About this paper

This guide supports private markets investors in applying human rights due diligence (HRDD) aligned with the UN Guiding Principles on Business and Human Rights (UNGPs). It serves as a foundational tool for early adopters and a reference for established practitioners. It applies most directly to control investors in private equity, infrastructure, and forestry. It is also relevant for limited partners (LPs), minority investors, and fund-of-fund managers to assess and influence general partners’ (GPs) human rights approaches. Case studies, such as those from StepStone and AP6, illustrate LPs’ engagement with GPs on human rights.

Why do it

Investors are increasingly expected to avoid infringing on human rights and address negative impacts. Despite international frameworks such as the UNGPs (2011) and OECD Guidelines, many investors have not made formal policy commitments.

Legislative developments—including the EU’s proposed Corporate Sustainability Due Diligence directive and laws in the UK, Germany, and Australia—are driving regulatory pressure. Meeting human rights expectations can help investors manage risks in areas like forced labour, community displacement, and health and safety, while aligning with broader ESG goals. For example, investors in infrastructure are often already required to conduct social impact assessments to maintain a social licence to operate.

How to do it

Investors should adopt a three-part approach:

• A policy commitment to respect internationally recognised human rights;
• Due diligence to identify, assess, prevent, and mitigate impacts;
• Provision or support for access to remedy.

This framework is cyclical and continuous, with all elements active throughout the investment lifecycle.

Establishing a policy commitment

Policies should reference global standards such as the UNGPs, International Bill of Human Rights, and ILO Conventions. They must be approved at senior levels, embedded in governance, and communicated transparently.

Policies should address both direct operations and value chains and include commitments to identify and engage with stakeholders, respect local laws and traditions, and apply consistent expectations across business relationships.

Improvements may include extending whistleblower coverage, implementing supplier codes across the value chain, and defining internal governance structures to manage severe risks.

Conducting due diligence

Due diligence should inform decisions at all stages. This includes country, sector, and company-level risk analysis; stakeholder mapping; and value chain assessment.

Investors should develop risk registers, conduct enhanced assessments where risks are high, and use tools such as site visits, stakeholder interviews, and remote assessments where necessary. Value chain analysis should prioritise Tier 1 suppliers and extend as far as feasible, with traceability audits and tools like SMETA.

Investors are advised to evaluate third-party due diligence with the same rigour as internal assessments. Continuous assessment is essential and should consider updates to strategy, operations, or stakeholder dynamics.

Providing access to remedy

Investors should assess their connection to impacts—whether they cause, contribute, or are directly linked—and respond accordingly. Remedy can include financial compensation, apologies, management reforms, or structural changes.

Grievance mechanisms should be assessed for legitimacy, accessibility, equity, transparency, and alignment with human rights standards. Stakeholder engagement is critical in designing and evaluating these systems.

Examples such as the Fair Food Program illustrate effective, rights-based grievance channels that include worker education, independent reporting, and regular audits.

Next steps

Investors should monitor regulatory developments and further embed the UNGPs. The PRI will continue to expand its human rights resources and support investor alignment with international standards.