How can we know if the measures we’ve put in place to protect people’s rights are actually working?
This is a question that keeps many human rights practitioners busy whether they are corporate professionals, advisors, representatives of civil society or multi-stakeholder initiatives.
And rightly so, as impact measurement matters from many different perspectives.
Why does measuring the impact of due diligence activities matter?
Most importantly, the rightsholder perspective.
Are we really addressing the risk for people? Does the measure really tackle the root causes for negative impact? That is the aim of human rights due diligence (HRDD). It exists to improve the situation for people who are (potentially) affected. This should be the main driver behind tracking effectiveness.
But it’s also a business issue.
Are we using our resources wisely? Are our approaches actually working? It is important to check if the measure brings about the desired change or if adjustments are needed. Monitoring and tracking effectiveness enables improvements. Furthermore, it is a legal requirement to check regularly if measures are having the planned impact, mitigating the risk or minimizing and/or ending a violation.
The goal is to understand where we stand, what is working – and where measures might need to be adapted. It is therefore a central element of a learning system and strategic due diligence processes.
Thus, impact measurement becomes the basis for management decisions, for strategic development, and – not to be underestimated – for strengthening internal buy-in by being able to demonstrate and justify the effectiveness of the measures.
How do you measure effectiveness of due diligence in practice?
First of all, it is important to recognize that effectiveness tracking should always be seen as part of a risk-based due diligence system, closely linked to the risk assessment. The risk assessment identifies the highest risks and most vulnerable groups, helping to prioritize efforts accordingly.
The graphic below illustrates a simple three-step approach from risk assessment to effectiveness tracking highlighting how the two are connected.
Secondly, it helps to keep in mind that measuring impact is still an experimental field on many levels. It’s not about having a perfect approach or getting everything right from the beginning, but to start and learn along the way.
Our experience shows us that there are some important principles that are helpful to consider in relation to tracking the effectiveness of human rights due diligence measures.
Think about effectiveness tracking from the beginning. Once you have identified your main risks and developed an action plan on how to tackle the risks and their root causes, it is important to consider how to track the effectiveness of the actions. This is crucial to establishing baseline data and set up channels to collect necessary information. It’s more difficult to do this retroactively.
Change your perspective when tracking effectiveness. Just like with the whole HRDD process, impact measurement needs to be approached from the perspective of the rightsholder. For instance, if you train managers on equal treatment, e.g., with a focus on employees with family responsibilities, the effectiveness tracking should focus on the key question: “What changed in the experience of those employees because the behaviour of the manager changed?”
Effectiveness tracking should look at the root cause. It is crucial to assess if the root cause of the risk is addressed. If companies only treat the symptoms (e.g., overwork or low wages), the same human rights violations are likely to reappear. By contrast, identifying and tackling underlying causes, such as irresponsible purchasing practices or weak local governance, allows companies to prevent the same problems from recurring. Preventive or remedial actions should focus on addressing root causes and so should the tracking of effectiveness.
Measure what really matters. It’s tempting to default to key performance indicators (KPIs) that are easier to track, such as the number of training sessions conducted or social audits completed, but these don’t always reflect real change. So, instead of tracking what is easy to measure, measure what matters.
For example, rather than tracking how many grievance channels have been set up, focus on whether workers actually feel safe using them. This can be assessed by measuring the number of resolved complaints or conducting surveys and engagements to get an understanding of the level of trust in the mechanism. Of course, KPIs must be feasible. There’s no point in defining metrics if the data isn’t accessible, but feasibility shouldn’t come at the expense of relevance. It’s about finding the right balance between meaningful and doable.
Stakeholder consultation is a must. Measures only work if the people affected recognize them as helpful. Whether we’re dealing with actual negative impacts or potential risks, involving rightsholders (or their representatives) in the tracking of effectiveness can help understand if the measures have the intended effect. Both internal and external stakeholders can add valuable perspectives, and their input often gives a clearer sense of whether a company‘s current human rights approach is working. Importantly, consulting stakeholders isn’t just best practice; It is also anchored in current and upcoming legal frameworks. Regulations like the German Supply Chain Act (LkSG) and the EU Directive on Corporate Sustainability Due Diligence (CSDDD) emphasize that affected people must be meaningfully involved in assessing risks and monitoring responses.
What methods and approaches are currently used by companies to measure effectiveness?
Looking at current practices, we come across many terms related to impact measurement:
- Theory of Change (ToC),
- indicators,
- KPI systems,
- scorecards,
- monitoring,
- feedback from affected stakeholders,
- and so on.
Now, let’s look at some methods that help to put these principles into practice.
At first, these may sound like separate methods but in reality, they can be seen as different building blocks or perspectives that often overlap, complement one another, or can be combined.
These methods are not mutually exclusive. In fact, they can be meaningfully combined. E.g., an effectiveness tracking system may use:
- ToC for logic
- Indicators for monitoring
- Feedback for validation
It’s not about choosing one single method. It’s about asking: “What helps me truly to understand and improve the impact of our measures?” The goal isn’t to commit to just one of these approaches, but to combine the right set of tools that fits your specific context.
With so many tools available, it helps to take a closer look at one approach that is increasingly gaining traction across sectors: The Theory of Change. We’re highlighting it here because it has proven especially useful in practice, as a strategic and learning-oriented method that supports effective implementation of human rights due diligence (HRDD).
Theory of Change (ToC) has its roots in international development and was used to help plan and explain social change. Some positive attributes of ToC are as follows:
- ToC untangles complex interventions and puts them into a clear, logical framework. This helps teams see how specific activities are expected to lead to concrete outcomes and long-term impact.
- It focuses on real-world impact for people, not just company goals. The ToC approach asks: “Are our actions improving conditions for rightsholders?”
- It makes assumptions visible (e.g., “If we train suppliers, it will lead to changes in behavior.”) These assumptions can then be tested and refined.
- It provides a strong basis for developing indicators: Once you’ve mapped out what kind of change you’re aiming for with each activity, you can ask: “What do we need to measure and why?”
- It acts as both a strategy and a learning tool. By encouraging critical reflection, a ToC model helps organizations adapt and improve their approach over time.
A Step-by-Step Implementation of Theory of Change in the Context of Human Rights Due Diligence
A classic ToC chain looks like this (similar to the IAOOI approach):
Input → Activity → Output → Outcome → Impact
It maps the path from action to change, clearly and logically.
But here’s the trick: you actually work backwards.
You start by asking:
What is the desired impact?
- Example: Workers in the supply chain earn a living wage that covers basic needs and allows for a decent standard of living
What outcomes are needed to get there?
- Example: Suppliers consistently pay wages that meet or exceed local living wage benchmarks
Which outputs contribute to those outcomes?
- Example: Wage assessments are conducted; wage gaps are identified and addressed; supplier contracts reflect living wage expectations.
What activities will produce those outputs?
- Example: Engage suppliers in wage analysis; provide tools and benchmarks; integrate wage requirements into purchasing agreements; capacity-building support for supplier and own procurement functions.
And finally, what inputs do we need to make those activities happen?
- Example: Partnership with wage experts, access to benchmarking tools, procurement policy updates, staff time and financial resources for supplier engagement.
This reverse thinking ensures that every step along the way is purpose-driven and pays into the desired change for people.
No matter which framework you choose, what really counts is how you put it into practice.
As mentioned earlier, it’s not about perfection it’s about getting started, learning along the way, and building something that works in your context.
This brings us to the end of Part 1 of this series on tracking the effectiveness of human rights due diligence measures. In Part 2 , we will provide five practical tips for tracking the effectiveness of human rights due diligence measures, based on our experience establishing such methods for various companies.
If you’re working on tracking the effectiveness of your human rights due diligence actions and would like to have an exchange, we’re always happy to connect: hello@peopleatcore.com
Stephanie for the CORE team
