The OECD marks half a century of the MNE Guidelines. Its own data shows more workers seeking remedy than ever — and a grievance mechanism effectiveness gap that audits cannot see. This month the OECD marked fifty years of the Guidelines for Multinational Enterprises — the first international standard on responsible business, and, in the OECD's words, “the north star for responsible business in an ever-changing world.” Presenting the latest activity data at the anniversary Forum, the OECD reported a record year for its National Contact Point system — the non-judicial grievance mechanism that sits under the Guidelines' Access to Remedy pillar: 120 new cases, more than twice any prior year, and past 900 in total since 2000. The more telling figure sat underneath. For the first time, 71% of submissions came from individuals rather than NGOs or unions (OECD, 50th Anniversary Global Forum on Responsible Business Conduct, June 2026). The people the Guidelines exist to protect are no longer waiting for an organisation to raise a concern for them. They are coming forward directly — even as access to remedy remains one of the least developed parts of responsible business conduct. The standard has moved to remedy. The evidence base most buyers rely on hasn't. Under the UNGPs, the OECD Guidelines, and now hard law such as CSDDD Article 9, buyers are expected to do more than publish a grievance policy. They are expected to run grievance mechanisms workers can actually reach — and to show those mechanisms work. UNGP Principle 31, under the Access to Remedy pillar, sets eight effectiveness criteria for non-judicial grievance mechanisms. Each has to be evidenced, not asserted. The same shift is visible in enforcement: US Customs and Border Protection's tightened forced-labor due diligence expectations turn on documented, defensible due diligence — not attestations. Two themes ran through the anniversary session. First, awareness of these mechanisms is uneven — outreach reaches governments and business far more readily than the workers most exposed to harm, many of whom are nowhere near the channels that outreach runs on. Second, as the field moves from voluntary commitment to mandatory law — what one advisor called “business and human rights 3.0” — there is a real risk companies collapse the work into a compliance exercise: a mechanism that exists on paper and satisfies a filing, without reaching the people it was built for. New laws increasingly require operational-level grievance mechanisms at the site itself, and, as the session noted, standing one up and proving it works is among the harder things a company is now asked to do. Where the gap actually sits: grievance mechanism effectiveness A grievance mechanism can be fully documented and still fail the people it is for. An audit confirms the mechanism exists. Only workers can tell you whether it works. One buyer ran the WELL Cycle with Grievance Integrity across 50 strategic and high-risk manufacturing sites in six countries, reaching more than 100,000 workers. Going in, the picture looked adequate: two Operational Grievance Mechanisms, one in-house and one third-party. Together they had received fewer than 20 cases across the entire year, from all strategic sites. Low case volume reads easily as “no problems.” It was the opposite. When workers were asked directly, more than 65% responded to the WELL Worker Survey — and reported they didn't know how to raise a concern outside the company, that formal channels felt inaccessible, and that management rarely acted on feedback (WELL Grievance Integrity case study, Labor Solutions). Silence was not safety. It was a trust gap the paperwork couldn't show. That pattern is not exceptional. Across our programs, worker voice surfaces serious risks in 35% of sites that had already passed audit (WELL program data, Labor Solutions). Audits tell buyers what sites built. Worker voice tells buyers whether it works. And under CSDDD, LkSG, and ESRS S2, the difference is now a liability. The eight criteria — and who can answer them Principle 31 can only be evidenced from two sides at once. Some criteria only workers can assess — whether a channel is genuinely reachable, whether raising a concern changes anything. Others need a systems view workers have no line of sight into, such as whether resolutions meet international standards. A worker survey alone does not produce a defensible assessment; neither does a systems review. WELL Grievance Integrity measures both. UNGP Principle 31 criterion What it asks Evidenced by Legitimate Workers trust the mechanism is fair and impartial. Worker Survey + Self-Diagnostic Tool Accessible Workers can find and use it without barriers. Worker Survey + Self-Diagnostic Tool Predictable Workers understand the process and experience it consistently. Worker Survey + Self-Diagnostic Tool Equitable Access holds equally across worker groups. Worker Survey + Self-Diagnostic Tool Transparent Workers are kept informed of how the process works and what happens to complaints. Worker Survey + Self-Diagnostic Tool Engagement & Dialogue Workers can raise concerns collectively; management listens and responds. Worker Survey + Self-Diagnostic Tool Rights-Compatible Outcomes meet internationally recognised human rights standards. Self-Diagnostic Tool (systems) Continuous Learning Grievance data drives systemic improvement. Self-Diagnostic Tool (systems) What Closing it Actually Takes- Engaging Workers WELL Grievance Integrity maps worker and site data against all eight criteria and runs through the WELL Cycle — Listen, Diagnose, Improve, Educate, Repeat — turning worker signal into diagnosed cause, site-owned action, and a WELL Intelligence trail that gets stronger every year. For the buyer above, six months after the 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. What that looked like site by site — and how the program evidenced all eight Principle 31 criteria — is the case study. Fifty Years in, the Question is the Right One The OECD's anniversary question — how do we build fairer, more resilient value chains with people at the centre? — is the question Worker-Driven Due Diligence was built to answer. We have run this work since 2013. Worker-Driven Due Diligence is not a response to regulation. It is what due diligence is when workers are at the centre. Human rights is a practice, not a project. → See what one buyer's grievance data revealed once workers were asked — and how WELL Grievance Integrity evidenced all eight UNGP Principle 31 criteria across 50 sites. Read the case study.

Human rights due diligence without humans isn't due diligence. On June 9, 2026, U.S. Customs and Border Protection published the Forced Labor Enforcement Operational Guidance for Importers — Publication No. 5560-0526. It is the first document to consolidate CBP's enforcement framework across three legal authorities: the UFLPA, CAATSA, and the general forced labor import prohibition under 19 U.S.C. § 1307. It supersedes the June 2022 guidance, which covered the UFLPA alone. Most commentary since has treated it as a trade law story. That reading misses the shift that matters. Read closely, the guidance is a statement about evidence — what counts, who holds it, and how much of it an importer needs. On all three questions, it points somewhere most compliance programs have never seriously looked: workers. CBP's enforcement record explains why this can no longer wait. Of the 42,807 shipments stopped for UFLPA review since enforcement began, only 39% have been released into U.S. commerce. Ignorance of the process is no longer a defensible position. Forced labor due diligence starts with a clear and convincing standard — and with engagement To win a UFLPA exception, an importer must demonstrate by clear and convincing evidence that goods were not made with forced labor. The guidance points to the UFLPA Strategy's eight due-diligence elements as the benchmark. Element one, in the Strategy's own words: "engagement with suppliers and other stakeholders" to assess and address forced labor risk. That includes workers — and it is listed first for a reason. Engagement with suppliers and other stakeholders to assess and address forced labor risk Mapping of the value chain and assessment of risks from raw materials onward A written supplier code of conduct prohibiting forced labor Training on forced labor risks for staff who select and manage sites Monitoring of site compliance with the code of conduct Remediation of any forced labor conditions identified Independent verification of the due diligence system Public reporting on the due diligence system Those seven elements are only as credible as the engagement beneath them. A single gap renders the submission insufficient. A program that monitors paperwork but never asks workers what they experience is not meeting the standard CBP points to. The twelve commodities in Appendix A — from cotton and apparel to polysilicon, seafood, steel, and copper — all require full value chain traceability. For every one of them, the indicators that actually confirm forced labor conditions are held by workers, not documents. Three legal regimes are converging on the same requirement This is not a CBP-specific standard. Principles 18 and 19 of the UN Guiding Principles — the core of Pillar 2's due diligence architecture — have required meaningful consultation with affected rights-holders since 2011. Not proxies. Not auditors speaking on their behalf. Principle 31 sits in Pillar 3, the remedy pillar, and it sets the effectiveness criteria for non-judicial grievance mechanisms: legitimacy, accessibility, awareness, trust. None of those criteria can be assessed without asking workers directly. An audit can confirm a mechanism exists. It cannot confirm whether workers know about it, trust it, or would use it. CSDDD, LkSG, and ESRS S2 build on the same architecture. What the June guidance adds is not a new idea — it is enforcement teeth at the border. Worker engagement was never optional under the UNGPs. Now the cost of treating it as optional arrives with the shipment. Framework What it requires WELL Cycle stage that measures it UNGP Principles 18 & 19 (Pillar 2) Meaningful consultation with affected workers as ongoing due diligence Listen — the WELL Worker Survey UNGP Principle 31 (Pillar 3) Grievance mechanisms that are legitimate, accessible, known, and trusted Diagnose — the WELL Self-Diagnostic Tool CSDDD, LkSG, ESRS S2 Ongoing value-chain due diligence and stakeholder engagement Repeat — the full WELL Cycle, compounding into WELL Intelligence The audit gap is structural The ILO has identified eleven indicators of forced labor. They include debt bondage from recruitment fees, document retention, restriction of movement, threats, and false promises at hiring. Not one of them is reliably visible in a standard social compliance audit. That is not a criticism of auditors. It is a structural limitation of audit-only programs. Audits examine documents, physical conditions, and management systems — what a site prepares for. They do not reach the workers who know whether recruitment was honest, whether they can leave, whether the mechanism they were shown actually works. This is not a gap that more audits close. An importer can hold a complete audit file and still lack the one input CBP's standard turns on: what workers themselves report about recruitment, movement, and remedy. The strongest evidence file is the one that includes their accounts — and most do not yet. CBP is now calling it insufficient. The data bears that out: the WELL Survey found conditions consistent with forced labor indicators at 35% of sites audits had previously cleared — recruitment fees, restricted movement, false promises at hiring. Not edge cases. One in three. The strongest value chains do not audit more. They engage constantly. Across years of working with buyers, one thing separates the value chains with the lowest forced labor exposure. It is not audit frequency. They invest in their sites and back those sites in investing in their people — because good human resources infrastructure is the foundation of good human rights practice. They are supportive, not punitive. They choose engagement over enforcement. And they maintain constant dialogue with workers — not as a one-time assessment but as a practice — which means they keep finding things. New risks. New gaps. New evidence that conditions have changed. Workers trust the mechanism because it visibly responds. Grievance data is active, not decorative. Recruitment practices are verified through worker reports, not only recruiter contracts. Listen. Diagnose. Improve. Educate. Repeat. We built the WELL Cycle to run forced labor due diligence as a continuous practice — and each stage maps to what CBP's standard, and UNGP Pillar 2, actually require. The WELL Worker Survey reaches workers directly — in their language, through channels they trust, in formats designed for low-literacy environments. It is the starting point of the cycle, and the source of the primary evidence a document-tracing regime cannot produce. The WELL Self-Diagnostic Tool follows. Site teams examine the systems, policies, and practices behind what workers reported — including whether workers knew the grievance mechanism existed and believed it was safe to use. This is the difference between a program that understands its risks and one that has merely documented a policy. We diagnose, not just report. The WELL Action Plan closes the gaps surfaced by the Survey and diagnosed by the Self-Diagnostic Tool — site-owned, tied to specific indicators, paired with WELL Digital Learning, and communicated back to workers. That loop generates the stakeholder engagement and notification records CBP's evidentiary standard names explicitly. Where sites need worker-facing infrastructure, the WOVO app puts it directly in workers' hands: an Operational Grievance Mechanism, WELL Digital Learning, and Local Surveys — producing grievance records that are structured, current, and defensible. Each stage compounds into WELL Intelligence — a risk and remediation record that deepens with every cycle. That is the point every regulator is now circling: clear and convincing evidence is not a snapshot. It is a record built over time. Worker-Driven Due Diligence, run as an annual practice, is how that record gets built. What changed is the cost of ignoring it CBP's June 2026 guidance did not change what good practice looks like. It changed the cost of not practicing it. The question is no longer whether you have a policy against forced labor. It is whether workers can tell you it is working — and whether their answer is documented in a way that holds at the border. The next step is a simple test: put your current evidence file against the eight elements and ask which of them contains workers' own accounts. If the answer is none, start where the cycle starts — listen. 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 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, write to info@laborsolutions.tech. Workers first. Always.

Worker-Driven Due Diligence for responsible, resilient value chains doesn’t start with a policy. It starts with asking workers directly. The WELL Cycle is how that happens — four connected steps that surface risk, diagnose root cause, drive site-owned action, and build worker and manager capability, year after year. Each step builds on the last. Each cycle compounds the evidence. Choose Your Program Before the cycle starts, buyers choose a program. The program isn’t just a survey configuration — it governs the whole cycle. The indicators a program includes are the backbone of every step: what workers are asked in Listen, what the WELL Self-Diagnostic Tool examines in Diagnose, what the WELL Action Plan closes in Improve, and what WELL Digital Learning addresses in Educate. Six curated programs cover the most common value chain contexts. A seventh lets buyers build their own. The Core WELL Program is the foundation — eight indicators covering universal workplace risks. Engagement, Fair Pay + Compensation, Professional Development, Occupational Health + Safety, Harassment + Abuse, Communication, Access to Remedy, and Wellbeing. UNGP-aligned, industry-tested, value chain ready. Aligned to UNGP, CSDDD, and ILO core labor standards. Migrant Worker Focus extends the core for value chains relying on migrant or cross-border labor. It adds Responsible Recruitment, Freedom of Movement, Migrant Worker Equity, Fair Working Hours, and Social Connection — covering forced labor risk, debt bondage, document retention, and access to information in workers’ own languages. Aligned to ILO forced labor and migrant worker conventions. Relevant to CSDDD, UK Modern Slavery Act, and LkSG for buyers with exposure in those jurisdictions. Grievance Integrity is built for buyers with obligations under UNGP Principle 31. It adds indicators that measure whether grievance channels are known, trusted, accessible, and lead to meaningful outcomes — from awareness through to resolution. UNGP Principle 31 sets eight criteria for what an effective grievance mechanism looks like from a worker’s perspective. This program measures all eight. Relevant to CSDDD operational grievance mechanism obligations and ESRS S2 reporting on grievance effectiveness for value chain workers. Gender Equity Lens is designed for sectors with high female worker concentration. It extends the core with Gender Equity and Sexual Harassment indicators, surfacing promotion barriers, pay gaps, and conditions that disproportionately affect women workers. Aligned to ILO equal remuneration and harassment conventions. Relevant to ESRS S2 reporting on equal treatment and opportunities across the value chain. High-Risk Manufacturing covers the full risk picture for Tier 1 and Tier 2 manufacturing sites — safety culture, fair pay, production pressure, overtime, and the complete grievance pathway from worker awareness to resolution. Aligned to ILO working hours and occupational safety conventions. Maps to UNGP and CSDDD due diligence obligations. Leadership + Culture is for buyers investing in site capability beyond compliance. It extends into management quality, worker voice, social connection, and the conditions that make sustained improvement possible over time. Maps to UNGP and CSDDD obligations on worker engagement and ongoing due diligence. Build Your Own — buyers who need something more specific can build a program from the full indicator library directly. Core indicators address universal workplace risks and are the foundation of every program. Risk-based indicators extend into specific domains: migrant labor exposure, grievance infrastructure integrity, gender equity gaps, recruitment debt, document retention, and forced labor signals. Impact indicators measure the conditions that drive retention, capability, and long-term improvement — leadership quality, social connection, work-life balance, and housing conditions. Build a global core for comparability across your value chain — then add risk and impact indicators where local conditions demand. Listen — the WELL Worker Survey The starting point of every cycle. Workers are surveyed in their language, through channels they trust, in formats designed for low-literacy environments — accessible by QR code, web link, the WOVO app, or trained surveyors. The survey asks workers about every indicator in their program. Scores are not verdicts — they are signals that open the next conversation. Diagnose — the WELL Self-Diagnostic Tool Survey scores open conversations. The WELL Self-Diagnostic Tool is where the conversation gets specific. Triggered by a site’s three lowest WELL Survey indicators and any salient risks, the Self-Diagnostic Tool is a structured digital assessment for human resources and management teams. Teams answer targeted questions about the systems, policies, and practices behind the survey results — examining the same indicators the workers just scored, from the management side. The Self-Diagnostic Tool is competency- and maturity-based. It meets sites where they are across three maturity levels: Planning + Intention, Implement + Listen, Engage + Empower. Sites stop at the level that reflects their current state. This is the step that separates a survey program from a due diligence program. Scores without diagnosis produce defensiveness. Diagnosis without scores produces guesswork. Together, they produce a root cause management can act on — and that buyers can document. For CSDDD and ESRS S2 reporting, the Self-Diagnostic output is part of the evidence that due diligence goes beyond data collection to root cause identification. Improve — the WELL Action Plan Worker feedback becomes site-owned action. The WELL Action Plan is structured as Intended Outcomes — each one closing a specific gap workers surfaced and management diagnosed. Every Intended Outcome ties a competency gap to a corrective action, a verification method, and a communication back to workers. The plan is site-owned. That distinction matters. A corrective action plan assigned from outside can be ticked as complete on paper while the underlying condition persists. A WELL Action Plan is built from the site’s own diagnosis, with verification that loops back to the workers who raised the concern. Every WELL Action Plan is paired with matched WELL Digital Learning for workers and managers — so the skills and awareness needed to close the gap are built alongside the structural changes. Educate — WELL Digital Learning Workers and managers who understand their rights and responsibilities raise concerns earlier, resolve issues faster, and sustain improvements between survey cycles. Informed workers are twice as likely to raise concerns. WELL Digital Learning is a library of rights-based modules mapped directly to WELL indicators — developed with the ILO, Better Work, RISE, and IOM, and delivered on any device. Digital Learning is matched to the specific gaps a site’s WELL Action Plan is closing — not deployed as a standalone training. Repeat. Year after year. Human rights is a practice, not a project. Each cycle compounds the evidence. Risk findings get more targeted. Actions get sharper. Trajectories, persistent gaps, and cross-portfolio patterns become visible across years. The structured output of the cycle — WELL Intelligence — is a site and portfolio risk view grounded in worker voice, layered with site context and structured self-reflection, ranked by severity, paired with next actions, and updated with each improvement. That compounding body of evidence is what meets regulatory obligations. UNGP requires buyers to demonstrate that grievance mechanisms actually work from a worker’s perspective — not just that a mechanism exists on paper. CSDDD makes those obligations legally binding for in-scope EU buyers. ESRS S2 turns them into mandated public disclosure, requiring structured worker-voice evidence on who faces greater risk and whether remedy is accessible. The WELL Cycle generates that evidence at each step and builds it year over year. Interested in learning more or to run the WELL Cycle in your organization? Workers first. Always.

Key Takeaways Worker voice is an operating model, not a tool. Selecting a survey platform and expecting results is the most common implementation failure. The most common failure point is deployment — when sites distribute a survey through factory management, workers do not respond honestly. Build the grievance mechanism alongside the survey, not after it. The survey surfaces what workers are experiencing; the WELL Operational Grievace Mechansim is what workers use when they need something to change. Sites buy-in is the single biggest predictor of program success. adidas has deployed WOVO for over eight years — worker satisfaction rose from 39% to 79%, response time fell from 49 hours to under 11 hours. Before implementation, two questions need answered: what worker voice is and whether the business case justifies the investment. A program deployed without clarity on both typically produces data nobody acts on. The question ‘how do we implement worker voice’ almost always starts in the wrong place. The instinct is to find a survey tool, run a pilot, and see what happens. The problem is that worker voice is not a tool. It is an operating model. The tool is only useful if the infrastructure around it — deployment, trust-building, site engagement, case management, and follow-through — is built to make it work. Step 1: Align internally before you go anywhere near workers Worker voice programs fail most often not because the technology is wrong but because the organization behind it is not aligned. Before deployment, brands need to agree on what questions they are actually trying to answer, what they will do with the answers, and who owns the follow-through. If survey findings surface a serious issue and there is no agreed process for what happens next, the program produces data that goes nowhere. Workers notice when nothing changes. Trust erodes. The program dies. If leadership needs the financial case before committing, the business case for worker engagement covers the ROI evidence, regulatory penalty exposure, and board-level disclosure requirements that make this a risk management decision, not only an ethical one. Step 2: Choose a methodology aligned to international standards Not all worker surveys are equal. The WELL Worker Survey is co-designed through a multi-stakeholder process, aligned to UN Guiding Principles on Business and Human Rights Principle 31. Its core question set — 22 questions across 8 indicators — covers wages, safety, management behavior, freedom of association, and working hours. Validated methodology also matters for worker trust: workers who have participated in poorly designed surveys are harder to re-engage. Step 3: Solve the deployment problem, not just the technology problem The most common failure point is deployment. A brand selects a survey platform and then leaves deployment to the site. The site asks managers to distribute it. Workers complete it in a group, on a shared device, in full view of the person whose behavior they are being asked to evaluate. The result is unusable data — and workers who are less likely to engage honestly in future. Effective deployment requires direct outreach to workers in their language, through channels they control, in a context where anonymity is credible. Labor Solutions handles deployment directly — including real-time participation monitoring so brands know not just that the survey ran, but that it ran with genuine reach. Step 4: Build the grievance mechanism alongside the survey, not after it The survey surfaces what workers are experiencing. The grievance mechanism is what workers use when they need something to change — not once a year when the survey runs, but continuously. The WELL Operational Grievance Mechanism is always-on infrastructure, not a periodic reporting tool. Workers who complete a survey and then see no mechanism for raising the concerns they surfaced become less likely to engage in the future. The survey and the grievance mechanism are parts of the same system and need to be built together. Step 5: Engage sites as partners, not compliance subjects Site buy-in is the single biggest predictor of program success. The framing that works is operational, not moral: sites who engage workers effectively have lower turnover, fewer grievances that escalate, and more stable production. The WELL Self-Diagnostic Tool is designed with this in mind — self-assessments completed by the site, action plans limited to three priorities at a time, a maturity framework that gives sites visible progression rather than a pass/fail. The commercial argument — 1:3 ROI, 44% reduction in absenteeism, 33% improvement in retention — belongs in the site conversation too, not just the brand's internal business case. See the business case for worker engagement for the evidence to bring to that conversation. Step 6: Repeat annually. Human rights is a practice, not a project. A one-time survey tells you something. An annual survey, with a continuous grievance mechanism running alongside it, tells you whether things are actually changing. Read how adidas has deployed WOVO for over eight years — worker satisfaction rising from 39% to 79%, response time on grievances falling from 49 hours to under 11 hours. To discuss how to scope a worker voice program for your value chain. FAQs How long does it take to deploy a worker voice program across a Tier 1 value chain? adidas achieved 100% Tier 1 coverage — 402,500 workers across 92 facilities — and was generating meaningful grievance data within its first year of deployment. Timeline depends on the number of sites, language complexity, and deployment model. Labor Solutions handles deployment directly, including real-time participation monitoring. What is the difference between a worker survey and a worker voice program? A worker survey is a single data collection event. A worker voice program is the operating infrastructure that runs continuously: a validated annual survey, an always-on grievance mechanism, rights-based education, and a supplier improvement framework. The survey generates data; the program generates change. How do you ensure workers respond honestly to a survey in a factory setting? Workers respond honestly when anonymity is credible, deployment is independent of factory management, and the survey reaches them through channels they control. Labor Solutions deploys the WELL Survey directly to workers — not through factory administration — and provides audiovisual support for low-literacy environments in 41+ languages. How does the WELL Self-Diagnostic Tool support site engagement in an implementation? The WELL Self-Diagnostic Tool is the site self-diagnostic element of the WOVO platform. Sites complete the self-assessment themselves rather than receiving externally imposed corrective action plans. Action plans are limited to three priorities at a time. The maturity framework gives sites visible progression rather than a pass/fail, which makes them substantially more likely to engage honestly in the next cycle.

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 A whistleblower hotline and an operational grievance mechanism are not the same thing — and for value chain workers, the difference determines whether the system gets used at all. 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. A helpline is a starting point. Worker-driven due diligence is the goal.

The EU Directive on Corporate Sustainability Due Diligence (CSDDD) is a regulation that is commonly referred to as the "EU Directive on Due Diligence", "CSDDD" or "CS3D". It requires certain businesses to identify, prevent, mitigate, and account for the potential adverse human rights and environmental impacts of their operations and value chains. The CSDDD is expected to be finalized in 2025 and will apply to businesses that have significant operations or sales in the EU, as well as businesses that sell products or services in the EU. It is important to note that the CSDDD is not the same as the Corporate Sustainability Reporting Directive (CSRD), which is a broader reporting framework that encourages companies to report on their sustainability activities. The CSDDD focuses specifically on corporate due diligence on human rights and the environment, including prevention and remedy, and will feed into CSRD reporting. If you want to find out if your company is affected by the CSDDD and how to comply with it, keep reading. This is important information for both European companies and their suppliers. Brief Overview The CSDDD, just like other recent human rights and environmental due diligence laws such as the LkSG (German Supply Chain Due Diligence Act), requires businesses to follow a due diligence process that aligns with the OECD Guidelines and UN Guiding Principles. These laws aim to address the potential impacts of your business and supply chain partners' operations and sourcing on workers and other people who might be affected. However, they do not require you to identify and remedy the risks of these operations to your business. The scope of these laws and the companies directly impacted, as well as the supply chain partners included, vary from law to law. It's important to note that EU Directives must be implemented by national law to be effective, so please check with your legal counsel about your legal requirements. This summary is intended to provide a general overview for informational purposes. Does CSDDD affect your business? The EU Directive on Due Diligence will affect fewer companies than originally planned. However, many large companies based in the EU or with significant EU operations will be covered. The regulation will apply to both European and foreign companies with 1,000 employees and a turnover of €450 million during the five-year phase-in period. Companies with 5,000 employees and €1,500 million turnover will be impacted first and should expect changes within the next three years. The high-risk sector approach has been removed temporarily, but it may be considered in the future as part of the CSDDD. If your business does not sell or operate in the EU, you may not be directly affected by the CSDDD. However, you may still be impacted due to your association with value chain partners. If you are a contractor, subcontractor, manufacturer, service provider, distributor, or retailer for a European business (or other business that falls under the CSDDD), you may notice changes in your contractual relationships that enable regulated businesses to comply with their obligations. These new regulations make each business responsible for human rights and environmental issues in its supply partners, distributors, and customers. Therefore, any company that conducts business with a company that has a significant European presence, or operations could be affected indirectly. By being prepared, the impact of these new laws can be minimized, as explained below. After the EU Directive is finalized, each EU member state will have to pass national legislation to implement it, which may vary slightly from the original directive. The national legislation is expected to be passed by 2025, and each company will have to consider which national laws apply to its operations and what specific requirements they entail. You can keep track of the progress of the EU Directive on Due Diligence. Are you ready for the upcoming CSDDD? Don't let the changes catch you off guard. Allow us to help you kickstart to ensure a seamless transition. Practical Guide for CSDDD Compliance Requirements: To work with EU buyers, it's important to be prepared for their requirements, which may vary slightly across member states implementing their version of the CSDDD. Direct Requirements: HRDD Process, Internal Governance + Supply Chain Grievance Businesses that are directly regulated will be obligated to implement a human rights due diligence process that is similar to the LkSG and other HREDD regulations. This process consists of six steps: design, assess, identify, prevent, remediate, and report. The goal is to identify and manage human rights and environmental risks, establish internal governance standards, and implement a human rights policy with a grievance mechanism for impacted individuals to report issues or complaints. Labor Solutions has covered these in detail in eBook "Strategies for Effective Human Rights Due Diligence in Your Supply Chain". Indirect Requirements: Support Identification, Prevention, Remedy and Reporting Indirectly regulated businesses must collaborate with their directly regulated supply chain partners to comply with new regulations. This involves updating contractual obligations and codes of conduct, providing training and support, fulfilling reporting requirements, and implementing other mechanisms that satisfy the law. Obligations: Scope of Risks Responsible New in the CSDDD (and different from some other HRDD) is the scope of the risks and operations that are covered. For example, the LkSG requires that only the risks presented by direct suppliers (and risks posed by indirect suppliers if known) must be addressed, prevented, and remedied. On the other hand, the CSDDD proposes that partners both upstream and downstream be included in the scope of responsibility, which is likely to encompass indirect suppliers. Scope of Actions Required These regulations pertain to business practices rather than reporting requirements or compliance laws. As such, they call for a distinct approach from what may be accustomed to. To comply with these regulations, it's necessary to continually monitor and proactively engage with customers and suppliers to ensure a focus on preventing and minimizing the negative impact of human rights and environmental issues on people. Labor Solutions assists suppliers and regulated businesses in collecting quality data for better business and purchasing decisions. Labor Solutions offers tools like advisory and consulting work, as well as the HRDD Starter Kit that provides scalable solutions to meet CSDDD and HRDD requirements. The most important thing is to start, and you don’t have to do it all alone. First Steps to Compliance: HRDD Process Regulated businesses must perform due diligence, including risk assessment, identification, prevention, remediation, and reporting. More details about this process can be found here. The scope of risks and operations may differ, but it is always advisable to start understanding the general risks associated with the countries and industries you source from. This will help you identify specific risks in your value chain through surveys, grievance tools, audits, and assessments. When working with your suppliers, customers, and other stakeholders, start engaging with your supply chain partners. The suppliers should be responsible for conducting identification efforts, operating their grievance management system, implementing prevention methods, and remediating complaints. The objective is not to micromanage but to build trust and support mechanisms for suppliers when needed. Grievance or Complaints Process Businesses that are directly regulated must establish a complaints process or grievance mechanism that is accessible by workers and other individuals who may be affected by any company within your value chain. There are several service providers available that offer hotlines and grievance tools. However, it is essential to ensure that not only is there a communication channel, but it is also effective in collecting complaints and providing effective solutions. Our eLearning library offers a comprehensive range of courses to help you understand the requirements better. For example, our practitioner training on Access to Remedy provides detailed information on the elements of effective remedies and how to choose an appropriate service provider. We also recommend that you educate your suppliers about the new requirements. Our online modules on human rights due diligence can be customized to meet your company's specific needs and can assist you in communicating the due diligence process to all your direct and indirect suppliers effectively, across various risk-based categories. Suppliers and indirectly regulated businesses can prepare for the new due diligence requirements of their CSDDD buyers by following a few simple steps. We have helpful blog posts on this topic. Contact our advisory team if you need assistance in creating a risk management system. Start with conducting a Worker Survey to help identify the potential risks. Implement WOVO's Operational Grievance Mechanism features to ensure that you have an effective grievance mechanism and case management system in place to identify and prevent issues. Deploy our digital learning courses on rights and responsibilities or responsible recruitment to ensure that workers and managers know their responsibilities and rights, thus helping mitigate the risks. Collaborate with our advisory team to design a remediation plan. Use your WOVO dashboard to report and track trends. What CSDDD Requires for Grievance Mechanisms in Value Chains CSDDD requires companies to establish or participate in operational-level grievance mechanisms that are accessible to value chain workers and other affected stakeholders, protect against retaliation, and are aligned with the effectiveness criteria set out in UN Guiding Principles on Business and Human Rights Principle 31. A central corporate helpline is not sufficient. The mechanism must be accessible at the point of work — in workers' languages, through channels workers can actually use, in a context where workers credibly believe they will not face retaliation for using it. Companies must also produce documented evidence that the mechanism works — through case resolution records, longitudinal trends in worker conditions, and evidence of remediation. Non-compliance carries fines of up to 5% of global net turnover. What ESRS S2 Requires on Worker Engagement Reporting ESRS S2 — the social standards under the EU Corporate Sustainability Reporting Directive — requires companies to report publicly on their approach to worker engagement across their value chain, including the grievance mechanisms in place and evidence of their effectiveness. For companies subject to CSRD, this is mandatory. Board-level disclosure requirements mean this is no longer a sustainability team issue. It sits at the same level as financial disclosure. Worker survey data, case resolution records, and supplier improvement outcomes are the forms of evidence that satisfy this standard. Labor Solutions' supplier ownership, empowerment, and improvement approach is not only scalable but also allows companies to tackle the problem at the source and collect unparalleled data sets. Our solutions go beyond tick-box solutions and are designed to help your business meet the intent of labor laws while creating customized, sustainable solutions built around respect and trust between workers, buyers, suppliers, and brands. For more information, here are some of our previous posts on HRDD and how to work with your suppliers to meet the new requirements.

29 April 2026 Open Supply Hub (OS Hub) has announced the launch of OS Hub Spotlight, a new offering that connects siloed datasets to production facility profiles — expanding ​​visibility​​​​​​ ​across ​supply chain data​sets​ through a growing network of integration partners, including Labor Solutions. Through this integration, OS Hub Spotlight now highlights the availability of WOVO operational grievance mechanism data from Labor Solutions across relevant production location profiles on the platform. These new integrations mean that ​​social​ an​d environmental​​ data from ​Spotlight ​​​partner organizations can be more easily discovered through an open and collaborative platform. This gives users a more comprehensive view of production locations around the world and helps organizations better understand what remedy infrastructure exists at the facility level — a critical requirement under frameworks such as CSDDD, LkSG, and the UNGPs. What is Open Supply Hub? Open Supply Hub is a global open data platform that maps production locations and connects them with various datasets, helping organizations better understand and address risks and opportunities across their supply chains. To date, OS Hub has mapped over 2.5 million production locations from thousands of organizations, including suppliers, companies, service providers, and civil society organizations. What OS Hub Spotlight means for users Through OS Hub Spotlight, production location profiles on the platform now highlight where WOVO operational grievance mechanism data from Labor Solutions is available. Rather than hosting or replacing Labor Solutions' dataset, OS Hub acts as a connector — helping users navigate the supply chain data ecosystem and understand how different sources relate to real-world production locations. This makes it easier for brands, civil society organizations, and other stakeholders to discover whether a site-level operational grievance mechanism is in place — and to assess its status, utilization, and establishment date — all within a single open platform. For brands: Knowing that a supplier site has WOVO means brands no longer need to rely solely on audits or supplier self-assessments to confirm the existence of an operational grievance mechanism. Attention can shift to what matters more — the quality of case management and remediation. Better grievance data means better understanding of actual risk and better outcomes for workers. For suppliers: Facilities using WOVO can now demonstrate their commitment to worker voice with greater transparency. As brands increasingly prioritize human rights due diligence, suppliers with documented grievance infrastructure and measurable improvements stand out. WOVO presence on OS Hub becomes a visible signal to responsible buyers. Elena Fanjul-Debnam, Co-Founder & CEO, Labor Solutions: According to adidas’ 2024 Annual Report WOVO is "highly effective" and "trusted by workers" throughout the supply chain, evidenced by the “consistent, widespread”, “sustained usage" and "the high volume of cases received through the app.” Natalie Grillon, CEO, Open Supply Hub: "Strong supply chain data depends on connected systems and collaboration. In that spirit, we welcome Labor Solutions as a founding partner for OS Hub Spotlight, making operational grievance mechanism data easier for sourcing, due diligence, and compliance teams to discover, connect and use, alongside other key ESG insights." Building a collaborative ecosystem This partnership reflects Labor Solutions' belief that supply chain transparency requires collaboration. By contributing WOVO data to OS Hub's open platform, Labor Solutions joins nine other founding Spotlight Partners — amfori, Climate TRACE, the International Accord, Living Wage Institute, Social and Labor Convergence Program (SLCP), Ulula, WageIndicator Foundation, Worldwide Responsible Accredited Production (WRAP), and Worldly — in building a more comprehensive view of production locations worldwide. Together, these integrations make it easier for everyone in the supply chain to access the environmental, social, and assessment data they need to make responsible decisions. Looking ahead OS Hub will continue expanding the ecosystem of data connected to production locations on the platform. Additional Spotlight Partners will continue to be announced throughout 2026. Organizations interested in making their datasets easier to discover and connect to real-world production locations through the OS Hub platform are encouraged to reach out to Open Supply Hub. Already using WOVO and want to be listed on Open Supply Hub? Contact us at info@laborsolutions.tech Start exploring Labor Solutions' WOVO data on Open Supply Hub.

A Labor Solutions Analysis | MIT Research, Nelson & Wilmers (2025) Worker voice drives productivity. Not symbolically — measurably. New causal evidence from MIT shows that when manufacturers actively integrate worker input into production decisions, output rises by up to 15%, earnings increase, and turnover falls. For brands under CSDDD and human rights due diligence obligations, this is not a social outcome. It is a value chain capability. Key Takeaways Active worker voice is associated with productivity gains of up to 15% (Nelson & Wilmers, 2025, Table 3) Wage and retention effects persist even after controlling for productivity — indicating a genuine shift in worker bargaining power, not just an output effect Zero grievances at a supplier is not a safety signal. It is usually a sign the system is not trusted or accessible CSDDD requires evidence of grievance mechanism effectiveness — not just existence. Worker-generated data is the only way to provide that evidence The adidas WOVO programme — 402,500 workers, 47,200 grievances, 99% resolution, 79% satisfaction — is the published proof of what a functioning system produces at scale Worker Voice Produces Measurable Business Outcomes — Not Just Compliance Data Dylan Nelson and Nathan Wilmers at MIT have produced something rare in the labor space: causal evidence. Their study, Earnings Effects of Direct Worker Voice in Production (May 2025), examines what happens when manufacturers move from low to high use of worker input in production decisions. The findings are not subtle. Moving from low to high use of worker input is associated with productivity gains of up to 15% (Table 3, pp. 19–20). Earnings increase. Turnover decreases. These are not correlation findings — the study uses quasi-experimental methodology to isolate the effect. For brands, the downstream implication is direct. Factories that perform better produce more reliably: fewer last-minute production crises, more stable output, better absorption of demand volatility. When factories run more smoothly, downstream partners feel it. This is what Labor Solutions has measured in the adidas WOVO programme for eight years. Worker satisfaction at adidas Tier 1 facilities rose from 39% in 2019 to 79% in 2025 — a 40-point gain built through consistent programme investment, not a one-time survey cycle. The Distinction That Matters: Using Worker Input, Not Just Collecting It Nelson & Wilmers make a finding that should change how every brand evaluates its worker voice programme. It is not the existence of a mechanism that drives performance gains — it is whether worker input is actively used in decisions. Many programmes do the first. Very few do the second. Workers speak. Responses are logged. A PDF is produced at the end of a cycle. Nothing changes. A grievance mechanism that is not trusted, not used, and not acted upon is not a compliance asset — it is a liability, because CSDDD Article 9 requires evidence of effectiveness, not just existence. Are workers' insights shaping decisions — or just filling reports? The adidas WOVO programme demonstrates what an effective system looks like in practice. In 2025, 47,200 grievances were submitted by workers across 92 facilities — a 32% increase from 35,700 in 2024. The 99% resolution rate was maintained for the fourth consecutive year. Rising volume alongside a sustained resolution rate is not a problem. It is proof that workers trust the system enough to use it. Zero Grievances Is Not a Safety Signal — It Is Usually a Sign of a Broken System One of the most persistent misconceptions in human rights due diligence is that silence is good news. It is not. Zero grievances at a supplier almost always means one of three things: workers do not know the mechanism exists, they do not trust it, or they have learned from experience that speaking up carries risk. The MIT study reinforces why this matters. The earnings and retention effects it documents persist even after controlling for productivity — meaning the benefit of worker voice is not simply that workers produce more and therefore earn more. It reflects a structural shift in how knowledge and influence are distributed at the facility level. Workers whose input shapes decisions become indispensable contributors. That indispensability shows up in wages and in retention. A programme that workers do not trust cannot produce this effect. Which is why consistent usage, rising volume, and sustained resolution rates are not just a headline — they are evidence of a programme that workers have decided to rely on. Frontline Workers See What Audits Cannot — and They See It First Audits document the past. Workers report the present. Frontline workers are typically the first to notice deteriorating conditions, abusive supervision, wage inconsistencies, safety shortcuts, and the kind of operational friction that becomes a quality or compliance incident months later. The WELL Worker Survey's electronics sector case study found that 35% of suppliers who passed their most recent social audit had workers paying illegal recruitment fees. Seventy-three percent of workers in the same cohort had low rights awareness — none of it visible to auditors. Audits check systems. Workers experience them. When worker feedback is integrated into operational decisions — not logged and filed — those signals are captured early, interpreted in context, and acted on before they become non-compliances. That is real-time risk mitigation. It is also, as the MIT study shows, associated with measurably better facility performance. Worker Voice Is a Value Chain Capability. Here Is What That Requires. The Nelson & Wilmers study gives empirical backing to what practitioners in this field have observed for years: when worker voice is real, factories perform better and workers do better. For brands, that means worker voice belongs in sourcing strategy, risk management, HRDD and CSDDD reporting, and supplier selection criteria — not in a CSR workstream that sits beside the business. If you are: Building or assessing a worker survey programme — the WELL Worker Survey generates primary data directly from value chain workers, surfacing root causes that audits cannot see. Learn about WELL. Looking for an operational grievance mechanism that workers actually use — WOVO CONNECT is an always-on, in-app mechanism that workers can access anonymously, with structured case management for suppliers and live dashboards for buyers. It is not a hotline. Learn about WOVO CONNECT. Working to turn worker feedback into supplier-owned action plans — WOVO IMPROVE translates findings into structured, trackable improvement plans that suppliers own rather than manage. Learn about WOVO IMPROVE. Ready to build the full programme — get in touch . We are happy to continue the conversation. All findings from the MIT study cited in this post are drawn from Nelson, D. & Wilmers, N. (2025), "Earnings Effects of Direct Worker Voice in Production," ILR Review (May 2025). All adidas programme data is drawn from adidas' publicly available annual sustainability reports 2019–2025. Labor Solutions is the provider of the WOVO platform deployed across adidas' Tier 1 value chain. Further Reading Worker Grievances Up 32% — Here's Why That's adidas' Biggest WOVO Milestone Yet What Is Worker Voice — and Why Audits Can't Replace It Operational Grievance Mechanisms: What Buyers Should Look For Worker-Driven Due Diligence vs EcoVadis Worker Voice Connect: What Brands Need to Know Frequently Asked Questions Does the MIT research apply to value chains specifically? Nelson & Wilmers (2025) studied manufacturing facilities — the same operational context as most Tier 1 and Tier 2 value chain suppliers for fashion, electronics, and consumer goods brands. The productivity, earnings, and retention effects documented are directly relevant to the supplier facilities where brands have the most leverage and the most compliance exposure. What is the difference between having a worker voice tool and actually using worker voice? The MIT study is explicit: it is the active use of worker input in decisions — not the existence of a mechanism — that produces the performance effects. A survey that generates a report no one acts on does not qualify. An always-on grievance mechanism with consistent annual usage, 99% resolution, and rising year-on-year volume — like the adidas WOVO deployment — does. How does this research connect to CSDDD compliance requirements? CSDDD Article 9 requires companies to establish or participate in effective grievance mechanisms and demonstrate their effectiveness through usage data, resolution rates, and worker satisfaction — reported under ESRS S2. The MIT study provides independent academic evidence for why this matters operationally, not just legally: a functioning worker voice system produces measurable business performance, not just a compliance paper trail.

Key Takeaways Worker voice is the structured, ongoing process of enabling value chain workers to share experiences, raise concerns, and access remedy — not a single tool or survey. CSDDD, LkSG, and France's Duty of Vigilance Law require worker participation, stakeholder engagement, and access to remedy. They do not require audits. Audits are an industry habit, not a legal requirement. 35% of audit-passing sites have serious risks when workers are given a safe, anonymous channel to share their actual experiences (WELL Worker Survey data). Worker voice only works as a system: survey + grievance mechanism + rights education, running continuously. For the past two decades, the dominant response to human rights risks in global value chains has been the social compliance audit. A team of auditors visits a facility, reviews documentation, interviews a handful of workers, and produces a report. The factory passes or fails. If it passes, brands assume compliance. The problem is not that audits are badly done. Audits serve a legitimate purpose for specific things — physical facility conditions, building safety, policy existence. But they were never designed to tell you what workers actually experience. And the law never asked them to. Most companies built their human rights due diligence infrastructure around audits by industry habit. The legislation — CSDDD, LkSG, France's Duty of Vigilance Law — was built around something else entirely: direct worker participation, stakeholder engagement, and access to remedy. Worker voice is not the thing you add after you have done your audits. It is what the law requires. Worker Voice Is Not a Survey Three Conditions, Not One Tool Worker voice is a worker's ability to influence the conditions of their own working life. Not to be surveyed. Not to be consulted. Not to have a phone number they can call. Not to have a box they can drop a note in. To influence outcomes. That requires three things to be true simultaneously: workers can speak, workers are heard, and something changes as a result. Remove any one and what remains is not voice — it is data extraction dressed as participation. A survey with no visible follow-through is data extraction. A grievance hotline no one trusts is data extraction. Rights education with no channel to act on it is awareness theater. Why the Legal Bar Is Higher Than Most Programs Meet This distinction matters legally. CSDDD does not require companies to collect worker data. It requires worker participation and access to remedy — a meaningfully higher bar that most audit-era compliance programs do not meet. It matters practically too, because workers know the difference. Workers who raise concerns and see nothing change learn not to raise concerns. Workers surveyed through a process they associate with factory management answer in ways they think are safe. The data looks clean. The risk remains. Measurement Without Employer Response Is Not Worker Voice Worker voice is only real when someone who can make change is an engaged and willing participant. In most cases that is the direct employer — the site, the factory manager, the HR director. Government, brand, and multistakeholder initiative mechanisms are important, but a last resort. Employer-employee dialogue is the foundation of a healthy, low-risk workplace — not external enforcement. Change is possible where employers are willing to listen, engage, understand, and act. The WELL Worker Survey is always accompanied by the WELL Self-Diagnostic Tool — a site self-diagnostic tool, not an externally imposed corrective action plan. Sites use it to understand the root causes behind what workers reported, then build their own action plans limited to three priorities at a time. The process is owned by the sites because change has to be owned by the employer to last. Two continuous mechanisms support this cycle: an always-on operational grievance mechanism workers can use between annual survey cycles, and rights-based Digital Learning to ensure workers know their rights, which results in workers being more likely to raise concerns directly with their employer. The goal is not escalation. The goal is a workplace where workers and employers communicate well enough that escalation is rarely necessary. What Social Compliance Audits Miss — and Why A Pattern, Not an Exception The gap between what social compliance audits find and what workers experience is structural, not incidental. Audits are point-in-time assessments conducted by outsiders asking questions workers have every reason to answer carefully. This is not an isolated failure. A 2023 New York Times investigation documented it in detail because it happened to involve recognizable US brands — but the pattern is routine. Auditors reviewed 20 production facilities. Child labor violations were missed at every single one. Children worked the night shift. Auditors arrived in the morning. These failures happen daily across value chains worldwide. The Times investigation named them. Most go unnamed. The Question Your Own Audit Results Should Prompt Consider your own audit results. What proportion come back non-compliant? In industries and regions with documented, well-researched labor risks — recruitment fees, excessive overtime, restricted movement — a system that consistently returns clean results is not evidence that conditions are good. It is evidence that the tool cannot see what is there. Brands that describe audits as "the bare minimum" or "basic compliance" should ask what compliance, exactly, is being measured — and whether the volume of non-findings is a credible reflection of reality in the facilities they source from. What Worker-Led Data Finds Instead The WELL Worker Survey finds serious gaps where audits find none. In documented deployments, 35% of audit-passing sites have been found to carry serious risks — illegal recruitment fees, wage theft, harassment, safety violations — when workers are given a safe, anonymous channel to share their actual experiences. These are facilities that cleared social compliance review. Workers knew. The audit did not ask. The WELL Survey did. The Audit Model Is Not Improving — the Data Confirms It Thirty Years, Zero Movement According to a Deloitte analysis, fewer than 10% of sites are audited under the analogue approach in any given period. Of the audits that do take place, more than 50% are falsified as a direct result of punitive audit strategies. And across a seven-year period of sustained audit activity, the industry has seen 0% improvement in the underlying issues being measured (Sourcing Journal, October 2020). The Legislation Never Asked for Audits What CSDDD and LkSG Actually Require Here is what most companies have not fully absorbed: CSDDD, LkSG, and France's Duty of Vigilance Law do not require audits. They require worker participation, stakeholder engagement, and access to remedy. What the law has always asked for is direct engagement with workers as rightholders. CSDDD Article 9 requires operational-level grievance mechanisms accessible to value chain workers. LkSG requires a complaints procedure that workers throughout the value chain can access. Most companies built their human rights due diligence infrastructure around auditors. The legislation was built around workers. A System Sites Own, Not a Programme Brands Impose The Labor Solutions methodology begins with site engagement, not site inspection. Worker voice only generates honest data when sites understand why the programme exists, see the operational benefit of participating, and own the action plans that follow. A cycle that brands impose and sites manage defensively produces the same result as the audit it replaces — clean-looking data that reflects what sites want brands to see. The model that works is continuous: workers share their experiences, sites act on what they hear, brands verify through longitudinal data rather than point-in-time visits. That cycle has to be owned at the site level to function. The WELL Self-Diagnostic Tool is built around that principle — site self-diagnostic, site-led action plans, three priorities at a time, visible maturity progression over multiple cycles. WOVO is trusted by adidas (402,500 workers, 92 facilities, 100% Tier 1 coverage), Carter's, Nike, H&M, Diageo, Puma, Decathlon, and others across fashion, food & beverage, and technology. The adidas case study documents eight years of outcomes. The Carter's case study shows what scaled deployment looks like across a North American value chain. Want to discuss yours. Workers First. Always. FAQs What is worker voice in a value chain? Worker voice is the structured, ongoing process of enabling value chain workers to share their experiences, raise concerns, and participate in decisions that affect their working lives. It has three components: validated surveys that ask workers about their actual conditions; operational grievance mechanisms they can use continuously; and rights-based education so workers understand what they can raise and how. All three are required for the system to work. Does CSDDD require social audits? No. CSDDD requires worker participation, stakeholder engagement, and access to remedy — not audits. Most companies built their HRDD infrastructure around audits by industry habit. The legislation bypasses audits entirely and requires direct engagement with workers as rightholders. How does worker voice differ from a social audit? Audits assess documented systems and policies at a point in time. Worker voice asks workers directly about their actual experiences — safety, wages, management behavior, recruitment, freedom of movement. 35% of audit-passing sites have serious risks when workers are given a safe, anonymous channel to share what they experience. The difference is structural: workers have every reason to answer carefully in an audit. They do not in a well-designed, anonymous survey. What tools does Labor Solutions provide for worker voice? Labor Solutions provides WOVO, an integrated platform with four modules: the WELL Survey (validated worker wellbeing survey, UNGP Principle 31-aligned); WELL Operational Grievance Mechanism (always-on operational grievance mechanism, not a hotline); WELL Digital Learning (rights-based digital learning for workers and managers); and teh WELL Self-Diagnostic Tool (site self-diagnostic and action planning tool). The platform reaches 3.8M+ active workers in 41+ languages across 180+ countries.