Once the company has completed an overall saliency analysis, assessed serious risks and harms in more depth, and created a human rights strategy, it is ready to take action to cease harmful practices and prevent and mitigate the identified risks and violations.
A formal human rights strategy provides a useful framework for organizing the company’s decisions about its priorities and objectives for its work on human rights.
A company’s human rights strategy should directly reflect the findings from its risk and harm assessments, prioritizing issues that are most prevalent, serious, and within the company’s responsibility to address. The strategy should cover the company’s key salient issues, state the core objectives the company seeks to achieve through its human rights program, and identify the commodities and geographies in which the company will prioritize its efforts.
The company uses the insights from its assessment of risks and harms to define its priorities for action and core objectives related to human rights.
In addition to “Basic,” the company has a human rights strategy in place that incorporates stakeholder consultation, and it is implementing the strategy.
In addition to “Established,” the company routinely evaluates the sufficiency of its human rights strategy to drive impact and updates its priorities, objectives, and resourcing as necessary.
Once the company has a human rights strategy in place, it should develop indicators and set targets to measure progress.
In the early stages of maturity, the company will likely focus primarily on process indicators and targets, measuring the implementation of its due diligence systems. As the company matures in its human rights due diligence, it should measure its impact on salient issues as well. Human rights strategies should include clear timelines for transitioning from process measurements to impact assessments. Establishing human rights indicators and targets requires a formal process with clear accountability assigned at senior leadership levels
The company has developed high-level key performance indicators (KPIs) to measure progress toward its human rights objectives and its impact on salient issues. It has set targets for each indicator.
In addition to “Basic,” the company has built out its KPI framework to include supporting indicators and targets to drive progress on HRDD implementation and impact.
In addition to “Established,” the company actively uses impact indicators and targets to drive continual improvement in the effectiveness of its HRDD system at reducing risks and harms associated with its salient issues.
Once the company has developed its human rights strategy and defined the indicators and targets it will use to drive progress on its objectives, it is ready to develop detailed action plans.
Companies typically develop action plans for specific combinations of salient issues, commodities, and geographies—such as child labor in Côte d’Ivoire’s cocoa industry—though plans may address multiple commodities, human rights issues, or countries simultaneously.
The process of developing action plans should build upon the knowledge gained through in-depth assessments, including relevant root cause analysis. The deployment of action plans relies heavily on in-country personnel, knowledge, and resources. The company should plan to support its local teams, and/or those of its suppliers, to carry them out.
The company has developed action plans to implement its human rights strategy and achieve its objectives in prioritized commodities and geographies.
In addition to “Basic,” the company is implementing action plans for its highest priority commodities and geographies, building awareness and capability among suppliers and other partners.
In addition to “Established,” the company is well advanced in implementing impact-focused action plans, and it is expanding action planning to additional at-risk suppliers, commodities, and geographies.
If a company’s own operations or business practices are directly causing or contributing to human rights harms, or potentially could cause or contribute to such harms, the company should cease those practices.
Addressing human rights issues may require adopting new business models or transforming existing ones. Companies might need to alter their product mix or reconsider certain business relationships and market operations, while avoiding the temptation to simply withdraw from high-risk countries. Progress on human rights requires engagement with governments, civil society, and industry peers to address underlying drivers of risk wherever possible. In the long run, sustained engagement is necessary to create safe and fair agricultural workplaces and value chains.
The company has examined its business practices to determine if any are contributing to human rights risks and harms, and it has prioritized improvement actions.
In addition to “Basic,” the company has secured senior management endorsement and buy-in from affected departments, and it has implemented changes to business practices that had been causing or contributing to human rights harms.
In addition to “Established,” the company routinely reviews and revises business practices that cause or contribute to human rights risks and harms, and it implements additional practices that have direct positive impacts on farmers and workers.
Capability building for suppliers is often an important enabler of human rights due diligence and should be included in most human rights strategies and action plans.
Many suppliers will need help to develop or improve their internal human rights-related systems and processes, adjust their business practices, better track and report data, and reduce the drivers of human rights risks or harms. Capability building for suppliers often implies formal training, but it can also include other kinds of programmatic investments. These include awareness-raising and consulting support to design and implement monitoring systems, manage risks, remediate harms identified, and track progress.
The company has conducted an assessment across its supplier base and uses it to prioritize specific groups of suppliers for training and to identify learning objectives for each group. It has begun providing basic-level training to some suppliers.
In addition to “Basic,” the company is building the skills and capabilities of key suppliers, enabling them to implement effective human rights due diligence of their own operations and supply chains.
In addition to “Established,” the company is building the capabilities of suppliers in all priority commodities and geographies, enabling suppliers to self-manage human rights risks and harms. Training is updated as needed to reflect supplier performance challenges and changes in risk profiles and regulatory requirements.
Within first mile operations, there are many target groups that can benefit from training and capability building.
Examples include the operations’ own staff, the service providers they work with (e.g. labor providers or providers of services such as crop spraying), agronomists or buying agents who visit farms on a regular basis, the farmers who sell to the operation, farm workers, and others. Training and awareness-raising programs in the first mile should be appropriate to stakeholders’ linguistic, cultural, and educational backgrounds, and to local levels of access to technology. Any training or awareness raising program should be respectful of the time constraints faced by trainees, especially during labor-intensive phases of agricultural cycles.
As part of its supplier assessment process, the company has identified the first mile operations in its supply chain that are most in need of capability building, and set key learning objectives for those operations. It has developed training plans and begun rolling out training to some first mile operations.
In addition to “Basic,” the company (and/or its supplier) continues to train first mile operations, building their capacity to implement effective human rights due diligence in their own operations and supply chains.
In addition to “Established,” the target audience for training extends beyond first mile operations to other actors in the first mile, such as farmers who supply to the first mile operation, labor recruiters, and farm workers. Capability building also continues for first mile operations, with training curricula updated as needed.
Companies rarely achieve human rights objectives alone. This is because business operations span diverse geographic, political, institutional, social, economic, and cultural contexts, with root causes of human rights risks typically extending beyond any single company’s control.
Companies can collaborate with partners across the private sector, government, and/or civil society. Forms of collaboration include public-private partnerships, multi-stakeholder groups, industry-specific initiatives, industry-led platforms and associations, and landscape approaches, among others. Together with partners, companies should explore collective ways to address common human rights risks, and design interventions that align different stakeholders’ actions to complement and support one another. This is particularly important when working on landscape- or country-level root cause issues that drive risk for all companies, not just in one supply chain.
Based on its assessments and supplier evaluations, the company has identified which human rights risks and supplier related risks it has the leverage to address by itself, and which will require collaboration, such as through multi-stakeholder initiatives, industry groups, or government engagement.
In addition to “Basic,” the company has identified collaborations that will help it achieve its human rights objectives, and it has started engaging with the relevant partners and/or joining existing initiatives.
In addition to “Established,” the company is an active member of one or more collaborative initiative(s) and commits funds and resources to ensuring their success.