Grievance Mechanisms: What the Law Requires and What Actually Works
- Aug 21, 2025
- 6 min read
Updated: 1 day ago
Treat global helplines as a checkbox. Invest your energy in tools that actually reach workers.
What the Law Actually Requires
Buyers Must Maintain Independent Helplines — and Remain Responsible for Risk, Even in Silence
HRDD regulations, including LkSG, CSDDD,, and the U.S. National Action Plan — require companies to establish complaints procedures that are accessible across their value chains. Buyers must therefore maintain an independent helpline or complaints mechanism as part of their human rights due diligence obligations. This responsibility exists regardless of whether complaints are received.
Under HRDD frameworks, access to remedy is not conditional on usage; it is a structural requirement. A buyer cannot assume that silence indicates the absence of harm. The absence of complaints does not equal the absence of risk. In fact, regulations hold companies accountable not only for harms they know about, but for risks they should have reasonably identified.
A helpline alone will never surface the full spectrum of those risks.
Given that buyer-led complaints mechanisms often experience extremely low utilization and limited worker trust, companies should implement them to meet regulatory obligations — but shift serious attention and resources toward tools that actively engage workers and proactively identify risk.
This is where stronger local tools — including supplier-owned operational grievance mechanisms and proactive engagement tools such as worker surveys — become essential.
While a supplier's own internal operational grievance mechanism does not alone satisfy the buyer's obligation to operate a complaints mechanism under LkSG, CSDDD, or the UNGPs, effective operational grievance mechanisms at a site level is critical for risk reduction and worker safety. They are where issues can be raised early, addressed quickly, and prevented from escalating.
Proactive Approaches
Unlike complaints lines, which rely on individuals choosing to report harm, surveys systematically engage the broader workforce and generate insight regardless of whether workers are prepared to file a complaint. They can surface patterns related to wages, harassment, excessive hours, retaliation fears, or lack of trust in management, issues that may never reach a formal grievance channel or show up in an audit. Surveys help buyers proactively engage workers and identify leading indicators of risk rather than waiting for crises to emerge.
The most effective due diligence systems combine independent helplines, strong supplier-level operational grievance mechanisms, and proactive engagement tools to meaningfully support and protect workers. Together, these layers create a more complete system of prevention, escalation, and remedy. However, many teams operate with limited resources, requiring a strategic — rather than purely holistic — approach to implementation.
In these cases, global helplines should be treated as a compliance baseline: necessary to meet regulatory expectations, but insufficient as a standalone risk identification tool. The greater investment of time, budget, and leadership attention should be directed toward mechanisms that actually reach workers, build trust, and surface risk in real time. Tools that proactively engage workers and strengthen site-level resolution capacity are far more likely to reduce harm than complaint channels that sit unused.
What Actually Makes a Grievance Mechanism Work
Effective Grievance Mechanisms Are a Form of Due Diligence and Early Risk Identification
Effective grievance mechanisms need to be known, trusted, transparent, rights-aligned, accessible, two-way, and fast to respond (UNGPs set out eight effectiveness criteria).
Most importantly workers who see their feedback lead to action keep using the system. Those who don't, stop. (Read a Case Study)
This is straightforward in principle. It's extraordinarily hard to deliver at a global level — and this is precisely why globally managed helplines fall short. Building worker awareness requires consistent, local promotion. Building trust requires cultural and linguistic fluency, local credibility, and evidence that issues actually get resolved. Two-way communication requires local capacity to investigate and follow up. None of this scales cleanly across dozens of countries and languages from a central helpline.
Regulations require global complaints channels — and you should have one. But the honest reality is that meeting the letter of that requirement and actually reaching workers are two different things. A report from the Ethical Trade Initiative (ETI) found that "while many companies report the existence of grievance mechanisms, there is often little evidence that these are used by workers, demonstrating a gap between policy and practice.”
The mechanisms that work are the ones embedded in how suppliers operate, supported by local engagement, and backed by real follow-through.
Helplines vs. Operational Grievance Mechanisms
Helplines and operational grievance mechanisms are often used interchangeably, but they serve distinct purposes — and confusing them can create serious gaps in both legal compliance and worker protection.
Buyers should require both operational grievance mechanisms and independent HRDD complaints processes in order to effectively support and protect workers.
Helplines (Buyer's Obligation)
Under Human Rights Due Diligence (HRDD) frameworks, including emerging regulations such as CS3D and LkSG, buyers are expected to provide access to remedy across their value chain. This obligation is typically fulfilled through buyer-level complaints processes or third-party helplines.
These mechanisms should be designed to be accessible not only to direct employees, but to workers throughout the supply chain, as well as farmers, contractors, and affected community members. They are independent from site management and should be backed by clear investigation procedures, escalation pathways, protection against retaliation, and meaningful remediation processes. Importantly, this is the buyer’s responsibility — not the supplier’s.
In theory, these helplines exist to fill gaps where state-based grievance systems are weak or inaccessible. In practice, however, they are difficult to design and manage effectively. Many brands rely on country-specific NGO channels, multi-stakeholder initiative grievance lines, or large third-party providers such as Navex or SpeakUp. While these systems can provide independence and formal structure, they often risk becoming compliance mechanisms in form rather than function — technically available, but rarely trusted by workers or poorly integrated with site-level resolution processes.
Treat global helplines as a checkbox. Invest your energy in tools that actually reach workers.
Operational Grievance Mechanisms
Operational grievance mechanisms, by contrast, are internal to a facility and are essential for day-to-day worker voice. These include HR complaint channels, tech tools and apps like WOVO Connect, worker committees, suggestion boxes, supervisor reporting structures, union representatives, and internal hotlines. When designed and supported well, they are where real resolution should occur: close to the issue, embedded in daily operations, and capable of addressing concerns quickly. However, they are often constrained by power imbalances, fear of retaliation, weak documentation practices, and limited escalation pathways. Workers may know these channels exist, but confidence erodes when complaints stall, require escalation, or fail to result in visible remedy.
Operational mechanisms alone are insufficient to satisfy buyer HRDD obligations. At the same time, buyer-level helplines cannot compensate for weak site-level systems. The most common failure point is the gap between system design and worker experience.
Many facilities can describe their grievance procedures in detail, yet far fewer can demonstrate worker trust, safe escalation, consistent follow-through, and meaningful remedy. Low complaint volume is frequently interpreted as success, when in reality it may signal fear, futility, or lack of awareness. In a functioning system, steady and diverse utilization is often a healthier indicator than silence.
For buyers, the key is not simply verifying that both types of mechanisms exist, but assessing how they function and interact. (What Buyers Should Look For — and Why Utilization Matters).
In Practice: adidas requires WOVO's operational grievance management platform at all Tier 1 supplier facilities. According to their 2024 Annual Report, WOVO is "highly effective" and "trusted by workers," evidenced by "consistent, widespread, sustained usage and the high volume of cases received." adidas uses performance metrics to monitor engagement in real time and intervene where necessary.
In Practice: Getting suppliers to close the gap between policy and practice is harder than it looks. Read our case study on assessing grievance mechanism effectiveness →
What's Out There? Mechanisms Worth Knowing
Several sectors have established their own mechanisms — including the Ethical Toy Program, Fair Wear Foundation, RMG Sustainability Council, Responsible Jewellery Council, Ethical Trading Initiative, Fair Labor Association, Roundtable on Sustainable Palm Oil, and the Responsible Minerals Initiative. Where relevant to your sector, these are worth knowing about — though like global helplines, their effectiveness varies and they should not be treated as a substitute for direct worker engagement.
Country-specific mechanisms tend to outperform global helplines — they're more likely to be known by workers and trusted over time. Where one exists, prioritize it.
Bangladesh: Amader Kotha Helpline · RSC OSH Complaints Mechanism
Cambodia, Vietnam, Indonesia, Haiti, Jordan: Better Work — ILO-IFC joint program providing factory-level grievance advisory services
A Note on Global Helplines
Globally managed helplines often struggle to build worker trust — especially when they're not locally embedded or backed by real engagement. Low trust leads to low use, and low use means the risks you're trying to surface stay hidden.
Put one in place if regulations require it — Speak Up and Navex are common options. Then focus where it counts: active risk identification, direct worker engagement, and grievance systems embedded in how suppliers operate.
