Embedding responsible business conduct: implementing OECD due diligence step 1

The OECD Due Diligence Guidance for Responsible Business Conduct provides the internationally recognized reference framework for how enterprises should carry out due diligence to identify, prevent and address adverse impacts on people, the environment and society. It applies to businesses across all sectors, sizes and structures and outlines a six-step process in which Step 1, embedding responsible business conduct (RBC) into policies and management systems, forms the structural foundation for all subsequent stages of due diligence. Without a robust and coherent Step 1, later efforts to identify, mitigate and track risks may become disconnected from decision-making, insufficiently documented or difficult to operationalize. 

The OECD emphasizes that its Guidance outlines overarching expectations that must be translated into practical systems and processes that reflect an enterprise’s operational context.  Many entities face challenges in moving from high-level commitments to practical implementation, particularly when integrating responsible business conduct into existing governance functions, operational procedures and supply chain relationships.

This article therefore focuses on Step 1 of the OECD due diligence framework and provides a practical guide to supporting enterprises in moving from commitment to implementation. It explores how policies, governance structures and internal processes can be aligned to create a coherent internal framework that enables the systematic and measurable integration of responsible business conduct across the organisation and forms the basis for effective due diligence.

These considerations are particularly relevant in high-impact sectors such as the minerals sector, where enterprises often operate complex sites, interact closely with local communities and face heightened environmental and social risks.

The OECD Guidance for Responsible Business Conduct presents a six-step process for the implementation of due diligence and responsible business practices, as illustrated in Figure 1. Complementing this, the OECD Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provides a five-step framework tailored to the specific challenges of risk-based due diligence in the minerals sector. Both documents provide a comprehensive foundation that can be used as the basis for developing and implementing an enterprise’s due diligence system.

The first step of the OECD Guidance requires to develop a management system that integrates responsible business conduct into everyday decision-making. This step establishes the structural and procedural foundation for all subsequent parts of the due diligence process and ensures that due diligence becomes part of regular business practice rather than an additional or isolated activity. From a measurability perspective, Step 1 determines the governance and process landscape that will later be used to generate, consolidate and review information. It therefore represents the phase during which the foundations for performance tracking and accountability are laid.

• Devise, adopt and disseminate polices on RBC issues that demonstrate commitment and outline how the enterprise intends to implement due diligence across its operations, supply chain and business relationships. 
• Embed defined RBC policies into enterprise’s oversight bodies and management systems to ensure that RBC becomes part of regular business processes and internal decision making. 
• Incorporate RBC expectations and policies into engagement with suppliers and other business relationships to support alignment across the value chain.

Together, these actions establish the organisational structures, internal alignment mechanisms and communication channels that enable effective due diligence. In practice, this also requires internal steering and accountability mechanisms, such as clear responsibilities, performance monitoring and appropriate incentive structures, to ensure that RBC commitments are effectively implemented and reflected in day-to-day decision-making. They form the essential groundwork upon which the more detailed and operational aspects of due diligence can subsequently build.

To move from these normative expectations to a structured implementation approach, enterprises require a clear analytical framework that enables them to assess existing structures, identify contextual risk exposure and translate commitments into functional processes. The following section develops such a framework for Step 1.

Table 2 translates the diagnostic structure outlined in Table 1 into an operational assessment matrix. It enables enterprises to map the Step 1 criteria against existing functions, governance structures and management processes, thereby identifying gaps and concrete integration points. For each criterion, the matrix links organisational entry points with illustrative indicators, supporting companies in developing tailored KPIs and embedding RBC into day-to-day decision-making. Rather than prescribing fixed metrics, it serves as a structured starting framework from which more detailed planning, performance tracking and implementation activities can evolve.