A reality check on HRDD progress in the garment & footwear sector

If we forget the main objective of HRDD, it risks becoming a system of tools, focusing on the process, relying too often on audits and anonymous data, while overlooking the real struggles of workers. The OECD Forum on Due Diligence in the Garment Sector 2025, presented participants with a critical reminder of this. 

In the session From promise to progress, Nandita Shivakumar, an independent business and human rights advisor from India, emphasised the importance of hyperlocal solutions. Global frameworks and technical one-size-fits-all approaches often fail to address the nuanced realities of workers and communities in different contexts. In contrast, local trade unions and grassroots organisations often hold greater understanding of the local context and can help shed light on otherwise overlooked aspects. 

It was also refreshing to see side sessions re-emphasising the need to connect HRDD processes with the reality of supply chain settings. Where ideally, this work should start. Idil Ander, Director of the WE programme, emphasised the need for approaches “rooted in what people need at the factory level, starting with the reality of the workers, and based on meaningful stakeholder engagement”. We need to humanise HRDD by systematically focusing on people and ensuring meaningful stakeholder engagement (MSE), specifically with rightsholders. This was certainly the most commonly used phrase during the forum. Yet, according to the World Benchmarking Alliance’s Social Benchmark 2024, only 9% of companies benchmarked engage with rightsholders during the HRDD process. This reflects the crucial need for a clear definition of MSE and practical guidance for implementation.

In partnership with the STITCH consortium, ETI has developed a framework for meaningful stakeholder engagement, which identifies five key principles, to help companies embed this process into their human rights due diligence efforts. Critically, it defines MSE as being constructive and inclusive (rather than top-down and extractive) and makes it clear that engagement with rightsholders must include acting on what is heard. 

Learn more about ETI's approach to meaningful stakeholder engagement.

According to the ITUC’s Global Rights Index 2024, 75% of countries exclude workers from the right to establish or join a trade union.  Findings from the Corporate Human Rights Benchmark  indicate that only 5%  of companies benchmarked involve unions or civil society in their human rights risk assessments.  Across the forum, many discussions focused on groundbreaking achievements through enforceable binding agreement (EBAs), sector-wide collective bargaining agreements (CBAs), global framework agreements (GFAs), but also the need for legally binding agreements with unions in ensuring compliance and fostering better labour conditions. Important milestones, such as the Accord International, serve as a reminder of the crucial role of trade unions in securing justice for workers. The labour rights we enjoy today are thanks to the continuous fight of trade unions and grassroots organisations to date. 

In 2024, ETI conducted a series of workshops to support brands with the implementation of ETI Base Code clause 2, on freedom of association (FoA) and collective bargaining (CB), aligned to HRDD processes and procedures and ILO Conventions.  

During the session on Union and worker engagement in practice trade unionists emphasised that many brands were aware of the role of trade unions and the importance of FoA. According to Athit Kong, a prominent Cambodian trade union leader, the largest vacuum of knowledge is found at other levels: in understanding the value of FoA by manufacturers, and the role of unions by the workers themselves. Most of them do not know or understand the mechanisms through which agreements such as GFAs and CBAs actually work. Therefore, while the process and development of formal agreements with unions demonstrates positive progress, training social stakeholders should remain a prime consideration to ensure these agreements enable “quality engagement” at a local level and tangible change for the workers.

ETI has longstanding expertise in this area, having delivered workplace programmes on social dialogue for more than 10 years. In Bangladesh, this work is complemented by sharing knowledge and engagement at industry level. As we plan future work on FoA, we can capitalise on this crucial expertise to ensure continuous progress on this enabling right for workers across companies’ supply chains.

In the session on Responsible disengagement – deciding when and knowing how, ETI Executive Director, Giles Bolton emphasised that both the decision to stay or to leave a context where human rights risks are heightened can have adverse impacts on workers. Whatever action is taken, companies must also take steps to mitigate these impacts and prioritise workers in their decision-making processes. If the UN Guiding Principles and OECD guidelines are critical reference points for company due diligence, practical guidance on how to disengage responsibly from challenging contexts requires clearer guidance to support companies and stakeholders.

The reality is that amid climate crisis, responsible disengagement is no longer just about immediate human rights risks. Environmental impacts of climate change are reshaping sourcing risks and decisions and, as companies focus on decarbonising their supply chains, shifts in sourcing countries are being driven by environmental targets. As emphasised by Gabrielle Holly of the Danish Institute for Human Rights, responsible disengagement should be included in just transition and climate adaptation plans. A very valid point and definitely one for us to engage on and integrate into our work on Just Transition at ETI.

In the garment and footwear sector, most companies set high standards for their suppliers regarding human rights and gender equality. However, according to the 2023 Gender Benchmark only 27% of apparel companies enable their suppliers to meet these expectations through responsible purchasing practices. 

During the session on How addressing business practices and gender norms in global garment supply chains can help tackle gender based violence and harassment, we discussed the need to better define the concept of ‘zero tolerance’ for gender-based violence and harassment (GBVH). Progressive companies understand it's not about claiming zero incidents – it's about demonstrating zero tolerance for inaction. We need to shift from a tick-box compliance to gender-responsive HRDD, rooted in dialogue with stakeholders, and acknowledging the leverage companies can have through purchasing practices. Leading brands are transforming their supplier relationships by incentivising progress on gender issues through longer-term commitments and order stability. 

We recently gathered stakeholders, including companies, trade unions and NGOs to discuss the role of enforceable binding agreements and purchasing practices in tackling GBVH. In 2025, ETI continues to facilitate learning and exchange of good practice with a group of members committed to tackling GBVH in their supply chains through the application of a gender responsive HRDD. 

Finally, implementing HRDD beyond tier one demands engagement with deeper levels of the supply chain. This is where workers are most marginalised and disproportionately impacted by the industry practices. This is also where progress is less apparent and the challenges are not as extensively and openly discussed in HRDD fora.

These workers, with the least influence over companies, are the most underrepresented voice in this type of forum. To bring real change to the sector, we need to ensure that these voices are not only heard but centred in conversations and decision-making processes. 

This is also the most challenging part of HRDD, but the challenge is not new: many trade unions and CSOs are already working with informal workers. Approaches and lessons from other sectors exist that can be utilised in garment and footwear supply chains. 

I’m looking forward to next year’s Forum where we hope to see all sessions of the Forum opened with framing remarks from rightsholders, or their representatives, or by CSOs working for and with them. Ines Kaempfer of The Centre for Child Rights and Business did this brilliantly in a session on circularity, and it helped ground the conversation in these realities.