Human rights due diligence beyond tier one: lessons from smallholder agriculture

Innovation Forum, in partnership with CottonConnect, convened brands, suppliers and practitioners at the Responsible Sourcing and Ethical Trade conference 2026, for a crucial cross industry dialogue with the goal to look beyond the cotton sector.

By exploring how other smallholder agricultural industries approach Human Rights Due Diligence (HRDD), we identified key lessons that can be implemented across agricultural and commodity supply chains. The conversation was candid, and the conclusions pointed to a sector still navigating a significant gap between policy intent and farm-level reality.

Beyond Tier One

HRDD in smallholder agriculture presents fundamentally different conditions compared to tier-one manufacturing environments. Fragmented supply chains, households cultivating multiple crops, and predominantly informal labour arrangements all add to the challenge. Workers, including migrants, move across commodities and regions in ways that rarely align with how companies define responsibility.

While many organisations now operate with structured HRDD frameworks aligned to international standards, translating those frameworks into meaningful action at farm level remains difficult. Participants described this space between policy and practice (particularly between farm and first formal processing stage) as one of the least understood areas of supply chain due diligence.

Assessment fatigue

A recurring concern was the sector’s growing reliance on risk assessments, audits, and data collection. While these tools are essential for identifying risks, participants noted that:

Efforts are increasingly skewed toward measurement over action
Suppliers and partners face a proliferation of overlapping questionnaires and reporting demands
Data collection risks becoming an end, rather than a means to improve outcomes

This has led to “assessment fatigue,” raising concerns that the industry may be moving backwards in its ability to drive meaningful change.

Local context is not optional

A key takeaway was the importance of grounding HRDD in local realities. Language differences alone can undermine well-intentioned interventions. While seemingly minor, such misunderstandings reinforce perceptions that global actors do not fully understand local realities.

Participants stressed that:

Human rights risks, and their solutions, are highly context-specific
Language, cultural understanding, and local power dynamics are critical
Misinterpretation, even at a basic level, can undermine trust and effectiveness

This points to the importance of local partners and staff – not just as implementers, but as co-designers of the approach. What looks coherent in a policy document can feel very different at farm level. Effective HRDD, participants argued, depends on shifting away from externally imposed models towards locally informed solutions.

Fragmentation across the system

Despite shared goals, HRDD efforts remain highly fragmented.

Challenges include:

Siloed commodity approaches, which fail to reflect the reality that farmers often grow multiple crops
Unclear roles and responsibilities across brands, suppliers, and intermediaries
Limited alignment between global commitments and local implementation

Participants noted that this lack of clarity becomes particularly visible when addressing risks affecting mobile or informal workers, who may fall between organisational mandates and national systems of protection.

The measurement gap

Measuring effectiveness is challenging. Participants highlighted the need to move beyond purely quantitative metrics and consider:

Changes in livelihoods and wellbeing
Access to services such as healthcare and education
Workers’ and farmers’ lived experiences

There is a growing need to translate qualitative insights into forms that can inform decision-making and meet reporting expectations. Yet qualitative evidence, however rich, is difficult to translate into the forms that management decisions and regulatory reporting require.

Bridging this gap and finding ways to capture human reality without losing it in the process of standardisation, was recognised as one of the sector’s most pressing unsolved challenges.

One-size-fits-all does not work

Experiences shared across commodities, from cotton and cocoa to sugar and tomatoes, reinforced that interventions must be highly context specific. What works in one geography or crop system may fail completely in another.

Participants stressed the importance of identifying “low-hanging fruit” to build momentum while recognising that structural change can take decades. Progress in sectors such as cocoa, for example, has required sustained pressure, investment and coordination over many years.

Rather than attempting universal solutions, organisations increasingly need to act more like “plastic surgeons than general practitioners” –diagnosing and treating problems in a highly targeted way.

The complexity of remediation

Discussions on remediation highlighted the difficulty of addressing human rights risks in vulnerable contexts.

Examples included:

Children present in workplaces due to lack of safe alternatives
Informal labour arrangements shaped by economic necessity
Gender dynamics influencing participation and risk exposure

Participants acknowledged that solutions are often imperfect and require navigating trade-offs. This reinforces the need for continuous dialogue with affected communities and a willingness to adapt approaches over time.

Collaboration under pressure

No single brand, supplier or NGO can fix HRDD in smallholder systems alone. Progress requires coordinated, sector-wide effort: aligning around shared priorities, clarifying roles across the value chain, building on existing initiatives rather than launching new ones, and investing meaningfully in local capacity.

Regulatory pressure complicates this. As legal requirements tighten, companies tend to narrow their focus – concentrating on the commodities or supply chain tiers where obligations are clearest, rather than engaging with systemic risks that cut across sectors and geographies. Participants saw maintaining a focus on meaningful impact, rather than compliance alone, as the defining challenge for the period ahead.

Towards a more systemic approach

Looking ahead, several priorities emerged for strengthening HRDD in agricultural supply chains:

Aligning stakeholders around shared priorities and expectations
Clarifying roles across the value chain to reduce duplication and gaps
Building on existing initiatives rather than creating new, fragmented solutions
Investing in local partnerships and capacity building
Balancing data requirements with genuine engagement on the ground

Participants emphasised that HRDD in smallholder agriculture is a long-term, systemic challenge. Progress will depend not only on better tools and frameworks, but on deeper collaboration, trust, and a shared commitment to learning.