Solari advises organizations designing human rights due diligence programs aligned with the EU Corporate Sustainability Due Diligence Directive, the UN Guiding Principles on Business and Human Rights, and the OECD Due Diligence Guidance. One domain within a broader advisory practice.
Human rights due diligence is the process through which organizations identify, assess, prevent, mitigate, and account for adverse human rights impacts in their own operations and across their value chains. It is the mechanism through which the UN Guiding Principles on Business and Human Rights translate from policy commitment into operational practice — mapping exposure, prioritizing action, and building the documentation infrastructure that demonstrates accountability to regulators, investors, and affected communities.
The EU Corporate Sustainability Due Diligence Directive has shifted human rights due diligence from a voluntary best practice to a legal obligation for organizations above defined thresholds operating in or supplying to the EU market. For organizations within scope, the question is no longer whether to conduct HRDD but how to design an HRDD process that functions as genuine risk management rather than documentation compliance. The distinction matters because the Directive requires organizations to act on what they find, not merely to record that they looked.
The structural challenge is that human rights due diligence by definition reaches beyond the organization's direct operations into relationships it does not control. Effective HRDD programs are designed for that condition — built to surface salient human rights risks in complex value chains and produce findings that drive operational decisions, not reports that satisfy disclosure requirements while leaving underlying exposure unchanged.
The EU Corporate Sustainability Due Diligence Directive establishes mandatory human rights due diligence obligations for large companies operating in the EU. Organizations within scope must identify and address adverse impacts, establish grievance mechanisms, and adopt transition plans aligned with the Paris Agreement.
Phased implementation from 2027. Transposition into member-state law underway.
The UN Guiding Principles on Business and Human Rights (Ruggie Framework) establish the foundational three-pillar structure: state duty to protect, corporate responsibility to respect, and access to remedy. The HRDD process is derived from Pillar II and is the operational mechanism through which corporate responsibility to respect human rights is discharged.
Endorsed by the UN Human Rights Council in 2011. The baseline standard for all subsequent mandatory HRDD instruments.
The OECD Due Diligence Guidance for Responsible Business Conduct provides the most operationally detailed framework for conducting HRDD across value chains. Sector-specific supplements exist for extractive industries, garment, agriculture, and financial services. OECD National Contact Points provide a grievance mechanism for affected communities.
The Voluntary Principles on Security and Human Rights govern extractive sector operations in conflict-affected areas. The ICMM Human Rights in the Mining and Metals Sector guidance applies to mining companies. The German Supply Chain Act and French Duty of Vigilance Law preceded CSDDD and remain in force for organizations within their jurisdictions.
Map actual and potential adverse human rights impacts across operations and value chain relationships. Prioritize by severity and likelihood. Identify the salient human rights risks given the organization's sector, geography, and supply chain structure.
Embed findings into procurement decisions, supplier contracts, operational procedures, and governance structures. Where the organization causes or contributes to harm, it must cease or prevent the conduct. Where harm is directly linked through business relationships, it must use leverage to influence the responsible party.
Establish indicators and review processes that assess whether responses to identified impacts are effective. HRDD is a continuous process, not a one-time assessment. Tracking requires mechanisms that capture whether impacts have been prevented, mitigated, or remediated over time.
Report publicly on how human rights impacts are identified and addressed. The EU CSDDD and CSRD establish specific disclosure requirements. Communication must be sufficient to enable external stakeholders to assess the adequacy of the organization's response — not merely to assert that an HRDD process exists.
The HRDD frameworks — UNGPs, OECD Due Diligence Guidance, CSDDD implementation guidance — specify what organizations must do. They do not resolve the substantive questions that determine whether an HRDD program actually functions: which human rights risks are salient for this organization given its specific value chain, how to design a credible prioritization methodology when resources are constrained, how to build leverage with a supplier that resists engagement, or how to structure a grievance mechanism that affected communities will actually use.
Solari's HRDD advisory work engages those substantive questions directly. Engagements cover human rights impact assessment design, salient risk identification and prioritization, supply chain mapping and risk exposure analysis, grievance mechanism design, CSDDD readiness assessments, and the governance and reporting infrastructure that satisfies regulatory disclosure requirements without reducing HRDD to a documentation exercise.
The analytical foundation is grounded in institutional human rights research: research contribution to UN Human Rights Council Report A/HRC/54/30 on contemporary forms of slavery, produced as a Graduate Research Analyst under the UN Special Rapporteur, and active advisory engagement with organizations entering CSDDD scope in the extractive sector, where supply chain human rights risk is most structurally complex.
HRDD stands for human rights due diligence. It is the ongoing process through which organizations identify, assess, prevent, mitigate, and account for adverse human rights impacts in their operations and across their value chains. The term is rooted in the UN Guiding Principles on Business and Human Rights, which established HRDD as the primary mechanism for discharging the corporate responsibility to respect human rights. HRDD is distinct from legal compliance in that it requires organizations to address impacts irrespective of whether local law prohibits the underlying conduct.
The requirements depend on which instruments apply. The EU CSDDD requires large organizations within scope to identify and address adverse human rights and environmental impacts, establish grievance mechanisms, adopt climate transition plans, and report publicly on their HRDD processes. The UN Guiding Principles establish a framework of identify, act, track, and communicate that applies to all businesses regardless of size or jurisdiction. The OECD Due Diligence Guidance provides the most operationally detailed requirements. Organizations subject to the German Supply Chain Act or French Duty of Vigilance Law face additional obligations under those national regimes. The content requirements are broadly consistent across instruments; the legal consequences of non-compliance differ significantly.
The first step is identifying and assessing actual and potential adverse human rights impacts across the organization's operations and value chain relationships. This requires mapping the value chain to understand which relationships and activities carry human rights exposure, then assessing those exposures against internationally recognized human rights standards to identify which are salient given the organization's specific context. Prioritization by severity and likelihood follows. Organizations routinely underestimate how far into the value chain the assessment must reach — the instruments require engagement with supply chain relationships the organization does not directly control.
The EU Corporate Sustainability Due Diligence Directive (CSDDD) establishes mandatory human rights and environmental due diligence obligations for large companies operating in the EU. It applies to EU companies with more than 1,000 employees and net worldwide turnover above €450 million, and to non-EU companies with net EU turnover above the same threshold. Implementation is phased: the largest organizations come into scope first, with smaller organizations entering scope in subsequent years. Member states must transpose the Directive into national law. Organizations within scope that fail to conduct adequate HRDD face civil liability and administrative penalties.
Salient human rights risks are those that represent the most severe potential human rights impacts through an organization's activities and relationships, prioritized by the severity of harm and the number of people potentially affected rather than by the probability of legal liability. The concept of salience comes from the UN Guiding Principles and is central to the HRDD methodology because organizations cannot address all human rights risks with equal resources. A credible HRDD program demonstrates that it has identified which risks are most salient for its specific value chain and has allocated attention and resources accordingly — the prioritization methodology is itself a point of regulatory scrutiny.
ESG reporting is a disclosure function: communicating social, environmental, and governance performance to investors and other stakeholders through standardized metrics and frameworks. Human rights due diligence is an operational function: a process of identification, action, tracking, and communication that is designed to prevent and address harm rather than to report on it. The two are related — HRDD findings feed into ESG disclosures, and the EU CSRD creates disclosure obligations that parallel the CSDDD's due diligence obligations — but they are distinct in purpose. An organization can produce comprehensive ESG disclosures while conducting no meaningful HRDD, and the gap between the two is increasingly the focus of regulatory enforcement and civil liability.
Every engagement begins with a structured session in which Solari assesses the HRDD problem at hand, identifies which regulatory instruments apply, and maps the gap between the organization's current state and what genuine compliance requires. A written analysis follows within three days. Where the scope warrants a sustained engagement, a retainer proposal accompanies the diagnostic.
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