Human Rights Due Diligence

23 steps from the Human Rights Capacity Diagnostic

(based on twentyfifty Ltd.)

Human rights may initially appear to be a topic unrelated to sports. However, the assumption of social responsibility has long been an important principle of action, which must be further underlined by an approach specifically designed concerning the respect for human rights.


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The following general steps can help you to improve your management capacity for human rights due diligence:

  • Identify quick wins and opportunities for embedding human rights in your management systems, e.g. an upcoming review of existing processes or an upcoming internationalization strategy opportunity in a new country, a new product development or a general update of an organization’s mission and vision
  • Choose a starting point and prioritize depending on where along your value chain you have identified your most salient human rights risks 
  • Define concrete next steps according to your risk profile and priorities and monitor implementation accordingly

Engage with internal and external stakeholders – including rights holders – to discuss and refine assessment results and follow-up actions, benchmark your performance, raise awareness and identify opportunities to cooperate



Your human rights policy commitment sets the “tone from the top” that is needed to embed respect for human rights in your sporting organization and demonstrate your understanding of human rights responsibility. The availability of your policy influences how these commitments are embedded in the working culture, day-to-day behavior and decision making by managers and employees.

Initial step: Try to engage the company leadership to signal top management support for the policy, e.g. in the form of a short video or letter from the CEO that is published on the organization website.

Your new/updated policy framework should reflect your organization’s human rights risk profile and its ambitions with regards to the improvement of its due diligence processes and impact management.

Initial step: Engage with colleagues, stakeholders to make sure that the policy framework adequately reflects your salient human rights risks and is based on international standards, as well as a possible contribution to the Sustainable Development Goals.


Objective and Scope


Development and Review

Due to emerging international expectations, your human rights risk profile and business priorities may change over time. Your policy framework should respond to these changes.

Initial step: Review when (if there is an existing policy) and why your policy has been last updated and set clear criteria for what should trigger a policy update. 

A sound understanding of your human rights risks is the basis for setting up and improving your human rights due diligence processes. Ensure your human rights risk assessment process covers the whole corporate value chain and most important business relationships and that potentially affected groups and those at higher risk as well as salient human rights risks for these groups have been identified.

Initial step: Establish cross-working groups to get insights into all departments (e.g. merchandising, stadium management, HR) and all relevant risks. Use this template as a starting point: 


Risk Analysis


Assessing Impacts

Engage your colleagues to understand which management processes are in place to collect information and review together about your actual organization’s impacts on people (e.g. audits, consultation of trade union representatives, health and safety monitoring, employee surveys, monitoring of security incidents, social and environmental assessments)

Initial step: Collect the most relevant reports and evaluate together whether adequate “red flags” and follow-up processes are in place when negative impacts have been identified or concretize them according to international standards.

Your activities as an organization and the corresponding risk profile determine whether you should improve your capacity to manage product related risks and impacts. Merchandising products are a crucial starting point for sporting organizations to reflect on.

Initial step: Evaluate jointly with product managers whether and how potential impacts on rightsholders are considered in Research and Development (specific focus on digital products), Product Stewardship or Sales and Client Management and what could be quick wins to

improve risk and impact management (e.g. by raising awareness and providing training to relevant functions).


Product Impacts


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Address the sporadic use of due diligence mechanisms in sports through adjusting existing practices in the sporting context with the target of implementing human rights considerations into every business operation and decision.


Engaging Rightsholders

Strategic rightsholder engagement is a key element of effective human rights due diligence and distinguishes an advanced approach. Sporting organizations with a lower risk profile should aim to gather rightsholder perspectives through using expert resources or consulting representatives if possible.

Initial step: Involve internal rightsholders and/or their representatives (e.g. employees, trade unions) when gathering information about your risks and existing mitigation measures.

Sporting organizations operating in high risk and conflict affected areas should respect international humanitarian law and adopt conflict sensitive business practices to avoid complicity with human rights abuses.

Initial step: Assess whether you are currently operating in conflict affected or conflict-prone areas or work with strategic decision makers/risk management to understand whether there are plans to do so in the future and identify risks of complicity with human rights abuses.


Conflict Areas



Your human rights risk profile determines which management capacities are required to do so. It will, however, require an accountability structure involving relevant functions across your organization.

Initial step: Use relevant meetings/informal conversations with senior management to raise awareness for your company’s human rights risks and impacts and the advantages of a proactive management approach; try to get senior management/your CEO to demonstrate support for your organization’s human rights agenda.

Taking strategic decisions about the future of your organization, e.g. in relation to investments, new product development, entering new markets or efficiency measures, will likely involve human rights dilemmas, e.g. when you are approving a project potentially affecting local communities or decide to invest in a high-risk market with high business opportunities.

Initial step: Map key decision-making processes and potential ‘red flags’ related to the above mentioned strategic business decisions and engage with colleagues involved in the decision-making process around how to better integrate human rights considerations early-on in the process.


Business Strategy


Organisation and Budget

Internal ownership and dedicated resources adequate to your organization’s human rights risk profile are the backdrops of effective due diligence processes and continuous improvement.

Initial step: Draw on existing structures to set up an internal governance structure for the implementation of your human rights policy commitments that matches your organization’s risk profile and culture (e.g. a cross-functional working group, assigning a human rights focal point in legal, human resources or product management)

Think about the level of awareness on human rights and due diligence you need within your organization to be able to effectively manage your risks and impacts.

Initial step: You can work on raising awareness on your policy commitments and due diligence practices through increasing the availability of your policy, developing training strategies tailored to the knowledge needs of the different departments and why it might affect them, building leadership in your organization and integrating human rights in performance management (see #14).




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From a matter of reputation to a matter of liability – human right risks must be monitored and evaluated. This will be fundamental in order to understand their impact and be accordingly improved.



Human rights training should ideally incorporate elements of awareness-raising about the salient issues for the sporting organization, incentives for behavior changes and concrete

information on what the different departments or representatives should do (differently) when identifying a human rights risk or impact or encountering a dilemma situation.

Initial step: Use the conducted risk analysis [step 4, link] and work with colleagues responsible for existing training formats (e.g. related to compliance, anti-bribery or health and safety training) to identify lessons learned and opportunities to integrate human rights into these formats.

If you want to embed human rights due diligence in your organization and inspire behavior change amongst your organization’s management and employees, setting incentives and rewarding individuals for their engagement is key.

Initial step: Work with HR to review existing performance indicators for senior-level staff in higher-risk positions (e.g. within procurement or HR) and assess whether and how they reflect your organization’s human rights commitments and risk profile. How is non-compliance with your policy commitments currently sanctioned? Define improvement measures accordingly!


Performance Management


Responsible Sourcing

The corporate responsibility to respect human rights applies to the entire corporate value chain. It requires companies to understand and, as far as possible, address human rights risks and impacts beyond tier 1 and integrate due diligence in sourcing and supply chain management processes.

Initial step: Work with your colleagues in sourcing and buying to identify higher risk supply chains and get an overview of the risks for adverse human rights impacts along the tiers of your main sourcing categories plus jointly identify opportunities to embed due diligence in existing supply chain management.

This is particularly important if you are in a position to choose and influence your business partners or customers. A business partner is any potential individual/organization that is not a supplier, e.g. potential investors, sales, intermediaries, franchising partners or state-investor relationships.

Initial step: Collaborate with your colleagues across functions to understand whether key business relationships have been captured in your human rights risk analysis processes so far. Try to understand the range of human rights impacts you could cause, contribute to or be linked to through your relationships with business partners and particularly customers. 


Business Partner Due Diligence


Government Relations

If you regularly engage with governments and government officials in home and host countries, these dialogue processes can be an opportunity to discuss local human rights challenges and identify the contributions each party can make to address them. They can also bear a risk of counteracting corporate human rights commitments or practice, e.g. by being linked to human rights abuses committed by governmental actors.

Initial step: High corruption levels in a country or region are very likely to correlate with higher human rights risks. Start by working with your colleagues to review the effectiveness of your current anti-corruption and anti-bribery measures in higher-risk operating or sourcing countries.

This implies a more open communication on challenges, learnings, and the effectiveness of your due diligence measures, with a particular focus on those affected.

Initial step: Make sure basic information about your organization’s commitments, due diligence processes, salient risks/impacts, and actions taken in response is publicly available gather stories and examples for how negative human rights impacts are identified and dealt with and positive impacts achieved in particular operations and locations.


Focus of Communication


Communication Strategy

Communication is not a one-way street – honest communication that is understandable for your stakeholders and rightsholders can help you to learn about your risks and impacts and help prevent negative impacts before they occur.

Initial step: When working on your strategy, try to think about innovative channels or ways to reach rightsholders affected by your organization, e.g. community meetings, posters in local language when operating abroad, or (video) conferences.

The intention of effective grievance mechanisms is to identify and address grievances as early as possible to address concerns, and if necessary provide a remedy, before they escalate.

Initial step: Work with your colleagues in compliance/HR/customer services etc. to map existing complaints channels (e.g. customer complaints or compliance hotline) against your human rights risk profile and assess where improvements need to be made so that affected individuals can reach you in case they feel negatively impacted. Engage with suppliers or business partners to learn from their experience or encourage them to adopt grievance mechanisms.


Existence of Grievance Mechanisms


Ensuring Access and Effectiveness

Effective grievance mechanisms are not only essential in preventing harm to people – they provide companies with an opportunity to find solutions for problems and concerns before issues escalate and require judicial remedy.

Initial step: Engage your colleagues to understand how existing mechanisms are currently reviewed and how their existence is currently communicated to intended users.

Embedding the results of grievance mechanisms can help you to improve your due diligence measures and better factor human rights risks into strategic business decisions.

Initial step: Review your grievance processes to make sure potentially affected parties receive regular updates throughout the complaints process and that any follow-up action does not result in retaliation risks for the complainants (e.g. being let go after forming a workers union).

→ very good to visualize everything and present the board (you can see what’s missing)