Stakeholder Engagement Guide  

Introduction

This guide was developed to guide implementing organization teams through the second stage of our risk assessment process. It focuses specifically on the sugarcane and ethanol sector, encompassing national, regional, and local levels. 

Human rights risk assessment (HRRA) is a fundamental process for human rights due diligence (HRDD). While stakeholder consultation is part of all stages of HRDD, this guide delves specifically into the "Identify and Act," "Integrate," and follow-up/monitoring of implementation, which are directly linked to HRRD. 

There is no one-size-fits-all approach to stakeholder engagement. However, this document presents some key principles to help mills and companies deepen their understanding of human rights issues and impacts. Engaging with relevant stakeholders is crucial to enriching our understanding of important issues and their causes, helping to ensure that risks do not become impacts. 

Note on Root Cause: During ARDH, it is common to discuss human rights issues and their symptoms. In our assessments, we seek to go beyond identifying the superficial causes of a problem, exploring the deeper causes to determine actions/solutions that can systematically mitigate and prevent current and potential problems.

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Key Terms (Interested Parties, Rights Holders & Representatives) 

INTERESTED PARTY

A stakeholder can be a person, group, or organization that has an interest in or can affect a business or its activities, as well as those who may be impacted by it.

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RIGHT HOLDERS

All people are rights holders. However, in this context, the focus is on female rights holders who are particularly vulnerable to adverse impacts.

REPRESENTATIVES

Prosecutors can be representatives (formal or informal) of affected groups or human rights experts. For example, NGOs, trade unions, community organizations, or international organizations.

Steps for stakeholder consultations 

Stakeholder consultations can be divided into four main stages: 

Identification of Relevant Stakeholders

Mapping and prioritizing stakeholders for engagement

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Planning

Consider times, formats and content.

Query Content Planning

Assessment teams may need to tailor each engagement to the specific needs of relevant stakeholders. Therefore, rather than a fixed set of questions, this guide proposes three main steps to guide consultations: 

Engage with stakeholders

Reach and interview

Analyze the results and include the analysis

Review the data and include it in the full ARDH report

Identifying relevant stakeholders for the consultation

While it would be ideal for our teams to consult directly with a wide range of relevant rights holders, this is not always feasible or appropriate. The UN Guiding Principles (UNGPs) recognize that companies further down the chain, in particular, may need to rely on engagement with representatives to gain insights into risks and issues further up the chain. 

It is important to consult with a variety of rights holders and their representatives in the sugarcane industry. In many cases, it is not feasible or appropriate to directly involve each individual, so we rely on trusted representatives, such as local unions, smallholder associations, or Indigenous Peoples and Local Community (IP&LC) organizations. 

Identifying these stakeholders should begin with the initial mapping of the Human Rights Risk Assessment (HRA) desk review. However, additional research may be needed to fill gaps and ensure all relevant voices are considered. Consultation selection should prioritize the three most vulnerable groups in the sector: workers , communities , and smallholders . 

For each assessment, the implementing organization should aim to conduct at least 8 to 10 consultation groups. The exact number should be adjusted based on the risks and issues prioritized in the document review. If there are several salient issues across different topics, it may be necessary to increase the number of consultations, taking into account the project budget. 

For example, if three distinct issues have been identified—child labor, Indigenous peoples' land rights, and smallholder livelihoods—it may be necessary to consult with more than 10 stakeholders. 

For stakeholder selection to be effective, several key factors must be considered. The goal is to create a diverse group that offers broad and balanced perspectives on the topic. 

  • Knowledge and Experience: Prioritize people and organizations that have specific knowledge about the issues at hand and the geographic area of ​​the project. 

  • Representation: Ensure participation from a diverse mix of relevant groups, such as unions, NGOs, business associations, and community representatives. 

  • Bias and Power Relations: Be aware of potential biases or power imbalances. For example, when consulting with government agencies or industry groups, consider how their opinions may be influenced by your positions and interests. Seek to balance these perspectives with those of more vulnerable or underrepresented groups. 

  • Prioritization: Given time and budget constraints, prioritize stakeholders based on the most pressing issues identified in the project. 

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Planning

Good planning is essential to ensure effective consultations and useful information. These consultations are also an opportunity to establish or strengthen relationships with key stakeholders. 

For consultations to be successful, the following points must be considered: 

  • Timing: Consultations should be scheduled during periods that allow for stakeholder participation. Avoid holidays, elections, or other sensitive dates that could compromise safety or participation. In the sugarcane industry, it is strategic to align the schedule with the sugarcane cycle. Schedule consultations with workers at the beginning or end of the harvest, and with the mill's internal team or small producers outside of this period. 

  • Location and Format: In-person meetings are ideal, but if these aren't feasible, consultations can be conducted virtually. Discuss the budgetary implications of any required travel with the project team. Meetings can be individual or group, depending on the context. Other formats, such as questionnaires or telephone interviews, can also be considered. 

  • Content: Consultations should be semi-structured . Questions should be flexible, allowing for adaptation to the responses and the flow of the conversation. Below, we detail the steps to guide the content of consultations (see below).

Validate results of document analysis 

  • Validate results of document analysis 

  • Validate with the stakeholder the issues identified as salient in the document analysis 

  • Confirm which activities or actions are causing or contributing to risks or impacts 

  • Check which groups are most at risk 

  • Identify and confirm where data gaps persist 

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Gather information about opportunities for action 

  • Stakeholders can provide relevant input on types of interventions and opportunities to address the salient issues identified (e.g., anti-child labor initiatives, smallholder livelihood programs, coalitions of organizations to address forced labor). 

  • These suggestions will be useful for developing the most appropriate combination of actions (within the plant's operations and/or together with other actors within or outside the chain). 

  • After identifying actions to eliminate or mitigate risks, it is important to consider which ones are feasible to implement in the short and medium term (suggested period of up to 1 year), considering the context is not conducive to their implementation.

Monitor and validate the action plan 

  • Obtain feedback on the effectiveness of implemented actions and validate the relevance of the action plan (action plan link). This allows you to adjust the strategy as needed, ensuring that interventions effectively address risks. 

Stakeholder Engagement

During consultations, it's crucial to be transparent about the scope of the evaluation and how the input will be used. This is crucial to establishing trust and credibility.

If your team lacks the necessary knowledge or experience to conduct these consultations, or if there are sensitive issues or conflicts of interest, consider enlisting the support of external consultants or specialized organizations. This can ensure greater neutrality in the process and protect the implementing organization from direct association with the identified risks.

If stakeholders are unfamiliar with this type of work, take a moment to present your process and objectives, setting expectations. Be clear about your role and your intention to use the evaluation to guide action, but be cautious with your language. Don't make commitments to support specific interventions or fund projects, as this can raise undue expectations.

Note on the outcome of stakeholder participation:

It's important for stakeholders to feel their voices have been heard. Budget planning should include some form of feedback to each person/organization consulted, at least by email. This may include a summary of our understanding of their inquiry and a request for confirmation or additional questions.

Analysis of Results and Integration of Conclusions

A robust risk assessment follows a logical and sequential flow. Document analysis and literature review are the first steps in identifying preliminary risks. The goal of stakeholder consultations, which follow, is to validate or refute these initial findings. Field engagement allows for the collection of information that contextualizes risks and helps understand the actions that lead to them. 

After fieldwork, it's essential to combine the information obtained from the consultations with the data from the document analysis, integrating and verifying the findings. For example, if the document analysis revealed information that has been widely refuted by stakeholders, this may indicate that the previous data is no longer valid. 

Below is the sequence to guide analysis and decision-making: 

 

  1. Literature review : Survey of risks and issues based on secondary sources. 

  1. Risk assessment : Identification of risks together with the plant. 

  1. Stakeholder Validation : Field consultations to validate or refute the risks raised and deepen understanding of the causes. 

  1. Analysis and consolidation : Bring together data from document analysis and consultations to form a robust conclusion. 

  1. Prioritization : Use a risk matrix to prioritize the most salient issues. 

  1. Root cause analysis : Deepen understanding of the factors behind the most critical risks. 

 

Once all findings have been consolidated, the implementing organization must prepare a single Human Rights Risk Assessment (HRA) report. This report should present the findings in an integrated and clear manner, including a heat map illustrating the salience of the risks. 

It is worth remembering that ongoing consultation with stakeholders is essential to monitor the implementation of these actions and validate the effectiveness of the developed plan, ensuring that interventions are relevant and effective over time. 

Deepen understanding of the real causes of risks 

  • Investigate the causes of the identified issues. Go beyond the obvious effects and symptoms to the causes that can be controlled and influenced. 

  • Ask stakeholders what factors are driving the occurrence of certain issues. You may need to ask "why" multiple times to get to the root cause of the risk (root cause link). 

  • The goal is to understand the underlying factors so that the risk is truly eliminated or mitigated.