Actions extracted from: Human rights in global value chains investor toolkit

Actions:

1. Raise modern slavery issues in direct company engagements

Engage companies through structured dialogue on governance, risk identification, remediation processes, and oversight of high-risk value chains to strengthen accountability and escalate where material risks persist (pp. 12–17; 34–35).

2. Request disclosure on supply chain due diligence

Seek transparent reporting on risk mapping beyond tier 1, use of grievance mechanisms, audit findings, and evidence that corrective actions are implemented, enabling stronger investor assessment of modern slavery risk management quality (pp. 13–16; 21–23).

3. Encourage adoption of UNGP- and OECD-aligned policies

Promote alignment with the UN Guiding Principles and OECD Guidelines to ensure systematic human rights due diligence, risk prioritisation, prevention, mitigation, and remediation across operations and value chains (pp. 28; 34–35).

Actions extracted from: Modern slavery and remediation – an investor’s guide

Example: Multiple ESG issues (illustrative)

Actions:

1. Escalate engagement to senior leadership and boards

Where companies are uncooperative or withhold information, arrange meetings with senior management, Board Chairs, or Directors to increase leverage and reinforce expectations regarding remediation, transparency, and compliance with due diligence obligations (p. 17).

2. Use shareholder rights and public accountability mechanisms

Consider filing or supporting shareholder resolutions, voting against directors or financial statements, and publishing statements where companies fail to provide adequate remedy or disclosure, signalling that inaction carries governance consequences (p. 17).

3. Pursue collaborative escalation or responsible divestment as a last resort

Collaborate with other investors to strengthen leverage, utilise formal complaints mechanisms, and, where all engagement avenues are exhausted, consider responsible divestment accompanied by clear rationale and expectations for remediation (p. 17).

Actions extracted from: A little less conversation, a little more action: 10 lessons learned from 10 years of helping investors to tackle climate

Actions:

1. Disclose engagement activity and voting records

Report on engagement objectives, company responses, and voting actions to demonstrate how stewardship has addressed material ESG risks and supported accountability in portfolio companies (pp. 33–37).

2. Link reporting to measurable ESG indicators

Use clear, comparable data and forward-looking indicators to evidence progress, ensuring stewardship outcomes are connected to defined objectives rather than narrative claims (pp. 15–17).

3. Translate reporting into demonstrable action

Move beyond disclosure to show how engagement outcomes influenced escalation, voting, or capital allocation decisions, reinforcing that reporting is a means to drive real-world change (pp. 27–29).

Actions extracted from: Good practice toolkit: Strengthening modern slavery responses

Actions:

1. Prioritise suppliers demonstrating respect for human rights

Incorporate human rights due diligence into supplier selection and tender processes, giving greater weighting to suppliers that demonstrate sustained respect for labour rights and robust due diligence systems (p. 19).

2. Engage stakeholders in policy design to identify material risk drivers

Use meaningful consultation with workers, unions, and civil society to inform risk assessment and policy development, ensuring ESG analysis targets real pathways to exploitation rather than relying on generic policies (pp. 8–9).

3. Strengthen risk detection through effective grievance and worker engagement mechanisms

Integrate insights from worker-led grievance mechanisms, surveys, and digital tools into ongoing monitoring and risk assessment to identify emerging modern slavery risks beyond audit-based approaches (pp. 11–13).

Actions extracted from: Bridging ESG silos: The intersection of climate change and modern slavery

Actions:

1. Integrate climate-related transition and physical risks into modern slavery risk assessments

Assess how decarbonisation pathways, renewable energy supply chains, and climate-related disruptions may increase vulnerability to forced labour, particularly in high-risk sectors and regions exposed to transition pressures (pp. 18–21).

2. Engage high-risk sectors linked to the energy transition

Prioritise engagement with companies operating in sectors such as mining, agriculture, and manufacturing where demand for transition-critical materials may heighten exploitation risks, and seek strengthened human rights safeguards (pp. 24–27).

3. Align climate action with just transition principles

Encourage companies to embed just transition commitments into climate strategies, ensuring decarbonisation efforts do not exacerbate worker vulnerability and instead support labour rights, social protection, and fair working conditions (pp. 30–33).

Actions extracted from: Preventing modern slavery and human trafficking: An agenda for action across the financial services sector

Actions:

1. Embed prevention into core business strategy and governance

Integrate modern slavery and human trafficking risks into board oversight, internal controls, and enterprise risk frameworks to move beyond reactive compliance and enable early identification and prevention of harm (pp. 14–18).

2. Address structural drivers of vulnerability in supply chains

Identify and mitigate root causes such as recruitment fees, debt bondage, insecure migration pathways, and harmful purchasing practices that heighten exploitation risks (pp. 22–27).

3. Strengthen cross-sector collaboration and victim-centred prevention strategies

Collaborate with governments, civil society, and industry initiatives to improve data sharing, survivor-informed approaches, and coordinated prevention efforts in high-risk sectors and regions (pp. 31–36).

Actions extracted from: Engaging affected stakeholders: The emerging duties of board members

Actions:

1. Clarify responsibility for affected stakeholders at board level

Ensure the board understands who may be most vulnerable to labour exploitation across operations and supply chains and integrates this analysis into oversight processes (pp. 19–20).

2. Oversee appropriate human rights mechanisms

Review whether grievance mechanisms, whistle-blower protections, due diligence systems and risk registers adequately address modern slavery risks and function effectively (pp. 20–22; 26–27).

3. Strengthen board skills and expertise on human rights

Ensure directors possess, or have access to, sufficient knowledge and experience to oversee human rights and modern slavery risks within ESG and sustainability frameworks (pp. 5–6; 21).

Actions extracted from: Engaging affected stakeholders: The emerging duties of board members

Actions:

1. Integrate human rights into strategic decision-making

Ensure directors consider human rights consequences, including labour exploitation risks, when fulfilling their duty to act in the best interests of the company (p. 26).

2. Require oversight of due diligence implementation

Establish clear board-level responsibility for putting in place and overseeing due diligence policies and reporting on their effectiveness (p. 26).

3. Monitor, evaluate and disclose progress

Ensure ongoing board review of modern slavery performance and transparent disclosure of engagement, due diligence and remediation outcomes (pp. 21–22; 15–17).

Actions extracted from: Engaging affected stakeholders: The emerging duties of board members

Actions:

1. Establish clear board-level oversight structures

Allocate responsibility for modern slavery risk to a sustainability or risk committee, ensuring regular reporting from management and documented board review (pp. 10–13; 20–21).

2. Integrate modern slavery into enterprise risk governance

Embed human rights and labour exploitation risks into enterprise risk registers and board discussions on strategy, resilience and long-term value (pp. 19–20; 26).

3. Link executive incentives to human rights performance

Incorporate ESG and human rights criteria into executive KPIs and remuneration frameworks to reinforce accountability for preventing and addressing exploitation risks (p. 13).

Actions extracted from: Emerging market perspectives on business and human rights measures and economic development

Actions:

1. Assess unintended consequences alongside intended outcomes

Evaluate how modern slavery and due diligence measures affect jobs, livelihoods, and vulnerability in EMDE contexts to ensure interventions reduce harm rather than shift or conceal it (pp. 9; 36–38).

2. Balance risk assessment with material impact on workers

Ensure monitoring frameworks track whether due diligence efforts meaningfully reduce forced labour and child labour risks, rather than concentrating resources primarily on audits and documentation (pp. 16–17; 39–40).

3. Reward positive labour outcomes, not just policy compliance

Incorporate incentives such as preferential market access, longer-term contracts, or pricing structures that recognise demonstrable improvements in working conditions (p. 46).

Actions extracted from: Emerging market perspectives on business and human rights measures and economic development

Actions:

1. Design traceability and monitoring systems with local stakeholders

Ensure measurement, monitoring and traceability processes are practical in informal and resource-constrained contexts and reflect local data realities (pp. 32–33; 46).

2. Ease the burden of proof through collaborative data solutions

Develop shared traceability tools and public databases that reduce duplication, avoid siloed reporting, and support credible verification without excluding higher-risk geographies (p. 46).

3. Align ESG data and benchmarks with real-world BHR outcomes

Engage ESG data providers to improve incorporation of human rights performance indicators and reduce over-reliance on policy disclosures or controversy-based metrics (p. 47).

Actions extracted from: Emerging market perspectives on business and human rights measures and economic development

Actions:

1. Track remediation effectiveness, not just incident resolution

Measure whether workers who experienced exploitation receive effective remedy and whether corrective actions prevent recurrence, rather than closing cases administratively (pp. 39–40).

2. Monitor economic impacts of compliance measures

Assess whether disengagement, contract termination, or strict compliance thresholds unintentionally worsen vulnerability in higher-risk markets, shifting rather than reducing harm (pp. 36–38).

3. Incorporate supplier capacity-building indicators

Track investment in training, systems strengthening, and local institutional capacity as leading indicators of sustained risk reduction in modern slavery exposure (pp. 32–33; 46).

Actions extracted from: Corporate human rights benchmark investor guidance

Actions:

1. Use CHRB indicators to assess forced labour risk management

Benchmark company policies, due diligence systems, and grievance mechanisms against CHRB indicators aligned with the UNGPs and OECD Guidelines to test credibility beyond policy commitments (pp. 5; 7; 13).

2. Press for saliency-based human rights risk assessments

Encourage companies to identify and assess their most salient human rights risks — including forced labour — across operations and supply chains, rather than relying on generic ESG risk systems (pp. 8–9; 13).

3. Ensure recruitment and supplier practices prohibit forced labour drivers

Engage companies on prohibiting recruitment fees, document retention, and other practices linked to coercion, particularly in high-risk sectors (p. 13).

Actions extracted from: Corporate human rights benchmark investor guidance

Actions:

1. Prioritise high-risk sectors for forced labour exposure

Use CHRB sector risk insights (e.g., agriculture, apparel, ICT, automotive) to guide engagement on modern slavery risks in value chains (pp. 12–13).

2. Assess supply chain leverage and responsible purchasing practices

Move beyond supplier codes of conduct to evaluate whether companies actively support and monitor suppliers to meet human rights expectations (p. 10).

3. Evaluate effectiveness of grievance and remedy systems

Test whether grievance mechanisms ensure rightsholder trust, transparency, and access to remedy — critical for addressing forced labour harms (pp. 9–10).

Actions extracted from: Corporate human rights benchmark investor guidance

Actions:

1. Reference CHRB sector risk frameworks in stewardship

Align engagement priorities with CHRB-identified high-risk sectors and issue areas (including forced labour, responsible sourcing, and working conditions) to ensure consistency with internationally recognised expectations (pp. 12–13).

2. Promote OECD-aligned supply chain due diligence practices

Encourage companies to incorporate contractual requirements and supplier expectations consistent with OECD Due Diligence Guidance, particularly in high-risk sourcing contexts (p. 15).

3. Use benchmark scorecards to drive disclosure improvement

Leverage publicly available rankings, company scorecards, and detailed datasets to push for stronger transparency on forced labour prevention and remediation practices (pp. 5–6).