Heightened Human Rights Due Diligence is not just important, but indispensable

Statement by Marcos Neto, UN Assistant Secretary-General, and Director of UNDP’s Bureau for Policy and Programme Support, for the session on 'Responsible business and armed conflict: what does enhanced due diligence entail?' at a seminar on Business and Human Rights in Oslo, Norway.

April 24, 2025

Ladies and Gentlemen,

We meet at a time of deep global turmoil. Conflicts are intensifying and multiplying – their number worldwide stands at 56, its highest since the Second World War. The human cost is staggering: lives lost, rights violated, communities torn apart, and development gains reversed—often in an instant.

These are not only humanitarian and political crises—they are also economic and environmental crises. Conflicts today disrupt global supply chains, fuel displacement and inequality, and push countries further into fragility and debt. 

And critically, they place businesses at the crossroads of risk and responsibility. The role of business is never neutral in contexts of fragility, during conflict, and during recovery.

It is in this context that heightened human rights due diligence (hHRDD) becomes not just important, but indispensable. It is the clearest expression of what it means to do business responsibly when the stakes are highest—when human rights are under greater threat and peace is at risk.

In these scenarios, there is not only a risk for people and peace. There is also a clear risk for companies and the countries which may be investing, during conflicts or recovery efforts, in operations linked to human rights abuses or conflict insensitive practices. Legal, reputational and operational risks are always around the corner in those moments, and may end up impacting heavily on the bottom line of those businesses.

That is why we are proud to have developed, in partnership with the UN Working Group on Business and Human Rights, a practical Guide on Heightened Human Rights Due Diligence for Business in Conflict-Affected Contexts. 

This Guide stems from the recognition – voiced in the UNGPs – that the higher the risk of human rights abuses, the more complex the processes that are expected of businesses. In other words, in conflict-affected areas – where the risk of abuses is enhanced - human rights due diligence should be heightened.

The Guide draws on best practice, gathered through consultations with companies, civil society, governments, and practitioners. it outlines concrete, context-sensitive steps that companies can take to:

  • Carry out conflict analysis to understand the conflict dynamics around them;
  • Identify and address risks to people and conflict; conflict triggers
  • And ensure that their operations contribute to resilience and do not fuel conflict or human rights abuses. 

Our work at field-level Implementation: Ukraine as a Case Study 

  • Since the beginning of the full-scale invasion, UNDP has been deeply engaged in supporting Ukraine’s people and institutions—laying the groundwork for recovery even as the conflict continues. A key pillar of that support has been promoting responsible business practices.
  • UNDP has already trained over 1,000 businesses across Ukraine, including more than 100 specifically on heightened human rights due diligence. These businesses range from local Small and Medium Enterprises (SMEs) to larger enterprises and are central to Ukraine’s future—its job creation, its resilience, and its eventual reconstruction.
  • But training on heightened human rights due diligence is only part of the equation. In parallel, UNDP is supporting the Ministry of Economy of Ukraine to create an enabling policy environment—one that supports responsible businesses, ensures a level playing field, and lays the foundation for sustainable trade and investment when peace returns.
  • In 2023, UNDP and the Ministry organised a conference on the “Recovery of Ukraine based on responsible business conduct”, which highlighted how Business and Human Rights principles must be at the centre of meaningful sustainable recovery efforts in the country.
  • This dual approach - working with companies and with policymakers, alongside civil society organisations and national human rights institutions - is central to our strategy. Because for heightened human rights due diligence to succeed, it must be embedded not just in business practice, but in national recovery strategies, procurement rules, and investment incentives.
  • And, crucially, this helps ensure that businesses in Ukraine are not just mitigating harm, but actively contributing to peace-positive recovery.  

Shaping the Evolving Global Landscape 

  • The practices outlined in the UNDP Guide are also finding resonance in the broader global regulatory landscape.
  • For example, the EU Corporate Sustainability Due Diligence Directive (CSDDD). This milestone piece of legislation directly cites the UNDP Guide, recognising that operating in conflict-affected or high-risk areas requires enhanced due diligence.
  • The growing integration of hHRDD principles into policy and regulatory frameworks is an encouraging signal—one that strengthens the alignment between corporate responsibility and Sustainable Development Goals. 

Investors: Responsibilities and Needs 

  • Just as “real economy” businesses must adapt in conflict-affected settings, so too must investors. This includes asking tough questions: Are companies in my portfolio involved in operations that could exacerbate conflict? Are they sourcing from regions where rights are being systematically violated?
  • But while responsibilities are growing, support for investors is still catching up. That is why UNDP is working to meet investors’ needs and provide:
  • Guidance for investors on how to engage companies with exposure to conflict-affected areas. This guidance stands to be launched at the Annual UN Forum on Business and Human Rights in November; and
  • Timely, reliable, and context-specific data to support investors in better risk assessment and decision-making. Although data is the lifeblood of the global financial system, there is currently a shortage of accurate data from conflict-affected contexts.
  • To help meet this need, UNDP is partnering with the Geneva Academy on International Humanitarian Law and Human Rights and Norwegian investors, including the Norwegian Pension Fund, KLP, Storebrand and Sparebank, in exploring the development of a service to provide reliable data to investors. It would allow them to direct capital away from those that may be complicit in abuses—and toward those that contribute to peace, resilience, and sustainable development.  

Heightened human rights due diligence is not just about avoiding harm and promoting just and peaceful outcomes — it is  about unlocking the full potential of business and investment as drivers of inclusive growth, sustainable markets, and economic resilience.

While doing that as the main objective. Heightened Human rights Due Diligence helps also companies and investors in managing their reputational and legal risks.

In conflict-affected contexts, businesses face higher risks. But they also have a higher calling. They can build markets that are inclusive, not exploitative. They can foster social cohesion instead of division. And they can create jobs and services that anchor recovery and hope.

UNDP stands ready to continue this work—with governments, with businesses, and with investors. The Guide on Heightened Human Rights Due Diligence is a blueprint for action, rooted in international standards and tailored to the realities of fragile contexts where business in conflict-affected settings becomes part of the solution, not part of the problem.