Pillar One
Corporate strategy &
supply chain engagement
Helping corporates redesign strategy, governance and due diligence for the age of transformation — a duty built into how the business is actually run.
What this pillar covers
Focus areas
- Governance & policy redesign for the risk-based duty
- Value-chain due-diligence operating model
- Board-level assurance regulators can believe
- Engagement & grievance systems built in
- Purchasing practices as a human rights lever, not only a climate one
- Exposure — what is at risk and what would be owed — quantified before the programme is sized
What we believe
For twenty years, corporate supply chain responsibility was built to protect the reputation of the buyer. Regulation has replaced that engine. Due diligence is now a designed capability of the business — an obligation of means tested by regulators, and an obligation of results tested at the border. Both are tested on evidence, and evidence cuts both ways: designed well, it proves control; designed carelessly, it proves knowledge. We design it with counsel from the start. The companies that meet it will not have better paperwork. They will be designed, governed and operated differently.
What we do
We aim to work with boards, general counsel, sustainability and sourcing leaders to move due diligence from a compliance artefact to an operating capability: governance that owns the duty, risk work that matches the risk, purchasing that does not cause the harm it audits for, and evidence an enforcement official can understand and see.
How we engage
Where we can help
01
Enabling learning
- Insights conversations: supply chain, sustainability and human rights expectations are being rewritten by regulation, enforcement and market access — bespoke insights conversations enable knowledge sharing through practitioners, and learnings from both successes and failures
- Briefings and analysis: board and senior leadership engagement on today’s developments and tomorrow’s direction of travel
02
Corporate strategy
- Ambition and positioning: define what good looks like for your business — the level of ambition, the risks you will own, and the commitments you can defend publicly — so the programme is a deliberate choice rather than a reaction to the last piece of regulation
- Internal/external alignment: align due diligence requirements internally, across own operations, and into your value chain to enable consistency across processes, data and evidence
- One duty, several harms: human rights, environment and climate obligations are converging in the same regulations and on the same suppliers — one strategy that treats them as a single engagement, not three parallel programmes
- Sequencing and roadmap: a phased plan matched to regulatory deadlines, commercial cycles and internal capacity — what must be in place now, what is built over the next two to three years, and what can reasonably wait
- The exposure case and mandate: quantify revenue at risk by product, commodity and country from detention, product-level bans and tariff differentials; cost the remedy that would be owed to workers if indicators were found, and the time to release; then add the upside of customer and investor requirements and resilience — to secure the budget, cross-functional ownership and board-level sponsorship the work actually requires
03
Governance & programme design
- Readiness and gap reviews against the CSDDD, forced-labour regimes (UFLPA, EU FLR) and other emerging regulations
- Due-diligence policy architecture: policy, escalation, decision rights and accountability designed with interoperability at front of mind
- Disclosure by design: what is recorded, disclosed, to whom and under what legal protection — privilege, retention, data protection and conflict-of-laws protocols, including for China — decided with counsel before data collection starts
- Own operations and value chain engagement: build the tools and approaches required for both your own operations and your value chain engagement
- Stakeholder engagement strategy: build the stakeholder engagement strategy at the start, to integrate into risk and due diligence operations, evidence and enforcement readiness and broader communication needs — including the role of trade unions and worker organisations in verification and remedy
- Programme design tested on intentionality, proportionality and effectiveness — the standards regulators actually apply
04
Risk & due diligence operations
- Risk-based identification, assessment and prioritisation across the value chain — matching assessment effort to the risks and controls actually in play
- Salient-issue and country/commodity deep dives, including heightened diligence for high-risk geographies and tiers
- Integration into sourcing: purchasing practices, supplier selection, dual-sourcing and country-risk decisions
- Partnership with consequence: supplier contracts with escalation, remediation milestones and responsible exit, and buyer commitments on price, lead time and payment, measured by suppliers’ own view of the buyer
- Purchasing practices as a human rights lever: prices below the cost of compliant production, short lead times, volatile orders and late payment drive excessive hours, wage shortfalls and debt-financed recruitment — which is why US Customs asks companies seeking to lift a detention order for an analysis of their own procurement practices, contracts and pricing pressures (the evidence)
- …and as the decarbonisation lever: contract length, volume commitment, price and supplier selection determine whether a supplier can finance an efficiency or energy investment — the same practices that determine whether they can pay a living wage
- Stakeholder engagement and grievance channels designed into every step of the due-diligence cycle — the listening layer as legal design requirement
05
Evidence & enforcement readiness
- Evidence architecture: documentation down the sub-tiers
- Forced-labour enforcement preparedness: detention and WRO response, remediation pathways, and pre-importation due diligence
- From social audit to independent verification: risk- and controls-based verification of supplier-run systems, checked against what workers report
- Exposure assessment: revenue at risk, remedy owed, time to release — how it works
- A programme an enforcement official can understand — and see the evidence
Boards, general counsel, chief risk, chief sustainability and chief procurement officers of companies in scope of the CSDDD and forced-labour regimes — or selling to companies that are.
For general counsel, evidence without avoidable liability. For procurement, fewer and better assessments. For risk, exposure quantified. For sustainability, a programme the business co-owns.
Five principles
Five principles run through every pillar
- Run by suppliers, verified independently. Suppliers run their own systems. Independent parties verify them, and many buyers rely on one result. Ownership of the system, not of the verdict. Evidence →
- Informed by workers, organised where possible. Anonymous channels to detect what audits miss; trade unions and worker organisations in governance, verification and remedy wherever they exist. Evidence →
- Partnership with consequence, both ways. Capability building backed by consequence: for suppliers that do not remediate, and for buyers whose price, lead times and payment terms cause harm. Evidence →
- Disclosure by design. What is recorded and disclosed, to whom and under what legal protection, decided with counsel before the first data point is collected.
- Exposure first. What the business stands to lose and what workers would be owed, quantified with the time evidence takes to build, set the case. Revenue reward is upside. Evidence →
Sic utere tuo ut alienum non laedas
Use what is yours so as to harm no other.
Talk to us about redesigning the duty