Accounting for human rights: Evidence of due diligence in EU-listed firms’ reporting

This paper investigates the extent and the strategies of human rights due diligence (HRDD) disclosure by the largest 100 EU-listed firms. Our work is performed at a key point in time when institutional expectations to conduct HRDD are building, allowing us to assess firms’ readiness for emerging and forthcoming legally binding regulation in the EU. To analyse corporate disclosures, we develop a scoring tool based on the United Nations’ Guiding Principles on Business and Human Rights (UNGPs). We interpret our findings building on Oliver’s (1991) theoretical framework of firms’ strategic responses to institutional pressures, as adopted in the context of social and environmental accounting and integrated with concepts from the literature on substantive and symbolic disclosure approaches. Our contributions advance the understanding of the ways that firms are engaging with the HRDD issue and the state or level of their engagement. We reveal three key HRDD disclosure strategies: dismissal, concealment, and compliance. The presence of the dismissal category is particularly significant, implying weak engagement with HRDD for many firms in our sample. Furthermore, we find that while many firms have a talk-orientation, where they communicate a commitment to protect human rights, the extent to which disclosures are action-oriented and detail the key practice of HRDD is significantly neglected. Important implications also follow for policymakers as our results can enhance the capability of new regulation to better enforce a strategic engagement outcome.