The Outcome Gap: Why Supply Chain Grievance Mechanisms Must Move Beyond Accessibility

Essay

Author: Mareike Standow

Date: August 21, 2026

In this essay, Mareike Standow argues that the effectiveness of supply chain grievance mechanisms cannot be judged by their accessibility to rightsholders alone. Drawing on her research on grievance mechanisms in the automotive sector in Mexico, the garment sector in India, and the agricultural sector in Spain, she identifies three recurring barriers to effective remedy and argues that remedial outcomes must be treated, alongside accessibility, as a core measure of how well grievance mechanisms actually work.

Illustration : Prateek Draik

Grievance mechanisms have become central tools for addressing human and labour rights violations in global supply chains. They appear across the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the EU Corporate Sustainability Due Diligence Directive (CSDDD), and national legislation such as Germany’s Supply Chain Act (LkSG). Their promise lies in their potential to improve access to justice for rightsholders who might otherwise face significant barriers in pursuing corporate accountability.

For workers and communities affected by corporate misconduct, judicial avenues are often difficult to access. Geographic distance from buyer companies, financial constraints, linguistic differences, power imbalances, and complex questions of legal admissibility can all make formal justice seem unachievable. Grievance mechanisms offer an alternative pathway: a specialised channel through which rightsholders can report harm occurring anywhere in a supply chain and, at least in theory, seek a remedy from companies that may be thousands of miles away.

As companies face growing regulatory pressure to demonstrate that they can identify and respond to human rights risks across their supply chains, considerable attention is being directed towards establishing grievance channels and showing that workers are able to access them. This includes considerations of whether rightsholders know about a mechanism, can access it in relevant languages, can submit complaints anonymously or in person, and whether barriers faced by women, migrant workers, or other marginalised groups have been addressed.

Accessibility is rightly included among the effectiveness criteria for grievance mechanisms set out in UNGP 31. A grievance mechanism that rightsholders do not know about or cannot safely or practically reach is of little value. However, accessibility alone is not sufficient to determine whether a grievance mechanism is effective. 

I argue that as companies seek to demonstrate progress on human rights due diligence, there is a risk that accessibility is becoming an end in itself when assessing the effectiveness of grievance mechanisms. Accessibility is comparatively visible and measurable: companies can establish hotlines and digital reporting platforms, translate them into multiple languages, conduct awareness-raising activities, and report how many rightsholders have been exposed to them. Digital technologies have made such systems easier to scale, while developments in AI are making multilingual communication and complaint intake increasingly feasible.

Effective remedy, by contrast, is considerably more difficult to measure. It may require a supplier to repay wages, reinstate a worker, clean a polluted river, change management practices, or address sexual harassment in its operations. It may also require a buyer company to exercise leverage over a supplier, reconsider its own purchasing practices, or intervene in arrangements that sustain existing power relations within the supply chain. These actions are harder to standardise and measure, but are more likely to challenge the status quo.

Thus, there is a risk that accessibility becomes a proxy for effectiveness: a mechanism may appear successful because rightsholders know about it, while far less attention is paid to whether submitted complaints actually lead to an outcome. I describe this disconnect between access and meaningful remedial outcomes as the “outcome gap.”

What does the outcome gap look like in practice?

In my ongoing research on non-judicial grievance mechanisms operating across global supply chains, I have examined grievance mechanisms and remedial systems in the automotive sector in Mexico, the garment sector in India, and the agricultural sector in Spain. Across these different contexts, I have looked closely at what happens when rightsholders raise a complaint through these mechanisms. 

Three recurring problems help explain why high levels of reported access to a grievance mechanism do not necessarily translate into effective remedial outcomes.

1. Many complaints never reach the stage of an agreed remedial outcome. 

Cases may be dropped for many reasons: complaints may be declared inadmissible, claimants may become difficult to contact, parties may fail to agree on a suitable outcome, or workers may withdraw because of dissatisfaction, long timelines, or fear of retaliation. The Mexican Mecanismo de Reclamación de Derechos Humanos (MRDH), a cross-company grievance mechanism piloted in the automotive supply chain, illustrates this problem. During its first full year, it received 49 complaints, of which 33 were declared inadmissible. Of the 16 admitted cases, none had reached a concluded and enforced remedial outcome by the time of the evaluation. Six were ultimately resolved through the direct intervention of the mechanism’s local outreach organisation outside its formal investigation and mediation process.

2. Power asymmetries continue to shape both the grievance process and its outcomes. 

Workers may be entering a process involving an employer on whom they depend for their livelihood, a buyer company with far greater resources, or administrators they do not perceive as neutral. These inequalities can affect whether claimants remain in the process, whether they feel able to articulate the remedy they want, and whether they feel pressured to accept an inadequate outcome. In Mexico, workers reported fears of retaliation not only from their immediate employers, but also from future employers, state actors and organised crime. In southern Spain, workers often placed greater trust in local civil society actors with whom they shared language, familiarity, or similar backgrounds than in the formal grievance mechanisms available to them. Where positive outcomes were reported, they were often achieved through the efforts of these actors working around the mechanism rather than through the mechanism itself.

3. Even where a remedy is agreed upon, implementation and sustainability remain significant challenges. 

Enforcement often depends on the willingness of companies or suppliers to follow through, while claimants have limited leverage to ensure that agreed outcomes are implemented. Furthermore, resolving an individual complaint does not necessarily address the conditions that produced it. Repaying withheld wages may remedy one worker’s grievance without preventing the practice from recurring; addressing an individual case of harassment may leave the workplace practices that enabled it unchanged.

The outcome gap emerges when high levels of reported accessibility are not matched by cases reaching satisfactory remedial outcomes for claimants. I argue that both accessibility and remedial outcomes should be treated as performance indicators when assessing the effectiveness of a grievance mechanism. Otherwise, grievance mechanisms risk becoming proxy tools that demonstrate rightsholder engagement whilst perpetuating existing harm. 

The outcome gap is not merely theoretical: workers who receive no meaningful outcome or only delayed, superficial responses without effective implementation or monitoring are far less likely to use the mechanism again.

Peer-to-peer communication plays a central role in shaping perceptions of accessibility. Workers regularly share experiences and information with one another about whether and how grievance mechanisms function in practice. As a result, the reputation of a mechanism is strongly influenced by the experiences of those who have used it. 

My research on the Dindigul Agreement to End Gender-Based Violence and Harassment in India showed what a much stronger focus on outcomes can look like. Its grievance mechanism, implemented by the Tamil Nadu Textile and Common Labour Union, a local, women-led and majority-Dalit trade union, demonstrated consistently high rates of timely complaint resolution. In its first year, 98% of grievances were resolved, with 20% resolved within a single day. By the second year, 76% were being resolved within two weeks, and independent monitoring through the Agreement’s third year found that more than three-quarters of complaints continued to be resolved within that timeframe. 

The Dindigul Agreement demonstrates that successful, visible outcomes break down workers’ initial skepticism regarding a mechanism. Workers who see the mechanism deliver satisfactory outcomes share their experience informally with colleagues and this peer validation drives greater use of the mechanism. This in turn produces more resolutions and further strengthens accessibility and awareness. 

What needs to change?

Closing the outcome gap means understanding accessibility as both a facilitator and a beneficiary of meaningful remedial outcomes, rather than as an end in itself.

A mechanism improves its accessibility when workers have reason to believe that grievances will be taken seriously, processes will be fair, and remedial outcomes will be meaningful and sustained. 

The rapid growth of digital grievance tools and hotlines has made it increasingly easy to demonstrate that a mechanism exists and can be accessed across different parts of a supply chain.

As due diligence legislation drives further expansion of these systems, policymakers should ensure that the indicators used to assess grievance mechanisms are centred on remedial outcomes: whether grievances are resolved, whether remedies are implemented, and what happens when companies or suppliers fail to deliver them. Where agreed remedies are not implemented, due diligence frameworks should provide for meaningful escalation and consequences.

For companies, remedial outcomes should likewise become a core effectiveness KPI for grievance mechanisms. This should not, however, be interpreted as a call for immediate high resolution rates or for incentives that encourage cases to be closed simply to improve performance figures. Building trusted mechanisms and addressing complex grievances takes time, particularly across fragmented and multi-tiered supply chains. Where companies are genuinely committed to remedy, the ability to deliver meaningful outcomes must remain the goal against which a mechanism develops and is ultimately assessed.

This matters because grievance mechanisms emerged in response to a deeper problem: workers and communities experiencing serious harms in global supply chains have had few effective avenues through which to seek remedy. The implementation of grievance mechanisms should therefore be judged against that purpose. Grievance mechanisms should not become another compliance requirement that can be satisfied by demonstrating the existence of an accessible channel, or a growing market for sophisticated complaint-intake systems, while the harms those mechanisms were created to address remain unresolved.

Mareike Standow, LL.M., is an expert in business and human rights with a specialisation in grievance mechanisms. As a research fellow at the European University Viadrina, she leads a Deutsche Forschungsgemeinschaft(DFG) funded research project on grievance mechanisms and vulnerable groups. Her research focuses particularly on vulnerability and the role of gender within the context of grievance mechanisms and human rights due diligence.