Issue 70: Seventy Articles Later
What a year of writing about Human Rights Due Diligence (HRDD) taught me.
I actually made it through a full year of writing every week.
A year ago, I hit publish on my first Substack article.
It took me more than six months to get there.
Part of the hesitation was imposter syndrome. Part of it was uncertainty about what would happen if I stepped outside the formal roles I had held for most of my career and wrote in my own voice.
For more than two decades, I had represented government, NGOs, philanthropic organizations, and global companies. I was comfortable writing for executives, boards, policymakers, and business audiences. I knew how to communicate risk, strategy, and business value.
But that kind of writing often leaves little room for personality.
It is polished. Structured. Objective.
Sometimes, if we’re being honest, it can read like a collection of bullet points and talking points.
I wasn’t sure I could write for a broader audience. More importantly, I wasn’t sure anyone would want to read it.
Friends and former colleagues who knew my work encouraged me to try.
They reminded me that I had already started testing the waters. In 2022, long before ChatGPT became a household name, I had published my first public article on a business issue that mattered deeply to me. The experience showed me that there was an audience for thoughtful discussion about the intersection of business, risk, trade, and human rights.
Still, I hesitated.
I remember staring at the screen longer than I care to admit before publishing that first Substack article.
Not because the article was controversial. It wasn’t.
Not because I doubted whether I had enough experience. After twenty years, I had accumulated plenty of stories, failures, and lessons worth sharing.
What gave me pause was something much simpler.
Did I really have something worth saying every week?
Could I continue writing about Human Rights Due Diligence, forced labor, trade policy, risk management, supply chains, governance, remediation, and regulation without repeating myself?
As it turns out, the answer was yes.
The more I wrote, the more questions I discovered.
And today, as I publish my 70th article, that may be the biggest lesson of all.
The deeper you go into this work, the more you realize how much there is still to learn.
It Started With a Simple Goal
When I launched this newsletter, I wasn’t trying to become a content creator.
I wasn’t building a personal brand.
I wasn’t chasing algorithms, followers, or engagement metrics.
I was trying to share what I’ve learned with a growing field of practitioners and business leaders, many of whom are newer to these issues or lack access to practical, in-house experience implementing Human Rights Due Diligence.
As I’ve gotten older, I’ve become increasingly aware that knowledge is only valuable if it is shared. I wanted to write partly to remember, partly to reflect, and partly to help build a global community of practitioners so that fewer people have to start from scratch.
When I began my career, this type of practical guidance simply didn’t exist.
There were frameworks, principles, and aspirations. But there was no roadmap for implementation.
The field was still being built. We were defining Human Rights Due Diligence in real time, testing ideas, learning from failures, and trying to solve problems that often felt impossible.
A few years ago, during an interview for a CEO role at a global impact firm, I was asked a question that caught me off guard:
“Do you consider yourself a risk taker?”
I remember pausing.
The question puzzled me because, from my perspective, meaningful progress requires risk.
If you want to improve systems, challenge assumptions, or create something better than what exists today, you have to be willing to take risks. You have to be willing to hear “no.” You have to be willing to fail.
Needless to say, I didn’t get the job.
But the question stayed with me.
Throughout my career, my goal has always been the same: to help organizations reach a higher standard than where they are today. That requires curiosity, experimentation, and a willingness to work through what I often think of as the messy middle, the space between ambition and execution where most real change happens.
That messy middle is where practitioners spend most of their time.
How do you convince a reluctant executive to invest in worker engagement?
How do you prioritize risks when everything feels urgent?
How do you build governance structures that survive organizational change?
How do you know whether your efforts are actually improving outcomes for workers?
These are rarely the questions discussed in conference keynotes or sustainability reports.
They are the questions being debated in team meetings, hallway conversations, and overly long calls between practitioners trying to figure things out.
I wanted to bring those conversations into the open.
So every week, I sat down and wrote about a question I was hearing from clients, colleagues, peers, or sometimes asking myself.
One article became five.
Five became twenty.
Twenty became fifty.
And now, somehow, seventy.
What I Was Really Writing About
When I started this newsletter, I intentionally focused on Human Rights Due Diligence (HRDD).
Partly because it was the area where I had spent much of my career, and partly because narrowing the scope felt manageable. Human rights is a broad field. HRDD provided a framework through which I could explore the issues I was seeing in practice.
Over the past year, I wrote about the business case for human rights, HRDD implementation, forced labor, trade policy, impact litigation, governance, worker voice, grievance mechanisms, social audits, and artificial intelligence.
Some articles were tactical.
Some were strategic.
Some were written in response to new regulations or emerging trends in real-time.
Others were sparked by conversations with colleagues, clients, workers, advocates, and business leaders trying to navigate increasingly complex challenges.
But somewhere around article forty, I started to notice a pattern.
No matter what topic I sat down to write about, I kept returning to the same place.
I wasn’t really writing about compliance.
I was writing about decisions.
Specifically, the decisions organizations need to make to do the work or make when there isn’t an obvious right answer.
What happens when trade policy and human rights objectives point in different directions?
What happens when a supplier is strategically important but repeatedly fails to improve?
What happens when a company discovers serious risks through a human rights impact assessment and realizes that addressing them will require significant investment, organizational change, or difficult conversations internally?
What happens when leaders genuinely want to do the right thing but struggle to translate commitments into action or it isn’t a Board priority?
Those are the questions that fascinate me most.
Because after two decades in this field, I’ve learned that most of the hard work begins after the assessment is completed, the audit is finished, or the report is published.
A risk assessment or social audit doesn’t improve working conditions.
A policy doesn’t prevent forced labor.
A disclosure doesn’t create remedy.
Those tools are important. They help us understand where the problems are and what needs attention.
But they don’t make decisions.
People do.
What I’ve come to appreciate is that these decisions happen within organizations that are constantly managing tradeoffs. Budgets are finite and determined a year in advance. Growth targets matter. Customers have expectations. Investors demand results. Regulations evolve. Operations need to keep moving.
Human rights practitioners often work at the intersection of these competing priorities, translating commitments into decisions that can withstand the realities of business while still improving outcomes for people.
That is why I have always been drawn to the implementation side of this work. This is where things get messy. Where leaders are forced to make difficult decisions with imperfect information. Where competing priorities come into focus. And where time reveals whether commitments were simply words on paper or catalysts for meaningful action.
It is also where my strength lies. I have always been able to look at a situation and sense, fairly quickly, whether something will hold in practice or fall apart under real-world conditions. Not in theory, but in execution.
Looking back, I think that is why I kept writing.
Every article was really an attempt to explore the same question from a different angle:
How do organizations make better decisions for their business, people, and communities?
In the end, Human Rights Due Diligence is not simply a compliance exercise. It is a discipline of learning, prioritizing, and acting.
And the organizations that make the greatest progress are the ones willing to make difficult decisions when the path forward is unclear, the incentives are misaligned, and the stakes extend far beyond the business itself.
I started this newsletter thinking I would spend most of my time writing about HRDD.
Instead, I found myself writing about leadership.
My Perspective on Audits Changed
Before I started this newsletter, I rarely questioned the role of social audits. In most corporate programs, they were treated as a standard component of responsible business practice. A required step. A familiar control.
When I began writing, I assumed audits would continue to sit at the center of how companies manage human rights risks. In many organizations, they still do.
But over the past year, through conversations with business leaders and practitioners and through reflecting on years of implementation experience, my view has evolved.
The question that interested me less over time was whether audits are “good” or “bad.”
That framing is not especially helpful in practice.
Audits are a tool, not a system.
They can help companies identify certain types of issues. They can improve visibility into parts of a supply chain. And they can create a documented baseline of conditions at a point in time.
All of that is useful.
But they do not, on their own, drive performance improvement.
They do not change purchasing decisions.
They do not strengthen supplier relationships.
They do not improve worker access to voice or remedy.
And they do not resolve the governance and incentive challenges that often sit behind recurring issues.
A simple way to think about it is this: an audit can tell you where problems may exist, but it cannot fix the conditions that create those problems in the first place.
The more I have focused on implementation, the clearer this distinction has become.
The real question is not whether audits “work.”
It is whether companies are using them appropriately within a broader due diligence system.
In practice, audits are most effective when they are one input among several, alongside worker engagement, grievance mechanisms, responsible purchasing practices, and strong internal governance.
Used in isolation, they can create a false sense of control or completeness. I share some of these limitations in Issue 49.
Used as part of a broader system, they can be valuable.
That distinction matters for any business trying to move from monitoring compliance to improving outcomes.
Governance Emerged as the Quiet Hero
One of my earlier and most read articles explored a deceptively simple question: Where human rights should sit inside a company?
When I started writing this newsletter, I expected supply chain and operational issues to dominate my thinking. That is where much of the field’s attention sits, and where many of the most visible risks show up.
Instead, governance kept coming up.
Over time, I began to see a pattern that changed how I understand performance in this space.
Many issues that are described externally as “zero-tolerance” or “high-risk” human rights non-compliance point, in practice, to governance failures inside organizations.
When no one is clearly accountable, progress slows.
When escalation pathways are unclear, risks remain unresolved.
When incentives are misaligned across functions, even well-designed programs can lose momentum.
And when there is no accountable leader or leadership is not directly engaged, responsibility tends to drift downward until it sits with teams who do not have the authority, budget, or decision rights to act.
This is where external stakeholders often misunderstand the problem.
Governance cannot be outsourced.
It cannot be solved by auditors, consultants, NGOs, or regulators.
Those actors can inform, pressure, advise, and hold companies to account. That role is important.
But they cannot create internal ownership.
Only companies can do that.
And more specifically, only in-house leadership and practitioners can enforce and sustain the governance structures that determine whether human rights commitments translate into action.
Over time, this changed how I evaluate programs.
The strongest systems I have seen are not defined by a single tool, policy, or initiative. They are defined by whether the organization has built clear accountability for decisions, and whether leadership is actively engaged in the tradeoffs those decisions require.
Governance is what makes that possible. If you want to learn more about building governance, you can check out Issue 42.
It defines ownership. It shapes incentives. It determines how issues move through the organization. And it ultimately decides whether human rights is integrated into core business decision-making or remains a parallel process managed at the edges.
That is why governance has become one of the most consistent themes in my work, even though I did not set out to focus on it.
Technology Changed the Conversation
A year ago, most conversations about artificial intelligence in the human rights field still felt exploratory. Interesting, but somewhat removed from day-to-day implementation.
Over the past year, I became more focused on how AI and machine learning can support due diligence work, not as a replacement for human judgment, but as an enabler of it. Last October, I also used AI to help build a human rights risk identification tool designed to save time, which I made freely available.
I do not believe technology will solve human rights challenges. But I do believe it can meaningfully accelerate progress when it is used to support, not substitute, human decision-making.
Human rights work remains fundamentally human. It depends on judgment, accountability, relationships, and decisions that cannot be automated.
What has changed is the scale and speed of the system around it.
More tools are being developed than ever before to support due diligence, monitoring, reporting, risk analysis, and supply chain traceability. At the same time, more information is being generated, collected, and analyzed faster than at any point in the history of this field. Issue 19 offers some examples.
Millions of data points now flow through audits, surveys, grievance systems, and third-party datasets, increasingly processed through AI-enabled systems.
Worker feedback is also being captured through more channels than ever before.
And regulatory requirements continue to expand in both scope and complexity.
The result is a fundamentally different operating environment for practitioners.
In this context, technology has an important role to play. When applied well, it can help organizations move through this volume of information more effectively, so that human attention is focused where it matters most: judgment, prioritization, and action.
The organizations that learn how to combine increasingly sophisticated tools with strong human expertise will likely be better positioned in the years ahead.
They will be more efficient and more capable of making decisions faster and more consistently, in an environment defined by increasing complexity.
That is my hope for where this is heading: technology that expands capacity without replacing judgment, and that helps organizations act with greater clarity and intent when it matters most.
Final Thought: 70 Articles Later
After seventy articles written in one year, my thinking has become clearer and more grounded.
Human Rights Due Diligence is ultimately about people, not processes.
Worker voice and local expertise remain some of the most underutilized sources of insight available to companies. Direct engagement with local stakeholders is not something to be avoided or outsourced, but something to be strengthened.
Governance determines whether commitments translate into action or remain well-intentioned statements.
Compliance on its own will never be sufficient.
Technology can expand capacity and improve speed, but it cannot replace judgment.
And the organizations that make the most meaningful progress are those willing to learn continuously, rather than search for static or perfect solutions.
As I wrote in 2022, there is no finish line in this work.
There is only the ongoing responsibility to identify risks, engage stakeholders, make decisions, learn from outcomes, and improve over time.
When I started this newsletter, I thought I was creating a space to share what I had learned over the course of my career.
What I did not expect was how much I would continue learning through the process itself.
From readers who challenge assumptions.
From practitioners working inside complex systems.
From executives navigating rising expectations.
From advocates pushing for higher standards.
From clients solving problems with urgency.
And from workers whose experiences keep this work grounded in reality.
Seventy articles later, I find myself more curious than when I started.
That feels like a good place to be.
The younger me would be proud of how far we’ve come.