“We are receiving more and more questionnaires from business partners about human rights.”
Recently, we have been hearing comments like this from people involved in corporate sustainability and procurement.
Does the company have a human rights policy? Does it assess human rights risks? Has it established consultation and whistleblowing channels?
Responding to these questionnaires is an important way to communicate the company’s current status to business partners. However, answering “yes” to a question is not necessarily the same as being able to explain the substance behind that answer.
Even when policies and systems are in place, responding to follow-up questions can be difficult if their scope, implementation status, and responsible departments have not been clearly organized.
The SSBJ Standards are designed to apply in phases depending on company size, and companies expected to fall within their scope are beginning to prepare for implementation. As businesses are increasingly expected to consider how sustainability information is identified, managed, and explained, what perspectives are needed to ensure that human rights questionnaires do not remain one-off administrative tasks, but instead serve as a starting point for human rights due diligence (HRDD)?
Why Are Human Rights Questionnaires Becoming More Common?
As sustainability disclosure requirements continue to develop in Japan and overseas, the SSBJ Standards have also been published in Japan, prompting companies to begin preparing for their future application.
Companies are increasingly expected not only to have policies in place, but also to explain how they identify, manage, and communicate risks.
Human rights questionnaires are not directly required under the SSBJ Standards. However, customers and parent companies may use them as a means of checking the status of suppliers when identifying human rights risks associated with their own operations and value chains.
As a result, companies are not only expected to disclose information themselves. They may also be viewed as information providers whose responses support the risk management and disclosures of other companies.
In this context, what matters is not simply whether a company can complete a questionnaire, but how clearly it can explain the policies, governance structures, records, and day-to-day practices supporting its answers.
Three Common Gaps in Human Rights Questionnaire Responses
The first is a gap between the response and actual practice.
For example, a company may answer that it has a consultation channel. However, it may not have clarified who can use it, which department handles a report after it is submitted, or how the outcome is recorded.
Having a system in place is important. However, if the company cannot explain who the system covers and how it operates, the basis for its answer may not be clear to the recipient.
The second is a gap between departments.
Human rights initiatives often involve multiple departments, including human resources, general affairs, legal, procurement, corporate planning, and sustainability.
Even when each department is taking the necessary actions, it can be difficult to provide a consistent company-wide explanation if the relevant information is not connected.
When the person responsible must contact multiple departments and collect the same information each time a questionnaire arrives, this may indicate a need to review not only how the questionnaire is answered, but also how information and responsibilities are organized internally.
The third is a gap in the order in which the system is designed.
If a company attempts to build an overall framework only after responding to a series of individual questionnaires, maintaining consistency with past responses may take priority over considering what kind of system is actually needed.
There is no need to reject or invalidate previous responses. A more practical approach is to review the scope and assumptions that applied when each answer was given, while organizing the company’s current practices and future improvement plans.
Moving from “Current Answers” to an Explainable System
Advancing HRDD does not necessarily mean introducing multiple new systems all at once.
A practical starting point is to identify the initiatives that already exist within the company, such as its human rights policy, employment rules, procurement standards, training programs, consultation channels, and supplier management processes, and then confirm their scope and implementation status.
The company can then organize points such as:
- Which business activities and suppliers should be covered
- Which human rights risks should be prioritized
- What information is managed by each department
- How actions and progress should be recorded and explained
When it is difficult to review every business activity and supplier to the same level of detail from the outset, the company can define the scope and priorities and proceed gradually, starting with the areas that matter most.
The important shift is from creating a new response for each questionnaire to building a state in which answers can be supported by everyday management practices and records.
From Questionnaire Responses to the Ongoing Operation of HRDD
Responding to questionnaires is not the entirety of HRDD. It is one way for a company to understand where it currently stands.
The first step is to organize the policies, rules, internal structures, consultation channels, and supplier management practices that are already in place, and to identify what the company is already doing and what still needs to be developed.
Rather than building everything at once, it is important to strengthen the necessary initiatives gradually, beginning with the highest-priority areas.
The diagram below illustrates the overall process of using questionnaire responses as an entry point, moving through a review of current practices and prioritization, and ultimately connecting these efforts to the ongoing operation of HRDD.
From Questionnaire Responses to the Ongoing Operation of HRDD
HRDD is an ongoing process that connects risk identification and assessment, prevention and mitigation, remediation and access to remedy, monitoring, and disclosure.
However, not every company needs to develop its approach in the same order or on the same scale. The priorities will differ depending on the nature of the business, its commercial relationships, and the systems and internal structures already in place.
Questionnaires can also be used within this broader framework as a tool for identifying what the company is already doing and what still needs to be organized.
Start by Understanding What Is Already in Place
Questionnaire responses may depend too heavily on a single person. Initiatives may remain disconnected across departments. It may be difficult to explain the substance behind the answers provided.
When these challenges exist, a practical starting point is to organize current initiatives and information flows, and identify what the company is already doing and what still needs to be addressed.
Neuromagic supports companies from this initial assessment stage, including reviewing current questionnaire responses and internal documents, and identifying existing policies, rules, and practices.
Based on each company’s circumstances, we work together to organize human rights risks, set priorities, and connect these efforts with internal governance and disclosure, starting with the areas where support is most needed.
“We would like to clarify where to begin.” “We would like to review our current approach to human rights questionnaires.”
We welcome consultations from companies at this early stage.
The first step toward HRDD may not be creating a new system, but organizing what is already in place.
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