That means fixing the harm, learning from each case, and strengthening systems to prevent recurrence.

The conversation (full transcript)

Kerry Stares: Hello, I’m Kerry Stares, a partner at Charles Russell Speechlys. Welcome to the second of our short videos on how to do risk-based human rights due diligence. I’m joined again by Louise Herring, founder of Inherently Human.

If you haven’t already watched earlier videos in this series, including on why doing risk-based human rights due diligence makes good business sense, you can find those on our website.

Today we’ll cover two things. First, how to engage stakeholders to strengthen your human rights due diligence and risk management. And second, how to design effective grievance mechanisms.

The UN Guiding Principles on Business and Human Rights, or the UNGPs, which have set the benchmark for best practice since 2011, expect companies to carry out meaningful stakeholder consultation as part of their human rights due diligence process. That means talking to people affected by your business, and not just relying on desk-based research, internal expertise, or external consultants.

The recently revised EU Corporate Sustainability Due Diligence Directive, or the CSDDD, also requires companies to consult with relevant stakeholders at certain stages of the due diligence process, including when gathering the necessary information to identify, assess, and prioritise human rights risks.

Louise Herring: Exactly. Effective human rights due diligence should be shaped by insight from the people whose rights are at risk and those who can protect them in the supply chain. Think in three groups: your internal teams, including procurement and in-house legal; external partners like suppliers, labour providers, and governments; and affected people and their representatives, including workers, unions, and trusted local institutions like community groups, NGOs, faith leaders, or health providers.

If you have staff in sourcing regions, use them to speak directly with workers and communities. Bring those voices into your risk assessment and when you design actions. Their lived experience is critical in helping you understand where risks are highest and devise solutions that are effective in practice.

And remember, you can’t do this without your suppliers. They’re closest to the issues and often to the solutions. Supporting site managers in UK agriculture to build rapport with migrant workers and bring in unions or NGOs to explain workers’ rights clearly, for example, is far more effective than top-down head office edicts. Engagement beats enforcement alone.

Kerry Stares: Let’s turn to grievance mechanisms. Under the UNGPs, businesses should establish or participate in operational-level grievance mechanisms that affected individuals and communities can access directly, to raise concerns about adverse human rights impacts linked to a company and to seek remedy. In a similar vein, the CSDDD requires companies to have a complaints procedure and to establish a fair, publicly available, accessible, predictable, and transparent procedure for dealing with any complaints submitted.

Louise Herring: Done well, grievance mechanisms are independent, confidential, and safe. They surface issues like unsafe conditions, recruitment fees, unpaid wages, or discrimination early, so you can fix problems, mitigate risk, and prevent harm.

History shows why this matters. When worker concerns are ignored, the consequences can be catastrophic for people and for businesses. Rana Plaza is one of the most well-known examples. Sadly, workers raised concerns about the building structure shortly before it collapsed.

Kerry Stares: To be effective in practice, mechanisms should be legitimate, accessible, predictable, equitable, and transparent. People must trust the process, know how it works, be able to use it without barriers, have fair access to information and support, and receive clear updates and outcomes.

Louise Herring: Most companies need an ecosystem of options, so workers and communities can choose what’s right for their situation. Onsite channels for everyday issues, collective routes via unions or worker councils, third-party tools for confidential reporting, and where appropriate, state or multi-stakeholder hotlines. Government options can be vital for serious issues like forced labour, but they’re not always available or trusted. In some sectors, independent channels that offer anonymity by phone, online, or messaging apps can make all the difference.

Kerry Stares: Effective grievance mechanisms are more than a compliance task. They’re an early warning system. They build trust, help you meet regulatory expectations, support business continuity, and drive continuous improvement. And they only really work if you act on them. Listening is the start; remedy is the goal. Fixing the harm, strengthening risk management, preventing it from happening again, and learning from every case.

Thank you for watching. Do look out for more videos in this series on how to do risk-based human rights due diligence. These videos are designed to give you a taster of what’s involved. For more information and tailored advice, please do get in touch.

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