Building a Supply-Chain Human Rights team from scratch

For a growing number of businesses, human rights due diligence has quietly morphed from a policy statement to an operational capability that someone, somewhere, has to actually deliver. The pressure is coming from several directions at once: regulation, investors, customers and campaigners; and most organisations are discovering that the job is far bigger than a paragraph in the modern slavery statement. It needs a team. And for many companies, that team does not yet exist.

The regulatory backdrop is the most visible driver. The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) entered a new phase when the Omnibus I amendments took effect in March 2026. The changes narrowed its reach considerably; the directive now bites hardest on the very largest companies, those above roughly 5,000 employees and €1.5 billion in turnover, with national laws due by mid-2028. But the core obligation survived the rollback intact: risk-based human rights and environmental due diligence across the full chain of activities, not just your immediate suppliers, with real grievance and remediation mechanisms behind it. Simplified, in other words, but certainly not abandoned.

Crucially, the number of companies building this capability is far larger than the number strictly in scope. Once your customers are regulated, their due-diligence obligations flow straight down to you through contracts and supplier codes. The result is a wave of organisations - many with no prior specialist function - trying to build a human rights team from a standing start. Here is how to think about it.

 

Why it can’t just be bolted onto procurement or legal

Historically, supply-chain human rights work was scattered: a bit of it in procurement, a bit in legal, a bit in a CSR team focused mainly on reporting. That model breaks under real due diligence, because the work is genuinely cross-disciplinary and genuinely operational. It requires someone who understands international human rights frameworks and the mechanics of a purchasing decision; who can read a saliency assessment and negotiate a corrective action plan with a supplier eight time zones away. Spreading that across people who already have day jobs guarantees it gets done superficially or not at all. A dedicated function, however small at first, is what turns intention into practice.

 

The roles: build in layers, not all at once

Very few organisations should - or can - hire an entire team on day one. The sensible pattern is to build in layers, starting with leadership and capability and adding specialisation as the programme matures:

• The function lead  - a Head of Human Rights, Responsible Sourcing or Supply Chain Sustainability. Your first and most important hire: someone senior enough to command a mandate across procurement, legal and ESG, and credible enough to be believed by both the board and civil society. Early on, expect this person to be a player-coach who both sets strategy and does the work.
• Due diligence / human rights risk analyst  - the engine room. Maps and prioritises risk across the supply base, runs saliency assessments, interrogates supplier data and turns it into a defensible, risk-based programme. Analytical, methodical, comfortable with imperfect data.
• Responsible sourcing specialists  - the field operators embedded closest to procurement. They engage suppliers, oversee audits and social assessments, and drive corrective action on the ground. This is where human rights meets commercial reality.
• Grievance & remediation lead  - owns the operational grievance mechanisms and worker-voice channels, and ensures that when harm is found, something actually happens. Increasingly non-negotiable under CSDDD.
• Data & systems capability  - traceability, supplier platforms (Sedex, EcoVadis and the like) and the reporting infrastructure. Sometimes a dedicated hire, sometimes borrowed from a wider ESG data team.

Around this core sit the cross-functional partners you influence rather than employ: procurement, legal, ESG, sustainability and communications. Getting their mandate right matters as much as any individual hire.

 

The skills that actually matter

The technical foundations are reasonably well defined: fluency in the UN Guiding Principles on Business and Human Rights, the OECD Guidelines and core ILO conventions; a working grasp of due-diligence methodology; and enough supply-chain and procurement literacy to be taken seriously by commercial teams. Data literacy is fast becoming essential as supplier datasets grow. But the technical skills are the easy part to screen for.

What separates a good hire from a frustrated one is a cluster of harder-to-find attributes: pragmatism in the face of imperfect information, comfort with ambiguity, and above all the ability to influence without authority. These roles rarely control budgets or suppliers directly; they succeed by persuading people who do. Cultural range and language skills matter too, because the risks and the relationships are global. Look for people who can hold a principled line and land a workable compromise — not one or the other.

 

Where to find them

This is a genuinely scarce talent pool, and the honest starting point is that you will rarely find someone who ticks every box. The strongest strategy is to target adjacent, trainable talent in the right pools rather than waiting for a unicorn. The most productive hunting grounds are the specialist consultancies and assurance firms that have run these programmes for clients (the responsible-sourcing and social-audit practices in particular); multi-stakeholder initiatives and certification bodies such as amfori, the Ethical Trading Initiative, Fair Wear and Sedex; NGOs and civil-society organisations in the business-and-human-rights space; and law firms with dedicated BHR practices. Beyond the specialists, industries that were forced to mature early - apparel, footwear, food and electronics - are full of people who have done the real work and can transfer it sideways into sectors just now waking up to it.

Because the supply is thin and the need is often immediate, many organisations sensibly blend permanent and interim resource; bringing in experienced contract specialists to stand the programme up while they recruit the permanent leadership underneath. Done well, that buys time without stalling momentum.

 

The mistakes worth avoiding

Three failure patterns recur. The first is burying the function inside procurement with no independent mandate, so it can never challenge a commercial decision. The second is hiring at one extreme of the spectrum - a policy expert with no operational reality, or an auditor with no grounding in rights - and expecting them to cover the whole field alone. The third, and most common, is asking a single overstretched person to be strategist, analyst, auditor and remediator all at once, then wondering why the programme stalls. Building in layers, with a clear mandate and realistic expectations, is what avoids all three.

 

How Leonid can help

Standing up a human rights function from scratch is as much a talent-strategy problem as a compliance one: you are designing roles that are new to your organisation, in a market where the specialists are few and the best candidates sit in adjacent fields you may not be looking in. This is precisely where our data-powered, human-led approach earns its place; helping you scope and sequence the team, benchmark scarce and fast-moving salary bands, and reach the people who rarely appear on a standard shortlist, across the UK, Europe and beyond.

 

For further information on recruiting human rights jobs, please get in touch with Adam Bond for a friendly chat.