The Global Business Initiative on Human Rights (GBI) released the latest instalment in its Guidance Briefing Series, What "Good" Looks Like: Direct Linkage (June 2026), setting out practice-based guidance for companies on assessing when they are directly linked to human rights impacts under the UN Guiding Principles on Business and Human Rights (UNGPs).
Human Level’s Take:
- What does it take for a company to be “directly linked” to harm, how should this be assessed, and what do practitioners need to know? Through the use of practice-based insights and knowledge, GBI's latest guidance briefing sets out to answer these questions.
- The briefing clarifies that direct linkage is not a “safe harbour,” or a lighter version of causing or contributing to harm — it is an active, ongoing responsibility to exercise leverage.
- Two questions determine whether a connection is direct: is there a specific link between a company’s own operations, products or services and a particular harm, and can that connection be traced through evidence or reasonable inference? Geography, sector presence and the replaceability of a company’s services or products don’t answer either of these questions.
- Drawing on scenarios and realities from practice, the briefing addresses some common myths about direct linkage and shows how assumptions made about business relationships, leverage, and a company’s distance from harm can play out across different contexts, including how direct linkage can escalate to contribution.
- The guidance briefing provides operational takeaways for practitioners, advising companies to treat human rights due diligence (HRDD) as an ongoing process and reassess linkage when new information comes to light.
- Companies are also invited to assess whether their exercise of leverage within a business relationship is meaningfully preventing or mitigating adverse impacts, rather than simply demonstrating engagement, warning that leaving available leverage unused can itself deepen a company’s involvement in harm over time.
Some key takeaways:
- Assessing direct linkage: Two criteria determine when a company's connection to an adverse human rights impact crosses the threshold into direct linkage: specificity and traceability. Specificity asks whether a connection can be drawn between a company's particular operations, products or services and a particular mechanism through which harm is caused, rather than a general association with a harmful context, sector or geography. Traceability asks whether each step in that connection can be established through evidence, sound operational logic or reasonable inference, rather than assumption or speculation. The briefing frames these criteria as analytical tools rather than a checklist, intended to structure judgement in situations that often involve incomplete information and genuine uncertainty. “Negligibility” presents a particular challenge, where a company's product forms only a small part of a harmful outcome. The guidance frames this type of situation as a pitfall, stating that while negligible connections are a lower priority, they are still priorities and not exclusions. A small or negligible contribution does not rule out linkage — instead, it affects how the company prioritises its response and what leverage it can reasonably be expected to exercise.
- Involvement in harms is a “film rather than a photograph”: The briefing emphasises that a company's assessment of causing, contributing and direct linkage is not fixed, and requires reassessment at each material decision point and as facts evolve, rather than being treated as a one-off determination made at contracting. Three mechanisms can drive the escalation from direct linkage toward contribution: continued engagement without a meaningful response once credible information of harm exists; changes in the foreseeability of harm as evidence accumulates; and "performative leverage," where engagement is designed to document effort rather than to drive change. Six sector scenarios spanning extractives, finance, logistics, technology, supply chains and fashion, show how the framework applies in practice, whether a company is several tiers removed from harm or in a direct contractual relationship. The scenarios demonstrate that factors such as distance in a supply chain, theoretical replaceability of a product, and a company's small share of a business relationship's revenue do not, on their own, determine whether a direct link exists. The briefing also documents common myths observed in practice, including the idea that direct linkage is a "safe harbour" with minimal responsibilities, that lack of control over a supplier removes responsibility, and that being several tiers removed from harm in a supply chain rules out a direct linkage.
- What does this mean for practitioners?: GBI recommends applying the two criteria for assessing direct linkage as a judgement framework rather than a checklist, documenting the basis for a finding of linkage or no linkage with equal rigour and treating assessment findings as provisional, to be revisited when new information or a shift in deployment comes to light. Another key takeaway is the clear distinction made between invoking leverage and exercising it. A letter, audit or contractual reminder might serve as a record of activity, but this alone does not constitute evidence that a company has influenced the conduct or activities causing harm. Failing to use available leverage, or using it in form but not in substance, is itself treated as conduct. Companies are reminded that continuing a business relationship unchanged following credible evidence of harm, or an ineffective company response to that evidence, can shift their position from direct linkage toward contribution.
