From declarative to verified: 5 human rights due diligence takeaways
Letizia La Sorte
Solutions Expert
24 Apr 2026
About 5 mins
In this webinar, Sedex and L’Oréal shared a practical and experience‑based perspective on how organisations can move from a largely declarative approach to human rights due diligence towards a model that is verified, scalable and embedded into business decision‑making.
Drawing on regulatory expectations, industry standards and L’Oréal’s own transformation journey, the discussion highlighted what effective due diligence looks like in practice today.
Below, we summarise the five key takeaways from the session, followed by a selection of questions raised by participants and the responses shared during the webinar.
Key takeaway #1 – Due diligence is an ongoing, risk‑based management process
A central message of the webinar was that human rights due diligence cannot be treated as a one‑off exercise or a purely compliance‑driven activity. Aligned with the OECD framework and reinforced by emerging regulations such as the Corporate Sustainability Due Diligence Directive (CSDDD), due diligence is best understood as a continuous cycle: identifying risks, preventing and mitigating harm, tracking the effectiveness of actions taken, and communicating transparently on progress.
This represents a shift in focus. Rather than looking only at risks to the business, organisations are increasingly expected to assess and manage risks to people across their supply chains. For procurement and sustainability teams, this means strengthening existing supplier risk management processes with deeper verification, clearer prioritisation, and documented remediation over time.
Key takeaway #2 – Meaningful risk management requires visibility beyond tier 1
The discussion also underlined that some of the most severe human rights risks are rarely found at tier1 level alone. They often sit further upstream, among tier2 and tier3 suppliers, subcontractors, traders or raw material producers. Without visibility beyond direct suppliers, it becomes difficult to understand where the most critical risks are located and where action is most urgently needed.
Sedex supports this challenge by allowing organisations to combine country‑ and sector‑level inherent risk data with site‑level information gathered through assessments and audits. This layered visibility helps teams move away from assumptions and towards a more evidence‑based understanding of risk across complex supply chains.
Key takeaway #3 – Combining different data sources enables smarter prioritisation
Rather than relying on a single tool or data point, effective due diligence brings together multiple sources of information. As discussed in the webinar, inherent risk indicators provide a starting point by highlighting higher‑risk countries, sectors and activities. Supplier self‑assessments then add important context, offering insight into management systems, policies and day‑to‑day practices at site level.
Onsite SMETA audits, using either the 2pillar or 4pillar methodology, play a complementary role by verifying conditions and identifying nonconformities. When used together, these elements allow organisations to prioritise audits and remediation efforts where both risk and potential impact on workers are greatest, rather than applying a uniform approach across all suppliers.
Key takeaway #4 – SMETA 7.0 supports a deeper focus on systemic risks
The webinar highlighted how the evolution of SMETA, strengthens the assessment of systemic and emerging risks. Beyond traditional compliance checks, the methodology places increased emphasis on issues such as recruitment fees and forced labor risks, living wage gaps, gender equity and the maturity of management systems.
By encouraging a more structured assessment of policies, resources, training and controls, SMETA 7.0 helps organisations move beyond isolated corrective actions. Instead, it supports a more holistic approach to identifying root causes and driving continuous improvement across suppliers.
Key takeaway #5 – L’Oréal’s journey shows how due diligence can be scaled pragmatically
L’Oréal shared how its long‑standing social audit program, originally launched in 2006, is now transitioning to Sedex and SMETA as part of a structured three‑year transformation plan. Key objectives behind this shift include alignment with a widely recognisedmarket standard, a reduction in audit fatigue for suppliers, and increased supplier ownership of the audit process.
By translating qualitative audit findings into an internal scoring system and integrating this data into procurement tools, L’Oréal is strengthening how due diligence insights inform business decisions. At the same time, this approach allows teams to spend less time on administration and more time supporting remediation and improvement on the ground.
Audience Q&A – questions and responses with Alice Follot, Sustainable Sourcing Manager at L’Oréal
Have you identified gaps between SMETA audits and L’Oréal’s previous internal approach?
Overall, L’Oréal noted that the main trends identified through SMETA audits are consistent with those seen under its previous internal program. However, certain topics, particularly living wages, were not previously assessed in the same way. With SMETA 7.0, these issues are now more visible, while L’Oréal continues to run complementary programs to support suppliers in these areas.
How have suppliers responded to joining Sedex?
Supplier responses have varied. Those already familiar with Sedex generally welcomed the transition, particularly because it helps reduce audit duplication and fatigue. For other suppliers, especially smaller organisations or those with limited business volumes, additional engagement has been required. L’Oréal supports this onboarding through clear communication, buyer involvement, dedicated webinars and Sedex’s supplier engagement services.
Do you impose restrictions on which audit firms suppliers can use?
L’Oréal relies on Sedex’s list of approved audit companies, which has been subject to due diligence. This approach helps ensure audit quality while also increasing auditor availability and reducing bottlenecks in certain regions.
Conclusion
The webinar reinforced a clear message: effective due diligence at scale depends on standardisation, data and collaboration. By combining risk intelligence, verified audits and a focus on remediation, organisations can move beyond a compliance mindset and work towards more resilient and responsible supply chains.
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