Human Rights Due Diligence: The Landscape and amfori’s Recommendations for EU Institutions



Supporting our members on their journey to advance human rights due diligence (HRDD) is one of the foundations of amfori’s activities. Here we are publishing a set of recommendations for EU institutions, alongside key principles for due diligence.

In addition to these recommendations, we are also publishing a briefing for our members describing the current HRDD landscape. This provides an overview of existing approaches, frameworks; what they mean for amfori’s members and where amfori can support. 

Key Policy Recommendations for EU Institutions

  • Develop an EU-wide approach requiring companies operating in the EU to carry out human rights due diligence (HRDD)  proportionate to the size / leverage in the supply chain and commensurate with the nature of the adverse impact.
  • Foresee a phased approach to implementation so that companies are given time to adjust their internal systems and processes without rushing into compliance unprepared.
  • Establish a proper monitoring and enforcement mechanism, while safeguarding a pragmatic approach on due diligence.
  • Strive for a smart mix of measures (voluntary and mandatory), including incentives to reward those companies that go beyond compliance.
  • Make responsible business conduct one of the criteria of the EU Institutions’ and Member States’ procurement policies.
  • Consider the specific risks and differentiated impacts of business activities on vulnerable groups such as women, migrant workers and children.
  • Pursue trade preferences and investment policies as an important tool to further the protection of human rights in third countries.


For any EU due diligence system to be as effective and viable as it could be, it would need to be based on the following principles:

  • HRDD should be based on international frameworks like the UNGP, the OECD Guidance on Responsible Business Conduct (RBC) and the ILO Core Conventions.
  • HRDD should be informed by an ongoing risk-assessment and impact-oriented approach to not only identify risks but also remediate adverse impacts.
  • HRDD should be regarded as a dynamic process of continuous improvement.
  • HRDD should be encouraged as part of a wider collaborative effort both along the supply chain and with external stakeholders (peers, NGOs, local communities and governments etc.).