Human Rights Due Diligence in the UAE and GCC: From Obligation to Opportunity
The Gulf region is at the centre of the global debate on human rights and corporate accountability. With migrant workers forming the majority of the labour force across the GCC, questions about recruitment practices, fair wages, and living conditions are inextricably linked to business operations. Against this backdrop, Human Rights Due Diligence (HRDD) in the UAE and GCC has become a defining priority for companies that wish to remain compliant, competitive, and credible.
HRDD is about avoiding legal penalties while protecting workers, strengthening resilience, and earning the trust of international investors and partners.
Why HRDD Matters in the GCC
Across the six GCC countries, the UAE, Saudi Arabia, Qatar, Oman, Bahrain, and Kuwait, migrant workers are indispensable to economic growth. In some states, foreign nationals represent over 80% of the workforce. This reliance creates unique vulnerabilities around recruitment, working conditions, and worker welfare.
International frameworks, such as the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises, emphasise that businesses must conduct Human Rights Due Diligence in the GCC to identify, prevent, and mitigate the risks of human rights abuse.
Failure to do so can result in reputational damage, investor scrutiny, and exclusion from global supply chains. With the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) and mandatory reporting rules in place, the pressure on GCC-based companies and multinationals operating in the region has never been greater.
Key Risks That HRDD Must Address
Recruitment Fees and Debt Bondage
Many workers from sending countries such as India, Nepal, and Bangladesh pay high recruitment fees to secure jobs. This often leads to debt bondage.
Effective HRDD in the UAE and GCC requires verifying that recruitment agencies comply with zero-fee policies.
Contract Substitution and Transparency Issues
Workers are sometimes promised certain salaries or roles before departure, only to face downgraded contracts upon arrival.
Rigorous HRDD processes protect against deceptive practices by requiring contract audits and multilingual worker engagement.
Wage Theft and Delayed Payments
Deducting hidden costs or delaying salaries creates financial vulnerability.
Companies conducting Human Rights Due Diligence in the GCC should audit payroll systems and enforce grievance mechanisms.
Living and Working Conditions
Accommodation, health, and safety remain key concerns. Inadequate housing or unsafe work sites endanger workers and expose companies to reputational crises.
HRDD Progress in the UAE and GCC
The region has made notable strides.
The UAE has introduced legislation mandating private and public companies to disclose their emissions and sustainability data, with human rights increasingly becoming part of compliance frameworks.
Saudi Arabia’s Vision 2030 includes reforms on labour mobility and worker protection, signalling a shift toward more transparent governance.
The Abu Dhabi Dialogue (ADD) has emerged as a multilateral platform connecting GCC states with migrant-sending countries to promote safe and fair recruitment.
Still, implementation challenges remain. Regulations are evolving, enforcement is uneven, and cultural practices sometimes delay progress. This is why structured HRDD, led by businesses themselves, is vital.
How Companies Can Conduct Effective HRDD in the UAE and GCC
Policy Commitment
Publicly commit to human rights and embed HRDD into codes of conduct and supplier agreements.
Risk Assessment
Map high-risk areas, including recruitment channels and subcontracted labour.
Engage directly with workers in multiple languages to understand risks.
Monitoring and Auditing
Conduct independent audits of recruitment agencies and supply chains.
Use digital tools for worker feedback and contract verification.
Grievance Mechanisms
Provide safe, anonymous, and accessible channels for workers to raise concerns.
Ensure follow-up with transparent reporting of remediation steps.
Remediation
Where recruitment fees have been paid, companies must design repayment mechanisms.
Partner with NGOs and international bodies to implement corrective action.
Business Case for HRDD in the GCC
Investor Confidence: ESG-minded investors require proof of ethical labour practices. Demonstrating strong HRDD practices in the UAE and GCC opens doors to international capital.
Operational Continuity: Addressing human rights risks reduces disruptions such as strikes, worker shortages, or reputational crises.
Legal Compliance: HRDD aligns with upcoming global directives, ensuring companies are prepared for audits and disclosure requirements.
Brand Value: Transparent HRDD fosters consumer trust, particularly in the hospitality, retail, and construction sectors.
Case Studies of HRDD in Action
Recruitment Fee Repayment in the UAE: A multinational identified migrant workers who had paid recruitment fees and implemented a repayment plan aligned with ILO guidelines.
Human Rights Impact Assessment in Oman: A metals company reviewed contractor practices by visiting worksites and accommodations to ensure alignment with local laws and international standards.
Hospitality Sector Risk Assessment: A hotel chain operating in the UAE and Saudi Arabia conducted multilingual worker interviews and trained 200 managers on responsible labour practices.
These examples demonstrate how Human Rights Due Diligence in the GCC transitions from compliance to practical, measurable change.
The Future of HRDD in the UAE and GCC
Looking ahead, HRDD will become inseparable from broader ESG agendas in the region. Companies that treat human rights as a core part of their business strategy will be better positioned to attract investment, secure partnerships, and build long-term resilience.
As GCC countries introduce stricter regulations and global supply chains demand ethical assurance, businesses that proactively embrace Human Rights Due Diligence in the UAE and GCC will lead the way in building ethical, sustainable, and profitable futures.
The Gulf’s reliance on migrant workers makes human rights due diligence non-negotiable. For companies, HRDD is no longer a box-ticking exercise but a strategic pathway to competitiveness and credibility. By embedding HRDD into governance, recruitment, and supply chains, businesses protect their workers and secure their own future in a global market where sustainability and responsibility are inextricably linked.