Forced Labor Due Diligence in Practice: Risk Assessment and Grievance Mechanisms at adidas
- Jan 1
- 4 min read
The fight against forced labor remains one of the most urgent human rights challenges facing global supply chains.
Millions of people worldwide are affected, and regulatory expectations on companies to identify, prevent, and remediate forced labor risks continue to increase.
Recent assessments make clear that many companies are still struggling to meet minimum expectations.
A report by the Business & Human Rights Resource Centre’s KnowTheChain initiative found that only a small number of companies met baseline standards for forced labor due diligence. Among them, adidas stood out for its approach to worker engagement, risk identification, and grievance mechanisms.
This post examines what companies can learn from adidas’s approach, and how those lessons align with emerging legal expectations under the UN Guiding Principles on Business and Human Rights (UNGPs) and the EU’s Corporate Sustainability Due Diligence Directive (CSDDD).
Where Companies Are Falling Behind
Across jurisdictions, mandatory human rights due diligence (HRDD) frameworks increasingly require companies to demonstrate that their systems function effectively in practice, not merely that policies or procedures exist.
This expectation is grounded in:
UNGP Principle 18, which requires companies to identify and assess actual and potential human rights impacts through meaningful engagement with affected stakeholders
UNGP Principle 29, which calls for effective operational-level grievance mechanisms
UNGP Principle 31, which sets effectiveness criteria for grievance mechanisms
The CSDDD, which requires companies to take appropriate measures to identify, prevent, mitigate, and bring to an end adverse human rights impacts, including through stakeholder engagement and grievance mechanisms
Two gaps consistently emerge in assessments of forced labor due diligence:
Risk identification that is not grounded in worker experience
Grievance mechanisms that exist on paper but do not function in practice
Both gaps undermine legal compliance and effective risk management, because many forced labor risks are not visible without direct worker participation.
Challenge #1:
Risk Assessments That Don’t Reach Workers
Many companies continue to rely primarily on audits and supplier self-assessments to identify forced labor risks. While these tools can play a role, they are often limited by:
narrow audit windows
management-selected interviews
documentation that does not reflect daily practice
lack of real-time insight into working conditions
This approach is increasingly misaligned with legal expectations.
Under UNGP Principle 18, companies are expected to assess human rights impacts by drawing on direct input from affected stakeholders, including workers, particularly where risks are severe.
Similarly, the CSDDD emphasizes ongoing risk identification across the value chain, not periodic verification exercises.
What Works Better in Practice
Effective forced labor due diligence requires ongoing, systematic worker engagement that complements traditional tools.
adidas’s approach demonstrates how worker input can strengthen risk identification by:
surfacing risks that audits miss
revealing country- and sector-specific dynamics
enabling earlier prevention and targeted mitigation
This approach aligns with both UNGP Principle 18 and CSDDD requirements to identify risks based on actual impacts, not assumptions.
Challenge #2:
Grievance Mechanisms That Exist on Paper but Not in Practice
Many companies report having grievance mechanisms, yet worker usage remains low. Under HRDD frameworks, low grievance volume is not evidence of low risk.
The UNGPs are explicit on this point:
UNGP Principle 29
Requires companies to establish or participate in operational-level grievance mechanisms
UNGP Principle 31
Specifies that such mechanisms must be legitimate, accessible, predictable, equitable, transparent, rights-compatible, and trusted
The CSDDD similarly requires companies to provide a grievance mechanism that affected persons can access in practice, not merely in theory.
In practice, low usage often indicates that grievance mechanisms are:
unknown to workers
inaccessible due to literacy, language, or technology barriers
not trusted to protect against retaliation
unable to deliver timely or meaningful outcomes
What Operational Grievance Mechanisms Look Like
Operational grievance mechanisms differ from traditional hotlines or compliance-only reporting channels. They are embedded into day-to-day operations and supplier management, rather than existing as symbolic or external tools.
Effective mechanisms typically include:
multiple access points appropriate to worker context
anonymity and confidentiality safeguards
structured case management and documented follow-up
supplier responsibility for resolution, with appropriate brand oversight
evidence of dialogue, outcomes, and learning over time
These characteristics align directly with the effectiveness criteria set out in UNGP Principle 31 and the CSDDD’s emphasis on remediation and corrective action.
adidas’s experience illustrates how embedding grievance mechanisms within supplier operations can increase trust, usage, and meaningful resolution.
Why Supplier Engagement Is Central to Legal Compliance
A key lesson from adidas’s approach is that grievance mechanisms are most effective when suppliers are actively involved in resolving issues, rather than bypassed.
This is legally significant because:
UNGP Principle 29 anticipates mechanisms that operate at the point where impacts occur
The CSDDD expects companies to take appropriate measures to bring adverse impacts to an end and prevent recurrence, which often requires supplier-level action
Supplier engagement supports:
faster remediation
prevention of repeat violations
clearer accountability
stronger evidence of effective due diligence
Moving Beyond Tick-Box Compliance
Forced labor due diligence is no longer assessed by whether a company can point to:
a policy
a hotline
a completed audit
Instead, companies are increasingly expected to demonstrate:
how risks are identified on an ongoing basis (UNGP 18)
whether workers can safely raise concerns (UNGP 29)
whether grievance mechanisms meet effectiveness criteria (UNGP 31)
how remediation and prevention are carried out in practice (CSDDD)
To acheive this adidas closely monitors worker engagement with performance metrics to
“evaluate the efficacy of the grievance channels, see major cases in real time, and undertake timely interventions where necessary.”
adidas’s experience shows that worker engagement and operational grievance mechanisms are central to meeting these expectations, not optional add-ons.
What Companies Should Be Asking Themselves
As forced labor and HRDD expectations continue to evolve, companies should ask:
Do our risk assessments meaningfully engage workers as rights holders?
Can workers raise concerns safely and without fear of retaliation?
Do our grievance mechanisms meet the effectiveness criteria in UNGP Principle 31?
Are suppliers equipped and accountable for resolving issues?
Can we demonstrate prevention and remediation over time, as required under the CSDDD?
Answering these questions requires systems that function in practice—not just on paper.
Want to see what worker-driven HRDD looks like in practice?
Explore how adidas operationalized worker engagement and grievance mechanisms to strengthen forced labor due diligence.
If you’d like to discuss what these approaches could look like in your own supply chain, contact us at info@laborsolutions.tech.