Does your company, its subsidiaries, or its suppliers operate in conflict-affected areas? And how can you know whether those operations are contributing to, or insulated from, the harms created by conflict itself? It is self-evident that the very risks inherent in conflict situations make it more difficult for companies to obtain the information they need to assess the human rights risks and impacts of their operations. The complexities of doing so were laid out at the UN Forum on Business and Human Rights in October 2025.
The Forum heard that the “small universe” of ESG data providers is failing to capture grassroots dynamics in conflict zones in ways that meet investor needs — and that some providers may even be withdrawing from this work altogether, often under political pressure. Dan Neale from the Investor Initiative on Human Rights Data described how it is becoming increasingly difficult to access data relating to conflict and harm. He explained how the investor network has responded by identifying information gaps and working with MSCI and other ESG data providers used by investors, with the aim of narrowing those gaps, saying, “It is a genuine challenge to double down despite the complexities.”
Mauricio Lazala, Head of the Office of the High Commissioner for Human Rights, made the case for why sourcing such information is essential. “Human rights due diligence is inherently context-specific, which is why it must be enhanced in conflict-affected areas. It is challenging to get the information, but it is always necessary. Ask people directly affected, but also engage with several partners, including their representatives, experts, business partners, NGOs, and legitimate trade union federations. There is no escape from painstaking and detailed heightened human rights due diligence, and from treating each case independently, as each is different. You have to do your homework.”
Sam Jones from the U.S.-based Heartland Initiative, which describes itself as working to close data gaps between rights-holders, civil society organisations, and investors, reinforced the message that local collaboration remains key. “Don’t just think of headline conflicts like Israel–Gaza, Russia–Ukraine, or the Democratic Republic of Congo, but of the 60–70 conflicts with high to severe conflict risk worldwide. It’s not just about headlines; conflict is systematic,” Jones explained. “Political sensitivity over Gaza leaves companies inactive or reactive, playing Whac-A-Mole.”
He cited recent Heartland Initiative research with investor Schroders, which demonstrated the “saliency–materiality nexushttps://www.schroders.com/en-us/us/non-resident-clients/insights/the-saliency-materiality-nexus/”: the higher the human rights risk in an investment, the higher the financial risk. The study’s twelve case examples showed a combined $85 billion in financial risk, ranging from litigation and share-price losses to revenue decline. Risk to a company was also shown to vary greatly depending on location and the nature of its activities. “This needs more of a scalpel and less of a sledgehammer,” Jones said. “For example, after the coup in Myanmar, there was a long list of multinational companies operating in the country. However, proximity to harms on the ground can differ significantly between, for instance, an agribusiness and a fuel pipeline provider. The risks are very different.”
It is not unusual at the Forum to hear calls for companies and investors to ally with civil society organisations. In conflict-affected areas, however, it was argued that such collaboration is even more important and — despite the obstacles — always possible. “The human rights implications of a mining company in critical minerals, or an arms supplier operating in a conflict situation, will never be found on a public website or in publicly available reports. They can only be identified through information gathered on the ground,” Jones said.
He argued that heightened human rights due diligence in conflict zones requires companies to demonstrate that they have devoted additional resources to understanding on-the-ground dynamics. He pointed to partnerships with specialist conflict-risk organisations, such as Geneva-based Trustworks Global, as one potential approach.
A delegate from the Geneva Centre for Security Policy observed that while there had been extensive discussion of conflict and risk, there had been far less focus on peace. The consensus was that companies can contribute to peacebuilding in multiple ways — for example, through preferential employment practices for former combatants following the end of Colombia’s civil war.
However, due diligence remains a foundational tool to help companies mitigate and prevent harm. It may be only a starting point, but it represents the minimum required by respect for human rights. If companies cannot hope to solve all the world’s problems on their own, they can at least seek to ensure they are not making matters worse — the simple aim of “doing no harm”.
This article concludes a three-part series from the UN Forum on Business and Human Rights 2025 for Sustainable Brands by Richard Howitt. Previous articles explored why every business must now examine the ethics of artificial intelligence (Now every business will have to examine the ethics of Artificial Intelligence) and why silence on diversity, equity, and inclusion is no longer an option (DEI Silence Is Not an Option).
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Richard Howitt is a strategic adviser on Corporate Responsibility and Sustainability, Business and Human Rights. He is also a Board member, lecturer at Audencia Business School and host of the Frank Bold ‘Frankly Speaking’ responsible business podcast. Richard was Member of the European Parliament responsible for the EU’s first rules on corporate sustainability reporting and subsequently Chief Executive Officer of the International Integrated Reporting Council.
Published Jan 5, 2026 4am EST / 1am PST / 9am GMT / 10am CET