Human Rights Due Diligence Systems for Conflict-Affected and High-Risk Areas
Conventional approaches to human rights due diligence often reach their limits in conflict-affected and high-risk areas. In these settings, risks and implementation challenges do not arise solely from formal processes, but also from volatile political developments, informal power structures, security concerns, and limited operational control.
We help companies meet human rights due diligence requirements and develop functional management systems that are adapted to the operational realities of complex and volatile environments while remaining aligned with applicable legal and regulatory expectations.
Many organizations have established human rights due diligence systems.
However, these systems are often designed for stable regulatory and organizational environments and may encounter structural limitations when applied in conflict-affected and high-risk areas. In such environments, human rights risks and implementation challenges are shaped by the interaction between local power structures, political dynamics, security conditions, and limited operational control.
01Business activities such as recruitment, procurement, security arrangements, or site operations may unintentionally influence local tensions and contribute to adverse impacts.
02Grievance, remediation, and prevention mechanisms often struggle to function effectively where access is restricted or trust is limited.
03Measuring effectiveness is frequently perceived as complex and therefore receives insufficient attention in practice.
04Decision-making and escalation pathways are rarely designed for volatile environments and may lose effectiveness when rapid responses are required.
05Information is often fragmented, contradictory, or delayed, making consistent risk assessments difficult.
These structural weaknesses can result in human rights risks being identified too late or managed inconsistently. At the same time, they make it more difficult to demonstrate the rationale behind decisions to internal and external stakeholders. The consequences range from reduced effectiveness of due diligence efforts and increased regulatory or liability risks to poor decisions regarding sourcing, investments, security arrangements, and operational activities. In volatile environments, organizations may also face the risk of unintentionally contributing to conflict dynamics or failing to adequately address adverse impacts.
For this reason, human rights due diligence in conflict-affected and high-risk environments should not be viewed merely as a procedural compliance requirement. It should be understood as an operational management system that enables informed, accountable, and risk-aware decision-making.
You operate, invest, or source from conflict-affected and high-risk environments.
You have formally established human rights due diligence processes, but implementation and effectiveness remain limited in complex operating contexts.
You seek to implement enhanced human rights due diligence measures that meet regulatory expectations while remaining operationally practical.
How we work
01
Assess the Existing System
We review existing governance structures, policies, responsibilities, decision-making processes, and implementation practices in the relevant volatile environments.
02
Identify and Prioritize Gaps
We identify where formal due diligence requirements, operational realities, and documentation practices diverge and determine which structural gaps most significantly affect the effectiveness and manageability of the system.
03
Design the Target System and Implementation Pathway
Based on these findings, we develop a coherent and context-sensitive HRDD system together with a pragmatic implementation roadmap. This includes clearly defined roles and responsibilities, decision-making and escalation procedures, governance arrangements, and performance indicators.
What you get
A context-sensitive and operationally effective HRDD system designed for conflict-affected and high-risk environments
Clearly defined responsibilities, transparent decision-making and escalation pathways, and structured documentation requirements
Consistent information flows and decision-making processes across relevant departments and functions
Defensible documentation that supports internal governance processes as well as external audits, reviews, and regulatory assessments
Structuring Human Rights Due Diligence Across the Full Lifecycle
We assess and design human rights due diligence systems across all core elements of the HRDD cycle, including risk identification, prevention and mitigation measures, grievance and remediation mechanisms, effectiveness assessments, and reporting processes.
02
Strengthening Governance and Decision-Making Structures
We review and develop roles, responsibilities, and decision-making pathways to ensure that human rights risks are identified, assessed, escalated, and integrated into operational and strategic decisions in a consistent manner.
03
Prioritization and Maturity Assessment of Existing Systems
Existing structures are evaluated not only for their formal existence but also for their practical effectiveness under volatile conditions. Particular attention is paid to how systems function when information is incomplete, security risks are elevated, and stakeholder environments are complex. This approach allows organizations to build on existing strengths, avoid unnecessary duplication, and improve efficiency while strengthening effectiveness.
04
Alignment with International Standards
Our work is aligned with the legal and regulatory frameworks relevant to your organization, including the United Nations Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, the German Supply Chain Due Diligence Act (LkSG), the EU Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Forced Labor Regulation. As a result, the systems we develop are both operationally practical and capable of meeting audit, compliance, and regulatory expectations.
How We Support You
01
Governance Structures & Policies
Many companies already have codes of conduct, human rights policies, or internal due diligence requirements in place. In conflict-affected and high-risk areas, however, these frameworks are often insufficient to effectively manage risks. Responsibilities may be unclear, processes may not be designed for complex operating conditions, regulatory requirements may only be partially operationalized, and information-sharing across relevant functions may be inconsistent.
We support you in the development and strengthening of governance structures, policies, and internal processes for human rights due diligence. Our work is aligned with the frameworks most relevant to your organization, including the United Nations Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, the German Supply Chain Due Diligence Act (LkSG), the EU Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Forced Labor Regulation.
Our focus is on building structures that remain effective under complex and rapidly changing operational conditions while addressing the specific challenges of conflict-affected and high-risk environments. We design systems that are proportionate to your organization's risk profile, available resources, and regulatory obligations.
The result is clearer accountability, more robust decision-making processes, and a defensible foundation for human rights due diligence, compliance requirements, and internal governance.
02
Grievance Mechanisms
Effective grievance mechanisms are a core component of human rights due diligence. In conflict-affected and high-risk environments, however, existing systems are often difficult to access, insufficiently trusted by affected stakeholders, or poorly integrated into internal decision-making and remediation processes.
We design and support the implementation of grievance, escalation, and remediation mechanisms that are adapted to the realities of the operating environment. This includes consideration of accessibility, confidentiality, security concerns, case management procedures, and escalation pathways. Our objective is to create systems that not only meet the expectations of relevant international standards but are also practical and usable in day-to-day operations.
This helps you improve your ability to identify risks and adverse impacts at an early stage, strengthen the effectiveness of due diligence processes, and establish transparent procedures for receiving, assessing, and addressing complaints.
Many organizations can demonstrate that policies, procedures, and mitigation measures exist. Demonstrating whether these measures are actually effective is considerably more challenging. In conflict-affected and high-risk environments, volatile conditions and limited access to reliable information often make it difficult to assess outcomes, track progress, and determine whether interventions are achieving their intended objectives.
We support you in developing practical approaches to effectiveness measurement and continuous improvement within their human rights due diligence systems. This includes the development of qualitative and quantitative indicators, internal review processes, and structured methods for integrating lessons learned from risk assessments, stakeholder engagement activities, grievance mechanisms, and operational experience. We also support the transparent communication of findings and progress to both internal and external stakeholders.
This enables you to make better-informed decisions, strengthen accountability, improve transparency, and continuously enhance the effectiveness of their HRDD systems.
Value
What you gain
01
Context-Sensitive HRDD Systems
You receive governance structures and processes specifically adapted to complex and volatile operating environments. This ensures that human rights due diligence remains manageable and effective even under rapidly changing conditions and can be consistently integrated into operational and strategic decision-making.
02
Accessible and Trusted Grievance Mechanisms
We help establish mechanisms that are accessible, credible, and trusted by relevant stakeholders. This improves the early identification of risks, complaints, and adverse impacts while enabling concerns to be addressed more effectively and consistently.
03
Effectiveness-Oriented Management and Communication
You receive practical approaches for assessing the effectiveness of your due diligence measures, together with a robust basis for internal and external communication. This enables progress to be evaluated more transparently, improvement measures to be managed more effectively, and decisions to be justified with greater confidence.
04
Reliable Documentation
Methodologies, responsibilities, decisions, and outcomes are documented in a transparent and systematic manner. This creates a reliable foundation for governance processes, audits, reporting requirements, investor engagement, and potential regulatory or legal review processes.
Practice examples
Anonymized project scenarios
The following scenarios are generalized and do not include confidential client, country, or project details.
01
Building an HRDD System for a Changing Risk Environment
Context
A company operated in a region where security conditions were deteriorating due to the expansion of an armed conflict.
Challenge
The organization lacked structured processes for assessing human rights risks, as well as clearly defined responsibilities and escalation pathways. At the same time, business partners expected evidence of robust due diligence despite not being subject to equivalent regulatory requirements themselves.
Approach
We developed a risk-based HRDD framework with clearly defined responsibilities, risk assessment procedures, escalation processes, and documentation requirements.
Outcome
The company gained a practical and operationally viable HRDD system that enabled the structured assessment of human rights risks and strengthened its ability to respond to stakeholder expectations.
02
Addressing Grievance and Remediation Gaps in a High-Risk Supply Chain
Context
A company needed to demonstrate how concerns and allegations arising within a difficult-to-access supply chain were received, assessed, and addressed.
Challenge
Existing reporting channels formally existed but were difficult for relevant stakeholders to access and were insufficiently integrated into management and compliance processes.
Approach
We redesigned accessibility measures, case management procedures, escalation pathways, and remediation processes based on the specific risk profile of the operating environment.
Outcome
The resulting mechanism became more transparent, more accessible to stakeholders, and more closely integrated with management, governance, and compliance decision-making processes.
What sets us apart
Our HRDD systems are practical, context-sensitive, and risk-based.
01
Practical
We focus on developing and strengthening structures and processes that remain usable under real operational conditions and can be integrated into your day-to-day business activities.
02
Context-Sensitive
We account for volatility, restricted access, security concerns, and asymmetric information environments from the outset, ensuring that systems and processes reflect your operational realities rather than idealized assumptions.
03
Risk-Based
We design structures and processes that enable organizations to prioritize human rights and environmental risks according to their severity and relevance. This allows you to allocate resources more effectively and address significant risks at an earlier stage.
Key questions from initial conversations about scope, process, and practical implementation.
Does every company operating in conflict-affected and high-risk environments need an enhanced HRDD system?+
No. The scope and design of human rights due diligence should be proportionate to the legal frameworks applicable to your organization, your risk exposure, business activities, size, and ability to influence outcomes. We support both companies with extensive regulatory obligations and organizations seeking to establish a practical and proportionate due diligence system that meets the expectations of customers, investors, lenders, and business partners.
Can existing compliance or ESG structures be used as a foundation?+
Yes. Existing compliance, ESG, risk management, or governance structures typically provide the starting point. Rather than replacing existing systems, we build on them and strengthen areas that are particularly important in conflict-affected and high-risk environments, including accountability structures, escalation pathways, effectiveness measurement, and operational implementation.
What role do the UNGPs, CSDDD, and national legislation such as the German Supply Chain Due Diligence Act (LkSG) play in implementation?+
These frameworks define the expectations and requirements for human rights due diligence and increasingly shape the expectations of business partners, investors, lenders, auditors, and regulatory authorities. We identify the requirements most relevant to your organization and translate them into practical governance structures, operational processes, and decision-making mechanisms that can be applied in day-to-day business operations.
How can an HRDD system remain effective in conflict-affected and high-risk environments?+
The key is a risk-based and context-sensitive design. An effective HRDD system must be able to function despite limited information, volatile operating conditions, security constraints, and rapidly changing circumstances. We therefore design systems that remain operationally effective under uncertainty and can adapt as risks evolve.
Is an HRDD system primarily a compliance tool, or does it also provide operational value?+
Human rights due diligence is not merely a compliance exercise. When implemented effectively, an HRDD system strengthens decision-making, escalation processes, risk management, and organizational accountability. Particularly in volatile environments, it provides structure and guidance in situations where traditional risk management or management systems may no longer be sufficient.
How quickly can a functioning HRDD system be established?+
This depends largely on the structures and processes already in place. We typically begin with a structured assessment of existing systems and identify priority gaps that can be addressed in the short term. Our objective is to create a phased implementation pathway that delivers immediate practical improvements while building towards a more comprehensive system over time.
Do all elements of an HRDD system need to be implemented at the same time?+
No. Effective human rights due diligence systems are usually developed in phases. The key is clear prioritization. Organizations should first strengthen the elements that are most critical for risk management, decision-making, and accountability. Additional components, such as advanced reporting, monitoring, effectiveness measurement, and continuous improvement mechanisms, can then be developed progressively as the system matures.
