Cases of leading practices on rightsholder engagement in assurance processes

International norms such as the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD MNE Guidelines) set out expectations for companies to carry out human rights and environmental due diligence (HREDD). In the minerals sector, voluntary sustainability standards and assurance schemes are increasingly used to demonstrate compliance with these expectations.

The credibility and effectiveness of these assurance processes are significantly affected by whether or not rightsholders were meaningfully engaged as part of assurance. This is because risks to rightsholders and effective mitigation are best understood from rightsholders’ lived experiences and perspectives. Meaningful engagement is therefore critical not only to ensuring the credibility of the audit process, but also to ensuring that its findings and measures are accepted by workers and affected communities.

This review forms part of a wider research objective to advance the thinking and practice on due diligence assurance and verification, with a focus on rightsholder engagement as a decisive factor in advancing improved outcomes for affected people. Its objective is to identify more leading practices that enhance meaningful and effective rightsholder engagement in assurance and verification processes in HREDD in the minerals sector.

This report builds upon 10 practice cases of more meaningful and effective rightsholder engagement as part of assurance processes. It identifies six key practices from those 10 cases which support more meaningful and effective engagement with rightsholders and strengthen the contribution of audits to improved outcomes for affected communities.

This review draws on desktop research and semi-structured interviews to gather cases of more leading practice. These cases document specific instances where assurance processes in the minerals sector have effectively integrated affected people and demonstrate replicable and effective approaches to rightsholder engagement.

An initial pool of potential leading practice cases was identified through:

• the use of indicators from the DiliCHANCE assessment of voluntary assessment standards and assurance schemes, conducted in 2025, to identify schemes with a clear focus on rightsholder engagement;
• targeted focus groups with assurance schemes; and
• suggestions from DiliCHANCE civil society members and external actors.

Ten cases of more leading practice were selected based on eligibility, effectiveness and adaptability or replicability. Further research and interviews were then conducted to deepen the understanding of each case. The Initiative for Responsible Mining Assurance (IRMA) is disproportionately represented in the case sample, as the identification of cases of more leading practice relied heavily on publicly available audit reports. IRMA publishes more comprehensive and transparent audit reports than many other assurance schemes in the minerals sector, which contributed to its greater representation.

Across the final selected 10 cases, six key practices were identified that play an important role in ensuring meaningful and effective rightsholder engagement during assurance processes.

1. Independent rightsholder mapping to avoid bias

Meaningful rightsholder engagement depends on a credibly selected set of rightsholders. The mapping of rightsholders by auditors, should be conducted independently from the auditee to ensure that critical voices or less visible rightsholders are not excluded from such engagement, and that the potential bias towards or against particular rightsholder groups on the part of the auditee does not negatively influence the quality of audit findings. Auditors should verify information provided by the auditee, including lists of rightsholders to be engaged with, and draw on civil society organisation input to deepen their understanding of the local context. Independent mapping, grounded in an understanding of the local context and conducted independently from the auditee, helps to ensure identification of and engagement with a truly representative range of rightsholders.

2. Broad outreach for a comprehensive rightsholder sample

Broad, inclusive outreach to a diverse range of rightsholders is essential to enable a comprehensive identification of potential impacts and to avoid reinforcing existing inequalities. Engagement should mitigate the risks of overlooking marginalised rightsholder groups and the risk of prioritising groups with greater influence. Auditors can employ

communication methods that are tailored and responsive to various rightsholder groups’ needs, guided by their feedback and preferences, and that enable rightsholders to take co-ownership of their input where possible. Responsibility for this outreach should rest primarily with the audit team, rather than with the auditee, to maintain a neutral and independent approach.

3. Context-sensitive approach for building trust and setting the groundwork for meaningful engagement

A context-sensitive approach is important for building trust with rightsholders and understanding cultural norms and local realities, particularly when assessing companies whose operations impact Indigenous Peoples. In order to ensure engagement that is sensitive to cultural norms and realities, auditors can draw on civil society knowledge and networks and leverage existing methods or channels of communication. Involving Indigenous representatives and experts on other cultural norms and local realities in the assurance process can address a lack of knowledge within the audit team, enhance the findings of the audit while building trust and communication between auditors and affected communities.

4. Leveraging existing community-led initiatives to move beyond snapshot assessments

Existing community-led initiatives and mechanisms, especially those that monitor, gather and analyse information on the auditee’s human rights and environmental risks and impacts, can provide auditors with access to continuous, rightsholder-led, locally grounded information. Where such community-led structures are legitimate, inclusive and credible, they can offer auditors with longer-term insights beyond snapshot information gathered over the course of a few days, while also empowering rightsholders with greater agency and continuity in the process. This practice can support ongoing engagement with rightsholders beyond the assurance cycle and facilitate a more comprehensive, continuous and context-specific understanding of an operation’s risks and impacts.

5. Meaningful and timely engagement

Meaningful and timely engagement is critical to ensuring that rightsholders understand the assurance process, have adequate time to prepare and can see how their inputs feed into the assurance cycle. Such engagement strengthens both the quality and the credibility of the audit, especially in the eyes of rightsholders and their legitimate representatives. Engagement should be ongoing, two-way and responsive to rightsholders’ needs and feedback throughout the assurance cycle. Auditors should give rightsholders sufficient time to prepare, contribute and follow-up on outcomes, drawing on the support of civil society organisations where appropriate.

6. Safe engagement to protect rightsholders against retaliation

Safe engagement is essential to ensure that rightsholders can participate in audits without fear of reprisal, intimidation or breaches of privacy. When rightsholders trust that they can share their perspectives freely and confidentially, they are more likely to share accurate information, strengthening the legitimacy and the effectiveness of the audit’s assessment. Engagement should be conducted in a way that safeguards against such risks by providing confidential and accessible spaces for input.