The Social Responsibility Assessment: What It Covers and Why UNGP Steps 4-7 Matter
A social responsibility assessment maps a company's human rights risks against the UN Guiding Principles on Business and Human Rights (UNGPs), then tracks what the company does about them. Most tools on the market are built for the easy half of that job: identifying risk and writing a policy. Far fewer are built for the harder half, tracking whether action was taken, communicating it credibly, and giving affected people an actual path to remedy.
That gap is not an accident. Assessing risk produces a tidy output: a heat map, a register, a score. Tracking, communicating and remedy produce something messier, an ongoing obligation with no natural end point. So companies invest heavily in the first three steps of human rights due diligence and treat the last four as a reporting exercise rather than a management one. Australia's own experience with modern slavery reporting shows exactly what that produces.
What a social responsibility assessment should cover
The UNGPs, adopted by the UN Human Rights Council in 2011, set out a company's responsibility to respect human rights through an ongoing due diligence process. Guiding Principle 17 breaks that process into four core steps: assessing actual and potential impacts, integrating findings into decisions and acting on them, tracking whether responses work, and communicating how impacts are addressed. That's due diligence. Remedy is different. Sitting alongside due diligence is a separate pillar of the UNGPs entirely: access to remedy for people who are harmed regardless of how good the due diligence was.
Stretched into a practical seven-step cycle, that becomes: commit to a policy, assess impacts, integrate and act, track responses, communicate externally, operate a grievance mechanism, and provide remedy. A social responsibility assessment module should give a company evidence for every one of those seven steps, not just the early ones. In practice, most implementations stop being genuinely rigorous somewhere around step three.
Steps 1 to 3 are where the market has focused
Committing to a policy is a document exercise. Assessing impacts, mapping suppliers, geographies and business relationships against known risk indicators, is where most Social Responsibility Assessment and supplier risk tools concentrate their features, because it produces a defensible, presentable output: a risk score, a heat map, a shortlist of high-exposure suppliers. Integrating that into procurement decisions and supplier contracts is harder, but still has a clear finish line.
None of that is wrong. It is necessary. It is also not where the UNGPs expect the work to stop, and it is not where most scrutiny, from regulators, investors and civil society, is currently landing.
Step 4: tracking, and why a spreadsheet doesn't count
Tracking means monitoring whether the actions a company took in response to an identified risk actually reduced it. That requires baseline data, a defined follow-up point, and a record of what changed. A supplier flagged as high-risk for forced labour indicators, for example, needs a documented corrective action plan with dates, not a status field that says "engaged."
This is where most companies fall short in practice. Tracking gets collapsed into re-running the same risk assessment a year later and comparing scores, which tells a company whether its risk register looks better, not whether conditions for workers actually changed. A better risk register is not the same as safer workers. Genuine tracking needs a system that holds a corrective action open until it closes, links it back to the original finding, and flags when a follow-up is overdue. Very few internal processes do this by default, which is exactly why it is the first thing that erodes when a compliance team is under time pressure.
Step 5: communicating, beyond the annual statement
Communicating under the UNGPs means being able to account for how impacts are addressed, particularly to the people affected by them, not just to regulators once a year. Guiding Principle 21 is specific that this should be accessible to those who need it, not buried in a PDF written for an audit committee.
Australia's Modern Slavery Act 2018 is a useful test case, because it was designed around this exact step and has been reviewed against it. The independent review of the Act, led by Professor John McMillan AO and reported in 2023, found that its reporting-only design had raised awareness of modern slavery risk but had not reliably translated into accountability, with the seven mandatory reporting criteria producing statements that describe policies without disclosing what was actually found or done. Awareness went up. Accountability didn't follow. The Australian Government's December 2024 response agreed in principle to new mandatory criteria requiring entities to disclose identified incidents and risks, alongside their consultation efforts, an acknowledgement that the current bar for "communicating" is too low. A social responsibility assessment module that only helps a company produce its annual statement is solving for the version of step 5 that regulators are actively trying to move past.
Step 6 and 7: grievance mechanisms and remedy, the part almost nobody reports
Access to remedy is where the UNGPs place the heaviest expectation and where companies place the least attention. It requires two things: an accessible grievance mechanism that affected workers or communities can actually use, and a genuine remediation process once a grievance is substantiated, not just an internal note that the matter was reviewed.
The Law Council of Australia's 2025 submission on strengthening the Modern Slavery Act put this plainly: the current regime does not require reporting entities to disclose the remediation processes or grievance mechanisms they have in place, so a company can lodge a compliant statement without ever describing what happens when modern slavery is actually found. That is not a drafting oversight. It reflects how few companies have a remedy process mature enough to describe. A social responsibility assessment that treats remedy as an afterthought, rather than as evidence to be tracked and reported, is missing the step where the UNGPs' credibility, and increasingly a regulator's, is actually tested.
*This lines up the Modern Slavery Act's five reportable areas against the UNGP steps they roughly correspond to. The first four rows connect cleanly: structure and risks maps to assessing, actions taken maps to integrating and acting, effectiveness maps to tracking, and the annual statement maps to communicating. The bottom row is the point of the article: on the UNGP side there's a full step for grievance mechanisms and remedy, but on the Act side there's nothing requiring a company to disclose either one. That dashed line is the gap the McMillan review and the Law Council's 2025 submission both flagged.
Modern slavery and human rights due diligence as the entry point
Most companies come to this topic through a specific, mandatory obligation, not the UNGPs in the abstract. Australia's Modern Slavery Act 2018 requires entities with more than $100 million in annual revenue to report annually against seven criteria, including the risks identified and the actions taken to address them. The UK's Modern Slavery Act 2015 set an earlier, lighter-touch precedent. Both sit inside the same UNGP logic: assess, act, track, communicate, remedy.
Human rights due diligence is where that logic hardens from voluntary good practice into a defensible compliance position. A company that can show tracked corrective actions, a working grievance mechanism and evidence of remedy is in a fundamentally different position, with regulators, investors and its own board, than one that can only show a risk register from eighteen months ago. That difference is exactly what a properly built Social Responsibility Assessment module is designed to evidence.
References
- Guiding Principles on Business and Human Rights, Office of the UN High Commissioner for Human Rights, 2011.
- Report of the statutory review of the Modern Slavery Act 2018 (Cth), Attorney-General's Department, led by Professor John McMillan AO, 25 May 2023.
- Australian Government response to the review report of the Modern Slavery Act 2018, Attorney-General's Department, 2 December 2024.
- Strengthening the Modern Slavery Act, Law Council of Australia submission, 2025.
- Modern Slavery Act 2018 (Cth), Federal Register of Legislation.
- Modern Slavery Act 2015, UK Public General Acts.
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