Human Rights Due Diligence, in a Time of Conflict 

27th Mar 2026

Insights, Interview, Worker Rights

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Construction worker walks across the yard. He is wearing yelow wellies, a hard ht and gloves.

Impactt CEO, Patrick Shaw-Brown, reflects how companies can navigate human rights due diligence (HRDD) in a time of conflict, and the consequences of pausing this vital work. 

With ongoing uncertainty across the Middle East and Gulf, some companies are pausing efforts to address the significant risks faced by workers in the region. While prioritising immediate staff safety amid active conflict is understandable, there is a real danger that attention to vulnerable workers, particularly migrant workers, who are often the last to receive support, will fall further down the agenda. 

This is especially concerning given the structural vulnerabilities migrant workers face in Gulf labour markets: 

  • Dependence on employers for visas, housing and wages 
  • Limited freedom to change employment 
  • Recruitment fee debts that heighten coercion risks 
  • Limited access to grievance channels and information in their own languages 
  • Disruption of remittances that support families at home 

Periods of instability tend to increase these risks, not reduce them. 

A pause in physical operations does not mean HRDD should stop.  

Even when on‑the‑ground activity is restricted, companies can, and should, continue much of their human rights work. 

What can we learn from the pandemic?  

The Covid‑19 pandemic proved that physical access is not a prerequisite for impact. 

Across 2020–2022, Impactt worked with clients in the Gulf, South Asia and Southeast Asia to maintain progress by: 

  • Running remote worker interviews in multiple languages through secure phone and messaging platforms 
  • Delivering virtual supplier capacity‑building, including supervisor briefings and labour‑rights training 
  • Conducting remote recruitment fee remediation, reviewing payment records and verifying repayments digitally 
  • Mapping subcontractor risks using remote documentation review and WhatsApp‑based worker engagement 
  • Monitoring working‑hours trends and wage practices using payroll data shared electronically 

These methods were not second‑best alternatives, they were effective tools for maintaining visibility and mitigating risk when physical oversight was impossible. 

The lesson remains relevant today; do not let reduced access become reduced action. 

Why continued engagement matters now 

In conflict‑affected contexts, the risks to workers do not disappear, they often intensify: 

  • Wage delays and non‑payment increase as businesses struggle 
  • Workers’ mobility becomes further restricted 
  • Recruitment agents may exploit the uncertainty to charge higher fees 
  • Mental health pressures rise as workers face separation, fear, and instability 

This is a phenomenon we witnessed as we supported medical glove manufacturer, Top Glove during the pandemic, where rising demand for PPE, restriction of movement to contain the spread of the virus, and the cessation of in-person audits exacerbated the long-standing human rights risks. 

Maintaining even minimal, remote channels of engagement can prevent these issues escalating. 

Don’t let disruption undermine progress 

Periods of disruption can undermine months, and even years, of HRDD progress. 

Companies that stay engaged—remotely or otherwise—recover faster when conditions stabilise. 

Now is the time to: 

  • Keep suppliers informed and connected 
  • Review existing risk assessments and update them for the current context 
  • Plan for the phased return of on‑site assessments 
  • Identify lessons learned from earlier work and carry them forward 
  • Ensure continuity of recruitment‑fee repayment programmes 
  • Maintain open communication with workers in their languages 

Proactive planning now avoids a prolonged slowdown later. 

Impactt’s role in supporting companies through crisis 

At Impactt, we continue to support companies and suppliers across the Gulf and wider region before, during and after periods of crisis. Our experience delivering remote HRDD, worker engagement and remediation during Covid-19 means we can help organisations: 

  • Maintain progress when movement is restricted 
  • Reach workers directly, even when physical access is limited 
  • Monitor priority risks 
  • Strengthen systems so they remain functional in volatile environments 

We would be glad to discuss how to maintain momentum, protect vulnerable workers, and prepare for a stronger restart in these challenging conditions. 

Get in touch with Patrick at patrick@impacttlimited.com to discuss further.  

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