The Global Business Initiative for Human Rights (GBI) released What “Good” Looks Like: Heightened Human Rights Due Diligence (November 2025). The note is part of its series breaking down key business and human rights concepts.
Human Level’s Take:
- Operating in a conflict context poses heightened risks both for companies and for people on the ground — from employees, to contractors, to local communities, to customers. Through their products and services, activities, relationships or even just their presence, companies may also affect the conflict itself, potentially worsening it.
- In these situations, companies are expected to apply heightened human rights due diligence, which follows the steps of regular human rights due diligence while adapting them for a conflict context.
- GBI’s guidance outlines key components of HHRDD. For example, identifying human rights risks and impacts connected to the business also requires looking at the local actors and dynamics of the conflict and seeing how company activities or relationships could affect these. When it comes to taking action, companies will need to consider not only their own actions and how to build leverage, but also the ways in which acting or using leverage could create heightened risks or inflame tensions. And deciding to exit the context requires a careful analysis of the ways in which disengagement could harm rightsholders or generate new human rights risks and impacts.
- In addition to outlining the key steps of HHRDD, the guide also offers probing questions and real-life examples of what good practice looks like.
Some key takeaways:
- What is heightened human rights due diligence (HHRDD) and when is it needed?: HHRDD is used in contexts of heightened human rights risk caused by armed conflict, which could include military occupation, mass atrocities or widespread violence by non-State actors. It arises in cases where regular due diligence is no longer sufficient, due to the scale of risks and impacts and the potential for rapid change. GBI points out that identifying when HHRDD is needed is not always clear. Companies do not need to wait for a legal decision or formal designation of a conflict, but instead should create an internal decision framework that considers the context to identify when HHRDD is needed. GBI offers five questions that can help companies make the decision: Does the operating context show signs of conflict, political violence or systematic repression – including post-conflict signs? Are any partners, suppliers or public actors involved in or credibly linked to human rights violations? Could the company’s own activities – through their scale, location or nature – alter local access to power, land or resources? Is the company perceived, rightly or wrongly, as supporting one side of a dispute or conflict? Is the situation fluid, uncertain or poorly understood? To help answer these questions, companies can use resources like global conflict-monitoring systems, official reports from the UN and International Committee of the Red Cross, and credible NGO and media reports. Companies can also look to early warning signs at national or local level or grievance mechanisms and worker complaints, which can indicate when a pattern is starting to form.
- What are the features of HHRDD?: GBI outlines the ways in which heightened due diligence goes beyond regular due diligence. When it comes to identification and assessment of risks and impacts, HHRDD goes beyond risks to people to also understand the broader conflict context, for example, who is in control of territory or resources, who is marginalised or most at risk, and how could the company’s presence or operations feed the conflict. In terms of integrating findings and taking action, HHRDD entails adapting standard operating procedures to a conflict context, for example identifying whether suppliers and contractors could be linked to conflict actors; or ensuring that public and private security uphold the Voluntary Principles on Security and Human Rights. In a conflict context, leverage is key to taking action, although companies may need to consider the ways in which exercising their leverage could have implications for the conflict or how their activities could shift the balance of power. Remediation will also need to be adapted for the local context, taking care not to further inflame the conflict. On tracking and monitoring, the expectation is that companies will go beyond existing tracking to also monitor their own impact on the conflict; this depends on conflict-sensitive consultation and monitoring that ensures the safety and security of stakeholders. With regard to communication, companies are expected to disclose both their actions and their decision-making process considering conflict risks. Finally, companies are expected to plan for a responsible exit in cases where their continued activities perpetuate or legitimise harm. This also requires assessing the potential negative impacts of withdrawal and putting in place transition plans to prevent, mitigate and remediate impacts.
- What “good” looks like: The guide offers advice on good practices, coupled with real-life case studies. One key practice is conducting HHRDD early on and on an ongoing basis throughout the company’s involvement in or proximity to the situation. In addition, they can develop internal indicators or red flags that trigger certain decisions or processes. For example, key indicators could could include conflict intensity, the proximity of the conflict to the company’s operations and business relationships. Companies can also preemptively prepare rapid mitigation responses that can be rolled out quickly if the conflict intensifies or the situation changes. It is also critical to ensure the safety and well-being of employees, for example via providing mental health support and other types of support. Finally, a company making the decision to leave the context will need to make a plan for a responsible exit, for example by conducting a human rights risk assessment of turning over operations to another company or government, analysing the severity and likelihood of the risks of exiting, and making a plan to prevent, mitigate and remediate risks and impacts. The guide also includes a list of questions companies can ask themselves when conducting HHRDD to guide decision-making.
