Model for inclusion of affected stakeholders in assurance

Audits are among the most widely used due diligence tools in the sector, yet rightsholders, such as workers, communities, Indigenous Peoples and artisanal miners, remain largely absent from the audit process: only 6 of 20 assurance schemes assessed by DiliCHANCE explicitly require their engagement. In line with the UNGPs and the OECD MNE Guidelines, the primary focus of meaningful stakeholder engagement should be on rightsholders, whose perspectives and knowledge are central to the identification of risks and appropriate risk response measures. Audits that rely solely on auditee data cannot adequately assess actual impacts on people and the environment.

This Deep Dive examines how rightsholder engagement can be embedded across the audit cycle, from planning to corrective action and reporting back. It sets out nine prerequisites with practical approaches, reviews the structural enablers needed to support them and provides recommendations for assurance schemes, businesses, auditees and policymakers. The analysis highlights that, although good practice already exists, many barriers to meaningful engagement, such as resourcing, independence and clarity of roles, are systemic and cannot be solved by any single audit team alone. 

At its core, human rights and environmental due diligence (HREDD) is fundamentally concerned with advancing improved outcomes for rightsholders affected by business activity. It is therefore essential that rightsholders are active participants in such audit processes for two interrelated reasons:

1. Risks to human rights and the environment as well as the effective prevention, mitigation and remediation of those risks are best understood from the lived experiences and perspectives of individuals and groups who (potentially) experience adverse impacts in connection with business activities. This makes rightsholders' input indispensable in audit processes.
2. Rightsholder engagement enables the verification and triangulation of auditee data, building an evidence base that extends beyond auditee input alone. An audit team that only verifies the auditee's own systems for rightsholder engagement cannot adequately assess the effectiveness of that engagement, nor the actual impacts of the auditee's business practices.

Rightsholder engagement is therefore pivotal to the legitimacy and credibility of an audit and is necessary for the audit to fulfil its potential to provide credible verification of the efficacy of due diligence actions undertaken.

Significant challenges persist. Audit teams may lack sufficient time or other resources to conduct meaningful rightsholder engagement during a site visit, assurance schemes may struggle to find auditors with the right experience, or expectations may be misaligned between auditees, audit teams and assurance schemes. Many of these barriers are systemic, spanning several prerequisites at once, and lie beyond the ability of any single audit team or assurance scheme to address in isolation.

The Model therefore examines what is required of the system as a whole to support and enable rightsholder engagement in audits, identifying four structural enablers for meaningful and effective rightsholder engagement:

• Commitment from assurance schemes to meaningful and effective rightsholder engagement
• Appropriate resourcing
• Clear roles and expectations for auditees, audit teams and assurance schemes
• Guidance on the use of documentary evidence and weighing contradictory evidence

It makes recommendations for:

• Assurance schemes
• Businesses that use assurance schemes and industry associations
• Auditees
• Policymakers in both sourcing and mineral-producing countries