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

The most common question we hear from sustainability directors is not 'should we do this' — it is 'how do I convince everyone else we should do this.' The business case for worker engagement has to work at multiple levels simultaneously: legal and compliance teams worried about regulatory exposure, procurement teams focused on site relationships and cost, boards focused on reputational risk and investor disclosure, and sustainability teams needing to demonstrate genuine impact, not box-checking. Key Takeaways CSDDD and LkSG require worker engagement — not audits. Non-compliance carries fines of up to 5% of global net turnover; directors can be held personally liable. 35% of audit-passing sites have serious risks. Brands with audit-only data do not know what is actually happening in their value chain. Sites who engage actively with the WELL Cycle see a 1:3 return on investment, alongside a 44% reduction in absenteeism and 33% improvement in retention. adidas deploys WOVO across 402,500 workers — worker satisfaction rose from 39% to 79% over five years. That is board-level evidence. ESRS S2 requires mandatory public reporting on worker engagement and grievance mechanism effectiveness. The Business Case for Worker Engagement from Different Perspectives The regulatory case: the law requires worker engagement, not audits CSDDD, LkSG, and France’s Duty of Vigilance Law do not require audits. They require worker participation, stakeholder engagement, and access to remedy. Most companies built their human rights due diligence infrastructure around audits by industry habit. The legislation was built around workers. CSDDD requires companies to establish or participate in operational-level grievance mechanisms for value chain workers, conduct ongoing human rights risk assessments based on direct worker engagement, and produce documented evidence of risk identification, remediation, and outcomes. LkSG is already in force. Non-compliance under CSDDD carries fines of up to 5% of global net turnover. Directors can be held personally liable. The risk management case: audits leave you exposed 35% of audit-passing sites have been found to have serious risks when value chain workers are given a safe, anonymous channel via the WELL Worker Survey. The risks that produce reputational crises — forced labor, illegal recruitment fees, wage theft, harassment — are almost never the risks that appear on audit reports. A brand that has only audit data is a brand that does not know what is actually happening in its value chain. The site case: worker engagement produces operational outcomes Sites who engage actively with the WOVO platform see a 1:3 return on investment. Documented outcomes include a 44% reduction in absenteeism and 33% improvement in worker retention — which translate directly into lower recruitment costs, higher productivity, and more stable site relationships. Factories with low worker trust have higher turnover, more grievances that escalate, and more exposure to the kind of incident that ends a sourcing relationship. The board and investor case: evidence of process, not just intent 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. Board-level disclosure on human rights due diligence is no longer voluntary. adidas cites WOVO in their 2025 Annual Report as the foundation of worker engagement across 400,000 workers in 100% of strategic Tier 1 sites. Worker satisfaction rose from 39% to 79% over five years. Read the adidas case study for the full evidence base. What to say to people who are not yet convinced For legal and compliance: ‘Our current audit approach does not satisfy the CSDDD grievance mechanism requirement. We need to demonstrate that value chain workers have access to a remedy process that works.’ For procurement: ‘This reduces the risk of a sourcing crisis. Factories with worker engagement infrastructure are more stable. Here is the ROI evidence.’ For finance: ‘The cost of non-compliance under CSDDD is up to 5% of global net turnover. The cost of implementation is a fraction of that.’ For the board: ‘Our investors are asking about this. Our reporting obligations require evidence of it. Here is the program that provides it.’ Human rights is a practice, not a project. The sooner the infrastructure is in place, the more evidence accumulates — and the stronger the position when it is tested. To discuss how WOVO can meet your specific CSDDD and LkSG obligations. FAQs What is the ROI of worker engagement for sites? Sites who engage actively with the WELL Cycle powered by WOVO see a 1:3 return on investment, alongside a 44% reduction in absenteeism and 33% improvement in worker retention. These outcomes reflect lower recruitment and training costs, higher productivity, and more stable production. What are the penalties for non-compliance under CSDDD? Non-compliance with CSDDD carries fines of up to 5% of global net turnover. Directors can be held personally liable. The question for legal and compliance teams is not whether to implement worker engagement, but whether the implementation satisfies what the law actually requires. What evidence do boards and investors need on supply chain human rights due diligence? ESRS S2 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. Board-level disclosure requirements mean this is no longer a sustainability team issue. adidas cites WOVO in their 2024 Annual Report as the foundation of worker engagement across 402,500 workers in 100% of Tier 1 suppliers. How do I make the business case for worker engagement to my procurement team? The argument that lands with procurement is operational, not regulatory: factories with worker engagement infrastructure have lower turnover, fewer grievances that escalate into crises, and more stable production schedules. The 1:3 ROI figure and documented reductions in absenteeism and retention are supplier outcomes — not brand talking points. Present the evidence to operations and finance, not just the CSR contact.

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.

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.

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: worker voice. 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 — worker voice 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 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.

The EU decided the test. Workers hold the proof. On 26 June 2026, the European Commission published the implementation guidelines for the EU Forced Labour Regulation (Regulation (EU) 2024/3015), alongside the new Forced Labour Single Portal. From 14 December 2027, any product made with forced labour — in whole or in part, at any stage — is barred from the EU market, regardless of a company's size or sector. Read closely, the Regulation turns on a single question: can a company demonstrate that its product is clean? The evidence that answers it is held by workers. Know what the EU Forced Labour Regulation requires The Forced Labour Regulation is not a due diligence law. It sets an obligation of result — a product free of forced labour — and leaves the method of meeting it to the company. The guidelines are explicit that the Regulation imposes no due diligence obligation beyond what already exists in EU or national law. Due diligence is not mandated; it is how a company reaches the result and shows it has. That distinction governs enforcement. Cases are decided by public authorities, who carry the burden of proof, through a preliminary phase in which a company has 30 working days to respond to a request for information. The guidelines describe full, timely cooperation in that window as the best way to allay an authority's concern before a formal investigation opens. Thirty working days rewards the company that already holds an organised, credible record — and exposes the one that has to assemble it under pressure. Which companies come under scrutiny in the first place is risk-based — screened by sector, geography, volume and the share of a suspect input — and will sharpen once the European Union's upcoming public database on forced labour risks goes live, naming the sectors and geographies authorities will focus on first. No single method is prescribed. But the guidelines name three categories of evidence an authority may draw on: Worker interview transcripts and testimonies Surveys conducted by trade unions or worker representatives Records from grievance mechanisms On method, the guidelines state that workers should be interviewed by trusted third parties to protect confidentiality and safety. The evidence that survives scrutiny is the evidence a site cannot stage - Worker Voice as Evidence The logic is consistent throughout. The strongest evidence of conditions in a value chain is what workers themselves report — confidentially, to someone the site does not control. It is the one input a site cannot prepare in advance. This cuts both ways. A site cannot fabricate what workers report — and a buyer cannot credibly be the one to collect it either. The guidelines discount a social audit wherever workers are supervised by management or cannot speak freely; the condition, not the label, is what strips the evidence of weight. A survey a buyer runs across its own value chain reproduces that condition — workers are being asked to describe the party they answer to. The guidelines recommend that workers be interviewed by trusted third parties to protect confidentiality, accuracy and safety — the same protections self-collection removes. The guidelines' own examples of credible worker evidence point the same way — the surveys they name are those run by trade unions or worker representatives, not by the company under assessment. The guidelines don't require third-party collection — but they don't treat worker evidence gathered by the assessed party as credible either. Worker voice carries evidentiary weight only when the party collecting it is not the party being assessed. This is where most programs are thin, and where a common assumption fails. A grievance mechanism can exist on paper, be documented, and still say nothing about whether workers can reach it, trust it, or see anything change when they raise a concern. Existence is not effectiveness. Under an obligation of result, that difference is the exposure — and only workers can evidence it. See it built: 50 sites, one buyer, six months Consider what that record looks like in practice. A global electronics buyer ran Labor Solutions' WELL Grievance Integrity program — our framework for assessing grievance mechanisms against the UN Guiding Principles' effectiveness criteria, run inside the WELL Cycle — across 50 strategic and high-risk manufacturing sites in six countries, reaching more than 80,000 workers. On paper, the mechanisms existed. Two Operational Grievance Mechanisms, one in-house and one third-party, had received fewer than 20 worker cases across an entire year from all strategic sites combined. Low volume is easy to read as low risk. It is more often a signal that workers cannot access the channel or do not trust it — and that reading only comes from asking them. The WELL Worker Survey did. More than 65% of workers responded — a rate that itself signals readiness to speak when a trusted channel exists. Workers reported that they did not know how to seek help outside the company, that management rarely acted on feedback, and that formal channels were out of reach. WELL Grievance Integrity mapped those findings against all eight UNGP Principle 31 effectiveness criteria; the WELL Self-Diagnostic Tool then examined the management competency behind each gap — not whether a procedure existed, but whether supervisors handle reports without retaliation and whether feedback loops close. Each site received a WELL Action Plan. Six months on, 83% of sites had completed their assigned actions — manager training on grievance handling, more worker-centric reporting channels, and communicating external grievance options back to workers — and 72% had advanced a maturity level. The buyer now holds, per site, a criterion-by-criterion record of what workers experienced, the competency gap behind it, and the action taken to close it. That is the shape of an obligation-of-result record: not a snapshot, but a standing, improving account, grounded in worker evidence and documented over time. It is what the WELL Cycle produces each year as WELL Intelligence — a body of evidence that deepens with every stage and compounds because the cycle repeats. Three frameworks that point in one direction The EU is not moving alone. CBP's June 2026 forced labor guidance names stakeholder engagement first among its eight due-diligence elements. The UN Guiding Principles have set the expectation since 2011 — the responsibility to respect turns on meaningful consultation with affected workers (Principles 18 and 19, Pillar 2), and the effectiveness of a grievance mechanism (Principle 31, Access to Remedy) can only be established by asking workers directly - setting worker voice as evidence. CSDDD and ESRS S2 build on the same architecture. The capability that answers one answers them all: a worker-grounded, criterion-level record of what is happening and what has been done about it. Test your evidence file The Regulation did not change what credible due diligence looks like. It changed the cost of not holding the evidence — and set a 30-working-day clock on producing it. The question worth testing now is a simple one: if an authority asked today, could you show what workers themselves report about the risks in your value chain, and what you did in response? Where the answer is not yet, the place to start is where the WELL Cycle starts — by listening. To run the WELL Cycle on grievance mechanisms or other salient topics across your value chain — Human rights is a practice, not a project.

The regulatory floor stops at Tier 1. The exposure sits upstream. Buyers moving there now are ahead of the law and closer to the risk. The 2025 sustainability reporting cycle is showing the direction of travel. Buyers are naming Tier 2 as a 2026 priority and disclosing the worker engagement tools they use at Tier 1. ASICS' 2025 Sustainability Report is one public example — announcing expansion of human rights risk management to Tier 2 suppliers (Asics Sustainability Report 2025, p. 24) and naming Labor Solutions' WOVO app as part of its Tier 1 grievance and complaint mechanism at strategic factories in Cambodia, Vietnam, and Taiwan (p. 29). It is not the only such example. It is a signal of where the field is going. Regulation is not driving this. The CSDDD, the German Supply Chain Act (LkSG §8), and the EU Forced Labour Regulation (Regulation (EU) 2024/3015) all set Tier 1 as the compliance floor. Tier 2 is not required. Buyers going upstream are choosing to, because that is where a growing share of the risk actually sits. And Tier 2 is where grievance mechanisms are thinnest. Tier 2 grievance mechanisms carry a different load than Tier 1 At Tier 1, a buyer has a direct commercial relationship, a named site, contract language, and — usually — a grievance channel workers can be told about during onboarding. Even at that level, effectiveness is uneven: worker voice surfaces serious risks in 35% of sites that had already passed audit. Tier 2 introduces four structural changes at once. The buyer has no direct contract with the site. The workforce is often more migrant, more contracted, and more linguistically fragmented. The channel — if one exists — is usually operated by the Tier 1 supplier, not the buyer. And the workers are less likely to know the buyer exists, let alone which channel connects to it. Every one of UNGP Principle 31's eight effectiveness criteria — legitimate, accessible, predictable, equitable, transparent, engagement and dialogue, rights-compatible, and continuous learning — has to be evidenced under these conditions. None of them get easier upstream. CSDDD sets Tier 1 as the floor. The exposure sits upstream. The regulatory picture is precise, and it is worth being precise back. CSDDD Article 9 requires effective grievance mechanisms across the chain of activities, with the strongest obligations at Tier 1 and a risk-based extension beyond. LkSG §8 requires a complaints procedure accessible to workers in the buyer's own operations and direct suppliers. The EU Forced Labour Regulation, effective 14 December 2027, applies to any product placed on the EU market — meaning risk originating at Tier 2 or beyond can still trigger enforcement at the border, and a buyer has 30 working days in the preliminary phase to respond with evidence. The pattern across all three is the same: mandate at Tier 1, exposure at Tier 2 and beyond. A buyer who meets the Tier 1 floor and stops has closed the compliance gap and left the risk gap open. Accessibility fails first when the site isn't your direct supplier. Under Principle 31, accessibility means workers can find the mechanism and use it without barriers. At Tier 2, four barriers stack. Language coverage. Tier 2 workforces routinely include languages Tier 1 channels do not serve — migrant languages, minority languages, and dialects that do not appear in the buyer's HR materials. A channel that runs in the site's official language reaches management. A channel that runs in the languages workers actually speak reaches workers. Channel operator. If the channel is operated by the Tier 1 supplier that also holds the commercial relationship with the Tier 2 site, workers raising a concern are raising it to someone with a business interest in resolving it quietly. UNGP Principle 31 requires the channel to be trusted — trust is not asked of workers, it is evidenced by them. Line of sight to the buyer. A worker who does not know which brand ultimately buys the product cannot raise a concern to that brand's system, even where one exists. Buyer visibility is a design decision that has to be made at deployment, not assumed. Retaliation exposure. Tier 2 workers are often on shorter contracts and less visible to the buyer's own oversight. The consequence of raising a concern is closer to the surface. Anonymity and independence of the channel matter more here, not less. Predictability and engagement have to cross a contractual layer. Principle 31's predictability criterion asks that workers understand the process and experience it consistently. At Tier 2, the process usually runs through the Tier 1 supplier before it reaches the buyer, if it reaches the buyer at all. A worker who raises a concern does not see what happens after it leaves the site. Consistency across cases is difficult to establish and harder to evidence. Engagement and dialogue is the criterion that most often fails silently at Tier 2. Worker representation structures at Tier 2 are less mature. Collective mechanisms are less common. The dialogue channel between workers and management is weaker, and the dialogue channel between Tier 2 workers and the buyer typically does not exist at all. Closing these gaps is not a matter of extending a Tier 1 policy document to Tier 2. It requires a channel designed for the upstream context — its own accessibility work, its own trust-building, its own reporting flow that returns grievance data to the buyer rather than around it. Grievance data at Tier 2 has to flow back to the buyer, not around it. The output of a working Tier 2 grievance mechanism is not just resolution at the site. It is intelligence at the portfolio. A buyer extending grievance mechanisms upstream is building a data flow that surfaces where in the value chain the exposure sits, which Tier 2 sites are producing signals that Tier 1 audits missed, and where remediation resources should go first. This is what WELL Cycle is designed to produce: a site and portfolio risk view grounded in worker voice, layered with site context and structured self-reflection. It is where grievance data stops being a compliance record and becomes strategic intelligence. ASICS' 2025 disclosure describes the WOVO app — a Labor Solutions platform — as one such tool at Tier 1, noting that it "aims to improve communication between factory management and employees, leading to reduced human rights risks and improved factory performance" (ASICS Sustainability Report 2025, p. 29). Under CSDDD, that intelligence is disclosable. Under the EU Forced Labour Regulation, it is what a buyer will need to produce in the 30-working-day preliminary phase. Under CBP's June 2026 consolidated forced labor enforcement guidance, it is the documentation that meets the clear-and-convincing evidence standard. The buyers building this flow now are not doing it because the law requires it. They are doing it because the risk is already there, and the record is not. Tier 2 grievance integrity uses the same instruments as Tier 1, adapted for the upstream context. Labor Solutions has run the WELL Cycle across 50 strategic and high-risk manufacturing sites in six countries at Tier 1, reaching more than 100,000 workers and evidencing all eight UNGP Principle 31 criteria. Six months after WELL Action Plans were issued, 83% of sites had completed their assigned actions and 72% had progressed to the next maturity level on grievance mechanisms. The same instruments — the WELL Worker Survey for worker experience, the WELL Self-Diagnostic Tool for management systems — extend to Tier 2 with adaptations for the upstream context. Language coverage. Migrant worker sampling. Buyer visibility built into channel design. Grievance data structured to flow back through the Tier 1 relationship without being filtered by it. This is the next round of the WELL Cycle for buyers who have completed Tier 1 and are extending upstream. Listen. Diagnose. Improve. Educate. Repeat — one tier further out each time. The buyers moving upstream are moving toward the risk. The 2025 reporting cycle is showing which buyers are doing this work. The next reporting cycle will show which of them can evidence it. → Talk to us about evidencing grievance mechanism effectiveness across your value chain. Human rights is a practice, not a project. FAQs Does CSDDD require Tier 2 grievance mechanisms? CSDDD Article 9 requires effective grievance mechanisms across the chain of activities, with the strongest obligations at Tier 1 and a risk-based extension beyond. Tier 2 mechanisms are not mandated as a blanket requirement, but exposure at Tier 2 can still trigger CSDDD obligations where risk is identified. What does the EU Forced Labour Regulation require at Tier 2? Regulation (EU) 2024/3015 applies to any product placed on the EU market from 14 December 2027 onward, regardless of where in the value chain the forced labor risk sits. A buyer whose Tier 2 supplier is implicated can be required to respond with evidence within 30 working days in the preliminary phase. The regulation does not prescribe method, but the June 2026 implementation guidelines name worker interview transcripts, worker surveys conducted by trusted third parties, and grievance mechanism records as accepted evidence categories. What makes Tier 2 grievance mechanisms harder to run than Tier 1? Four structural factors: no direct commercial relationship between buyer and site, more linguistically fragmented and migrant-heavy workforces, channels typically operated by the Tier 1 supplier rather than the buyer, and lower worker awareness of the buyer's existence. Each of these compounds the effectiveness gap that Principle 31 asks buyers to close. What is a "trusted third party" under the EU Forced Labour Regulation guidelines? The Commission's June 2026 implementation guidelines state that workers should be interviewed by trusted third parties to protect confidentiality and safety. In practice this means an operator independent of the site and the buyer, running the channel with worker-facing accessibility work and confidentiality protection built in. How do you assess grievance mechanism effectiveness at Tier 2? Effectiveness under UNGP Principle 31 is evidenced from two sides at once: worker experience of the channel and the management systems supporting it. Labor Solutions' WELL Grievance Integrity Program measures both — the WELL Worker Survey captures whether workers know the channel exists, trust it, and see change when they use it, and the WELL Self-Diagnostic Tool captures whether the site has the systems to receive, process, and act on grievances. Neither alone is sufficient. What is the difference between a grievance channel and grievance integrity? A grievance channel is a mechanism a site has built. Grievance integrity is evidence that the mechanism works — that workers can reach it, trust it, and see resolution when they use it. Under CSDDD, LkSG, and the EU Forced Labour Regulation, existence is documented easily. Integrity has to be evidenced by workers.

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.

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.