Intermediaries: the data linchpins of human rights due diligence

This chapter examines the role of intermediaries in Human Rights Due Diligence (HRDD), a component of the UN Guiding Principles on Business and Human Rights that requires companies to identify and mitigate human rights violations in their supply chains. As HRDD regulations expand globally, businesses increasingly rely on third-party intermediaries-auditors, consultants, and ratings providers-to collect and analyze supply chain data. We critically assess these intermediaries, finding they often have to navigate significant challenges including conflicts of interest, unreliable data, superficial assessments, and audit fraud. We explore how intermediaries occupy an ambiguous space between public interest and commercial motivations, functioning as data linchpins with considerable influence yet minimal accountability. We conclude that effective HRDD implementation requires better regulation of intermediaries to ensure they balance public interest with private gain while maintaining integrity in human rights assessments.