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A Labor Solutions Case Study As expectations around human rights due diligence rise, seafood companies need tools that move beyond compliance and deliver real insight into worker experience. This case study demonstrates that the WELL Survey is effective in the seafood industry, capturing credible worker voice at scale and translating it into actionable labor insights. The pilot revealed seafood-specific risks, exposed inequities within workplaces, and generated clear priorities for action—showing how worker-centered measurement can strengthen due diligence in complex supply chains. Pilot Objective Testing Whether Worker Voice Delivers Actionable Insight in Seafood Operations The WELL Survey was piloted in the seafood industry to assess whether a worker-centered, cross-sector tool could effectively capture worker voice and generate actionable labor insights in a complex supply chain context. The primary objective of the pilot was to assess whether the WELL Survey could, in the seafood industry: Accurately reflect workers’ lived experiences Surface labor and wellbeing risks specific to seafood operations Reveal differences across gender, job type, and work location Produce insights that are relevant and actionable for seafood companies The pilot tested two deployment models — fully remote and hybrid — across sites with different workforce profiles. Deployment windows in seafood operations need to be built around workforce availability, not client timelines. Seasonal and migrant worker profiles mean the window for meaningful data collection is set by the operational calendar — scoping and stakeholder alignment have to happen well in advance to hit it. Findings The WELL Survey is Effective at Uncovering Risks in the Seafood Industry The WELL Survey Works in the Seafood Context The pilot confirmed that the WELL Survey is effective when applied in the seafood industry. Specifically, it demonstrated that the tool can: Engage seafood workers meaningfully, generating credible and differentiated responses Capture authentic worker voice across roles, genders, and work environments. The variation in results across worker groups confirms that the survey is sensitive to the realities of seafood workplaces, rather than producing uniform or superficial findings. Identify labor and wellbeing risks specific to seafood operations Reveal inequities within seafood workplaces that are often obscured in aggregate data Support informed decision-making and continuous improvement through actionable insights Seafood-Specific Risks Were Clearly Identified The pilot surfaced risk patterns that are particularly relevant to the seafood industry, including: Worker fatigue and exhaustion linked to production demands Harassment and psychological safety concerns, especially among women Unequal access to opportunity and voice across job types These risks appeared even where traditional compliance indicators performed relatively well. Disaggregation Added Critical Value in Seafood Operations By disaggregating results, the pilot highlighted how worker experience differs significantly within seafood workplaces, particularly between: Production and non-production roles Supervisory and non-supervisory workers Women and men These differences are especially relevant in seafood supply chains, where hierarchy and job segregation are common. Results Were Actionable for Seafood Companies The pilot generated clear, sector-relevant priorities for improvement, including: Strengthening harassment prevention mechanisms Addressing workload and fatigue management Improving worker participation in decision-making Closing gender-based gaps in opportunity and voice The findings were specific enough to inform corrective actions within seafood operations. Next Steps Scaling Within the Seafood Industry Based on the pilot results, the WELL Survey will now be rolled out at scale within the seafood industry. Scaling will enable: Consistent benchmarking across seafood operations Identification of systemic, sector-wide risks Tracking of improvement over time Stronger integration of worker voice into seafood-specific due diligence In seasonal operations, remediation planning needs to start before the deployment closes. Because the workforce may be entirely different by the next cycle, there is no continuity to build on — improvements need to be ready before the next group of workers arrives, not designed after they do. Why This Matters Strengthening Seafood Supply Chains Through Worker Voice The pilot confirms that worker-centered tools, when validated in the seafood industry, can generate reliable insights and support stronger, evidence-based due diligence across complex seafood supply chains. Ready to find out how the WELL Survey can support you? Human rights is a practice, not a project.

The buyer deployed the WELL Grievance Integrity program — Labor Solutions' thematic framework for UNGP Principle 31 assessment, run within the WELL Cycle— across 50 strategic and high-risk manufacturing sites in six countries, reaching more than 80,000 workers. Six months after WELL Action Plans were issued and implemented, 83% of sites had completed their assigned actions and 72% had progressed to the next maturity level on grievance mechanisms. Labor Solutions’ Worker-Driven Due Diligence methodology, WELL, moves annually through Listen, Diagnose, Improve, and Educate to turn worker voice into structured site-level risk intelligence The WELL Grievance Integrity program sets the indicators, maps worker and site data against all eight effectiveness criteria, and structures the gap analysis and action planning that follows — a fundamentally different model from audits, which start with systems. The WELL Cycle starts with rights-holders. Start with What Workers Experience — Not What Systems Document Across most value chains, grievance mechanisms exist on paper. Audits confirm their existence. They say nothing about whether workers can access them, whether sites have the management competencies to run them effectively, or whether anything changes for workers when they raise a concern. Low case volume signals access and trust gaps — not the absence of issues. Labor Solutions finds risks in 35% of sites that audits have cleared. This buyer was no different: two Operational Grievance Mechanisms — one in-house, one third-party — received fewer than 20 worker cases across the year from all strategic sites. The real question was whether the systems in place actually worked for workers — and if not, why. That gap is now a legal exposure. UNGP Principles 29–31 require buyers to ensure workers have access to effective grievance mechanisms. CSDDD makes that obligation enforceable — buyers must document that mechanisms work for workers, not just that they exist. ESRS S2-3 requires disclosure of how workers can access remediation and what the buyer has done when mechanisms fall short. An audit that confirms a procedure document exists satisfies none of these requirements. The scale of what was missing became clear when more than 65% of workers responded to the WELL Worker Survey — a response rate that itself signals worker readiness to speak when a trusted channel exists. Diagnose the Competency Gap Behind Every Worker-Reported Gap The buyer ran the WELL Cycle with Grievance Integrity as the program focus. Grievance Integrity sets the indicators, maps worker and site data against all eight UNGP Principle 31 effectiveness criteria and structures the gap analysis and action planning that follows — a fundamentally different model from audits, which start with systems. The WELL Cycle starts with rights-holders. The WELL Worker Survey surfaced how workers actually experienced the grievance mechanism. Grievance Integrity mapped those findings against all eight UNGP Principle 31 criteria — Legitimate, Accessible, Predictable, Equitable, Transparent, Rights-Compatible, Engagement & Dialogue, and Continuous Learning. Each criterion was assessed against the evidence source the criterion itself demands: some, like Accessible, can only be assessed by workers — they are the ones who know whether a channel is reachable. Others, like Rights-Compatible, require a systems assessment, because workers have no visibility into whether resolutions meet international standards. This is why both the WELL Worker Survey and the are required inputs — the worker survey alone does not produce a defensible UNGP Principle 31 assessment. Where workers reported gaps, the WELL Self-Diagnostic Tool assessed the management competencies behind each criterion — not whether a procedure existed, but whether supervisors handle reports without retaliation, whether workers are told what happens next, whether feedback loops close. Each site received a targeted WELL Action Plan. Close Gaps — and Show the Evidence: 83% Done, 72% Advanced Workers said they didn’t know how to get help outside the company, felt management rarely acted on feedback, and found formal channels inaccessible. The WELL Self-Diagnostic corroborated this: sites had no structured feedback loop, relied on supervisor-mediated reporting, and had never communicated external grievance options to workers. The problem wasn’t missing paperwork — it was missing competency. Six months after WELL Action Plans were issued and adopted by sites, 83% of sites completed their assigned actions, clustered around three areas: manager training on grievance handling, more worker-centric reporting channels, and communicating external grievance options back to workers. 72% advanced to the next maturity level. The buyer now sees, per site, what workers experienced, what management competency gap caused it, and what was done. Turn Worker Evidence into Regulatory Evidence — ESRS S2 and CSDDD Ready Labor Solutions produced a structured analysis that the buyer could directly use for their ESRS S2 report obligations. The Grievance Integrity findings substantiated the impact-side evidence for the double materiality assessment and supported disclosures under S2-2 (engagement with value chain workers), S2-3 (remediation processes and grievance channels), and S2-4 (actions taken on material impacts) — with worker-reported evidence, site-level, criterion by criterion. For buyers subject to ESRS reporting, that evidence is not optional: S2-3 and S2-4 requires disclosure of how workers access remediation and what the buyer has done when mechanisms fall short. Grievance Integrity produced both. For CSDDD, the Grievance Integrity program operationalized the core due diligence obligation end to end — the worker survey as documented rightsholder engagement and impact identification, the gap analysis as prioritization, the action plan as the prevention and mitigation evidence the directive requires. The buyer left with a complete, submittable evidence package across both regulatory frameworks. Run the WELL Cycle — and Know Whether Your Grievance Integrity Mechanisms Work UNGP Principle 31 assesses grievance mechanisms by worker experience across eight criteria — not by whether a procedure document exists. Audits tell buyers what sites built. The WELL Cycle tells buyers whether it works — and produces the criterion-level, worker-grounded evidence that regulators and rightsholders now require. That is Worker-Driven Due Diligence. To run the WELL Cycle on grievance mechanisms or other salient topics across your value chain — Workers first. Always.

Executive Summary As part of a strategic shift toward more effective Human Rights Due Diligence, Carter’s, Inc. moved beyond traditional compliance audits to adopt a data-driven worker voice model. By incorporating the scores from supplier worker surveys into their Vendor Scorecard, Carter’s is able to take a scalable, yet locally-tailored approach to supporting supplier standards focused on ensuring worker wellbeing and continuous improvement rather than audit and policing. By deploying the Labor Solutions WELL (Worker Wellbeing, Engagement and Livelihoods) Survey across its global supply chain, Carter’s heard from more than 65,000 workers across 24 suppliers in five major manufacturing hubs: Bangladesh, Vietnam, Ethiopia, Thailand, and Cambodia. Carter’s selected the WELL Survey for its indicator-based structure, which the company described as helping them “build a comprehensive understanding of workers’ experiences across each topic, ensuring we focus on the issues that matter most.” This deployment supports Carter’s broader Raise the Future commitment to improve the lives of one million workers by 2030. Scope of the Initiative Scaling Worker Voice Across Multiple Regions The deployment was designed to capture a representative, high-volume dataset across Tier 1 and Tier 2 suppliers, while minimizing operational burden on factories. Geographic Reach: Bangladesh, Vietnam, Ethiopia, Thailand, and Cambodia Supplier Participation: 24 manufacturing partners Worker Engagement: Over 65,000 anonymous responses Methodology: Mobile-based, anonymous deployment using QR codes Carter’s emphasized that the WELL Survey questions are “simple, easy for workers to understand, and effective at capturing the reality on the production floor.” Combined with a streamlined deployment model, the process was “quick and highly scalable, allowing us to engage key suppliers simultaneously without creating operational burden.” Key WELL Survey Indicators The WELL Survey’s modular design enabled Carter’s to measure 12 core dimensions of worker experience, providing what the company described as “fast, structured insights that help identify areas of risk and opportunities for improvement.” The indicators include Access to Remedy, Fair Pay and Working Hours, Gender Equity, Responsible Recruitment, Harassment and Abuse, Occupational Health and Safety, Wellbeing, and Workplace Climate, among others. Together, these indicators move beyond surface-level compliance to capture lived worker experience across facilities, scaling worker voice in varying local contexts. Why Carter’s Uses Worker Survey Data Incentivizing Worker Wellbeing Beyond Audits By adding a worker survey to their supplier engagement toolkit, Carter’s signals to suppliers that how workers experience their rights and working conditions is a key indicator of supplier performance. By aligning with suppliers before the first deployment on the objectives of the survey and what lower results than expected mean in terms of support Carter’s will provide to help suppliers improve, Carter’s creates an environment of alignment, where all supply chain parties work towards improvement instead of perfection. Strengthening Human Rights Due Diligence Worker survey data has become, in Carter’s words, “an important part of our Human Rights Due Diligence strategy.” The WELL Survey enables Carter’s to “validate conditions beyond traditional audits,” strengthening supplier risk assessments with direct worker input rather than relying solely on documentation and scheduled interviews. Enabling More Meaningful Supplier Engagement Rather than functioning as a compliance scorecard, the survey data helps Carter’s “guide more meaningful conversations with suppliers about worker well-being and responsible workplace practices.” Indicator-level results allow suppliers to identify specific gaps and implement targeted remediation actions. By listening directly to the voices of more than 65,000 workers, Carter’s has strengthened its ability to identify risk, validate working conditions, and engage suppliers in continuous improvement. As Carter’s summarized, the WELL Survey “provides clear, reliable insights into workers’ experiences,” supporting a more effective, worker-centered approach to Human Rights Due Diligence at scale. Turn worker voice into actionable due diligence. The WELL Survey helps brands move beyond audits to gain clear, reliable insight into worker experience at scale. Learn how WELL can strengthen your Human Rights Due Diligence, improve supplier engagement, and surface risks that traditional tools miss. → Explore the WELL Survey

Organizations: GIZ Responsible Business Hub (RBH) Network; Labor Solutions Launch Date: July 2025 | Geographic Scope: Global (23 countries) Why This Matters Compliance Expectations Are Rising — But Most Suppliers Still Lack the Tools to Act Suppliers across global value chains are under increasing pressure to demonstrate compliance with Human Rights and Environmental Due Diligence (HREDD) requirements. While expectations are rising, many suppliers — particularly in sourcing countries — lack access to affordable, practical, and localized training that enables them to translate due diligence standards into day-to-day operational practice. To address this gap, the GIZ Responsible Business Hub (RBH) Network and Labor Solutions co-developed HREDD in Action: A Practical Approach for Suppliers, a free, scalable, multilingual e-learning program designed to build supplier implementation capacity rather than awareness alone. The course is delivered via the atingi learning platform and WOVO Educate, expanding access for suppliers, brands, and ecosystem partners. The Gap Suppliers Face Cost, Language, and Complexity Are Blocking Suppliers From Implementing HREDD Suppliers face recurring structural challenges, including: Limited access to affordable, high-quality training Language and localization gaps Difficulty translating international standards into operational processes Misalignment between buyer expectations and supplier realities Without targeted and practical support, these barriers slow progress on responsible business conduct and increase compliance and reputational risk for both suppliers and buyers. Turning Expectations Into Action We Built a Free, Multilingual Program to Turn Expectations Into Action The RBH Network and Labor Solutions designed a supplier-centric, practice-oriented e-learning program focused on operationalizing HREDD requirements. Key design principles included: Free and scalable access to remove cost barriers Multilingual delivery to support suppliers in sourcing countries Practical, application-first content embedded with tools and templates Alignment with buyer expectations through multinational peer review The program enables suppliers to apply HREDD concepts through e-learning directly within existing business processes. Designed for Application, Not Theory 17 Modules, Real Scenarios, Embedded Templates — Built for Operational Use, Not Theory The course was developed using a learner-centered methodology, including: Needs-based design informed by pre-survey data on supplier challenges across RBH countries Modular structure enabling flexible, self-paced learning Scenario-based learning and country-specific case studies reflecting real operating environments Embedded implementation tools, including: Risk identification and assessment templates Responsible Business Conduct (RBC) integration checklists Sample grievance mechanism components and remediation pathways Monitoring, documentation, and communication templates Peer review by 11 multinational enterprises to ensure alignment with buyer expectations Localization and translation to enhance relevance and comprehension Delivery via atingi and WOVO Educate enables open access, learner tracking, and certification. What the Program Covers From HREDD Foundations to Country-Specific Practice The program consists of 17 interactive modules, covering: Foundations of HREDD Introduction to HREDD Business relevance and resilience Human rights and environmental risks and impacts The HREDD Process (Supplier Perspective) Embedding Responsible Business Conduct (RBC) Risk identification and assessment Prevention and mitigation of adverse impacts Grievance mechanisms and access to remedy Monitoring and communication of performance Country-Specific Case Studies Cambodia Tunisia Pakistan Türkiye Bangladesh Vietnam Serbia Responsible Contracting Introduction to Supplier Model Contract Clauses Assessment and Certification Participants complete a knowledge assessment and receive an official certificate upon successful completion. Built for Global Access Free in 10 Languages, Available to Suppliers in 23 Countries The course is available free of charge in: English; Khmer; Mandarin; Spanish; Turkish; Vietnamese; Urdu; French; Serbia; Bangla. This multilingual approach supports supplier learning in local business and regulatory contexts. What Changed Hundreds of Suppliers Trained Across 23 Countries Within Months of Launch Within months of launch: Suppliers reached in 23 countries Hundreds of suppliers trained on practical HREDD implementation 17 modular learning units delivered at scale 11 multinational enterprises engaged as peer reviewers Strong uptake across sourcing regions, signaling demand for practical, supplier-focused capacity building How It Was Built Built With Buyers and Suppliers Together The program was developed through collaboration between: GIZ Responsible Business Hub (RBH) Network Labor Solutions Responsible Contracting Project 11 multinational enterprises serving as peer reviewers This ensured technical credibility, operational feasibility, and alignment across buyers and suppliers. Use It Standalone or Integrate It Into Your Due Diligence System The program works as a standalone capacity-building intervention — or as part of an integrated approach: Supporting Supplier Improvement The course builds practical understanding of roles, responsibilities, and implementation steps, increasing readiness for corrective action, remediation, and continuous improvement. Responding to Worker Insights Insights from worker voice and survey data, including WELL Survey results, can guide targeted deployment when gaps are identified in grievance mechanisms, access to remedy, or due diligence processes. Strengthening Grievance Handling When paired with CONNECT, the course ensures that individuals receiving worker messages understand: Worker rights and supplier responsibilities under HREDD How grievance mechanisms should function in practice Appropriate response, escalation, and remediation pathways This ensures worker messages are not only received, but understood and acted upon appropriately. Complementing Worker Education Supplier training can be paired with worker-focused education on rights awareness and grievance use, strengthening shared understanding, trust, and system effectiveness. Put It to Work Get Started: The Course Is Free Organizations seeking to strengthen supplier due diligence implementation, improve grievance mechanism effectiveness, or translate worker insights into action can deploy HREDD in Action: A Practical Approach for Suppliers as a standalone intervention or as part of an integrated approach. The course is available free of charge via: atingi: https://lnkd.in/gFr-W-TA WOVO Educate To learn more about implementing custom eLearning curricula at your organization with WOVO Educate or your own LMS, get in touch with us. Worker first always.

Regulatory expectations on human rights due diligence are increasing across jurisdictions. The EU Corporate Sustainability Due Diligence Directive (CSDDD) and related legislation make clear that companies must identify, prevent, mitigate, and account for adverse impacts on workers throughout their supply chains. The UN Guiding Principles on Business and Human Rights (UNGPs) provide the governance framework. The Sustainable Development Goals (SDGs) articulate the social and economic outcomes. How can companies generate credible, comparable evidence about workers’ lived experience across global supply chains? The WELL Survey (Wellbeing, Engagement and Livelihoods Survey) was developed to address this gap. Led by Labor Solutions and co-created through a multi-stakeholder group of brands, advisors, and industry actors - including early contributors such as adidas, H&M, Decathlon, carter’s, Lake Advisory and others - the WELL Survey provides a standardized, modular worker survey framework designed for global benchmarking and local relevance. It functions as: A supply chain worker survey A labor rights survey tool A human rights due diligence survey A workforce listening platform Most importantly, it captures structured, experience-based worker data aligned with internationally recognized standards. Worker Voice as a Core Element of Human Rights Due Diligence Under the UNGPs, companies must: Identify actual and potential human rights impacts Integrate findings into decision-making Track effectiveness Provide access to remedy Meaningful engagement with affected stakeholders - particularly workers - is central to this responsibility. The WELL Survey operationalizes that engagement requirement. Rather than assessing policy intent or documentation alone, it collects worker-reported experience across standardized indicators. This enables organizations to evaluate whether management systems function as intended in practice. The framework directly supports alignment with: SDG 8 – Decent Work and Economic Growth SDG 16 – Peace, Justice and Strong Institutions SDG 5 – Gender Equality SDG 3 – Good Health and Well-being SDG 10 – Reduced Inequalities SDG 1, SDG 2, SDG 4, SDG 6 and SDG 11 where relevant Comprehensive Indicator Framework of the WELL Survey The WELL Survey includes a standardized Core Questionnaire, with optional modules and limited customization capacity. Each indicator represents a fixed grouping of experience-based questions, ensuring comparability across suppliers, brands, and geographies. Governance, Voice and Institutional Accountability Engagement - Worker trust in management, perception of responsiveness Communication - Access to information and ability to raise questions Leadership - Fair, inclusive, and accountable management Access to Remedy - Confidence that concerns are addressed Grievance Mechanism Accessibility - Safe and barrier-free reporting channels Grievance Mechanism Process + Transparency - Clear and consistent complaint handling Freedom of Association - Ability to organize and participate collectively These indicators align particularly with SDG 8 (worker participation and labor rights) and SDG 16 (transparency, accountability, institutional effectiveness). Livelihoods, Economic Security and Labor Conditions Fair Pay + Compensation - Transparent wage calculation and income sufficiency Fair Working Hours - Predictable schedules and voluntary overtime Responsible Recruitment - No recruitment fees, clear contracts, absence of debt bondage Freedom of Movement - No coercion or restriction of employment mobility Child Labor Prevention - Protection of education and development These indicators align primarily with SDG 8 (decent work), SDG 1 (income security), SDG 4 (education), and SDG 10 (protection of vulnerable groups). Equality, Protection and Opportunity Gender Equity - Addressing structural barriers and ensuring equitable access Equality (Non-Discrimination) - Equal treatment across demographic groups Professional Development - Fair access to training and advancement Harassment + Abuse - Protection from physical and psychological harm Sexual Harassment - Protection from gender-based violence These align with SDG 5 (gender equality), SDG 10 (reduced inequalities), and SDG 16 (protection from violence and discrimination). Health, Safety and Living Conditions Occupational Health + Safety – Safe working environments and injury prevention Workplace Climate + Environment – Access to sanitation, water, and dignified facilities Dormitories + Accommodation – Safe, clean, and adequate housing Wellbeing – Emotional, physical, and financial health Family + Work Balance – Policies supporting caregiving and work-life balance Social Connection – Ability to build relationships and community These indicators align with SDG 3 (health and wellbeing), SDG 6 (water and sanitation), SDG 11 (adequate housing), and SDG 8 (dignified work). Standardization with Local Relevance A persistent challenge in supply-chain worker surveys is duplication and fragmentation. Suppliers are often asked to respond to multiple overlapping surveys, reducing efficiency and worker trust. The WELL Survey was designed as a shared framework to streamline this landscape. Its structure includes: A fixed Core Questionnaire for global benchmarking Optional modules addressing specific risk areas (e.g., grievance systems, recruitment, working hours) Up to three custom questions to reflect local priorities Because each indicator is standardized, results remain comparable across industries and countries while still allowing contextual relevance. Experience-Based Design and Reporting The survey uses experience-based questions to encourage candid responses and reduce abstract or perception-only metrics. All surveys are multilingual, supporting accessibility across diverse regions. Participating organizations receive structured reporting, including: Indicator rankings Employee Net Promoter Scores (eNPS) Demographic breakdowns Year-over-year tracking This enables trend analysis, benchmarking, and targeted corrective action planning. Participating workplaces may also earn the annual WELL Seal, demonstrating commitment to structured worker voice measurement. From Measurement to Alignment The SDGs define development objectives. The UNGPs define corporate governance responsibilities. The WELL Survey provides a structured mechanism to assess whether workplace conditions align with those expectations in practice. It does not duplicate what audits assess — physical facility conditions, policy existence, building safety. It reaches what audits were never designed to access: what workers actually experience. In an environment where regulators, investors, and consumers increasingly require demonstrable due diligence, structured worker voice is no longer optional. It is a governance necessity. The WELL Survey was designed to meet that need - through multi-stakeholder collaboration, standardized methodology, and globally comparable indicators. Workplaces improve when worker experience is systematically measured, analyzed, and acted upon. Workers first always.

The UN Guiding Principles on Business and Human Rights have been the global standard for corporate human rights responsibility since 2011. Most large brands reference them in their sustainability reports. Most compliance teams can point to a policy that cites them. What very few can do is demonstrate, with structured evidence, that those principles are being respected in practice — in the facilities, with the workers, across their value chain. That gap is precisely where regulators are looking. And it's the gap that the WELL Survey and WOVO Improve are built to close. Audits Show You a Day. Workers Tell You the Truth. The UNGPs are built around three pillars: the state duty to protect, the corporate responsibility to respect, and access to remedy. For brands operating through complex global supply chains, the second and third pillars are where the compliance work lives — and where the evidence is hardest to collect. Facility audits capture a snapshot. Supplier self-certifications capture a statement. Neither captures what workers actually experience — whether they feel safe raising a concern, whether a grievance mechanism is genuinely accessible to them, whether a policy that exists on paper has reached the factory floor. CSDDD and LkSG make this distinction legally explicit: the law requires worker participation, access to remedy, and operational grievance mechanisms — not audit compliance. Two Products, One Mapping Architecture: Worker Voice Meets Supplier Systems The WELL Survey and WOVO Improve are designed as complementary instruments — two different lenses on the same question. The distinction that drives the architecture is this: some UNGP principles can only be assessed by asking workers directly. Others require examining what suppliers have built. The WELL Survey captures the worker voice side. It produces evidence against the principles that depend on lived experience — whether core internationally recognized rights are being respected (P12), whether adverse impacts are being avoided or addressed (P13), whether meaningful consultation is taking place (P18), whether remediation is genuinely accessible (P22). These are not questions a supplier can answer on a worker's behalf. WOVO Improve captures the supplier system side. It assesses whether policy commitments are real (P16), whether human rights due diligence is actually being conducted (P17), whether findings are being integrated into operational decisions (P19), and whether suppliers are meeting their accountability obligations to external stakeholders (P21). Neither instrument alone produces a complete picture. Deployed together, they generate the kind of structured, cross-referenced evidence that CSDDD, LkSG, and equivalent frameworks require — evidence that can withstand regulatory scrutiny and investor review. Every indicator in both products is mapped in our WELLBank, the single source of truth for all question-level, indicator-level, and competency-level UNGP mappings across our product suite. When the Stakes Are Highest, the Scoring Reflects That Not all rights violations carry the same weight — and our indicator architecture doesn't treat them as if they do. Across the full indicator suite — covering Occupational Health and Safety, Harassment and Abuse, Responsible Recruitment, Freedom of Movement, Child Labour, and Grievance Mechanisms, among others — the indicators that measure the most severe potential violations are designated as salient. A low score on a salient indicator doesn't simply flag a gap in a dashboard. It triggers an elevated risk classification and a defined response protocol, reflecting how the UNGPs themselves approach severity: adverse impacts that are grave, widespread, or irreversible require prioritized attention (P24) and a proportionate due diligence response (P17, P19). UNGP Principle 31: The Eight Criteria Most Brands Have Never Actually Measured One of the most consequential — and most overlooked — elements of the UNGP framework is Principle 31, which sets out eight effectiveness criteria that any company-level grievance mechanism must meet to be considered functional. These criteria appear in regulatory guidance, investor questionnaires, and sustainability commitments across the industry. They are almost never measured directly. For the full legal definition of what makes a mechanism ‘operational-level’ under CSDDD — including the distinction between a corporate hotline and a genuine mechanism accessible at the point of work — see the legal breakdown. The WELL Survey and WOVO Improve both include Grievance Mechanism indicators that map individually to each of the eight P31 criteria — distinguishing between what workers report experiencing and what supplier systems are designed to provide. When both instruments are deployed together, the combined output produces a structured finding against each criterion: not a general impression, but an evidenced position on whether the mechanism is actually working for the people it is supposed to serve. The UN Guiding Principles - Built for CSDDD, LkSG, and the Regulatory Landscape You're Already Operating In The UNGP mapping doesn't sit in isolation. Every WELL indicator and every WOVO Improve competency is also mapped to the relevant ILO conventions, SDG targets, and — critically — the EU Corporate Sustainability Due Diligence Directive. As mandatory human rights due diligence obligations expand across jurisdictions — CSDDD in the EU, LkSG in Germany, the UK Modern Slavery Act, and equivalent frameworks emerging across Asia and the Americas — the question for brands is no longer whether to conduct due diligence. It's whether the due diligence they're conducting is demonstrably meaningful. A survey score in isolation is not a compliance artefact. But a structured programme of worker voice measurement, combined with supplier self-assessment, cross-referenced against a documented framework mapping — that is what due diligence looks like in practice. The WELL and WOVO Improve mappings are designed to produce exactly that kind of documentation, in language aligned with how regulators and auditors expect to see it presented. The Signal That No Audit Will Reliably Surface The most valuable output of running the WELL Survey and WOVO Improve together is not a score. It's the divergence. When a supplier demonstrates strong systems in WOVO Improve — policy commitments in place, due diligence processes documented — but WELL Survey results show workers reporting a different experience, that gap is telling you something critical: the system exists, but it isn't reaching the people it is supposed to protect. That divergence — policy present, practice absent — is precisely the scenario that human rights due diligence frameworks are designed to surface. It is also the scenario that audit-only approaches will routinely miss. Evidence That Works Across Every Audience A structured UNGP mapping also makes your compliance evidence portable. Whether you're completing a CSDDD due diligence record, responding to an investor ESG questionnaire, preparing for a regulatory submission, or communicating findings to a civil society stakeholder, the same underlying data can be presented in the language each audience expects — without starting from scratch for every reporting cycle. Human rights due diligence is not a project, its a practice. The value of a rigorous mapping architecture is that it keeps that practice grounded in what matters: the experiences of workers, the systems suppliers are building, and the global standards that both are accountable to. Ready to Build an Evidence Base That Holds Up? Explore the WELL Survey, explore WOVO Improve, or talk to the Labor Solutions team about building a due diligence program that produces evidence regulators, investors, and auditors will accept. Human rights is a practice, not a project.

A Labor Solutions Analysis | Based on adidas Annual Reports 2017–2025 Eight Years of Public Data From adidas Is the Clearest Answer Available to CSDDD CSDDD doesn't ask for evidence of existence — it asks for evidence of effectiveness. Most brands fall short: channels exist, policies are written, boxes are ticked. But the data that would show whether workers are using those channels, whether complaints resolve, and whether trust is building over time is rarely collected or disclosed. Since 2017, adidas has done exactly that — making it one of the most concrete answers available to the question CSDDD is asking. CSDDD Doesn't Ask If You Have a Grievance Mechanism — It Asks If Workers Actually Use It CSDDD requires mechanisms that are accessible (including anonymously), trusted (workers believe raising a concern leads to a real outcome), effective (complaints resolved in a timely manner), and demonstrable through monitoring and disclosure. These requirements describe a program with measurable inputs, outputs, and outcomes — not a policy document. One Platform, Three Systems, 400,000+ Workers, One Integrated Due Diligence System Since 2017, adidas has deployed WOVO across 100% of its strategic Tier 1 manufacturing partners — reaching 400,000+ workers across up to 17 countries annually. Three CSDDD-relevant components: the WOVO grievance mechanism, the Worker Pulse survey (biannual, rights-focused), and targeted surveys on specific rights issues including gender equality. All three feed into adidas' human rights due diligence systems and supplier S-KPI ratings. The Full Record: Grievances, Resolution Rates, and Satisfaction From 2019 to 2025 100% Tier 1 Coverage, Every Year — Coverage Has Never Been the Gap adidas has maintained 100% Tier 1 coverage every year with access consistently above 400,000 workers across multiple countries — even as its value chain consolidated. Coverage has never been the gap. What the data shows is whether the mechanisms behind that coverage are working. 99% Resolution Rate, Held at Scale: The Floor, Not the Ceiling Resolution rate has held at 99% every year since 2021. This is the most basic measure of whether a grievance mechanism functions at all — and it is also the floor. A 99% resolution rate tells you complaints are being processed. Satisfaction and response time tell you whether they are being processed well. 39% to 79% in Six Years: Satisfaction Gains at This Scale Don't Happen by Accident Worker satisfaction with complaint resolution has risen 40 points over six years, with gains in almost every year. This is the metric CSDDD cares about most and that most brands have the least data on. A mechanism that resolves complaints on paper but leaves workers dissatisfied is not providing meaningful access to remedy. Response Times Fell 80%: Workers Now Hear Back in Under Half a Business Day Average response time fell from 49 hours in 2020 to under 11 hours in 2025 — a reduction of nearly 80%. Workers are not just getting responses; they are getting them fast enough to matter. Volume Dropped, Then Jumped 32%: What the Rebound Actually Measures Volume reflects both program maturity and value chain size. As adidas consolidated its supplier base, fewer facilities produced fewer absolute grievances. The 32% rebound to 47,200 in 2025 — against further facility reduction — is the meaningful signal: more workers per facility chose to use the system. That is the clearest evidence of growing trust. Reactive Isn't Enough: How Worker Pulse Meets CSDDD's Stakeholder Engagement Requirement The Worker Pulse now runs across 96 facilities in 13 countries, with favorable responses rising from 78% to 91% since 2020. CSDDD's stakeholder engagement requirements go beyond reactive grievance handling — brands must proactively engage workers to understand their experiences and risks. The Gender Equality survey (51,000 workers, 87/100 in 2025) demonstrates the same infrastructure can target specific rights categories. Three Things Eight Years of adidas WOVO CSDDD worker engagement Data Proves — That Most Brands Haven't Learned Yet Effectiveness is built, not installed. The improvement from 58% satisfaction in 2020 to 79% in 2025 happened because adidas invested consistently in supplier capability, KPI tracking, and worker communication over years — not because the platform was deployed. The metrics that matter most are the ones most brands don't collect. Resolution rate is table stakes; satisfaction, response time, and sentiment trends are what regulators will ask for. Coverage and integration are separate problems. 100% Tier 1 coverage is a coverage achievement. WOVO data feeding into S-KPI ratings and due diligence priorities is an integration achievement. CSDDD requires both. CSDDD Compliance Isn't Built at Deadline. It's Built Over Years. Eight years of publicly disclosed adidas WOVO CSDDD worker engagement data makes a clear case: technology-enabled worker engagement, consistently governed and properly integrated into due diligence systems, produces measurable, compounding improvements in the outcomes CSDDD demands. Satisfaction doubles. Response times fall 80%. Coverage scales to hundreds of thousands of workers without quality erosion. The brands that will find CSDDD compliance straightforward are not the ones with the simplest value chains — they are the ones that started building their evidence base early. Want to learn more? Human rights is a practice, not a project. *All data cited in this report is drawn exclusively from adidas' publicly available annual sustainability reports for the years 2019–2025. Labor Solutions is the provider of the WOVO platform deployed across adidas' Tier 1 value chain.

Why high use of workplace grievance mechanisms signals trust, and why third-party helplines should be a backstop, not the starting point. As human rights due diligence requirements expand under laws such as Germany’s Supply Chain Due Diligence Act (LkSG) and the EU Corporate Sustainability Due Diligence Directive (CSDDD), grievance mechanisms have become a core expectation for buyers sourcing from global value chains. But in practice, the challenge is rarely whether a supplier has a grievance mechanism. The real question is whether workers trust it enough to use it — and whether buyers know how to interpret what they see. Grievances Don’t Start as Complaints - They Start as Questions For most workers, raising a concern is intimidating. Calling a third-party helpline or reporting an issue outside the workplace often feels extreme — something people do only as a last resort. In reality, most grievances begin as questions, not accusations: Is this allowed? Was my pay calculated correctly? Can my supervisor speak to me this way? Who can I talk to if something doesn’t feel right? When workers have no safe way to ask these questions, concerns either remain hidden or escalate unnecessarily. This is why operational-level grievance mechanisms are so important. Two channels. Different Purposes. Both Necessary. What Is an Operational Grievance Mechanism? An operational grievance mechanism is the system that exists inside a workplace — at the factory, farm, or site level — that allows workers to raise concerns directly with their employer. When done well, it allows workers to: Ask questions anonymously Raise concerns early Receive explanations and follow-up See issues addressed close to where they occur For employers, this enables faster resolution and clearer communication.For buyers, it is often the earliest and most reliable signal of risk. Why Third-Party Helplines Are Still Necessary, but Not Enough Third-party grievance mechanisms and helplines play a critical role, especially when: Workers do not trust local management There is fear of retaliation Serious abuse or exploitation is involved Independent oversight is needed However, these channels are typically used only when workers feel they have no other option. Operational grievance mechanisms and third-party helplines serve different but complementary purposes: Operational mechanisms support early dialogue and everyday problem-solving Third-party mechanisms act as a safeguard when internal systems fail or feel unsafe The strongest grievance ecosystems include both — and workers understand when and how to use each. What an Effective Operational Grievance Mechanism Looks Like From a worker’s perspective, an operational grievance mechanism works when it is: Safe Workers can raise concerns anonymously or confidentially, without fear of retaliation. Known The system is clearly explained, regularly promoted, and discussed during onboarding and team meetings. Accessible It reflects workers’ realities — their language, literacy levels, and access to technology. Open-door policies are helpful, but they are not enough on their own. Many workers will not raise sensitive issues face-to-face, especially where power dynamics exist. From an employer’s perspective, effective mechanisms allow for: Two-way communication and clarification Clear tracking and follow-up Identification of recurring or systemic issues Why Utilization Matters and How Buyers Should Interpret It One of the most common mistakes buyers make is assuming that fewer grievances mean lower risk. In practice, the opposite is often true. What “Good” Utilization Looks Like High utilization of operational grievance mechanisms is usually a positive sign. It suggests that workers: Trust their employer enough to speak up Feel safe asking questions Believe they will receive a response Low utilization of third-party grievance mechanisms can also be a healthy signal when operational systems are trusted and effective. In these cases, third-party channels function as a backstop, not the primary entry point. A Simple KPI Framework for Buyers When assessing grievance mechanisms, buyers should focus on patterns, not just numbers. Operational Mechanism Utilization High use generally reflects trust, accessibility, and effective communication. Types of Issues Raised A healthy system captures both questions and complaints across topics such as pay, supervision, and health and safety. Response Time and Follow-Up Fast acknowledgment and clear communication strongly correlate with worker trust and continued use. Escalation Patterns Occasional escalation to third-party mechanisms is expected. Frequent escalation may indicate gaps in operational systems. What Buyers Should Not Assume “Zero grievances” does not mean zero problems. In many cases, it means workers do not feel safe, informed, or confident enough to speak up. Buyers should apply healthy skepticism when suppliers report no grievances at all, especially in higher-risk contexts. Why This Matters for Buyers Under HRDD laws now in force, buyers are increasingly expected to understand how risks are identified and addressed — not just whether policies exist. Operational grievance mechanisms are one of the most practical tools buyers have to: Detect risk early Prevent harm Reduce escalation Strengthen supplier relationships The goal is not silence.The goal is trusted systems, early dialogue, and problems solved before they become crises. Turning Insight Into Action Buyers often understand why grievance mechanisms matter — but need support implementing and assessing them in practice. If you are: Assessing supplier grievance mechanisms and need a framework to understand the gap between what employers think is happening and what workers actually experience, our survey and improvement tools can help. Looking for an effective operational grievance mechanism, WOVO Connect allows workers to anonymously message their employer while giving buyers appropriate oversight into how concerns are handled and resolved. Working to strengthen operational grievance mechanisms across your supply chain, we support buyers and suppliers in building systems that encourage early dialogue rather than last-resort escalation. If you’d like to discuss how to assess, design, or strengthen operational grievance mechanisms in your supply chain, we’re happy to continue the conversation. Workers First Always

A Labor Solutions Case Study | adidas 2025 Sustainability Report The adidas 2025 Annual Report, published under the European Sustainability Reporting Standards (ESRS) section on Workers in the Value Chain, contains a number that would alarm most compliance teams: a 32% increase in worker grievances. This post unpacks why adidas counts it as a milestone — and what six years of WOVO data reveal about what a functioning operational grievance mechanism actually looks like. More Complaints, Same 99% Resolution Rate: Why Volume Growth Is the Metric adidas Wanted When grievance volumes rise, most brands get nervous. At adidas, a 32% increase is a sign the system is working. In 2025, workers submitted close to 47,200 complaints through WOVO — up from 35,700 in 2024 — and 99% were resolved by year-end. Higher volume, same near-perfect resolution rate: that is proof of trust, not a problem. Satisfaction Rose From 39% to 79% in Six Years — and the Trajectory Is Still Improving Worker satisfaction with grievance resolution has risen from 39% in 2019 to nearly 79% in 2025 — a 40-point transformation over six years of consistent WOVO investment. Average response time fell from 49 hours in 2020 to under 11 hours in 2025. Workers who raise a concern today can expect a response in less than half a business day. The Supplier Base Shrank. Worker Coverage Didn't. 402,500 Workers Still Have Full Access. In 2025, more than 402,500 workers across 92 manufacturing facilities in ten countries had access to WOVO — covering 100% of adidas' core Tier 1 manufacturing partners. The reduction from 105 facilities in 2024 reflects value chain consolidation, not a reduction in WOVO coverage. From Miscommunication to Missing Benefits Workers Finally Have a Channel For Everyday Worker Grievances The 47,200 grievances in 2025 spanned internal communication (~13,300 cases), benefits (~8,300), and general facilities (~5,800). These are the everyday friction points that go unvoiced when workers don't trust the channel — and that quietly erode morale and retention when left unaddressed. The 99% resolution rate means nearly every complaint gets closed; the 79% satisfaction rate means workers find the outcomes fair. 91% Favorable Across 96 Facilities: How adidas Listens Before Problems Escalate The Worker Pulse survey ran across 96 facilities in 13 countries in 2025, with favorable responses reaching nearly 91% — up from 78% in 2020. The Gender Equality survey reached 51,000 workers with an average favorable score of 87/100. Together with the grievance mechanism, these create a three-channel listening infrastructure: reactive, proactive, and targeted. Every Complaint Feeds a Supplier KPI: How Worker Voice Becomes Management Consequence adidas does not treat WOVO data as a reporting metric — it treats it as an operational input. Grievance satisfaction ratings, response time data, and KPI dashboards feed directly into adidas' supplier social impact (S-KPI) rating. Workers who use WOVO know that what they say influences how their factory is rated. Six CSDDD Requirements. Six Data Points. An Evidence Base Built Over Six Years. CSDDD requires access to remedy that is effective, not just available. adidas' 2025 model: Accessible (402,500+ workers), Used (47,200 grievances), Trusted (79% satisfaction), Fast (<11 hours), Measured (supplier KPIs), Proactive (Worker Pulse + Gender Equality surveys). This is the standard CSDDD expects — and a didas has built an evidence base showing consistent improvement year over year. Ready to build a program like this? Contact Labor Solutions to discuss how WOVO can support your due diligence and worker engagement program. Source: adidas 2025 Annual Sustainability Report (ESRS S2). All data drawn from adidas' public disclosures.

What CSDDD actually requires — and why the brands getting it right run a cycle, not a checklist. CSDDD does not use the word "audit." It does not require a one-time systems assessment or a point-in-time review. The word it uses — in Article 8, in Article 9, throughout — is "ongoing." Ongoing risk identification. Ongoing worker engagement. Ongoing access to remedy. Ongoing documentation of what you found and what you did about it. That word carries a structural implication that most compliance teams have not yet fully absorbed: you are not building a system. You are building a practice. And a practice, by definition, repeats. The difference between a project and a practice is not intensity or cost. It is what happens in Year Two. A project ends. A practice compounds. The brands that will have the strongest CSDDD evidence base in 2027 are not the ones that deployed the most tools in 2025. They are the ones that started their annual cycle early enough that they have multiple turns of data to show. Worker-Driven Due Diligence (HRDD) is the operating model that makes "ongoing" a reality — not a declaration of intent, but a documented, repeating cycle of listening, diagnosing, acting, and evidencing. This is what it looks like in practice. Worker-Driven Due Diligence in practice: four stages, run in sequence, every year. Stage 1: Workers tell you what audits can't. The WELL Worker Survey (Wellbeing, Engagement and Livelihoods) reaches workers directly — in their language, through channels they control, with anonymity that is credible because it is structurally guaranteed, not just promised. Workers share what they actually experience: wages, safety, management behavior, hours, recruitment. The survey runs across the supplier base simultaneously. You get a dataset, not a snapshot. Stage 2: Suppliers diagnose root cause. WOVO IMPROVE gives suppliers a self-assessment tool built around what workers indicated. The supplier does not receive a corrective action plan imposed from outside. They work through what their workers said, identify the root causes they can actually address, and build an action plan they own. Priorities are capped at three — because a list of forty corrective actions is not accountability. It is paralysis. Stage 3: Action plans generate evidence. Targeted action plans based on worker signals and the self-assessment are tracked over time. WOVO EDUCATE delivers rights-based digital training to workers and managers. WOVO CONNECT — an always-on operational grievance mechanism, not a hotline — remains open throughout the year so workers can raise concerns between survey cycles. All of this generates a documented trail: what was found, what was done, what changed. Stage 4: Reports make it producible. Global and local reports aggregate the data from every stage. Risk indicators. High-risk suppliers. Cohort trends. Supplier-level progress on action plans. Worker satisfaction scores over time. This is the documentation CSDDD Article 10 requires — and the evidence ESRS S2 reporting standards ask brands to disclose publicly. Then the cycle repeats. Annually. Because human rights is a practice, not a project. What the cycle reveals that no single deployment can The case for running an annual cycle rather than a one-time engagement is not philosophical. It is evidentiary. A seafood industry pilot using the WELL Survey found — in its first cycle — what no prior supplier reporting or audit had surfaced: debt bondage linked to local recruitment agencies, excessive hours, harassment and psychological safety concerns, and water and occupational health and safety issues across geographies. Ninety-two percent of workers participated. Eighty-seven percent of farmers participated. Thirty-eight thousand respondents across three languages. Zero prior visibility through conventional channels. That is what a first cycle surfaces. But a first cycle does not tell you whether conditions improved. It does not give you a baseline to measure against. It does not tell you which suppliers are responding to their action plans and which are not. It does not give you the trend data CSDDD requires as evidence of ongoing engagement. The second cycle does that. So does the third. In the electronics sector, Labor Solutions' WELL Survey found that 35% of suppliers who had passed recent social audits had workers paying illegal recruitment fees — a serious forced labor indicator. Seventy-three percent of workers in that same cohort had low awareness of their rights. Both findings required a second cycle to begin measuring improvement. The first cycle is necessary. It is not sufficient. What changes when suppliers own their improvement The structural difference between a corrective action plan (CAP) and a worker-driven action plan is ownership. CAPs are issued from outside. Supplier self-assessments are built from within — starting with what workers said, worked through by the people who have to implement the changes. Carter's deployed the WELL Survey across 65,000+ workers in 24 suppliers across five countries — Bangladesh, Vietnam, Ethiopia, Thailand, and Cambodia. The decision to move beyond audits reflected a recognition that audit data was not telling them what was happening to workers in their value chain. Crucially, Carter's integrated WELL Survey scores into their Vendor Scorecard — embedding worker experience data into the sourcing decisions that suppliers actually respond to. When worker voice data has commercial consequences for the supplier relationship, supplier engagement in the improvement cycle is not optional. It is structural. That integration — worker survey findings into commercial accountability — is the operational definition of a Worker-Driven Due Diligence programme. It is also what CSDDD expects: that the findings of ongoing engagement with workers have consequences, and that those consequences are documented. One year of data satisfies the minimum. Three years is what holds up under ESRS S2 scrutiny. CSDDD Article 10 requires companies to produce documented evidence of what they did to prevent and mitigate human rights risks — and what changed as a result. This is not a policy question. It is a data question. And data accumulates over time, not at deployment. ESRS S2, which governs how companies subject to CSRD must report publicly on their value chain worker engagement, requires disclosure of: the channels through which workers can raise concerns; the effectiveness of those channels; the company's approach to due diligence; and the outcomes of that approach. A company reporting in 2026 with one year of data reports minimally. A company reporting with three years of trend data reports compellingly. The brands that will satisfy ESRS S2 scrutiny are not those that deployed the best tools. They are the ones that deployed early enough to have a story to tell — a story that begins "in Year One, we found this; in Year Two, conditions changed in these ways; by Year Three, satisfaction across our Tier 1 base had moved from this to that." That story requires a cycle. It requires repetition. It requires not stopping after Year One because the results were uncomfortable or the supplier engagement was harder than expected. WOVO is the platform that makes repetition operationally feasible at scale — 3.8 million active workers, 180+ countries, 41+ languages, deployable across a Tier 1 supplier base as a continuous annual program, not a periodic project. The compliance posture that actually holds up under scrutiny When a regulator asks whether your company has engaged workers in its value chain, there are two possible answers. One is: "We deployed a worker survey." The other is: "We have been running a Worker-Driven Due Diligence cycle for three years. Here are the findings from each year, the supplier improvement plans those findings generated, the change in worker satisfaction scores over that period, and the grievance resolution data from the mechanism workers used between survey cycles." The first answer is a project. The second is a practice. CSDDD is not asking for the first. Labor Solutions is the provider of the WOVO platform — the only worker engagement tool focused exclusively on value chain workers and suppliers, deployed continuously, in 180+ countries and 41+ languages. The proof points cited in this post reflect confirmed programme data from WOVO deployments across apparel, footwear, electronics, and seafood value chains. If you are working toward CSDDD compliance If you are building a worker engagement program ahead of CSDDD obligations, the Carter's case study shows what a structured, multi-country deployment looks like when worker data is integrated into sourcing decisions. If you are in seafood, agriculture, or food supply chains, the seafood worker voice programme documents what a first cycle surfaces in high-risk migrant worker contexts. If you need a practical breakdown of what CSDDD requires at each article, the CSDDD practical guide maps each obligation to the evidence standard it demands. And if you are ready to begin, contact the Labor Solutions team to scope a Worker-Driven Due Diligence program for your value chain. Frequently Asked Questions Does running a worker survey once satisfy CSDDD's ongoing engagement requirement? No. CSDDD requires ongoing worker engagement — not a one-time survey. A single survey cycle establishes a baseline. Ongoing compliance requires an annual cycle of listening, root cause analysis, supplier improvement tracking, and grievance mechanism access between cycles. Single-cycle data cannot demonstrate the trend evidence CSDDD and ESRS S2 require. What is Worker-Driven Due Diligence? Worker-Driven Due Diligence (HRDD) is Labor Solutions' framing for human rights due diligence built on continuous, direct worker engagement — as opposed to audit-based models that are point-in-time and externally assessed. It means workers generate the primary data through validated surveys and always-on grievance mechanisms, suppliers own their improvement plans, and brands accumulate longitudinal evidence of what is actually happening in their value chains. How is the WOVO annual cycle different from a social audit program? Social audits assess what a supplier built — policies, documented systems, physical conditions — on a specific day. The WOVO cycle generates what workers know: their actual experiences, through channels they trust, continuously. An audit produces a compliance rating. The WOVO cycle produces a dataset that compounds in value every year it is repeated — and that satisfies the ongoing engagement and evidence standards CSDDD requires. What does CSDDD require as evidence of worker engagement? CSDDD requires companies to document that they identified human rights risks in their value chains, took action to prevent or mitigate those risks, and can demonstrate the outcomes of those actions. This requires primary worker data (not audit reports), a functioning grievance mechanism with usage and resolution data, documented supplier improvement plans, and longitudinal trend data showing what changed. ESRS S2 adds public reporting obligations for companies subject to CSRD. How quickly can an annual cycle be established? The first survey cycle can be deployed within weeks across a Tier 1 supplier base using the WOVO platform. WOVO CONNECT is always-on from the point of deployment. The first full cycle — survey, self-assessment, action plans, and initial reporting — is typically complete within a year, positioning brands to begin their second cycle with a documented baseline and a functioning supplier engagement infrastructure already in place.