Human rights has moved from the margins of corporate responsibility to the centre of ESG expectations — and for Thai companies in international supply chains, it is increasingly a condition of doing business. Human rights due diligence (HRDD) is the process by which a company identifies, prevents, mitigates and accounts for its impacts on people. This guide explains what HRDD involves under the UN Guiding Principles, why it matters now, and how Thai companies can run and disclose it credibly.
What Human Rights Due Diligence Is
Human rights due diligence is an ongoing risk-management process focused on people rather than the company’s own financial risk. It asks a different question from traditional compliance: not “what could harm us?” but “how might our operations and value chain harm workers, communities and other rights-holders — and what are we doing about it?” HRDD covers a company’s own activities and, crucially, its business relationships and supply chain, which is often where the most severe risks sit.
The UN Guiding Principles Foundation
HRDD is grounded in the UN Guiding Principles on Business and Human Rights (UNGPs), endorsed in 2011 and now the global reference. The UNGPs set out a “protect, respect and remedy” framework: states protect, companies respect, and both must enable access to remedy. For companies, the responsibility to respect human rights is discharged largely through HRDD — knowing your impacts and acting on them. Thailand has a National Action Plan on Business and Human Rights, one of the first in Asia, which raises the domestic expectation on companies to align with the UNGPs.
Why HRDD Matters Now
Three forces are pushing HRDD up the agenda for Thai companies:
- Mandatory due-diligence laws abroad. Regulations such as the EU’s corporate sustainability due-diligence rules push human-rights expectations down global supply chains — reaching Thai suppliers to European buyers.
- The social pillar of ESG ratings. Raters increasingly score companies on human-rights policy, salient-risk identification and grievance mechanisms.
- Investor and buyer expectations. Both increasingly treat a credible HRDD process as a baseline requirement, not a nice-to-have.
For exporters especially, HRDD is becoming a commercial passport — and a gap can cost contracts.
The HRDD Process
A UNGP-aligned HRDD process runs as a continuous cycle:
- Identify salient risks — the most severe potential impacts on people across operations and the value chain.
- Assess — evaluate actual and potential impacts, prioritising by severity.
- Integrate and act — embed findings into decisions and take steps to prevent and mitigate harm.
- Track — monitor whether the actions are working.
- Communicate — report on how impacts are being addressed.
- Remedy — enable access to remediation where harm has occurred.
Salient Human Rights Risks in the Thai Context
“Salient” risks are the most severe potential impacts, and they vary by sector. In the Thai context, common salient risks include labour conditions and wages, migrant-worker rights, occupational health and safety, forced labour and recruitment fees in supply chains, community and land impacts, and data privacy. A credible HRDD process starts by honestly identifying which of these are most severe for your business — an exercise that connects closely to your materiality assessment.
Grievance Mechanisms and Remedy
Under the UNGPs, identifying risks is not enough — companies must enable remedy. That means operating (or participating in) a grievance mechanism that rights-holders can access safely, and remediating harm the company has caused or contributed to. Effective grievance mechanisms are legitimate, accessible, predictable, equitable and transparent — and, in the Thai context, they must be genuinely usable by workers who may speak Thai, a migrant language, or English.
Disclosing HRDD Credibly
How a company discloses its HRDD is itself scored by raters and scrutinised by buyers. Credible disclosure sets out the policy commitment, the due-diligence process, salient risks, and access to remedy — aligned to the UNGP reporting expectations. Vague or aspirational language reads as a governance weakness, so precision matters. This feeds directly into the social pillar of your การเปิดเผยข้อมูล ESG.
The Bilingual Dimension
Human-rights commitments are scrutinised precisely because they concern people, so a vague or inconsistent translation of a grievance mechanism or remediation commitment reads as a red flag. For Thai companies, HRDD disclosure must be rendered so the scope of each commitment is exact and identical across Thai and English — the version a European buyer relies on must say exactly what the Thai one does. This is where ESG-literate bilingual ESG advisory matters most.
HRDD and Mandatory Due-Diligence Laws
The biggest external driver of HRDD for Thai companies is the spread of mandatory due-diligence legislation in export markets. The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) and similar laws require large companies to conduct human-rights and environmental due diligence across their value chains — and that obligation flows down to their suppliers. For a Thai manufacturer or agricultural producer selling into Europe, this means European buyers will increasingly ask for evidence of an HRDD process, salient-risk assessments and grievance mechanisms as a condition of the commercial relationship. HRDD is therefore no longer a purely voluntary or reputational matter; for exporters, it is becoming a contractual and market-access requirement, and the companies that can demonstrate a credible process will have an advantage over those that cannot.
Building an HRDD Programme: Where to Start
For companies new to HRDD, the goal of the first cycle is a credible start, not perfection. A practical sequence: publish a human-rights policy commitment approved at board level; conduct a salient-risk assessment focused on the most severe potential impacts in your operations and supply chain; establish or join a grievance mechanism that affected people can actually use; and begin disclosing the process honestly, including what is still being developed. As with Scope 3 emissions, a focused, transparent programme that improves each year is far more credible — to raters, buyers and investors — than a polished policy with no substance behind it. Starting is what matters.
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Related services from Othello International
Othello International is a Bangkok-based bilingual (EN↔TH) technical translation and ESG advisory firm. Related specialist services:
- human rights due diligence — UNGP-aligned disclosure
- materiality assessment — double-materiality, rater-ready
- ESG disclosure translation — IFRS S2, GRI, FTSE-ready
- งานที่ปรึกษา ESG — ratings, climate, materiality
