Human Rights Due Diligence in U.S. Supply Chains: Integrating Screening, Escalation, and Remediation That Aligns with Global Norms

Boards and procurement leaders in the United States are increasingly judged not only by what they buy, but by how they identify, escalate, and resolve human rights risks buried within complex supplier networks. Enforcement under the Tariff Act and the Uyghur Forced Labor Prevention Act (UFLPA) has raised the cost of weak screening and slow escalation. At the same time, European legislation has set a new global benchmark for responsible value chain management. Together, these forces are redefining what credible due diligence looks like.

This article outlines the priorities that help companies meet U.S. enforcement expectations while remaining interoperable with global norms.

Why Integration Matters — and Why It Must Map to Global Standards

A credible human rights due diligence program links screening, escalation, and remediation in one continuous workflow. The UN Guiding Principles on Business and Human Rights define due diligence as a four-part process: assess, integrate and act, track, and communicate. Remediation should be available whenever harm occurs. This structure provides the operational backbone for policy design, supplier engagement, and executive oversight.

From 2024 onward, the European Corporate Sustainability Due Diligence Directive (CSDDD) has become a reference point for investors and multinationals. It requires companies, including many U.S. groups active in the EU, to identify and address adverse human rights impacts across their chains of activities, with staged application from 2027 to 2029. Using this directive as a north star ensures that U.S. programs remain interoperable with global frameworks and investor expectations.

Key takeaway

Companies that build U.S. compliance systems aligned with EU due diligence standards future-proof their operations and satisfy both regulators and investors.

Need help mapping your U.S. due diligence program to EU and OECD standards? Our experts can benchmark your current screening and escalation process against global expectations — and design a roadmap that clears both CBP and investor review. Get in touch here.

What Effective Screening Looks Like in the United States

1. Build screening for U.S. enforcement realities.

Under the UFLPA, U.S. Customs and Border Protection (CBP) has detained thousands of shipments tied to forced labor concerns. By December 2023, CBP had reviewed more than 6,000 shipments valued above $2 billion, and the UFLPA Entity List continued to expand. Weak traceability is no longer just a compliance problem; it is a direct commercial risk. Procurement and trade teams should therefore design screening that can withstand port-level scrutiny.

2. Anchor screening to public law signals.

The California Transparency in Supply Chains Act requires large retailers and manufacturers to disclose practices across five categories: verification, audits, certification, accountability, and training. These disclosures should drive real controls, not exist as static web content.

3. Align screening to OECD guidance.

The OECD Due Diligence Guidance for Responsible Business Conduct (updated in 2023) codifies six practical steps—from embedding expectations in management systems to cooperating in remediation. This model travels well across sectors and is familiar to institutional investors.

Practical move: Use the OECD six-step model as the framework for internal screening checklists and supplier assessments.

From Traceability to Evidence That Convinces CBP

Traceability only matters if it can be turned into a narrative that a CBP officer can follow. Practical programs do three things:

• Maintain chain-of-custody records linking purchase orders, bills of materials, and lot codes to upstream producers.

• Preserve independent verification that confirms the absence of links to entities on the UFLPA list.

• Prepare a response package in advance, including supplier affidavits, recruitment fee attestations, and third-party test results where relevant.

Reuters reporting shows that enforcement has scaled rapidly, with billions of dollars in shipments reviewed and a significant portion denied or delayed. That means importer documentation must now be decision-grade, not narrative-only (Reuters).

To operationalize this, companies should embed evidence templates directly into their trade compliance workflow. These include:

• An origin narrative explaining supplier and material flows.

• A supplier and facility map highlighting any proximity to high-risk regions.

• A recruitment fee ledger covering workers hired through agencies.

When a shipment is detained, the compliance team can submit a standardized evidence pack that mirrors how CBP reviews files. A simple internal chart tracking detentions by product category—mirroring CBP’s own dashboard—can help set quarterly priorities.

Escalation That Is Fast, Cross-Functional, and Rights-Holder Aware

Escalation pathways often fail because they are siloed within one department. In practice, escalation works best when trade compliance, procurement, legal, and sustainability teams share one playbook with pre-agreed thresholds. These should define:

• When to hold purchase orders.

• When to switch sources.

• When to disclose issues externally.

Worker voice mechanisms should be treated as decision-grade data, not anecdotal feedback. Our field experience shows that issues move faster when worker signals are integrated into escalation logic.

Typical triggers that warrant a formal incident ticket and executive owner include:

• A credible link to a high-risk region or an entity on a government list.

• Recruitment fee risk for migrant workers.

• Repeat violations on wages, hours, or document retention.

• Any signal that would likely lead to detention at the border under UFLPA.

Checklist: Refresh blocked-party lists monthly. DHS added new companies to the UFLPA Entity List in late 2024 and again in January 2025, making timely updates essential.

Designing a U.S. Escalation Playbook That Maps to Global Norms

A well-structured escalation playbook should align cleanly with both the UN Guiding Principles and the OECD due diligence steps. The OECD framework describes six stages: embedding expectations, identifying and assessing risks, ceasing or preventing harm, tracking progress, communicating results, and providing or cooperating in remediation. Aligning escalation processes to these stages helps companies brief boards effectively, respond to European customers, and prepare for independent assurance.

Operational triggers must be specific and objective. Escalation often fails when thresholds are ambiguous. Examples of clear bright lines include:

• Any supplier that matches an entity on the current UFLPA list.

• Any evidence of worker-paid recruitment fees.

• Repeated non-compliance on wages or hours after prior corrective action.

Pull quote: “Escalation is effective only when everyone knows the trigger point and the next move.”

These steps make U.S. escalation frameworks both defensible under enforcement and interoperable with global investor expectations.

Remediation That Closes the Loop — With Evidence

Remediation is not a press release; it is a documented pathway that addresses harm, proves change, and prevents recurrence. A credible remediation plan generally includes:

• Worker repayment where relevant.

• Independent verification by a third party.

• New controls that prevent recurrence.

There are concrete examples of how this looks in practice. In 2021 and 2022, CBP modified its findings on Malaysia-based Top Glove after verifying repayments and operational improvements. The U.S. Department of Labor (DOL) recorded that Top Glove issued more than $30 million in remediation payments to workers and improved labor and living conditions. This case remains a public benchmark for credible remediation (U.S. Department of Labor, link).

Remediation is equally relevant inside U.S. borders. In January 2024, the DOL recovered $1.1 million for 165 garment workers in Los Angeles, required the brand involved to fund back wages and damages, and secured an enhanced compliance agreement including monitoring and a worker hotline. For apparel brands sourcing domestically, that case provides a template for worker-centered remediation (DOL release).

Metrics, Governance, and Disclosure That Investors Trust

Investors and customers increasingly want evidence that due diligence programs are operational, not performative. Two governance moves make the difference between marketing and credibility.

First, connect key human rights metrics directly to board and executive oversight. Track indicators such as:

• Number of shipments detained or released.

• Escalations opened and closed.

• Remediation outcomes verified and published.

Present these figures in quarterly reports reviewed by the audit or sustainability committee. Linking due diligence data to board governance demonstrates accountability and signals seriousness to both investors and regulators.

Second, align disclosures with established rule sets. The U.S. Securities and Exchange Commission (SEC) Form SD filings—used for conflict minerals reporting—remain a concrete annual demonstration of supply chain governance. These filings require supplier inquiries, risk assessments, and due diligence narratives, with submission due each May 31 for the prior calendar year. Treating that cadence as a baseline discipline helps companies manage other high-risk commodities under the same level of scrutiny.

Governance credibility starts when due diligence metrics are reviewed alongside financials, not after them.

Integrating U.S. Screening, Escalation, and Remediation with Global Expectations

An effective due diligence model pairs traceability evidence with decision-making that withstands regulator and investor examination. The UFLPA enforcement dashboard and CBP materials show that enforcement data is becoming more detailed and public. Importers now need documentation that answers specific questions about origin, intermediaries, and labor recruitment practices.

Treat the UFLPA dashboard as a proxy for enforcement focus and build your evidence framework accordingly. For example, if a product category shows rising detentions, prioritize supplier verification and worker recruitment audits in that area.

To make this approach sustainable:

• Embed evidence templates into your compliance systems.

• Require supplier attestations as part of purchase order release.

• Conduct quarterly internal mock reviews to test readiness against CBP standards.

This not only supports U.S. compliance but also positions companies for EU assurance and investor disclosure, since the same evidence base serves both audiences.

Remediation That Centers Workers and Prevents Recurrence

The strongest remediation examples combine direct benefits for affected workers with controls that eliminate recurrence. Apple’s 2024 progress report and related DOL materials show how suppliers repaid more than $34 million in recruitment fees to tens of thousands of workers since adopting its zero-fees policy. The program also mapped hundreds of labor agencies to prevent reoccurrence.

This combination of repayment, supplier discipline, and transparency demonstrates how remediation can drive structural change. Companies in other sectors can adapt similar frameworks—tying repayment to contractual obligations, publishing progress summaries, and using independent validation.

Remediation must also extend to domestic suppliers. The California Garment Worker Protection Act reinforces accountability for brands operating within the state. The DOL’s Los Angeles enforcement cases show that effective domestic remediation includes back-pay recovery, brand accountability, and new compliance agreements with worker feedback channels.

Key takeaway: The most credible remediation outcomes repair harm for workers and prevent future violations through structural controls.

Practical Starting Moves for the Next Quarter

For companies ready to strengthen their human rights due diligence programs, the following steps deliver visible results within a single quarter while laying the foundation for longer-term assurance.

1. Build a single source of truth for supplier and facility data.

Integrate purchase orders, supplier details, and facility identifiers into one database. Tag any links to UFLPA-listed entities. Conduct internal mock CBP reviews before shipments leave port.

2. Update codes of conduct and contracts.

Add clauses that enforce zero recruitment fees, employer-paid costs, and full agency disclosure. Use a repayment protocol modeled on public examples such as Apple’s, verified by a third party when feasible.

3. Create a cross-functional escalation council.

Meet every two weeks under legal or trade leadership. Give the council authority to hold or reroute purchase orders when credible risks arise. Experience shows that empowering this group reduces detention and write-off risk.

4. Train customs brokers and logistics partners.

Ensure documentation meets CBP expectations before submission. A complete and well-organized file shortens detention time and builds regulator confidence.

5. Pilot a worker voice channel.

Select two to three high-risk facilities and partner with a trusted third party to test anonymous reporting. Pre-design repayment or remediation pathways so that alerts can move from detection to action within weeks.

Tip: Start small but design for scale. Each pilot should inform the structure of your global due diligence model.

Call to Action

If your organization wants a due diligence program that clears CBP reviews, aligns with OECD and UNGP frameworks, and provides investor-grade evidence, Gasilov Group can help. We design operating models, evidence systems, and playbooks tailored to your sector, supplier footprint, and growth strategy.

Contact us to scope a two-week diagnostic sprint or a phased build focused on screening, escalation, and remediation performance.

Written by: Gasilov Group Editorial Team

Reviewed by: Arif Gasilov, Partner – Sustainability Strategy​​​

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Frequently Asked Questions (FAQ): Human Rights Due Diligence

1. What documents does CBP actually review for UFLPA compliance, and how should companies organize them?

CBP reviews a clear origin narrative, facility lists, bills of materials, production and shipping records, and independent verification proving no links to restricted entities. Organize files using the same categories shown on the CBP enforcement dashboard, then include recruitment fee attestations and worker repayment records where applicable.

2. How can U.S. companies align with the OECD framework without adding unnecessary bureaucracy?

Use the OECD’s six due diligence steps as column headers for your incident tracker, mapping each action to a control such as contract clauses for prevention, repayment protocols for remediation, and audit results for tracking. This structure aligns U.S. processes with EU expectations without duplicating work.

3. What counts as credible recruitment fee remediation in practice?

Credible remediation includes worker repayment, updated supplier policies, and public reporting of progress. Apple’s multi-year repayments exceeding $34 million provide a transparent benchmark that other companies can adapt for scale and accountability.

4. How do SEC conflict minerals filings connect to broader human rights due diligence?

SEC Form SD requires a structured process for supplier inquiries, risk assessments, and due diligence documentation, followed by a public filing each May. Companies can use this cadence to anchor similar governance cycles for other high-risk materials and align disclosure expectations across ESG domains.

5. What changed with the UFLPA Entity List during 2024 and 2025, and why does it matter for procurement?

The Department of Homeland Security expanded the Entity List twice—once in late 2024 and again in early 2025. Each addition triggers a need to refresh supplier screening and activate contingency sourcing. Procurement, trade, and legal teams should implement an automatic hold protocol whenever a counterparty, or a supplier to a supplier, appears on the list.