Modern slavery remains a pressing global issue, with an estimated 50 million people globally trapped in forced labour and exploitative working conditions. Businesses operating in international supply chains must take proactive steps to combat modern slavery by implementing a strong compliance programme. A well-designed framework not only ensures ethical sourcing but also mitigates legal, reputational and financial risks.
Governments, too, are increasingly focused on combating human rights abuses in international supply chains, by implementing legislation which requires organisations to conduct due diligence and report on efforts to eliminate any abuses. This has created a growing need for companies to deliver robust compliance programmes to ensure their supply chains are free from human rights violations.
As such, having the right team in place to manage supply chain due diligence is no longer non-negotiable.
Key regulatory approaches
A number of key laws have been introduced across the globe in recent months. For more information on these, please download our global hiring guide for ESG, Sustainability and Human Rights, which details each region’s approach to legislation.
Arguably the most prominent of these is the European Union’s Corporate Sustainability Due Diligence Directive which mandates due diligence for large companies operating within the EU; other geographies have taken the lead from this and have been implementing their own local laws.
Key features of an effective compliance programme
Corporate compliance, ESG and Risk professionals looking to combat human rights abuses in supply chains must understand that this effort requires an adaptable approach, balancing alignment with international standards and accommodating jurisdiction-specific requirements.
Key components include policy development, risk assessments, setting up due diligence processes, creating monitoring and reporting mechanisms and delivering training and awareness to the entire organisation.
Team Structure
At present, only Germany has mandated the appointment of a Human Rights Officer to comply with their local due diligence law (LkSG). However, it is widely acknowledged as best practice for any large organisation to make this appointment.
Some firms pass on the responsibility to ESG, legal or compliance teams. However, the workload is significant, and not easily spread between a team.
Appointing a Human Rights Officer
Even where not legally required, many large companies voluntarily appoint a Human Rights Officer to:
- Oversee all matters pertaining to human rights due diligence and compliance.
- Manage whistleblower and grievance mechanisms.
- Ensure alignment with international human rights frameworks (e.g., UN Guiding Principles on Business & Human Rights) and compliance with both local and international laws.
- Develop policies, set up due diligence processes, create monitoring and reporting mechanisms and deliver training and awareness to the wider organisation.
Certain industries also have specific requirements, including:
Financial Sector: Institutions following the OECD Guidelines for Multinational Enterprises or UN Principles for Responsible Banking are expected to implement human rights due diligence and appoint someone to oversee this function.
Extractive & Manufacturing Industries: Companies in high-risk sectors (e.g., mining, apparel) often face greater scrutiny and are encouraged to appoint dedicated human rights leads.
Where should the human rights function sit?
This is a topic of much debate, and there is no right or wrong answer as it really depends on the size and location of the organisation – and the industry sector in which it operates.
Standalone Human Rights Department (Ideal for Large, High-Risk Companies)
Best for: Multinationals, high-risk industries (extractives, apparel, tech)
Pros:
✅ Dedicated leadership & resources
✅ Strong independence from commercial pressures
✅ Enhanced visibility in ESG and sustainability strategies
Cons:
❌ High cost & resource-intensive
❌ Requires cross-departmental coordination
Within the Compliance or Legal Department
Best for: Companies focused on regulatory compliance (finance, pharmaceuticals)
Pros:
✅ Strong alignment with due diligence laws
✅ Legal expertise ensures risk mitigation
Cons:
❌ May prioritise legal protection over proactive human rights action
❌ Risk of reduced stakeholder engagement
Part of the ESG or Sustainability Function
Best for: Consumer-facing industries (retail, manufacturing, food & beverage)
Pros:
✅ Aligns with corporate social responsibility (CSR) goals
✅ Strong stakeholder & supply chain engagement
Cons:
❌ May lack legal and compliance enforcement power
❌ Can be seen as a PR-driven initiative rather than a core governance function
Integrated into Corporate Risk Management
Best for: Companies managing geopolitical risks (energy, tech, telecoms)
Pros:
✅ Human rights risks are assessed alongside financial & operational risks
✅ Strong alignment with enterprise risk management (ERM) frameworks
Cons:
❌ Potential for human rights to be deprioritised among other risks
❌ May lack direct expertise in human rights laws
Conclusion
A well-structured human rights function is not just a compliance requirement, it’s a strategic advantage that enhances reputation, mitigates risk and aligns with global sustainability goals. Whether embedded in compliance, ESG, or as a standalone function, companies must ensure clear leadership, strong governance and proactive engagement to effectively address human rights challenges.
For further information regarding human rights recruitment, please contact Adam Bond for a friendly chat.
