Follow the relationship. Protect the people.

Two lenses on the same relationship

An intermediary can create more than one kind of risk. A recruitment agent may arrange workers, charge improper fees and use opaque payments to obtain access. A supplier may present acceptable documents while relying on labour practices that purchasing teams never see.

Anti-corruption and human rights reviews should share relevant information, but they should not be reduced to one undifferentiated score. Corruption analysis examines improper influence, benefits and related control weaknesses. Human rights analysis considers adverse effects on people. The priorities may differ even within the same relationship.

The OECD’s 2021 Anti-Bribery Recommendation updates good-practice guidance for company internal controls, ethics and compliance programmes. Separately, the UN Guiding Principles frame business responsibility around respecting human rights, including due diligence and appropriate responses to impacts. These are reference frameworks; applicable legal duties still depend on the relevant jurisdictions.

References: UN Guiding Principles overview; OECD 2021 Anti-Bribery Recommendation overview.

Look beyond the questionnaire

A questionnaire can organise a review, but its answers require context. Ask why the third party is needed, what it actually does, how compensation is calculated and whether its capacity matches the proposed work. Unexplained complexity deserves attention rather than a quick assumption that the paperwork is sufficient.

For corruption exposure, examine unusual payment arrangements, vague deliverables and undisclosed relationships that may affect decisions. A warning sign does not prove misconduct. It identifies something to resolve before relying on the relationship.

For human rights exposure, ask whose experience is missing. Workers supplied by an agency may face conditions that permanent staff never encounter. Consider safe ways to understand recruitment, pay, working conditions and access to concerns channels. Do not rely solely on a manager speaking on behalf of potentially affected people.

Respond to harm, not just reputational exposure

The UN Guiding Principles distinguish impacts a business causes, contributes to or is directly linked to through a business relationship. The appropriate response depends on that relationship to the impact. Where a business causes or contributes to harm, remediation is part of the responsibility; direct linkage calls for prevention or mitigation through the relationship.

In practical terms, do not make contract termination the automatic answer to every difficult finding. Consider whether an abrupt exit could worsen the situation for affected people, while recognising that some relationships may need to be suspended or ended. Involve appropriate specialists when safety, criminal conduct or serious rights impacts are in question.

Set an action owner, a timetable and evidence that reflects the actual problem. A revised policy is not sufficient evidence that workers have recovered withheld documents or received money owed to them. Follow-up must connect to the experience of the people affected.

References: UN Guiding Principles overview; OECD 2021 Anti-Bribery Recommendation overview.

Keep watching after approval

The risk picture changes when a supplier subcontracts, ownership changes or volumes increase sharply. A review completed at onboarding should not become a permanent assurance label. Agree triggers for reconsidering the relationship and ensure business owners know how to report a material change.

Bring purchasing practices into the discussion. Very short lead times and unrealistic pricing can create pressures that a supplier questionnaire will not fix. That does not excuse misconduct; it identifies a condition the organisation can influence.

Report corruption and human rights findings with enough separation to preserve their meaning. A relationship can have a modest financial value and still involve serious harm. Management should see the issue, the affected people, the response and what remains unresolved—not just a colour assigned to a vendor.

Put it into practice

1. Map what one high-exposure intermediary actually does.
2. Identify potentially affected people and a safe way to hear their experience.
3. Separate corruption findings from human rights impacts in the decision record.
4. Define follow-up evidence that demonstrates the underlying issue has changed.