Top Priority Actions
1. Map risks systematically and connect the dots when assessing human rights risks to understand compounding impacts or risks
2. Reframe human rights internally as a business-resilience investment that can strengthen stability, reputation and long-term value in a shaky economic, political and social environment
3. Expand partnerships with suppliers, including through regional supplier forums and collaborative initiatives
4. Prioritise effective actions over collecting large amounts of data, and re-direct resources toward mitigation, engagement and remedy
5. Continue to share practical examples, challenges and what’s working, and to speak openly, to demystify human rights due diligence and address a growing “complexity complex”
6. Track HREDD legislation globally, not only the EU, to prepare for emerging expectations in other regions like Asia Pacific and Latin America
7. Assess the human rights impacts of AI use or development - including on discrimination, privacy, health safety and misinformation risks
8. Even amid political pushback, integrate gender and DEI perspectives into risk identification and mitigation - across issues - for a gender and DEI-responsive due diligence
9. Since migrant workers are increasingly at risk in today’s political context, strengthen migrant-worker protections by reviewing recruitment partners and contracts and the availability of grievance channel
10. Engage children, youth, Indigenous Peoples, farmers and migrant workers - or their representatives - in climate-related planning and transitions
1. The polycrisis is exposing systemic gaps, but also the interconnectedness of human rights and environmental issues
The current polycrisis, including from climate impacts, weakening rule of law, rollback of DEI commitments, geopolitical tensions, tariffs, conflicts and social and economic shocks, is exposing the deep vulnerabilities that still exist across supply chains and gaps in our human rights and environmental strategies and actions. Companies in some countries, for instance, have increased reliance on migrant workers across sectors due to labour supply gaps, yet migrant workers remain three times more likely to experience forced labour.
2. Human rights and governance gaps have real costs for business
The business case for human rights, and whether and how it needs to be made, was discussed at length. Companies participating shared how success and value creation depends on certainty, transparency, effective institutions and people being able to work, grow and prosper. Rising inequality, climate disruptions, and weakening multilateralism pose major risks to human rights, as well as to a stable and supportive business environment. For investors and policymakers this is also relevant, as systemic human rights risks within markets can increasingly affect investment returns and companies’ economic success.
3. Innovative partnerships are the future of human rights due diligence
Innovative partnerships are becoming foundational to the future of business and human rights, especially with suppliers, whose voices need to be more present in the UN Annual Forum. Regional supplier forums, for example, have improved trust and boosted human rights, environmental, and business outcomes in places such as Spain and Egypt, with suppliers increasingly recognised through better commercial terms and prices. In Spain, ethical trade forums have gradually expanded from supplier-only spaces to those that include workers, demonstrating that time and trust are required for meaningful collaboration. Multi-company or sectoral grievance mechanisms, like the German automotive sector mechanism in Mexico, also show how coordinated action can address systemic issues that no actor can tackle alone.
4. We lack examples of effective actions, not more standards, certifications or data
The UNGPs and OECD Guidelines remain fit for purpose as standards to apply to assess and address risks. A new challenge, however, is to overcome the perception that due diligence is too complex or needs large amounts of data, traceability and certification programmes to be effective. This “complexity complex” can be demystified if companies continue to show and discuss how human rights due diligence works in practice. For example, we saw companies asked to discuss concrete actions related to purchasing practices, contracting terms, freedom of association and global framework agreements, and pricing models. More public examples of what is working today are needed.
5. We know artificial intelligence (AI) and other new technologies impact human rights, but discussion around what is expected from business is only just starting
This year, the discussion around AI centred around public procurement systems, and not on private sector’s development and sourcing. At the same time, we also discussed how existing laws on privacy, discrimination and transparency - as well as the UNGPs and other business and human rights standards - already apply to businesses producing or sourcing AI systems. Even if AI and digital legislation is now being re-opened at EU level and uncertainty about expectations remains, the UNGPs offer a framework that can be applied to identify and address human rights impacts, such as the risks of discrimination against women, racial or ethnic minorities, and migrant workers, or the risks of safety for children. Systemic impacts from AI, like misinformation, should also be considered since they are impacting democracy, rule of law, and societal stability and increasing people’s vulnerability to other human rights issues.
6. Gender and DEI approaches remain essential to effective human rights due diligence
DEI policies adopted to address historic and structural discrimination are under attack in some regions, with companies continuing to dismount these and their DEI programmes. At the same time, speakers shared that risks of discrimination are growing, including by employers and AI systems (which often incorporate biased data sets). In response, even within a context of political backlash, companies can continue to advance DEI efforts by embedding gender and DEI perspectives into their day-to-day human rights risk identification, stakeholder engagement, mitigation and remediation.
7. A just transition is even more urgent in today’s context
Just transition, from companies’ perspectives, can be understood as implementing climate action plans in a way that is rights-informed, respectful and effective, particularly for those most vulnerable: children, Indigenous Peoples, migrant workers and others. For instance, children, who make up a third of the world’s population, face heightened vulnerability to climate impacts: extreme weather, air pollution, disease, water scarcity affect 739 million children globally. Yet children and young people are not often consulted or engaged with when designing climate actions and responses; and the same can be said for migrant workers or Indigenous peoples at risk.
8. Taking a more global look at HREDD legislation is important, while we continue to watch the EU CSDDD discussion.
While we keep an eye on the EU CSDDD discussions, it will be important to also follow other countries' advances and experiences. For example, momentum is building in other regions with countries such as Thailand, South Korea and Colombia advancing HREDD legislation of their own. Norway and Germany have also been reviewing their own legislations and their effectiveness - as well as the laws’ claimed impacts on competitiveness. Norway’s recent review of its Transparency Act, for example, found that the vast majority of the nearly 9,000 companies under the law considered due diligence obligations both manageable and appropriate.
