Search this site

A Labor Solutions Case Study Case Study Snapshot Client: Global electronics company Scope: 50+ Tier-1 & Tier-2 sites (India, Vietnam, Romania, Malaysia) Method: The WELL Worker Survey deployed via the WOVO Dashboard Why: Validate audit findings + gain between-audit visibility Key findings: 35% sites: workers reported illegal recruitment fees 27% sites: low engagement/mistrusted grievance mechanisms Additional risks: retaliation concerns, supervisory misconduct, harassment, hours How the WELL Survey Uncovered Hidden Risks Missed by Audits in Over 50 Electronics Sites A multinational electronics company deployed the WELL Survey across more than 50 sites that had already passed traditional social audits. The goal was to compare audit findings with direct worker experience. The Challenge Positive Audits, Lingering Doubts Although audit results suggested strong compliance, the brand suspected critical gaps in visibility. Across sites, grievance channels varied widely, worker trust in reporting mechanisms was low, and audit interviews were failing to surface systemic issues—particularly around recruitment fees. The brand needed a way to validate audit findings and gain “between-audit” visibility into real, day-to-day risks experienced by workers. Our Solution Deploying the WELL Worker Survey at Scale Labor Solutions implemented the WELL Worker Survey—a worker-centric, globally consistent human rights survey designed to capture lived experience while remaining sensitive to regional risk. The survey combined standardized core indicators for cross-supplier comparability with localized modules tailored to country-specific risks. Questions were experience-based and written in clear, worker-friendly language to encourage trust and honest participation. Labor Solutions provided full deployment support across all countries, with real-time analytics delivered through the WOVO Engage Dashboard. WOVO Engage Dashboard Results: The WELL Survey Revealed Significant Issues that Audits had Entirely Missed. Despite strong audit performance, the WELL Survey exposed systemic risks that audits had failed to detect in almost every supplier. What audits missed (worker-reported): At 35% of sites, workers reported paying illegal recruitment fees—issues that audits had failed to detect. At 27% of sites, low worker engagement pointed to unclear or mistrusted grievance mechanisms. Reported barriers: fear of retaliation, inaccessible channels, supervisory misconduct, harassment, working hours risks. These insights enabled targeted remediation planning and faster prioritization across the supply base. Actions Moving Data into Real Impact Fast Actions taken Results reviewed in real time in the dashboard (heatmaps / supplier comparisons) Findings shared with sites immediately Brand launched supplier self-diagnostic + action plans Real-Time, Actionable Insight Through WOVO Dashboard Using the WOVO Dashboard, the brand accessed survey results in real time as surveys were launched simultaneously across countries and languages. This provided immediate visibility into priority issues, risk levels across sites, and patterns across sites, regions, and supplier tiers—visualized through intuitive heatmaps and dashboards. With worker-level insights that had previously been inaccessible, the brand moved quickly from data to action. Findings were shared directly with sites, enabling targeted remediation within days rather than after the next audit cycle. As a result, the brand initiated site self-diagnostics and action plans to address identified risks. Immediate Impact + Remediation As a result, the brand was able to: Identify high-risk sites within days, not months Launch targeted remediation plans faster Compare risks across regions and supplier tiers Equip sites with actionable, worker-backed insights Using worker-level insights that were previously inaccessible, the brand has decided to conduct site self-diagnostic and action plans, using the WELL Cycle. This project demonstrated that even well-established audit programs can miss systemic, persistent issues—and reaffirmed that worker-driven data is essential to effective, modern due diligence. Why it Worked How the WELL Survey Turned Worker Voice into Comparable, Country-Specific Intelligence Global Consistency, Local Relevance The WELL Survey provided a standardized global structure covering core human rights topics—health and safety, access to remedy, harassment and abuse, and worker engagement—while allowing tailored indicators based on regional risks: Working hours focus for China Responsible recruitment for Malaysia and Romania Working environment and supervisory conduct for India This combination ensures comparability across countries and actionable insights within each region. Worker-Centric, Industry-Refined Questions: Revealing the Reality Behind Compliance Experience-based Questions Unlike audits, the WELL Survey relies on neutral, experience-based questions written in clear language and supported by scenario prompts. This approach helps workers reflect on real situations and share feedback they may otherwise withhold—revealing issues that often remain invisible during formal interviews. Deployment Support That Ensured High Engagement + Powered True Insights Labor Solutions managed the full rollout across all sites, onboarding each site in local languages and launching surveys simultaneously across regions. Workers participated anonymously via QR codes, increasing trust and response quality. Responses were analyzed and visualized in the WOVO Dashboard, allowing the brand to quickly spot patterns, compare sites, and prioritize action. Real-Time, Actionable Insight Through WOVO Dashboard The brand’s team accessed results instantly via the WOVO Dashboard, enabling them to launch surveys simultaneously across multiple countries and languages to gain immediate visibility into: Priority issues across countries Visualize risk levels through a supplier heatmap Compare priority issues across sites and regions Share insights directly with sites for follow-up This enabled action plans within days, not after the next audit cycle. What this Case Study Shows From Audit Validation to Continuous, Worker-Driven Due Diligence Audits can validate documentation and controls, but they may not capture lived experience — especially on sensitive issues like recruitment fees or fear of retaliation. Worker-reported data adds a complementary layer of risk visibility. Between-audit visibility changes the operating model from periodic compliance to continuous risk detection. Real-time survey feedback can surface systemic issues early and guide faster interventions. Standardization enables comparability across sites, while localization ensures relevance. A consistent core survey paired with country-specific modules supports both global oversight and local action. Trust and participation are the signal—not just the outcome. Low engagement can indicate mistrusted or unclear grievance mechanisms, which is itself a due diligence risk worth addressing. Actionability matters more than data volume. When results are delivered in a format teams can interpret quickly (heatmaps, supplier comparisons), it becomes easier to prioritize remediation and engage sites immediately. Curious about what you might find with worker surveys?

Asking workers was right. Buyers lacked a standard for how to ask and how to act on the answers. Many buyers have run a worker survey. They were right to. We speak directly to workers because workers know what audits can't — finding risks in 35% of sites audits had cleared. Then, for many buyers, little changed. They received a dashboard, noted the scores, and found the same risks a year later. Buyers did not cause this. We have built and run worker voice tools since 2013, and we saw the same three failures across industries. Surveys asked compliance questions, so workers gave safe answers Committees wrote many surveys. They asked what an audit already answers, often in a language workers did not fully understand, with a supervisor nearby and no anonymity. Workers tell the truth only when they believe it is safe. Sites did not know how the data would be used, so few joined. Response rates fell. There is a deeper reason workers hold back. An audit is a check between a buyer and a site. A worker survey asks a person to be honest about their own working life, and to trust that something will follow. When an honest answer could put a site’s contract at risk, sites manage the result and workers read the room. The programs that get candid answers treat finding risk as shared work with the site. Scores did not show buyers where the risk was A single score averages workers whose conditions differ sharply. A site can score well overall while its migrant workers score far lower on recruitment fees and freedom to leave. Scores were also not tied to risk or to the frameworks buyers report against. Buyers could not compare sites, track change from year to year, or report results internally. A one-off survey also dates quickly. Conditions change: a recruiter is replaced, a production line accelerates, a labor broker arrives mid-season. Without a second round, there is no trend, no proof anything improved, and no warning when conditions worsen. Buyers received data but no next step Every buyer asked: “What now?” Only the largest teams could act on the data. For the rest, the report went to the sustainability team and the problem stayed at the site. A score shows what is wrong, not why. A site that receives a scorecard instead of a plan changes nothing. Workers who report problems and see no change stop reporting, and the next survey collects fewer candid answers. There is also a clock running. When a worker reports a problem, the harm is already happening. A score left on a dashboard is not a neutral pause. It is a known risk that no one has acted on. One shared standard fixes all three failures Buyers did not lack engagement. They lacked a shared method: one trusted way to ask, results expressed as risk, a way to find the root cause, and a site-owned plan, repeated every year. WELL: One Standard. Every Industry. Modular Design. Developed with industry leaders including adidas, Nike, H&M, Decathlon, Dell, Carter’s, HP, Ralph Lauren, BT + Asker. The WELL Cycle has four steps: Listen. The WELL Worker Survey reaches value chain workers in their language, through channels they trust, in formats designed for low-literacy environments. Diagnose. The WELL Self-Diagnostic Tool is a digital tool to help sites understand worker feedback and identify root causes. Improve. The WELL Action Plan: worker feedback becomes site-owned action. Educate. WELL Digital Learning: rights-based learning mapped to WELL indicators — for workers and managers. The survey is the same at every site, every year, so results compare across a portfolio. Findings arrive ranked by severity, paired with next actions and mapped to regulatory obligations. One electronics buyer ran the WELL Cycle across 50 sites, reaching more than 80,000 workers; six months on, 83% completed their actions and 72% advanced a grievance-mechanism maturity level (see the case study). The cycle continues year after year because human rights is a practice, not a project. Audits are not the problem here. They have a clear role, a clear set of standards, and they do that job well. The trouble starts when every new risk gets added to the audit, even ones an audit was never built to see. Worker voice can carry that load, once it has a standard of its own. Audits tell buyers what sites built. WELL tells buyers if it’s working. Did your last survey produce a dashboard and no change? WELL starts there. Contact us. Workers first. Always. FAQ Why didn't our worker survey lead to change? A survey shows what is wrong, not why, and a scorecard is not a plan. Change needs a consistent method that diagnoses the root cause and hands the site an action plan it owns, repeated each year. What makes the WELL Worker Survey different from a standard worker survey? It reaches value chain workers in their language, through channels they trust, in formats designed for low-literacy environments, so answers are candid. It runs the same way at every site, so results compare across a portfolio. How does WELL turn survey findings into action? The WELL Self-Diagnostic Tool diagnoses the root cause behind each finding, and the WELL Action Plan turns it into site-owned steps, paired with WELL Digital Learning. Can WELL results be used for regulatory reporting? Findings arrive ranked by severity, paired with next actions and mapped to the frameworks buyers report against — the evidence a buyer needs when a regulator asks. Is WELL a certification or an audit? No. WELL is a Worker-Driven Due Diligence methodology — the standard buyers are adopting to ask consistently and act on what workers report. It does not certify sites or replace audit; it shows buyers whether what a site built is working.

How Food & Beverage Brands Are Scaling Worker Voice Beyond Audits Implementing worker voice in food and beverage supply chains requires more than surveys and audits. Agriculture, seafood, and food processing depend heavily on seasonal, migrant, and informal labor—often in low-literacy, low-access contexts where traditional compliance tools struggle to capture real working conditions. As brands strengthen human rights due diligence expectations, worker voice must be designed for these realities. Labor Solutions works with global food and beverage companies to implement scalable, low-barrier worker voice systems that generate credible, decision-ready insight. Our approach combines worker surveys, grievance mechanism assessment, and targeted capacity-building to move from listening to action. At the center of this work is the WELL Worker Survey, deployed through WOVO and adapted to each supply chain’s operational context. This article shows how worker voice in agriculture provides sector-specific evidence that strengthens human rights due diligence beyond audits. Context Designing Worker Voice for How Agriculture Actually Works We begin by mapping how the supply chain functions in practice—farms, collection points, processing facilities, and seasonal gathering locations—and aligning deployment to production realities such as harvest cycles and peak processing periods. Surveys are delivered through QR codes where feasible, and through human-led, in-person deployment where literacy, language, or access barriers exist. Because limited literacy requires more support—not more automation—we do not rely on IVR. In agricultural and migrant worker settings, IVR consistently reduces understanding, engagement, and data quality. Trained deployment leaders are essential to ensure informed consent, trust, and meaningful participation. What This Looks Like in Practice Across agriculture, seafood, and food processing, worker-verified data revealed risks that audits alone did not surface—and enabled earlier, more targeted action. Agriculture: Worker and farmer surveys deployed across multiple countries achieved 92% worker and 87% farmer participation, uncovering wage, working-hours, debt bondage, and safety risks missed by audits. Migrant Labor (Southeast Asia): Nearly 60% response rates revealed overtime coercion risks reported by 85% of workers, prompting contract revisions, management training, and strengthened worker committees. Seafood: Worker surveys captured role- and gender-specific risks, including fatigue and psychological safety concerns, translating worker feedback into targeted improvement priorities. Across these contexts, worker voice data strengthened supplier engagement, enabled earlier risk detection, and supported more credible human rights due diligence. Why This Matters Beyond Agriculture Focusing on real worker experience While these examples focus on food and beverage supply chains, the lesson is broader: worker-centered due diligence depends on systems designed around workers’ realities—not audit convenience. When worker voice is embedded into supply chain governance and linked to follow-up, remediation, and capacity-building, it becomes an operational asset rather than a reporting exercise. Learn how brands use worker voice beyond audits.

Executive Summary An electronics manufacturing site had already built what a basic grievance mechanism needs - clear policies, defined channels, documented procedures. The open question was the one that matters most: does it work for workers? At baseline, less than 15% of workers said they clearly understood what happens after a problem is reported to management. Through the WELL Grievance Integrity Program, the site listened to what workers actually experienced, pinpointed where confidence was breaking down, and owned a practical plan to close the gap. Between baseline and endline surveys, worker confidence rose across every indicator in the Grievance Integrity Extension Program - Grievance Mechanism Accessibility, Grievance Mechanism Process + Transparency, and Communication - and by endline the site met 7 of the 8 UNGP Principle 31 criteria for an effective grievance mechanism. The site turned a mechanism that looked complete on paper into one workers know, trust, and use. A grievance mechanism can look complete and still fail workers. Most manufacturing sites arrive at the same point in their human rights work: the policies are written, the grievance channels exist, the procedures are documented. What comes next is harder. Does the mechanism actually work for workers - and if not, which part? Why isn’t it working? And how do you improve it? An audit can confirm a system exists on paper. It cannot tell a site whether workers know how to raise a concern, trust it will be handled fairly, or believe that speaking up changes anything. There is a further gap. Sites generally know what international standards expect of them - but breaking those standards down into tangible steps they can take in daily operations is difficult. The site wanted to close both gaps: to see clearly how its mechanism was working for workers, and to translate a high-level standard into practical actions its teams could actually carry out. The WELL Grievance Integrity Program turns UNGP Principle 31 into steps a site can act on. The WELL Cycle takes each question in turn, and the site owns every step. The WELL Grievance Integrity Program does the translation sites find hardest - turning an internationally recognized standard, UNGP Principle 31, into clear indicators, survey questions, and actions that both workers and managers can understand and act on. The Cycle is how that program runs inside a site: Listen, Diagnose, Improve, Educate. Repeat. Listen - the WELL Worker Survey captures how workers actually experience the grievance mechanism, in their own language. The Grievance Integrity Extension indicators carry the finding - Grievance Mechanism Accessibility, Grievance Mechanism Process + Transparency, and Communication - read alongside the WELL Core indicator Access to Remedy. It goes past a single average to surface the real drivers of low confidence - where workers hesitate, and which groups feel least sure where to turn. Diagnose - the WELL Self-Diagnostic Tool examines the systems behind those results. Read together with the survey, it shows what is really driving each gap - whether workers simply aren’t yet aware of how the mechanism works, or the mechanism itself needs strengthening, for example a more transparent way of handling cases or a clearly designated person responsible for each step. Each points to a targeted fix. Improve - with the gaps pinpointed, the site built its own WELL Action Plan of practical, targeted steps, structured as Intended Outcomes. A few examples: What workers told us Targeted action the site took Workers experience uncertainty and vague routing during follow-up, creating confusion about how complaints are actually processed. Map and clearly communicate the full reporting pathway - with named contact people - in workers’ own language Some workers hesitated to raise more sensitive concerns Train managers and grievance handlers to respond + handle sensitive issues, and share visible “You Said – We Did” updates so workers see outcomes Confidence in the mechanism varied between worker groups Track how different groups experience and use the mechanism, so access stays even for everyone The WELL Action Planner gave the site one structured place to run the plan and hold itself accountable: every action assigned to a named owner, a timeline set, and supporting evidence uploaded as each step was completed. That record is also the evidence trail buyers need for CSDDD Article 16 disclosure - status, owner, deadline, and evidence for every action, visible without waiting for the next survey cycle. Educate - WELL Digital Learning closed the same gaps from the other side. Workers took Understanding Grievances and Effective Communication. Line leaders took Responding Effectively to Grievances. Managers and practitioners took Implementing Your Grievance Mechanism and Access to Remedy. Every module maps to an indicator the survey flagged, so learning is targeted rather than blanket. Repeat - a follow-up WELL Worker Survey then checked the only measure that counts - whether the changes showed up in workers’ own experience. The WELL Cycle runs on an annual rhythm - each year’s survey, diagnosis, and action building on the year before. Read together, the WELL Worker Survey, the WELL Self-Diagnostic Tool, and the tracked actions produce WELL Intelligence: a site + portfolio risk view grounded in worker voice, layered with site context and structured self-reflection - ranked by severity, paired with next actions, updated with each improvement. Worker confidence rose across every part of raising a concern. The site completed 6 out of 7 planned actions and went back to workers with a second survey. The trend was clear: across every Grievance Integrity indicator, workers reported greater confidence than at baseline - clearer on how to speak up, more assured their concerns would be handled fairly, and more likely to feel heard. The percentage of workers understanding what happens after a concern is reported rose meaningfully and by endline the mechanism met 7 of the 8 UNGP Principle 31 criteria. A mechanism that was already well-built now works better in practice for the people who use it. One priority stays in focus - making sure every worker, in every group, can reach help easily and confidently - and that is exactly what the next cycle is for. This is the strength of the approach: not a one-off project, but a continuous process the site owns, one that keeps surfacing what workers experience, pinpointing where to act, and confirming whether action lands. It also shows why worker engagement is worth the effort - audits tell buyers what sites built, and WELL tells buyers if it is working. And because the Cycle repeats each year, WELL Intelligence compounds - the next survey starts from everything the last one established. You only know a mechanism works when workers use it. How do you know whether your grievance mechanism actually works for workers? Not from whether the policy exists - only from whether workers know it, trust it, use it, and see outcomes when they do. The sites that find out are the ones that ask workers directly and treat that feedback as a continuous cycle: Listen, Diagnose, Improve, Educate - then listen again. Does your grievance mechanism actually work for the workers who depend on it? If you can't yet answer that with evidence, that's where the WELL Grievance Integrity Program begins - turning UNGP Principle 31 into what workers report, a plan your sites own, and proof the changes reached the people who raise concerns. The next step is a conversation about where to start. 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 rights holders 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.

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.

Audits tell buyers what sites built. WELL tells buyers if it's working. WELL programs are now mapped against leading international frameworks - the UN Guiding Principles and the ILO conventions that national legislation increasingly builds on, making WELL outcomes easily transferable into the evidence buyers need to meet their own requirements. Selecting an extension on top of the WELL Core Program is what makes a framework mapping possible and the mapping is an outcome of the cycle. To measure universal workplace risks, every site starts in the same place Every WELL program runs the WELL Core Program at every site, every cycle — the same four indicators: Occupational Health + Safety Harassment + Abuse Access to Remedy Engagement Together they confirm workers were consulted, and the most severe harm categories were checked. The Core Indicators are sometimes included in the mapping, and are often used as contextual findings. For example, where workers have a low Engagement score, trust is low, indicating they may not have divulged everything in the survey. To reach the framework mapping they need to cite, buyers choose the depth Beyond the baseline, buyers choose extensions - indicator sets that deploy together, each built around a leading international framework. The extensions available today: Extension Anchor Framework Indicators Grievance Integrity UNGP Principle 31 Grievance Mechanism Accessibility + Grievance Mechanism Process + Transparency + Communication (optionally Freedom of Association) Fundamental Rights at Work ILO Declaration on Fundamental Principles and Rights at Work Freedom of Association, Freedom of Movement, Responsible Recruitment, and Child Labor and Gender Equality Forced Labor + Responsible Recruitment ILO C29, Forced Labour Freedom of Movement + Responsible Recruitment + Fair Pay + Compensation + Fair Working Hours (optionally Migrant Worker Equity and Dormitories + Accommodation) Fair Wages + Working Hours ILO C1, C95 and C131 Fair Pay + Compensation + Fair Working Hours + Wellbeing Workplace Safety ILO C155, Occupational Safety and Health Workplace Climate + Environment + Wellbeing Sexual Harassment ILO C190, Violence and Harassment Sexual Harassment + Gender Equity Worker Welfare ILO Decent Work Agenda Professional Development + Gender Equity + Fair Pay + Compensation + Workplace Communication + Wellbeing + Social Connection Leadership + Culture — carries no anchor framework, so it reports as contextual indicators and doesn't, on its own, qualify a deployment for External Reporting. Each extension's criteria are mapped to specific WELL indicators, questions, and findings - a buyer running one gets an assessment built around the criteria their own due diligence already has to answer, not a generic survey with a framework label attached. Demographic questions are built into every deployment - capturing dimensions such as gender, migrant status, and age - and disparity across those groups gets measured every time. It isn't an extension of its own; it's what keeps a finding honest across groups instead of flattening everyone into an average. Buyers choose which extensions to run, based on their own risk assessment. Labor Solutions provides the country and sector reference material to inform that choice - but which extensions to deploy is the buyer's decision to make, not ours. What comes out the other side: evidence buyers can put their name to Once a site runs the WELL Core Program plus at least one extension, findings stop sitting only in a site report. They become WELL Intelligence - a site and portfolio risk view, ranked by severity and paired with next actions - and from there they turn into structured, buyer-ready disclosure content, organized around the reporting obligation it answers rather than a framework the buyer has to translate on their own: program scope worker consultation evidence findings against the anchor framework the due diligence response remediation evidence Each piece gets built once, from the same worker-driven data, ready to drop into a buyer's own reporting. And because the WELL Cycle repeats, none of this is a snapshot. Each survey and re-survey adds to what came before, so the evidence deepens cycle over cycle instead of resetting to zero at the next audit window. An audit tells a buyer what a site looked like on the day. WELL Intelligence tells them whether it's getting better - and keeps telling them. That's the gap between a tool that points at a problem and a program that hands a buyer something they can put their name to. Interested in how WELL Grievance Integrity maps to UNGP Principle 31 for your value chain? Reach out to the Labor Solutions team. Human rights is a practice, not a project. Frequently asked questions What is the WELL Core Program? Four indicators — Occupational Health + Safety, Harassment + Abuse, Access to Remedy, and Engagement — deployed at every site in every WELL program. On its own, the WELL Core Program confirms workers were consulted and the most severe harm categories were checked. It doesn't carry an anchor framework. What is a WELL extension? A named set of indicators that deploys together and carries an anchor framework — a UNGP Principle or an ILO convention, for example. Buyers pick extensions based on their own risk assessment. What is the WELL Cycle? The methodology behind every WELL program: Listen, Diagnose, Improve, Educate, Repeat. The WELL Worker Survey and WELL Self-Diagnostic Tool sit inside Listen and Diagnose; extensions and their framework mappings apply to the same cycle, not a separate process. How is a WELL extension different from a compliance audit? An audit checks what a site built against a checklist. A WELL extension asks workers directly, then checks whether the site's own systems can identify and remediate what workers report — and ties both to a named external framework, so the finding is evidence, not just an observation. What is an anchor framework? The external standard an extension's findings get mapped against — UNGP Principle 31 for Grievance Integrity, ILO C155 for Workplace Safety, and so on. The framework is satisfied by the extension's full indicator set, not by any single indicator. How does an extension's mapping work? Each extension's framework is broken down to the criterion level, with specific WELL indicators, questions, and findings tied to each criterion. That's what lets a finding point back to a named requirement instead of a general theme. Can a buyer mix and match indicators instead of selecting a full extension? No. A framework citation needs the full indicator set an extension defines. Individual indicators on their own don't get you there.

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 with grievance mechanism data 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. Start exploring Labor Solutions' WOVO data on Open Supply Hub. Already using WOVO and want to be listed on Open Supply Hub? Human rights is a practice, not a project.

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 The WELL Cycle. 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.

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. → 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. Human rights is a practice, not a project.