Created in partnership with the Helpdesk on Business & Human Rights

Due Diligence Considerations

This section outlines due diligence steps that companies can take to promote gender equality in their operations and supply chains. At a minimum, business has the responsibility to respect the rights of women and girls, such as by putting in place non-discrimination and sexual harassment policies. In addition, companies can create inclusive business models and invest in women’s economic empowerment programmes. They can also partner with organizations to advance women’s rights and advocate for gender equality policies. Such actions to support women’s rights should be a complement, not a substitute for respecting women’s rights.

The described due diligence steps are aligned with the UN Guiding Principles on Business and Human Rights. Endorsed by the UN Human Rights Council in June 2011, the UNGPs provide an authoritative global standard for preventing and addressing the risk of adverse impacts on human rights linked to business activity. The UNGPs emphasize that women and girls experience business-related human rights abuses in unique ways and are often affected disproportionately. In a nutshell, business has a responsibility to respect human rights by avoiding any infringement of the human rights of others, including women, and addressing any adverse human rights impact with which the business is involved. Further information on UNGPs is provided in the ‘Key Human Rights Due Diligence Frameworks’ section below or in the Introduction.

Key Human Rights Due Diligence Frameworks

Several human rights frameworks describe the due diligence steps that businesses should ideally implement to address human rights issues, including gender equality. The primary framework is the UN Guiding Principles on Business and Human Rights (UNGPs). Launched in 2011, the UNGPs offer guidance on how to implement the United Nations “Protect, Respect and Remedy” Framework, which establishes the respective responsibilities of Governments and businesses — and where they intersect.

The UNGPs set out how companies, in meeting their responsibility to respect human rights, should put in place due diligence and other related policies and processes, which include:

A publicly available policy setting out the company’s commitment to respect human rights;
Assessment of any actual or potential adverse human rights impacts with which the company may be involved across its entire value chain;
Integration of the findings from their impact assessments into relevant internal functions/processes — and the taking of effective action to manage the same;
Tracking of the effectiveness of the company’s management actions;
Reporting on how the company is addressing its actual or potential adverse impacts; and
Remediation of adverse impacts that the company has caused or contributed to.

The steps outlined below follow the UNGPs framework and can be considered a process which a business looking to start implementing human rights due diligence processes can follow.

Additionally, the OECD Guidelines on Multinational Enterprises define the elements of responsible business conduct, including human and labour rights.

Another important reference document is the ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy (MNE Declaration), which contains the most detailed guidance on due diligence as it pertains to labour rights. These instruments, articulating principles of responsible business conduct, draw on international standards enjoying widespread consensus.

While the below steps provide guidance on gender equality in particular, it is important — and more resource-efficient — for companies to integrate gender equality into due diligence processes focusing on other human rights issues (e.g. applying a “gender lens” to child labour or forced labour).

Human Rights Due Diligence Through a Gender Lens

Companies can seek specific guidance on gender equality and other issues relating to international labour standards from the ILO Helpdesk for Business. The ILO Helpdesk assists company managers and workers that want to align their policies and practices with principles of international labour standards and build good industrial relations. It has a specific section on non-discrimination and equality. The WEPs Secretariat also offers support, guidance and capacity building to help companies fully implement the WEPs.

Additionally, the SME Compass offers guidance on the overall human rights due diligence process by taking businesses through five key due diligence phases. The SME Compass has been developed in particular to address the needs of SMEs but is freely available and can be used by other companies as well. The tool, available in English and German, is a joint project by the German Government’s Helpdesk on Business & Human Rights and the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH.

1. Develop a Policy Commitment on Gender Equality

UNGP Requirements

As per the UNGPs, a human rights policy should be:

“Approved at the most senior level” of the company;
“Informed by relevant internal and/or external expertise”;
Specific about company’s “human rights expectations of personnel, business partners and other parties directly linked to its operations, products or services”;
“Publicly available and communicated internally and externally to all personnel, business partners and other relevant parties”; and
“Reflected in operational policies and procedures necessary to embed it throughout the business”.

A logical starting point for any business to tackle gender discrimination is to develop a company commitment to gender equality. For example, the European telecommunications company Vodafone and the South African mining company AngloGold Ashanti both have stand-alone gender equality policies. The integration of women’s rights into a human rights policy is another option that companies such as H&M have adopted. Where companies do not have a human rights policy, gender equality is often addressed in other documentation, such as a business code of conduct or ethics and/or a supplier code of conduct.

Companies can demonstrate their policy commitment on gender equality and its implementation in day-to-day activities by joining the WEPs platform. By joining the WEPs community, the CEO signals commitment to the gender equality agenda at the highest levels of the company.

Businesses may also consider aligning their gender equality policies with relevant industry-wide or cross-industry policy commitments, for example:

Responsible Business Alliance (RBA) Code of Conduct
Ethical Trading Initiative (ETI) Base Code
amfori BSCI Code of Conduct
Fair Labor Association (FLA) Code of Conduct
EDGE Gender & Intersectional Equity Certification

Helpful Resources

Women’s Empowerment Principles, Equality Means Business: This is a toolkit for WEPs Signatories at all stages of the WEPs journey, from companies first learning about the WEPs to current Signatories looking to advance their work on gender equality and women’s empowerment. This platform also provides policy templates for businesses (e.g. Domestic Violence Policy, Gender-Based Violence and Harassment at Work Policy, Flexible Work Policy Template, etc.).
BSR, Gender Equality in Codes of Conduct Guidance: BSR has developed a guidance that makes recommendations on how companies can strengthen their clauses to promote gender equality in the workplace, with a specific focus on developing and emerging markets-based supply chains.
ILO, Gender Diversity Journey: Company Good Practices: This guidance was developed to share the experience of companies in attracting and retaining female talent, including ideas on how to establish an equal employment opportunity policy.
ILO-UN Women, Empowering Women at Work: Company Policies and Practices for Gender Equality: This resource presents key guiding frameworks and examples for companies to develop gender equality policies.
ICoCA, Guidelines for Private Security Providers on Preventing and Addressing Sexual Exploitation and Abuse: These guidelines are designed to help private security companies write Codes of Conduct to effectively prevent and address sexual exploitation.
The B Team, Gender Balance and Inclusive Cultures: A Guide for CEOs: This guide was developed to help CEOs improve corporate culture, support their employees and make their business more secure and profitable in the long-term by fostering greater diversity and inclusion.
Ethical Trading Initiative, Base Code Guidance: Gender Equality (B) — Gender and Human Rights Due Diligence: A detailed guide on human rights due diligence on gender equality, including a section on building company leadership and commitment to gender equality and women’s rights.
Women Win, Gender-Responsive Due Diligence (GRDD) Platform: This online platform describes the process of adding a gender lens to human rights due diligence, including Step 1 (“Embed in Policies”).
Girls Advocacy Alliance, A Gender-responsive Human Rights Due Diligence Tool: Organized around the six steps of human rights due diligence, this toolkit offers a conceptual framework, as well as practical guidance for planning, implementing and monitoring Gender-responsive Human Rights Due Diligence (GR-HRDD) processes, including Step 1 “Embed gender equality into your policies & management systems”.
SME Compass: Provides advice on how to develop a human rights strategy and formulate a policy statement.
SME Compass, Policy statement: Companies can use this practical guide to learn to develop a policy statement step-by-step. Several use cases illustrate how to implement the requirements.
United Nations Global Compact, Advancing decent work in business Learning Plan: This learning plan, helps companies understand each Labour Principle and its related concepts and best practices as well as practical steps to help companies understand and take action across a variety of issues.
United Nations Global Compact-OHCHR, A Guide for Business: How to Develop a Human Rights Policy: This guidance provides recommendations on how to develop a human rights policy and includes extracts from companies’ policies referencing non-discrimination.

2. Assess Gender Equality Impacts

UNGP Requirements

The UNGPs note that impact assessments:

Will vary in complexity depending on “the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations”;
Should cover impacts that the company may “cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships”;
Should involve “meaningful consultation with potentially affected groups and other relevant stakeholders” in addition to other sources of information such as audits; and
Should be ongoing.

Impact assessments should look at both actual and potential impacts, i.e. impacts that have already manifested or could manifest. This compares to risk assessments that would only look at potential impacts and may not satisfy all of the above criteria.

Impact assessments look at existing impacts from business practices, potential impacts that companies can anticipate, the likelihood of these impacts occurring and the severity of both actual and potential impacts. The scope of impact assessments should include not only gender equality issues in the workplace but also potential and actual impacts on gender equality in supply chains and in communities of operation.

A wide range of stakeholders, including suppliers and civil society, should be involved in the identification and assessment of gender equality impacts. Consulting experts with experience of working with vulnerable groups and collecting data on sensitive issues such as sexual and reproductive health, and violence against women and girls, may also be helpful for businesses to uncover gender-specific risks that may be hidden due to prevailing gender norms and inequality. To gain deeper insights, it is necessary to talk with (female) stakeholders directly outside the presence of men. Where access to female informants is limited (e.g. at the lower levels of the supply chain), secondary information can be gathered from trade union representatives, industry associations, local women’s organizations and community representatives.

To collect data for impact assessments companies should consider analyzing the following:

Activities, geographies or products where gender inequality risks are most likely to be present: Country-level information on gender equality may be helpful in identifying potential issues in countries of operation and supply, as well as in key consumer markets. This may include countries with severe gender-discrimination due to existing norms, conflict and post-conflict zones, sectors employing large numbers of women or products that potentially exclude women as customers. A guide on Gender Responsive Due Diligence in Supply Chains by BSR includes a list of global country-level gender indices.
Sex-disaggregated data on workforce in company operations and supply chains, including the number of employees and board directors, percentage of managers/supervisors, percentage of pregnancy/maternity leave versus total time available, percentage of home workers vs. on-site workers, etc. A Gender-responsive Human Rights Due Diligence Toolby Girls Advocacy Alliance provides a helpful list of indicators on workforce profile, workforce performance and worker impact that could be analyzed as part of data collection process. Collecting supplier sex-disaggregated workforce data is more difficult but could be achieved through suppliers self-assessment questionnaires or audits.
Existing policies and procedures that may be undermining women’s rights: This should include both internal policies and procedures and those with suppliers and local communities. For example, companies’ buying practices may cause or contribute to suppliers’ unethical practices, which in turn may impact the working conditions of female workers. External communication, advertising and marketing should also be included in the scope of policy and procedural review.
External risks from events outside the company and beyond its control. For example, natural disasters often affect women and men differently due to gender inequalities caused by socio-economic conditions and cultural beliefs. The COVID-19 pandemic offers another example of external risks outside of company control with significant impacts on women who were not only the main caretakers of the sick during the pandemic, but also were in the lowest paid jobs and therefore most vulnerable to layoffs.

Once a list of potential and actual impacts is compiled, companies should assess and prioritize them by evaluating their likelihood and severity. The following considerations should be made:

Assessing the likelihood and severity of each identified impact specifically for women: For example, women are significantly more likely to experience sexual harassment than men. Likewise, persistent overtime tends to have a bigger impact on women than on men due to women’s household and childcare responsibilities before and after work.
Differentiating impacts on different groups of women: Women from ethnic minorities may face a greater or different type of discrimination. Young women may face more harassment than older women. Pregnant women and mothers may have a higher chance of losing their jobs and fewer opportunities to join the workforce at a later stage.

To help companies conduct gender equality impact assessments, the UN Global Compact, in partnership with UN Women, the Multilateral Investment Fund of the Inter-American Development Bank and IDB Invest, developed the WEPs Gender Gap Analysis Tool. The WEPs Tool is designed to help companies assess current policies and programmes, identify areas for improvement and consider opportunities to set future corporate goals and targets. The WEPs Tool comprises 18 multiple choice questions that draw from global best practices and cover topics such as commitment to a gender equality strategy, equal pay, recruitment, supporting parents and caregivers, women’s health, inclusive sourcing and advocacy for gender equality in communities of operation.

Helpful Resources

Women Win, Gender-Responsive Due Diligence (GRDD) Platform: This online platform describes the process of adding a gender lens to human rights due diligence, including Step 2 (“Identify and assess adverse impacts”).
Girls Advocacy Alliance, A Gender-responsive Human Rights Due Diligence Tool: Organized around the six steps of human rights due diligence, this toolkit offers a conceptual framework, as well as practical guidance for planning, implementing and monitoring Gender-responsive Human Rights Due Diligence (GR-HRDD) processes, including Step 2 “Identify & assess gender risks & adverse impacts”).
BSR, Making Women Workers Count: A Framework for Conducting Gender Responsive Due Diligence in Supply Chains: This report helps both brands and suppliers conduct better and more effective gender-responsive due diligence. Provides recommendations along four phases of due diligence, including Phase 1 (Assess and Analyze).
WECF International, The Gender Impact Assessment and Monitoring Tool: This tool has been developed in the framework of the Women2030 programme, with the objective of providing Women2030 partners with a common understanding of how to assess gender issues within local, regional and national contexts.
Ethical Trading Initiative, Base Code Guidance: Gender Equality (B) — Gender and Human Rights Due Diligence: A detailed guide on human rights due diligence on gender equality, including ‘Assessment and Analysis’ section that provides guidance on a graduated approach to gender assessments.
ILO, Maternity and Paternity at Work: Law and Practice across the World: The study reviews national law and practice on both maternity and paternity at work in 185 countries and territories including leave, benefits, employment protection, health protection, breastfeeding arrangements at work and childcare.
ILO, Labour Statistics on Women: ILOSTAT contains a wide range of indicators disaggregated by sex, as well as breakdowns relevant to gender issues and indicators on gender gaps.
Arizona State University, Global SDG 5 Notification Tool: This tool provides insight into country-level progress towards eliminating discriminatory laws around the world.
The World Bank, Women, Business and the Law: This report analyzes laws and regulations affecting women’s economic inclusion in 190 economies.
UN Women, COVID-19 and Gender Rapid Self-Assessment Tool: Building on the seven WEPs, this tool enables companies to assess their COVID-19 response and ensure they are supporting women during and beyond the crisis with gender-sensitive measures throughout their value chain.
World Economic Forum, Global Gender Gap Report 2022: A report on gender parity that provides rankings for 146 countries on gender gaps in four areas: Economic Participation and Opportunity, Educational Attainment, Health and Survival, and Political Empowerment. This report also includes detailed country profiles.
Girl Stats: A resource that provides interactive data aligned with the SDGs, offering insight into key issues faced by adolescent girls and young women around the world.
CSR Risk Check: A tool allowing companies to check which international CSR risks (including related to gender equality) businesses are exposed to and what can be done to manage them. The tool provides tailor-made information on the local human rights situation as well as environmental, social and governance issues. It allows users to filter by product/raw material and country of origin. The tool was developed by MVO Netherland; the German version is funded and implemented by the German Government’s Helpdesk on Business & Human Rights and UPJ.
SME Compass: Provides advice on how to assess actual and potential human rights risks and how to assess and prioritize risks.
SME Compass, Risk Analysis Tool: This tool helps companies to locate, asses and prioritize significant human rights and environmental risks long their value chains.
SME Compass, Supplier review: This practical guide helps companies to find an approach to manage and review their suppliers with respect to human rights impacts.

3. Integrate and Take Action on Gender Equality Impacts

UNGP Requirements

As per the UNGPs, effective integration requires that:

“Responsibility for addressing [human rights] impacts is assigned to the appropriate level and function within the business enterprise” (e.g. senior leadership, executive and board level);
“Internal decision-making, budget allocations and oversight processes enable effective responses to such impacts”.

The WEPs platform provides a framework that companies can use to take action on gender equality in the workplace, marketplace and community. In addition, the UN Global Compact launched “Target Gender Equality”, an accelerator programme that uses the WEPs Gender Gap Analysis Tool to evaluate performance and identify risk areas, then puts principle into practice by guiding implementation and providing concrete steps towards achieving goals. The programme helps companies create more inclusive workplaces, break down barriers to equality and meet ambitious targets for women’s representation and leadership.

Some actionable steps towards gender parity in the workforce, marketplace and community include:

Addressing working practices that indirectly disadvantage women: These include checking hiring and promotion practices for potential bias, introducing targets and quotas for female representation, achieving equal pay for work of equal value, etc. As part of these efforts, companies can consider delivering unconscious bias training for workers at all levels, but particularly for senior management.
Fostering women in business and management: Companies can empower women to enter and remain in business and management roles by diversifying company talent and the executive pipeline, focusing on communication and transparency, providing tailored mentorship and development programmes, and promoting women’s entrepreneurship and closing the gender finance gap.
Promoting work-family balance and an equal sharing of childcare responsibilities: Companies may implement more flexible policies to promote a better work-life balance for caregivers and strengthen efforts towards retaining the female workforce, with consideration to policies that provide better parental leave, prevent discrimination against pregnant women, provide comprehensive healthcare, assist with onsite or nearby childcare, and facilitate smooth returns to the office following parental leave.
Preventing and ending violence and harassment in the world of work: Companies can play a key role in ending violence and harassment by helping to shape public policies, calling on Governments to ratify ILO Violence and Harassment Convention No. 190 and participating in social dialogue. The ILO guidance on ‘Company Policies and Practices for Gender Equality’ describes the specific actions companies can take towards fulfilling these objectives.
Create employment opportunities for both women and men: Employment opportunities will continue to be significantly altered by rapid technological changes, with mixed implications for the future of gender equality. Companies can take steps to empower women for the future workplace, such as conducting workshops for reskilling and upskilling, supporting women in STEM fields, and promoting women’s safety in cyberspace and automated environments.
Sourcing from women-owned businesses and vendors through proactive procurement: Per the WEPs Tool, companies can use outreach initiatives, trade fairs and databases to find women-owned businesses and expand relationships.
Advancing gender equality in affected communities: Companies operating in or sourcing from countries without strong gender protection laws can devote efforts to advocating for gender equality and lobbying for gender-based protections in local legal systems. Companies should also seek to understand how local gender dynamics can exacerbate human rights impacts on women.

Helpful Resources

ILO-UN Women, Empowering Women at Work: Company Policies and Practices for Gender Equality: This resource provides suggestions on how companies can promote gender equality in their operations.
ILO-UN Women, Empowering Women at Work: Policies and Practices for Gender Equality in Supply Chains: This resource provides illustrative examples of what companies can do to empower women workers in their supply chains.
ILO, Gender Diversity Journey: Company Good Practices: This guidance was developed to share the experience of companies in attracting and retaining female talent, including an overview of effective human resources management systems to promote diversity and equality of opportunity.
ILO and Partners, EW@W Capacity Development Platform: Tools and resources to promote gender equality and women’s empowerment in companies, including a self-assessment test to measure company’s capacity to promote gender equality and women’s empowerment and short on-line learning modules.
ILO, Promoting Equity: Gender-Neutral Job Evaluation for Equal Pay. A Step-by-Step Guide: The guide analyzes the overall process of promoting equity at work, from selecting which jobs to evaluate to equalizing pay in order to avoid discriminatory practices.
United Nations Global Compact, WEPs Gender Gap Analysis Tool: This resource helps companies assess current policies and programmes, highlight areas for improvement and identify opportunities to set future corporate goals and targets with respect to the WEPs.
Champions of Change Coalition, Disrupting the System — Preventing and Responding to Sexual Harassment in the Workplace: This report provides a guide to effective organizational approaches to preventing sexual harassment in the workplace.
UNICEF, Family-friendly Policies: Redesigning the Workplace of the Future: This policy brief presents policies that help to address the needs of parents and families for adequate time, resources and services to care for their young children, while fulfilling their work obligations, staying in their jobs and improving/unlocking their skills and productivity.
IFC, COVID-19 and Gender Equality: Six Actions for the Private Sector: This guidance note recommends six actions the private sector can implement to ensure that both women and men can return to economic activities during and after the pandemic, and participate equally as leaders, employees, business owners and consumers.
The B Team, Gender Balance and Inclusive Cultures: Non-profit organization the B Team provides two guidance reports on how to champion gender balance, diversity and inclusion and how to help close gender pay gaps.
Ethical Trading Initiative, Base Code Guidance: Gender Equality (B) — Gender and Human Rights Due Diligence: A detailed guide on human rights due diligence on gender equality, including a section on concrete steps for addressing gender inequality in the supply chain.
Women Win, Gender-Responsive Due Diligence (GRDD) Platform: This online platform describes the process of adding a gender lens to human rights due diligence, including Step 3 (“Address adverse impacts”).
Girls Advocacy Alliance, A Gender-responsive Human Rights Due Diligence Tool: Organized around the six steps of human rights due diligence, this toolkit offers a conceptual framework, as well as practical guidance for planning, implementing and monitoring Gender-responsive Human Rights Due Diligence (GR-HRDD) processes, including Step 3 “Cease, prevent or mitigate gender risks”.
BSR, Making Women Workers Count: A Framework for Conducting Gender Responsive Due Diligence in Supply Chains: This report helps both brands and suppliers conduct better and more effective gender-responsive due diligence. Provides recommendations along four phases of due diligence, including Phase 2 (Integrate and Act).
Women’s Empowerment Principles, Case Studies: A collection of case studies on implementing WEPs by companies around the world.
SME Compass: Provides advice on how to take action on human rights by embedding them in your company, creating and implementing an action plan, and conducting a supplier review and capacity building.
SME Compass, Identifying stakeholders and cooperation partners: This practical guide is intended to help companies identify and classify relevant stakeholders and cooperation partners.
SME Compass, Standards Compass: This online tool offers guidance on what to pay attention to when selecting sustainability standards or when participating in multi-stakeholder initiatives. It allows comparing standards and initiatives with respect to their contribution to human rights due diligence and their potential limitations.

4. Track Performance on Gender Equality

UNGP Requirements

As per the UNGPs, tracking should:

“Be based on appropriate qualitative and quantitative indicators”;
“Draw on feedback from both internal and external sources, including affected stakeholders” (e.g. through grievance mechanisms).

Advancing gender equality is not a checklist exercise. Rather, it is a process of continuous improvement. Companies must continuously assess and measure their progress in creating truly inclusive workplaces and supporting gender equality in the marketplace and community.

To effectively assess gender equality performance in the workplace, the collection and analysis of sex-disaggregated data is key. In addition to providing an overview of workplace composition and helping to identify where women are under-represented, the collection of sex-disaggregated data can help businesses understand how women and men may benefit differently from corporate trainings, flexible work policies and other benefits, track the effectiveness of parental leave policies and company grievance mechanisms.

Performance data on gender equality in the workplace can be collected in multiple ways, including through employee engagement and surveys, particularly anonymous ones. Supplier audits that include confidential worker interviews can help identify instances of gender discrimination in supply chains and allow a company to monitor performance. Companies should encourage their social auditors to apply a gender lens to supplier audits, by encouraging diverse audit teams and providing systematic gender training for auditors. Using anonymous feedback processes or ‘worker voice’ technologies can be helpful in ensuring companies receive ‘real’ information.

Similarly, a gender-sensitive approach enables companies to effectively track their performance in advancing gender equality in the marketplace and community. Collecting sex-disaggregated performance data can help companies assess the inclusion of women-owned businesses in a company’s value chain and determine if their community investments are benefiting women and girls.

Responsibility for tracking performance on gender equality should be clearly allocated to relevant roles within the company and performance KPIs should be clearly defined. For example, as part of the UN Global Compact Target Gender Equality programme, companies can take part in capacity-building workshops that provide guidance in the target-setting process and on how to define ambition and measure progress.

Helpful Resources

ILO, Guidance Note 3.1: Integrating Gender Equality in Monitoring and Evaluation: This guidance note explains how to integrate gender equality systematically into monitoring and evaluation processes.
Sustainable Trade Initiative, KPIs to Track and Evaluate Gender-Equality Interventions: This resource provides a set of KPIs that enables organizations to track the results of implementing gender equality interventions.
Ethical Trading Initiative, Base Code Guidance: Gender Equality (B) — Gender and Human Rights Due Diligence: A detailed guide on human rights due diligence on gender equality, including a section on tracking performance.
Women Win, Gender-Responsive Due Diligence (GRDD) Platform: This online platform describes the process of adding a gender lens to human rights due diligence, including Step 4 (“Track implementation and results”).
Girls Advocacy Alliance, A Gender-responsive Human Rights Due Diligence Tool: Organized around the six steps of human rights due diligence, this toolkit offers a conceptual framework, as well as practical guidance for planning, implementing and monitoring Gender-responsive Human Rights Due Diligence (GR-HRDD) processes, including Step 4 “Track progress on gender equality”.
BSR, Making Women Workers Count: A Framework for Conducting Gender Responsive Due Diligence in Supply Chains: This report helps both brands and suppliers conduct better and more effective gender-responsive due diligence. Provides recommendations along four phases of due diligence, including Phase 3 (Track).
BSR, Gender Equality in Social Auditing Guidance: This guidance identifies the main improvements required for gender-sensitive social auditing and provides recommendations, practical advice and relevant examples on how to effectively integrate gender considerations into audits.
European Institute for Gender Equality, Gender Audit: This tool allows to assess and check the institutionalization of gender equality into organizations, including in their policies, programmes, projects and/or provision of services, structures, proceedings and budgets.
SME Compass: Provides advice on how to measure human rights performance.
SME Compass: Key performance indicators for due diligence: Companies can use this overview of selected quantitative key performance indicators to measure implementation, manage it internally and/or report it externally.

5. Communicate Performance on Gender Equality

UNGP Requirements

As per the UNGPs, regular communications of performance should:

“Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences”;
“Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved”; and
“Not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality”.

External and internal stakeholders, including investors, trade unions, NGOs, board members and employees are increasingly expecting companies to report on their gender equality performance. Stock exchanges and Governments are also increasingly requiring companies to disclose data related to a growing number of gender equality indicators. In addition, stock exchanges themselves can play an important role in advancing gender equality, as seen through a guidance published by the Sustainable Stock Exchanges (SSE) Initiative on Gender Equality. The introduction of gender equality-focused business benchmarks — such as the World Benchmarking Alliance’s Gender Equality and Empowerment Benchmark — is also encouraging companies to be more transparent about their gender equality performance.

Companies are expected to communicate their performance on gender equality in a formal public report, which can take the form of a standalone report, a broader sustainability or human rights report or an annual Communication on Progress (CoP) in implementing the Ten Principles of the UN Global Compact. Other forms of external communication may include in-person meetings, online dialogues and consultation with affected stakeholders. In addition, companies should strive to communicate their progress on gender equality to internal stakeholders (i.e. employees) to promote good working practices.

Helpful Resources

Women’s Empowerment Principles, Progress Reports: This platform hosts corporate reports on implementing the WEPs. Companies can also check WEPs Guidance Note: How to Report Progress, which is a step-by-step guide designed to help WEPs Signatories report on progress against eight essential indicators of the WEPs Transparency and Accountability Framework (i.e. a reference guide).
Global Reporting Initiative, GRI 405: Diversity and Equal Opportunity: The 2016 standard lists the disclosures and activities needed for a business to achieve this standard on an annual basis.
IFC, Embedding Gender in Sustainability Reporting: A Practitioner’s Guide: This resource offers practical steps on how to embed gender in sustainability reporting.
Women Win, Gender-Responsive Due Diligence (GRDD) Platform: This online platform describes the process of adding a gender lens to human rights due diligence, including Step 5 (“Communicate how impacts are addressed”).
Girls Advocacy Alliance, A Gender-responsive Human Rights Due Diligence Tool: Organized around the six steps of human rights due diligence, this toolkit offers a conceptual framework, as well as practical guidance for planning, implementing and monitoring Gender-responsive Human Rights Due Diligence (GR-HRDD) processes, including Step 5 “Communicate how impacts are addressed”.
BSR, Making Women Workers Count: A Framework for Conducting Gender Responsive Due Diligence in Supply Chains: This report helps both brands and suppliers conduct better and more effective gender-responsive due diligence. Provides recommendations along four phases of due diligence, including Phase 4 (Communicate).
UNGP Reporting Framework: A short series of smart questions (‘Reporting Framework’), implementation guidance for reporting companies and assurance guidance for internal auditors and external assurance providers.
United Nations Global Compact, Communication on Progress (CoP): The CoP ensures further strengthening of corporate transparency and accountability, allowing companies to better track progress, inspire leadership, foster goal-setting and provide learning opportunities across the Ten Principles and SDGs.
United Nations Global Compact, Communication on Progress (CoP): The CoP ensures further strengthening of corporate transparency and accountability, allowing companies to better track progress, inspire leadership, foster goal-setting and provide learning opportunities across the Ten Principles and SDGs.
The Sustainability Code: A framework for reporting on non-financial performance that includes 20 criteria, including on human rights and employee rights.
SME Compass: Provides advice on how to communicate progress on human rights due diligence.
SME Compass, Target group-oriented communication: This practical guide helps companies to identify their stakeholders and find suitable communication formats and channels.

6. Remedy and Grievance Mechanisms

UNGP Requirements

As per the UNGPs, remedy and grievance mechanisms should include the following considerations:

“Where business enterprises identify that they have caused or contributed to adverse impacts, they should provide for or cooperate in their remediation through legitimate processes”.
“Operational-level grievance mechanisms for those potentially impacted by the business enterprise’s activities can be one effective means of enabling remediation when they meet certain core criteria.”

To ensure their effectiveness, grievance mechanisms should be:

Legitimate: “enabling trust from the stakeholder groups for whose use they are intended, and being accountable for the fair conduct of grievance processes”
Accessible: “being known to all stakeholder groups for whose use they are intended, and providing adequate assistance for those who may face particular barriers to access”
Predictable: “providing a clear and known procedure with an indicative time frame for each stage, and clarity on the types of process and outcome available and means of monitoring implementation”
Equitable: “seeking to ensure that aggrieved parties have reasonable access to sources of information, advice and expertise necessary to engage in a grievance process on fair, informed and respectful terms”
Transparent: “keeping parties to a grievance informed about its progress, and providing sufficient information about the mechanism’s performance to build confidence in its effectiveness and meet any public interest at stake”
Rights-compatible: “ensuring that outcomes and remedies accord with internationally recognized human rights”
A source of continuous learning: “drawing on relevant measures to identify lessons for improving the mechanism and preventing future grievances and harms”
Based on engagement and dialogue: “consulting the stakeholder groups for whose use they are intended on their design and performance, and focusing on dialogue as the means to address and resolve grievances”

Companies should develop grievance mechanisms and procedures to address complaints and provide recourse for women who have faced discrimination, violence or harassment. It is important that companies design grievance mechanisms that are gender-sensitive and gender-responsive. This means that grievance mechanisms should enable grievances from a diverse group of women in the workforce, supply chains and communities in which the company operates because experiences and impacts may vary across different groups of women. The establishment of an effective grievance mechanism will convey the message that the company takes gender discrimination and harassment seriously, is capable of dealing with complaints consistently and within a specified timeframe, and alerts employees to patterns of unacceptable conduct.

A toolkit developed by Girls Advocacy Alliance (GAA) recommends that beyond internal grievance mechanisms, companies can improve access to remedy in global supply chains by providing formal external grievance mechanisms that enable workers of a supplier to file complaints. A company can then follow up on the grievance with its supplier and push for remediation as it may constitute a violation of its supplier code of conduct. The GAA toolkit also recommends that companies participate in the grievance mechanisms of multi-stakeholder or sector initiatives, such as the third-party complaints mechanisms of the Fair Labor Association, Fair Wear Foundation and the Roundtable on Sustainable Palm Oil. Additionally, companies can establish specific grievance mechanisms developed for community complaints related to a high-impact project that can have potentially significant consequences for local communities.

Grievance mechanisms can play an important role in helping to identify and remediate cases of discrimination, violence or harassment in operations, supply chains and local communities. Remediating the issues of gender discrimination can be difficult and should be handled sensitively, as the harm caused to the victim could be significant. If legal proceedings have been taken against the business regarding gender discrimination, the business should seek legal advice and follow the laws of the country while striving to meet its own, potentially higher standards.

Helpful Resources

Women Win, Gender-Responsive Due Diligence (GRDD) Platform: This online platform describes the process of adding a gender lens to human rights due diligence, including Step 6 (“Provide for remediation”).
Girls Advocacy Alliance, A Gender-responsive Human Rights Due Diligence Tool: Organized around the six steps of human rights due diligence, this toolkit offers a conceptual framework, as well as practical guidance for planning, implementing and monitoring Gender-responsive Human Rights Due Diligence (GR-HRDD) processes, including Step 6 “Provide for, or cooperate in remediation when appropriate”.
Ethical Trading Initiative, Access to Remedy: Practical Guidance for Companies: This guidance explains key components of the mechanisms that allow workers to submit complaints and enable businesses to provide remedy.
SME Compass: The Practical Guide on Grievance Management outlines how to design grievance mechanisms following eight effectiveness criteria and includes examples from companies.
Global Compact Network Germany, Worth Listening: Understanding and Implementing Human Rights Grievance Management: A business guide intended to assist companies in designing effective human rights grievance mechanisms, including practical advice and case studies. Also available in German.
SME Compass: Provides advice on how to establish grievance mechanisms and manage complaints.
SME Compass, Managing grievances effectively: Companies can use this guide to design their grievance mechanisms more effectively – along the eight UNGP effectiveness criteria – and it includes practical examples from companies.
UN, Guidelines for gender inclusion language: The guidelines provide a range of strategies to help staff use gender-inclusive language in any type of communication and for any audience.

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