1. Introduction: Why Human Rights Compliance Matters for Businesses in Türkiye

The relationship between business activities and human rights has evolved from a peripheral ethical concern into a central legal, regulatory, and commercial issue. In today’s globalised economy, companies are no longer assessed solely on their financial performance, but increasingly on how their operations affect individuals, communities, and broader society. Business enterprises can have profound impacts on human rights through employment practices, supply chain management, environmental footprint, data processing activities, and engagement with local communities. As a result, human rights compliance has become an integral component of corporate governance, risk management, and long-term sustainability.

This transformation has been driven largely by the emergence of internationally recognised frameworks, most notably the United Nations Guiding Principles on Business and Human Rights (UNGPs), which established a global standard clarifying the respective roles of states and businesses. The UNGPs articulate that while states have the primary duty to protect human rights, companies bear an independent responsibility to respect them, regardless of the jurisdiction in which they operate (OHCHR 2011). This responsibility extends beyond direct actions and encompasses business relationships, including suppliers, contractors, and other entities within the value chain. Consequently, corporate responsibility is no longer confined to internal operations but has expanded to cover complex and often transnational networks of economic activity.

From a European perspective, the increasing regulatory emphasis on human rights and sustainability has further reinforced this shift. The European Union has progressively moved from soft-law guidance toward more binding regulatory approaches, integrating human rights considerations into corporate reporting, due diligence obligations, and trade relationships. This “smart mix” of legal and policy instruments reflects the EU’s broader objective of embedding human rights standards into global economic governance (EEAS 2025). For companies operating in or trading with the EU, including those based in Türkiye, these developments create indirect yet significant compliance obligations.

Türkiye occupies a strategically important position within global supply chains, particularly in sectors such as textiles, manufacturing, agriculture, construction, and logistics. As a result, Turkish companies are increasingly exposed to international expectations regarding labour rights, environmental standards, and human rights due diligence. Even in the absence of a single comprehensive domestic law dedicated specifically to business and human rights, a multifaceted regulatory environment is emerging. This includes constitutional guarantees, labour and criminal law provisions, anti-discrimination rules, and the growing importance of sustainability reporting frameworks such as the Turkish Sustainability Reporting Standards (TSRS), which require companies to disclose material sustainability-related risks and impacts, including those linked to human rights (KGK 2025).

At the institutional level, Türkiye has established mechanisms that contribute to the protection and promotion of human rights in the business context. The Human Rights and Equality Institution of Türkiye (TİHEK), established under Law No. 6701, plays a significant role in addressing discrimination, examining complaints, and raising awareness of human rights issues (TİHEK 2024/6701). In parallel, international organisations such as the United Nations Development Programme (UNDP) actively support capacity-building efforts and promote the integration of human rights considerations into business practices and public policy (UNDP Türkiye 2023). Furthermore, the OECD’s Responsible Business Conduct framework and its National Contact Point mechanism provide an additional layer of oversight and dialogue, particularly for companies engaged in cross-border activities (OECD 2024).

Against this background, human rights compliance for businesses in Türkiye should not be understood as a purely voluntary or reputational exercise. Rather, it represents a multi-layered compliance framework shaped by international standards, regional regulatory developments, domestic legal structures, and market-driven expectations. Companies that fail to address human rights risks may face not only legal consequences, but also contractual disputes, loss of market access, reputational damage, and diminished investor confidence.

This article argues that the emerging business and human rights landscape in Türkiye reflects a broader global transformation: from a state-centric model of human rights protection toward a more complex system in which businesses themselves are recognised as key actors. In this evolving framework, human rights compliance is not merely a defensive mechanism, but a strategic necessity for companies seeking to operate sustainably and competitively in both domestic and international markets.

2. Conceptual Framework

Any serious discussion of human rights compliance for businesses in Türkiye must begin with the conceptual framework established by the United Nations Guiding Principles on Business and Human Rights. The UNGPs remain the most authoritative and widely accepted global reference point in this field. Endorsed by the United Nations Human Rights Council in 2011, they do not create a new treaty regime; rather, they clarify how existing human rights standards apply in the context of business activity and corporate conduct (OHCHR 2011). Their importance lies in the fact that they transformed a previously fragmented discussion into a coherent governance model that is now used by states, companies, courts, investors, international organisations, and civil society.

At the heart of the UNGPs is the well-known “Protect, Respect and Remedy” framework. This framework is built on three interrelated pillars. First, states have the duty to protect individuals and communities against human rights abuses by third parties, including business enterprises. Second, business enterprises have an independent responsibility to respect human rights. Third, where business-related human rights harm occurs, those affected should have access to effective remedy through judicial and non-judicial mechanisms (OHCHR 2011). This three-pillar structure has also been reinforced in European regional materials, including the Council of Europe’s handbook for legal practitioners, which presents the same architecture as the central organising principle of business and human rights law and policy in Europe (Council of Europe 2018).

The first pillar, the state duty to protect, reflects a fundamental principle of international human rights law: states are the primary duty-bearers. They must take appropriate steps to prevent, investigate, punish, and redress human rights abuse by private actors, including companies. In practice, this means that human rights compliance in the business sphere is not solely a matter of private ethics or corporate choice. It is also shaped by legislation, regulation, adjudication, labour inspection, anti-discrimination enforcement, environmental controls, public procurement rules, and access to justice. The UNGPs make clear that a state may fail in its human rights obligations not only by directly violating rights, but also by failing to exercise adequate oversight over business conduct (OHCHR 2011). This understanding is particularly important in jurisdictions such as Türkiye, where corporate human rights compliance must be read together with the broader regulatory and constitutional environment.

The second pillar, the corporate responsibility to respect human rights, is the normative centre of the business and human rights framework. This responsibility exists independently of the state’s willingness or ability to fulfil its own obligations. In other words, a business enterprise cannot justify harmful conduct by pointing to weak enforcement, regulatory gaps, or permissive local practice. Under the UNGPs, all businesses are expected to avoid infringing the human rights of others and to address adverse human rights impacts with which they are involved (OHCHR 2011). The Council of Europe handbook similarly emphasises that although businesses have not traditionally been treated as direct duty-bearers under international human rights law, the contemporary legal order increasingly requires states to regulate corporate conduct in ways that make business respect for human rights a practical and enforceable expectation (Council of Europe 2018).

This corporate responsibility is broad in scope. It applies to all enterprises regardless of size, sector, ownership structure, or place of operation. However, the way in which a company fulfils this responsibility may vary according to its size, the nature of its activities, the operational context, and the severity of its human rights impacts (OHCHR 2011). This is an important point for the Turkish context. A large industrial exporter, a fintech company processing personal data, a textile manufacturer using subcontracted labour, and a medium-sized agricultural enterprise employing seasonal workers may all be subject to the same underlying responsibility to respect human rights, but the concrete compliance measures expected of them will differ. The principle is universal; the implementation is context-sensitive.

A particularly significant contribution of the UNGPs is their explanation of how companies may be involved in human rights harm. The framework distinguishes between three situations. A company may cause an adverse human rights impact through its own activities. It may contribute to such an impact together with other actors. Or the impact may be directly linked to its operations, products, or services through a business relationship, even where the company has not itself caused or contributed to the harm (OHCHR 2011). This distinction is essential because it determines the nature of the company’s response. Where the company causes harm, it must cease the harmful conduct and provide for remediation. Where it contributes to harm, it must cease its contribution and use its leverage to mitigate the remaining impact. Where the harm is directly linked through a business relationship, the company must seek to prevent or mitigate the impact, typically through leverage, contractual influence, monitoring, engagement, and, where necessary, disengagement. This tripartite distinction is one of the most important doctrinal tools in the entire field of business and human rights.

The UNGP framework also moved the discussion beyond abstract commitments by establishing human rights due diligence as the central operational process through which companies are expected to identify and manage risk. Human rights due diligence is not a one-time exercise and is not limited to a formal checklist. It is an ongoing process through which a business identifies actual and potential human rights impacts, integrates findings into internal decision-making, takes action to prevent or mitigate harm, tracks the effectiveness of its response, and communicates how impacts are addressed (OHCHR 2011). This concept has become the core compliance methodology in the field and has strongly influenced European regulatory thinking, policy guidance, and corporate governance practice. It also aligns with more practical tools promoted by institutions such as UNDP and other business and human rights actors, which increasingly treat due diligence as a necessary component of responsible business conduct rather than a voluntary extra (UNDP Türkiye 2023).

Another key conceptual element is that business and human rights is not confined to labour abuses in the narrow sense. The UNGPs adopt a much wider understanding of human rights impacts. These may include discrimination, unsafe working conditions, forced labour, child labour, privacy violations, harmful environmental exposure, interference with community rights, restrictions on freedom of association, and failures to provide remedy. In other words, the business and human rights field is not a specialised niche affecting only multinational manufacturers in high-risk jurisdictions. It is a framework capable of applying across diverse sectors, including finance, technology, retail, logistics, construction, agriculture, and public contracting. This wide scope is especially relevant in Türkiye, where the human rights footprint of business may arise not only in factories and fields, but also in digital services, surveillance practices, workplace equality policies, outsourcing chains, and consumer-facing operations.

The third pillar, access to remedy, ensures that the framework is not purely preventive or aspirational. Human rights compliance is incomplete if affected individuals and communities have no realistic pathway to challenge abuses and obtain redress. The UNGPs therefore stress that states must ensure access to effective remedy through judicial, administrative, legislative, or other appropriate means, while companies should establish or participate in effective operational-level grievance mechanisms where appropriate (OHCHR 2011). The Council of Europe handbook develops this point further by showing that effective remedy requires more than formal rights on paper; it also requires practical access, institutional capacity, procedural fairness, and mechanisms capable of overcoming the asymmetries that often exist between companies and affected persons (Council of Europe 2018). This aspect is particularly significant for any discussion of Türkiye, where the effectiveness of complaint channels, litigation routes, administrative remedies, and internal reporting mechanisms will be central to the practical meaning of human rights compliance.

For present purposes, one further conceptual clarification is important. Business and human rights should not be confused with corporate philanthropy, general corporate social responsibility, or public relations-driven sustainability language. A company may donate to social causes, support local communities, or publish a sustainability brochure, yet still fail to respect human rights in its workforce, supply chains, or data practices. The UNGP framework is not about image management; it is about preventing harm, managing risk, ensuring accountability, and embedding human rights considerations into governance and operations. This is why the framework has become increasingly relevant not only to human rights advocates, but also to boards of directors, compliance teams, investors, auditors, procurement departments, and legal advisers.

In the Turkish context, this conceptual framework provides the basis for understanding why human rights compliance must now be approached as a structured legal and governance issue. It helps explain how constitutional principles, labour protections, anti-discrimination rules, sustainability reporting standards, public institutional mechanisms, and international market expectations fit together. It also makes clear that even in the absence of a single codified business and human rights statute, Turkish companies may still face substantial compliance expectations through international norms, value chain pressures, investor scrutiny, and evolving reporting duties (KGK 2025), (OECD 2024), (TİHEK 2024/6701).

For all these reasons, the UNGPs are not merely a background reference. They are the conceptual foundation on which the modern law, policy, and practice of business and human rights is built. Any analysis of human rights compliance for businesses in Türkiye must therefore be grounded in this framework before turning to the more specific questions of regulation, due diligence, reporting, supply chains, remedy, and corporate accountability.

3. International and European Normative Sources Relevant to Türkiye

The conceptual framework established by the UN Guiding Principles provides the foundation for business and human rights; however, it is through a broader ecosystem of international and regional instruments that these principles are operationalised, reinforced, and, in some cases, transformed into binding or quasi-binding obligations. For businesses operating in or connected to Türkiye, this normative landscape is not merely theoretical. It has direct implications for compliance, market access, contractual relations, and risk exposure. This section examines the key international and European sources shaping human rights expectations for companies relevant to the Turkish context.

3.1. The UN System: From Normative Framework to Policy Integration

The United Nations system remains the central normative authority in the field of business and human rights. Beyond the UN Guiding Principles themselves, various UN bodies and programmes contribute to embedding human rights standards into economic activity. The UNGPs have been widely adopted as a baseline for policy-making, corporate governance, and international cooperation, forming the backbone of national action plans, corporate policies, and international development programmes (OHCHR 2011).

In this context, the role of development-oriented institutions is particularly significant. The United Nations Development Programme has played an important role in translating abstract principles into practical implementation strategies. Through country-level initiatives, including those in Türkiye, UNDP supports governments, businesses, and civil society in integrating human rights considerations into business operations, public procurement, and development policy. These efforts include capacity-building programmes, guidance materials, and pilot projects aimed at embedding human rights due diligence into corporate practice (UNDP Türkiye 2023). As a result, UNGP-based standards are increasingly reflected not only in legal discourse, but also in operational frameworks and institutional practice.

3.2. ILO Standards: Labour Rights as the Core of Corporate Human Rights Responsibility

Within the international system, the International Labour Organization occupies a central position in defining the content of business-related human rights obligations, particularly in the field of labour. The ILO’s fundamental conventions -covering forced labour, child labour, freedom of association, collective bargaining, and non-discrimination – constitute a core set of internationally recognised labour rights that are directly relevant to corporate conduct.

The importance of ILO standards lies in their practical applicability. While the UNGPs provide a general framework, the ILO offers detailed, sector-relevant guidance on what constitutes acceptable and unacceptable practices in the workplace. This includes issues such as occupational health and safety, fair wages, working hours, and social protection. For companies operating in Türkiye, especially in labour-intensive sectors such as textiles, agriculture, construction, and manufacturing, compliance with ILO standards is not only a matter of legal conformity but also a prerequisite for maintaining relationships with international buyers, investors, and partners.

Moreover, the ILO’s concept of “decent work” reinforces the idea that human rights compliance in business is most visibly manifested in employment relationships. Labour rights therefore represent the most concrete and frequently scrutinised dimension of business and human rights compliance.

3.3. OECD Guidelines and the National Contact Point Mechanism

Another critical pillar of the international normative framework is provided by the OECD Guidelines for Multinational Enterprises. These guidelines set out comprehensive standards for responsible business conduct, including human rights, labour relations, environment, anti-corruption, and consumer interests. Although formally non-binding, they carry significant practical weight due to their institutional support and enforcement mechanisms.

A key feature of the OECD system is the National Contact Point (NCP) mechanism, which provides a platform for addressing complaints related to alleged violations of the Guidelines. In Türkiye, this function is carried out by the National Contact Point operating under the Ministry of Industry and Technology. The NCP offers a non-judicial grievance mechanism that allows stakeholders – including workers, communities, and civil society organisations – to raise concerns about corporate conduct and seek mediation or resolution (OECD 2024).

For businesses, the importance of the OECD system lies not only in the potential outcomes of specific complaints, but also in the reputational and relational risks associated with being subject to NCP proceedings. Even in the absence of binding sanctions, such processes can influence investor perceptions, contractual relationships, and public trust. As a result, OECD standards have become an integral component of the broader compliance landscape for companies engaged in international business.

3.4. The European Union: From Soft Law to Binding Regulatory Influence

The European Union has emerged as one of the most influential actors in the global development of business and human rights standards. While initially relying on voluntary frameworks and policy guidance, the EU has increasingly adopted regulatory measures that incorporate human rights and sustainability considerations into corporate obligations. This shift reflects a broader strategic objective: ensuring that economic activity within and beyond the EU aligns with fundamental rights and sustainable development goals.

The EU’s approach is often described as a “smart mix”, combining binding legislation, policy instruments, and market-based mechanisms. This includes initiatives such as corporate sustainability reporting requirements, due diligence obligations, and human rights clauses in trade agreements. Importantly, these measures are not limited to companies headquartered within the EU. They frequently extend, directly or indirectly, to third-country companies that operate within EU markets or are part of EU-based value chains (EEAS 2025).

For Turkish businesses, this development is particularly significant. Companies exporting to the EU, supplying EU-based enterprises, or seeking European investment are increasingly expected to demonstrate compliance with human rights due diligence standards. In practice, this means that EU norms can function as de facto regulatory requirements, even in the absence of direct applicability under Turkish law.

3.5. Council of Europe and Regional Human Rights Jurisprudence

The European human rights system, particularly through the Council of Europe and the European Court of Human Rights (ECtHR), also plays an important role in shaping the business and human rights landscape. While the European Convention on Human Rights is primarily addressed to states, the jurisprudence of the Court has increasingly addressed situations where state failure to regulate or supervise private actors—including businesses—has resulted in human rights violations.

The Council of Europe’s handbook on business and human rights for legal practitioners highlights how concepts such as positive obligations have expanded the scope of state responsibility. States may be held accountable for failing to prevent harm caused by private entities, particularly in areas such as environmental protection, workplace safety, and access to justice (Council of Europe 2018). This development reinforces the expectation that states must establish effective regulatory and enforcement frameworks governing corporate conduct.

For Türkiye, as a member of the Council of Europe and a party to the European Convention on Human Rights, this jurisprudence has direct relevance. It underscores the importance of effective domestic regulation, enforcement, and judicial remedies in the business and human rights context.

3.6. Convergence of Norms and the Implications for Türkiye

Taken together, these international and European sources form a multi-layered normative system that shapes corporate behaviour. While each instrument—UNGPs, ILO standards, OECD Guidelines, EU policies, and Council of Europe jurisprudence—has its own legal nature and scope, they increasingly converge around a common set of expectations:

• Companies must identify and manage human rights risks;
• States must regulate and oversee corporate conduct;
• Affected individuals must have access to effective remedies;
• Transparency and reporting are essential components of accountability;
• Supply chains and business relationships fall within the scope of responsibility.

For Türkiye, this convergence has two important implications. First, it means that human rights compliance cannot be understood solely through the lens of domestic law. Turkish companies are embedded in a broader normative environment that shapes expectations regardless of formal legal boundaries. Second, it suggests that the direction of future legal and regulatory developments is relatively clear: toward greater integration of human rights into corporate governance, reporting, and due diligence processes.

In this context, international and European norms do not merely influence Turkish businesses from the outside. They actively contribute to the gradual formation of a domestic compliance culture in which human rights considerations become an inherent part of how business is conducted.

4. Turkish Legal and Institutional Framework

Türkiye does not yet have a single, standalone statute dedicated exclusively to business and human rights. Nevertheless, this does not mean that companies operate in a legal vacuum. On the contrary, the Turkish framework is best understood as a multi-source system in which constitutional guarantees, labour law, occupational health and safety rules, anti-discrimination norms, data protection law, criminal law, sustainability reporting requirements, and administrative institutions collectively shape the human rights responsibilities of business enterprises. In practical terms, human rights compliance in Türkiye emerges not from one code, but from the interaction of several legal regimes and oversight mechanisms.

At the constitutional level, the Turkish legal order protects a range of rights that are directly relevant to business conduct, including equality, personal dignity, privacy, property, fair trial rights, and the protection of workers and vulnerable persons. These constitutional principles form the normative backdrop against which sector-specific legislation is interpreted and applied. Even where legislation is framed in commercial, employment, administrative, or regulatory terms, its practical effect often concerns the protection of rights-holders against abuse, discrimination, unsafe working conditions, unlawful data processing, or exclusion from effective remedy. In that sense, the constitutional order provides the baseline from which corporate human rights compliance must be understood in Türkiye. This is consistent with the broader state duty to protect reflected in the UNGP framework and in European regional materials.

One of the most visible components of this framework is labour law. Turkish working life is structured in significant part around Labour Law No. 4857, which regulates core issues such as employment relationships, wages, working conditions, and general workplace rules. Alongside it, Law No. 6331 on Occupational Health and Safety establishes a distinct regime focused on prevention, employer obligations, and workplace safety management. The Ministry of Labour and Social Security materials emphasise that Labour Law No. 4857 remains the central statute governing general working conditions, while Law No. 6331 created a dedicated occupational safety and health framework applicable across a broad range of workplaces. For business and human rights purposes, these laws are critical because many of the most concrete human rights risks in commercial life arise in relation to employment, workplace safety, subcontracting, and the treatment of vulnerable workers.

A second pillar of the Turkish framework is anti-discrimination and equality protection, where the Human Rights and Equality Institution of Türkiye (TİHEK) occupies a central role. TİHEK was established by Law No. 6701, published in the Official Gazette on 20 April 2016. According to its official mandate, the institution was created to protect and promote human rights, secure equal treatment, prevent discrimination in the enjoyment of legally recognised rights and freedoms, and contribute to the fight against torture and ill-treatment. TİHEK’s official materials also confirm that both natural and legal persons who claim harm from a violation of the prohibition of discrimination may apply to the institution under Law No. 6701. This makes TİHEK directly relevant to the business context, especially in matters involving workplace equality, recruitment, treatment of employees, access to services, and other forms of discriminatory corporate conduct.

For companies, the practical significance of TİHEK lies in the fact that human rights compliance in Türkiye is not merely a matter of internal ethics or external reporting. It can also become the subject of institutional scrutiny through an administrative human rights body with a specific mandate concerning equality and rights protection. This means that businesses should treat anti-discrimination compliance, accessibility, equal treatment, internal complaint handling, and respect for dignity in the workplace as part of their core human rights architecture rather than as optional human resources policies. In sectors where employers interact intensively with workers, consumers, patients, students, residents, or other potentially vulnerable groups, TİHEK’s existence reinforces the need for structured compliance systems and documented preventive measures.

Another important component of the Turkish legal framework is personal data protection, which has become increasingly significant in the business and human rights field. The Personal Data Protection Law No. 6698 states that its purpose is to protect fundamental rights and freedoms, particularly the right to privacy, with respect to the processing of personal data, and to set out binding obligations, principles, and procedures for natural and legal persons processing such data. Official KVKK materials also note that the law entered into force following its publication in the Official Gazette on 7 April 2016. For present purposes, the importance of Law No. 6698 is that it links business activity directly to the protection of fundamental rights. Employers, digital platforms, financial institutions, retailers, health service providers, and technology companies all process personal data in ways that may affect privacy, autonomy, non-discrimination, and dignity. Accordingly, data governance is not a separate regulatory silo; it is a core part of modern human rights compliance.

The Turkish framework is also being reshaped by sustainability reporting regulation, which is increasingly relevant to human rights compliance. The Public Oversight, Accounting and Auditing Standards Authority (KGK) has established the Turkish Sustainability Reporting Standards (TSRS) framework and has published legal decisions concerning its application. KGK’s sustainability legislation page lists both the board decision determining the TSRS framework and the board decision on the scope of TSRS application. The Official Gazette decision of 16 July 2025 sets out the principles and procedures regarding the scope of application of TSRS. While TSRS is often discussed in sustainability or ESG terms, its significance for business and human rights is substantial: it pushes in-scope companies toward more structured governance, risk identification, and disclosure concerning sustainability-related matters that may include labour, value chain, and social impact issues.

This reporting layer is particularly important because it demonstrates that Türkiye’s framework is moving beyond a purely reactive model based on after-the-fact violations. Instead, it is increasingly incorporating ex ante governance and disclosure expectations. In other words, companies are not only expected to avoid unlawful conduct; they are also increasingly expected to identify risks, document their responses, and communicate material sustainability-related impacts through formal governance structures. That development brings the Turkish landscape closer to the international logic of due diligence and accountability reflected in the UNGPs, even if Türkiye has not enacted a single horizontal business and human rights statute.

Taken together, these elements show that the Turkish legal and institutional framework is fragmented but meaningful. Labour law addresses working conditions and employment-related risks. Occupational safety law targets the prevention of physical harm and unsafe workplaces. TİHEK provides an institutional avenue for equality and discrimination-related complaints. Data protection law protects privacy and imposes binding obligations on data controllers and processors. Sustainability reporting rules are adding a layer of governance, transparency, and board-level accountability. None of these mechanisms alone amounts to a comprehensive business and human rights code. Yet in combination, they create a domestic compliance environment in which human rights issues are already embedded in multiple areas of corporate operation.

For that reason, businesses in Türkiye should resist the common assumption that the absence of a dedicated business and human rights law means the absence of legal risk. The real position is the opposite. Human rights compliance obligations are already present, but they are distributed across several legal domains and institutional channels. The practical challenge for companies is therefore not to wait for a single new law, but to recognise how existing Turkish law already creates expectations regarding equality, safety, privacy, dignity, transparency, and access to complaint mechanisms. In this sense, the Turkish framework is not underdeveloped so much as multi-nodal: it requires integration, mapping, and governance rather than narrow legal formalism.

This is precisely why a human rights compliance approach in Türkiye must be cross-functional. It should involve legal, compliance, human resources, procurement, sustainability, data governance, and senior management functions. Only by reading the Turkish legal and institutional framework as an interconnected system can companies understand where their most significant human rights exposures actually lie.

V. Sustainability Reporting and Human Rights Disclosure in Türkiye

Sustainability reporting has become one of the most important channels through which human rights issues enter the governance and disclosure architecture of companies in Türkiye. This is because human rights impacts are no longer treated solely as matters of ethics, philanthropy, or reputational management. They are increasingly framed as sustainability-related risks and opportunities that may affect enterprise value, financing conditions, regulatory scrutiny, and stakeholder trust. In Türkiye, this shift is being driven most visibly by the Turkish Sustainability Reporting Standards (TSRS), adopted under the authority of the Public Oversight, Accounting and Auditing Standards Authority (KGK). KGK states that TSRS 1 addresses general requirements for the disclosure of sustainability-related financial information, while TSRS 2 addresses climate-related disclosures. The standards were introduced into Turkish law through publication in the Official Gazette in late 2023, and KGK has continued to refine the applicable framework since then.

The significance of TSRS for business and human rights lies not in the use of explicit human rights terminology in every disclosure requirement, but in the wider governance logic of the standards. TSRS is designed to require companies to identify, assess, manage, and disclose sustainability-related matters that are material to investors and other primary users of general purpose financial reports. In practice, this may include labour conditions, workforce practices, value chain vulnerabilities, community impacts, governance weaknesses, and social risk exposures where such matters affect strategy, risk profile, resilience, or financial performance. In this sense, sustainability reporting creates a structured route through which human rights-related issues become part of formal corporate disclosure and board-level oversight.

A key milestone was the initial determination of the companies subject to mandatory sustainability reporting from 1 January 2024 onward. KGK’s 2023-2024 framework established the first layer of mandatory TSRS reporting. Since then, the authority has amended and clarified the application scope. In particular, KGK’s public announcement dated 6 March 2025 explains that amendments had been made following the Board decision published in the Official Gazette on 18 December 2024, revising parts of the earlier TSRS application-scope decision. KGK’s sustainability page also shows that additional threshold-related decisions were issued in January 2026 concerning the criteria used in determining the scope of TSRS application. This demonstrates that the Turkish sustainability reporting system is not static; it is an evolving regulatory framework that companies must monitor continuously.

From a human rights compliance perspective, one of the most important consequences of TSRS is that companies can no longer treat social and human-rights-related matters as purely internal management issues. Once such matters become relevant to governance, risk, strategy, or value chain resilience, they may become disclosure issues. This is especially true in sectors where labour conditions, outsourced production, contractor dependence, seasonal employment, migration-related workforce issues, health and safety incidents, community opposition, or privacy-related practices may generate financially significant consequences. In other words, human rights-related harms can become reportable not only because they matter morally, but because they may be material to enterprise performance and sustainability-related financial decision-making.

Another important feature of the Turkish framework is that TSRS is closely aligned with the global sustainability disclosure architecture that has developed around the International Sustainability Standards Board. KGK expressly notes that Türkiye adopted the ISSB approach and translated the existing international standards into the Turkish reporting framework as TSRS 1 and TSRS 2. This is highly relevant to Turkish businesses connected to international capital markets, foreign investors, multinational customers, and cross-border supply chains. It means that the reporting language used in Türkiye is increasingly compatible with the expectations of global financial and regulatory actors. As a result, disclosure related to social risks, workforce management, value chain exposure, and governance quality may carry significance not only domestically, but also in international commercial and investment contexts.

In practical terms, this development reinforces the transition from informal sustainability narratives to documented, process-based accountability. TSRS-compatible reports already published through KGK’s sustainability portal show that companies are beginning to structure disclosures around topics such as value chain mapping, governance processes, materiality assessment, sector-specific risk evaluation, and resilience analysis. While many of these reports focus heavily on climate, they also reveal a broader move toward systematic disclosure architecture. That architecture can readily encompass human rights issues where those issues intersect with workforce conditions, procurement practices, operational risk, stakeholder relations, or long-term corporate resilience. This is why sustainability reporting should be treated as part of the human rights compliance ecosystem rather than as a separate ESG exercise.

For companies in Türkiye, the practical lesson is clear. Human rights disclosure is becoming part of mainstream corporate governance. Businesses should therefore not wait until a formal reporting obligation explicitly names every human rights category. Instead, they should identify which aspects of their operations are most likely to generate human rights-related sustainability risks, document governance and mitigation measures, and build internal reporting systems capable of supporting future disclosures. In this respect, sustainability reporting functions as both a compliance mechanism and a discipline of organisational preparedness: it compels companies to know their risk profile, show how risks are managed, and communicate in a manner that can withstand investor, auditor, regulatory, and stakeholder scrutiny.

This trend also has an important legal-cultural effect. Even where Turkish law does not yet impose a standalone business and human rights reporting code comparable to some emerging European models, TSRS contributes to the institutional normalisation of disclosure concerning governance quality, risk oversight, and sustainability-related impacts. In that sense, TSRS helps bridge the gap between domestic law and the broader international business and human rights framework. It pushes companies toward the same fundamental questions that arise under the UNGPs and related due diligence systems: What impacts may the business have on people? Where are the most serious risks? Who is accountable internally? How are those risks tracked? What is being communicated externally? The language may be sustainability reporting, but the underlying discipline increasingly overlaps with human rights compliance.

VI. Human Rights Due Diligence for Businesses in Türkiye

Human rights due diligence is the operational core of modern business and human rights compliance. Under the UN Guiding Principles, business enterprises are expected to carry out an ongoing process to identify, prevent, mitigate, and account for how they address adverse human rights impacts. That process should cover impacts a company may cause or contribute to through its own activities, as well as impacts directly linked to its operations, products, or services through business relationships (OHCHR 2011). OHCHR also describes the Guiding Principles as the global standard for preventing and addressing adverse human rights impacts involving business activity, while the UN Working Group’s materials emphasise that corporate human rights due diligence is the mechanism through which companies are expected to meet that responsibility in practice (OHCHR 2011).

For businesses in Türkiye, this concept is increasingly important not because a single Turkish statute has imposed a universal, standalone human rights due diligence law, but because due diligence expectations now arise from several overlapping sources. These include international soft-law frameworks, OECD responsible business conduct guidance, buyer and investor expectations, value chain requirements, public procurement trends, and the governance logic of sustainability reporting. The OECD explains that responsible business conduct due diligence is a risk-based process that helps companies assess and address actual and potential adverse impacts in their operations, supply chains, and business relationships. The OECD Due Diligence Guidance also sets out a practical framework built around embedding responsible business conduct into policies and management systems, identifying and assessing impacts, ceasing or preventing harm, tracking implementation, communicating externally, and providing for or cooperating in remediation (OECD 2024).

At a conceptual level, it is important to distinguish human rights due diligence from ordinary corporate risk management. Conventional enterprise risk systems usually focus on risks to the company: financial loss, regulatory exposure, litigation, operational disruption, or reputational damage. Human rights due diligence, by contrast, begins with risks to people. It asks how a company’s conduct, products, services, or relationships may harm workers, communities, consumers, contractors, migrants, or other rights-holders. This difference is fundamental. A business may treat a labour issue, data privacy problem, or community dispute as immaterial from a narrow commercial viewpoint, yet the same issue may be highly significant from a human rights perspective and later become commercially material as well. That is why the UNGP framework requires companies not merely to monitor business risks, but to identify and address adverse impacts on individuals and communities (OHCHR 2011), (Council of Europe 2018).

The due diligence process itself can be broken down into several core stages. First, the company should adopt and embed a policy commitment to respect human rights. Under the UNGPs, this commitment should be approved at the most senior level, informed by relevant expertise, communicated internally and externally, and reflected in operational policies and procedures (OHCHR 2011). In practical terms, a Turkish company should not treat such a policy as a generic website statement. It should be translated into procurement practices, workforce rules, whistleblowing systems, disciplinary mechanisms, contractual clauses, audit rights, and management reporting lines. Without internal integration, policy language remains symbolic rather than operational.

Second, the company should identify and assess actual and potential human rights impacts. Under the UNGPs, this assessment should draw on internal or external expertise and include meaningful consultation with potentially affected groups where appropriate (OHCHR 2011). In Türkiye, this stage may require businesses to map not only their own workforce and sites, but also outsourced labour, seasonal or migrant workers, subcontractors, logistics arrangements, security practices, data-processing activities, community interfaces, and supplier networks. A textile exporter, for example, may need to examine working hours, wage practices, recruitment channels, gender-based risks, dormitory conditions, and subcontracted workshops. A technology or fintech company may need to look at employee monitoring, algorithmic bias, privacy, fraud screening tools, and data governance. A construction or infrastructure business may need to assess health and safety, accommodation conditions, land-use impacts, and contractor controls. In each case, the due diligence question is the same: where and how may this business adversely affect people?

Third, the findings of the assessment must be integrated into decision-making and acted upon. This is one of the most demanding stages in practice because it requires moving from diagnosis to management action. The UNGPs make clear that responsibility for addressing impacts must be assigned to the appropriate level and function within the enterprise, and that internal decision-making, budget allocation, and oversight processes must enable an effective response (OHCHR 2011). For Turkish businesses, this means human rights due diligence cannot sit solely within the legal department. Human resources, procurement, compliance, operations, sustainability, internal audit, and senior management all need defined roles. If labour risks are identified but procurement deadlines still drive unrealistic production schedules, or if privacy concerns are raised but IT systems remain unchanged, due diligence has not actually been integrated.

Fourth, the company should track the effectiveness of its response. This requires more than confirming that a policy has been issued or that suppliers have signed a code of conduct. The UNGPs require companies to verify whether impacts are actually being addressed, using appropriate qualitative and quantitative indicators and drawing on internal and external feedback, including affected stakeholders where relevant (OHCHR 2011). In Türkiye, effective tracking may involve audit findings, grievance data, turnover patterns, absenteeism, accident records, supplier remediation performance, training participation, complaint resolution times, or follow-up interviews with workers and community representatives. The goal is not to produce perfect data, but to create a credible feedback loop showing whether the company’s interventions are reducing harm in practice.

Fifth, companies should be prepared to communicate externally how they address human rights impacts. The UNGPs say that communication may take different forms depending on the severity of the risks and the nature of the business, but where operations or operating contexts pose severe human rights risks, formal reporting is expected (OHCHR 2011). This is where due diligence intersects directly with Turkish sustainability reporting developments. KGK states that Türkiye has fully incorporated ISSB-based sustainability disclosure standards into TSRS, and its 2025 announcement confirms that TSRS has been mandatory in Turkish law since the end of 2023, with the application scope subsequently amended by board decisions published in late 2024 and reflected in 2025 disclosures (KGK 2025). Although TSRS is not a dedicated human rights statute, it strengthens the expectation that companies should know their social and governance risks, document their responses, and disclose material sustainability-related information in a structured way.

A sixth and indispensable component is remediation. The UNGPs provide that where business enterprises identify that they have caused or contributed to adverse impacts, they should provide for or cooperate in remediation through legitimate processes (OHCHR 2011). This means human rights due diligence does not end once a company has mapped risks or issued policies. If harm has occurred, the company must address it. In Turkish practice, this may require wage correction, reinstatement, medical support, corrective measures in the workplace, revision of abusive supplier practices, privacy breach response, or engagement with complainants through operational-level grievance mechanisms. The Council of Europe handbook likewise underlines that remedy is not an optional add-on but one of the three structural pillars of the business and human rights framework (Council of Europe 2018).

In the Turkish context, UNDP’s work is especially relevant because it has helped translate the due diligence idea into practical implementation language. UNDP Türkiye states that its Human Rights Due Diligence Training Facilitation Guide, translated into Turkish in 2023 within the scope of the “Business and Human Rights – Promoting Responsible Conduct Project,” is intended to explain the requirements of the human rights due diligence process using internationally recognised principles and terminology. UNDP also states that, beginning in 2022, it launched a Türkiye-focused project supported by the Government of Japan to improve human rights standards in business and to promote adherence to the UNGPs in both the public and private sectors. In addition, UNDP’s 2025 guide on public procurement in Türkiye expressly aims to support the integration of human rights due diligence into procurement rules and practices (UNDP Türkiye 2023). These developments show that due diligence is no longer a remote international concept; it is being actively operationalised in the Turkish policy environment.

For businesses in Türkiye, the practical design of a due diligence system should be proportionate but real. Small and medium-sized enterprises are not expected to build the same infrastructure as a large listed issuer or multinational exporter, yet the underlying logic still applies. Every company should be able to answer a minimum set of questions. What are our most serious human rights risks? Which workers, communities, customers, or partners may be affected? Where are the greatest vulnerabilities in our operations and business relationships? Who internally is accountable? How do complaints reach us? How do we decide when to escalate, investigate, or remediate? What evidence do we keep to show that we have acted? The precise format may differ, but the absence of a system is increasingly difficult to justify in sectors connected to international markets, investors, public contracts, or sensitive workforces.

It is also important to emphasise that due diligence is ongoing, not static. The UNGPs state that the process should continue over time because human rights risks change as operations and contexts evolve (OHCHR 2011). A Turkish company that enters a new export market, acquires another business, increases reliance on temporary labour, digitises customer operations, outsources logistics, or begins working in a disaster-affected or politically sensitive region may face a materially different risk profile from the one it had a year earlier. Due diligence therefore must be revisited when operations change, not treated as a one-time compliance project.

Ultimately, human rights due diligence provides the practical bridge between principle and implementation. It turns the general expectation to respect human rights into a concrete management process. For businesses in Türkiye, it is also becoming the bridge between domestic legal fragmentation and international compliance convergence. It allows a company to connect labour law, anti-discrimination obligations, data protection, supply chain oversight, sustainability reporting, and grievance handling within a single risk-governance framework. That is why human rights due diligence should be seen not as an imported compliance burden, but as the most coherent way to organise responsible business conduct in a market where legal, contractual, and reputational expectations are steadily converging.

VII. Labour Rights as the Core of Business and Human Rights

In practice, labour rights form the most visible and most frequently contested core of the business and human rights field. Although business-related human rights impacts may also arise in areas such as privacy, environmental harm, consumer protection, or community relations, the workplace remains the primary site where human dignity, equality, safety, and economic vulnerability intersect most directly. This is why international business and human rights frameworks consistently place labour-related issues at the centre of corporate responsibility. The UN Guiding Principles make clear that businesses are expected to respect internationally recognized human rights, including the fundamental principles and rights reflected in the International Labour Organization framework (OHCHR 2011). The Council of Europe’s business and human rights materials likewise underline that many of the most concrete state duties and corporate responsibilities arise in relation to employment, occupational safety, non-discrimination, and access to remedy in the workplace (Council of Europe 2018).

The centrality of labour rights is not accidental. Work is not only an economic activity; it is also a site of power, dependence, and vulnerability. A company can affect the rights of workers through wages, working hours, occupational safety, recruitment methods, privacy practices, disciplinary systems, subcontracting structures, dismissal processes, anti-union conduct, or discriminatory treatment. In many sectors, especially those characterised by price pressure, production deadlines, fragmented subcontracting, or a high reliance on temporary labour, these risks are not peripheral. They are embedded in the business model itself. That is why labour rights should not be viewed merely as one compliance category among many. They are often the clearest test of whether a company’s commitment to human rights is real or merely rhetorical.

From the perspective of international standards, the most important labour-related concerns include forced labour, child labour, discrimination, freedom of association, collective bargaining, fair and safe working conditions, and protection against abusive or degrading treatment. The ILO’s core labour rights framework gives these issues a universal structure, while the UNGPs incorporate them into the broader concept of human rights due diligence. This means that labour rights are no longer limited to domestic employment law compliance in the narrow sense. They are also matters of global supply chain responsibility, investor scrutiny, and sustainability governance. A company may comply formally with parts of domestic labour regulation and still face serious human rights criticism if, for example, it relies on exploitative subcontracting, ignores gender-based abuse, tolerates unsafe dormitory conditions, or benefits from opaque recruitment channels that expose migrant workers to coercion.

This broader understanding is particularly relevant in Türkiye. Turkish businesses operate in a labour market marked by deep sectoral variation, intensive subcontracting in some industries, and significant exposure to international markets. In sectors such as textiles, agriculture, food processing, construction, mining, manufacturing, logistics, and platform-based services, labour conditions often determine whether a company will be regarded as a responsible business partner by foreign buyers, investors, or regulators. In these sectors, labour rights are not merely internal management issues. They directly affect value chain integrity, contract sustainability, and reputational resilience.

A major reason labour rights are so central in the Turkish context is the presence of high-risk workforce structures. These may include seasonal workers, temporary agency workers, outsourced personnel, subcontracted production lines, informal labour arrangements, women in precarious employment, and migrant or refugee workers who may be particularly vulnerable to underpayment, excessive hours, document dependency, discriminatory treatment, unsafe accommodation, or barriers to complaint mechanisms. From a business and human rights perspective, the existence of such vulnerability does not merely create a social issue; it creates a due diligence priority. The UNGPs specifically require attention to groups at heightened risk of vulnerability or marginalization, and this has direct implications for workforce management in Türkiye (OHCHR 2011).

One of the most sensitive labour-related issues is forced labour and coercive dependency. In formal legal terms, forced labour may appear exceptional. In practical terms, however, coercion can take more subtle forms: withholding wages, retention of identity documents, abusive recruitment debt, threats linked to immigration status, dependence on labour intermediaries, or living conditions that create effective inability to leave employment. In export-oriented or labour-intensive sectors, these risks may arise not only in a company’s own direct workforce but also among subcontractors, field suppliers, workshop operators, labour brokers, or logistics partners. A company that ignores these patterns may not have intended the abuse, but it may still be directly linked to it through its business relationships. That is precisely the kind of scenario the business and human rights framework is designed to address.

Another critical issue is non-discrimination and equality in employment. Labour rights in the business and human rights sense go beyond formal equal treatment clauses. They also concern hiring practices, promotion pathways, pay gaps, disability access, maternity-related treatment, workplace harassment, religious or ethnic discrimination, and retaliation against workers who raise concerns. In Türkiye, this dimension is especially important because equality is not only a general constitutional value but also an area of institutional oversight through TİHEK. For businesses, this means that anti-discrimination compliance should be approached as part of a broader human rights architecture: internal policies, complaint channels, training, investigation procedures, documentation, and management accountability all matter. A workplace culture that tolerates humiliation, exclusion, or selective retaliation may generate both legal exposure and serious human rights concerns, even where no major public dispute has yet emerged.

Occupational health and safety is another indispensable pillar. In business and human rights terms, unsafe work is not only a technical compliance problem; it is a human rights issue because it affects bodily integrity, life, dignity, and access to decent work. This is particularly significant in sectors involving physical risk, such as construction, heavy industry, transportation, warehousing, mining, and agriculture. In Türkiye, occupational safety obligations are well developed as a matter of legislation, yet from a human rights perspective the key question is not simply whether formal obligations exist, but whether companies actually create a preventive culture. This includes proper training, realistic work schedules, protective equipment, effective supervision, incident reporting, contractor oversight, and the ability of workers to raise safety concerns without fear of retaliation. A company that delegates dangerous work to subcontractors without meaningful oversight does not remove the human rights dimension of the risk; it merely relocates it to a more vulnerable part of the value chain.

The question of working time and wage practices also deserves central attention. Excessive overtime, delayed payment, unlawful deductions, unpaid preparatory time, production-linked coercion, and unrealistic output expectations can all amount to serious labour rights concerns. In sectors under intense delivery pressure, such as textiles or fast-moving consumer production, commercial demands often translate into labour abuses through production bottlenecks and hidden overtime. This is one of the clearest examples of why labour rights must be understood as a board-level and procurement-level issue, not merely as a human resources issue. If commercial teams, sourcing managers, or buyers create unrealistic cost and timing expectations, the company may in practice be contributing to labour harm even where it does not directly supervise every workplace.

A particularly important topic in Türkiye is the labour dimension of migration and forced displacement. Companies may employ migrants or refugees directly, or indirectly benefit from labour pools shaped by displacement, informality, or weak bargaining power. In such contexts, the business and human rights approach requires more than formal legality. It requires attention to recruitment practices, wage protection, language access, grievance channels, accommodation standards, and safeguards against discriminatory or coercive dependency. This is not simply a humanitarian issue. It is a corporate governance issue, a due diligence issue, and in many cases a supply chain issue as well. Businesses that operate in sectors where migrant labour is prevalent should therefore treat this as a priority risk area requiring enhanced scrutiny.

The role of freedom of association and worker voice should also be stressed. Labour rights are not fully protected if workers cannot safely express concerns, organize collectively, or raise grievances about harmful conditions. From a business and human rights standpoint, grievance mechanisms are important, but they cannot replace legitimate worker representation. Companies should therefore avoid treating internal reporting systems as substitutes for freedom of association, collective bargaining, or meaningful worker dialogue. A company may have a hotline and still operate in a way that discourages complaints, isolates worker representatives, or penalizes collective action. That would undermine both labour rights and the credibility of its overall human rights compliance programme.

For Turkish businesses, the practical implication is that labour rights should be treated as the starting point of any serious human rights compliance strategy. A company may begin its wider human rights programme by asking a structured set of labour-focused questions. Do we know where our workforce risks are highest? Are subcontracted and temporary workers covered by the same practical safeguards as direct employees? Are there gender-specific risks in our operations? Are our recruitment channels transparent and free from coercive dependency? Can workers complain safely and effectively? Are procurement timelines creating hidden labour pressure? Are occupational safety risks actually controlled in practice? Do we know where the most vulnerable workers are in our value chain?

When those questions are asked honestly, labour rights often reveal the real condition of a company’s human rights governance. A business that gets labour rights seriously wrong is unlikely to be strong on human rights elsewhere. Conversely, a company that builds robust systems around fair treatment, safe work, equal opportunity, worker voice, recruitment integrity, and remedy will often have created the foundation for a more credible and effective business and human rights programme overall.

For that reason, labour rights should be understood not as one subsection of business and human rights, but as its operational centre. In the Turkish context especially, they are where law, compliance, supply chains, vulnerability, and corporate accountability most clearly meet.

VIII. Supply Chain and Value Chain Risks

One of the most significant developments in the field of business and human rights is the recognition that corporate responsibility extends far beyond the legal boundaries of the enterprise itself. Modern business operations are rarely confined to a single entity or location. Instead, they are structured through complex and often transnational networks of suppliers, subcontractors, logistics providers, distributors, service partners, and digital platforms. As a result, many of the most serious human rights risks do not arise within a company’s headquarters or direct workforce, but within its supply chain and broader value chain. The UN Guiding Principles explicitly acknowledge this reality by stating that companies are expected to address adverse human rights impacts that are directly linked to their operations, products, or services through business relationships, even where they have not caused or contributed to those impacts (OHCHR 2011).

This shift from entity-based responsibility to relationship-based responsibility is one of the defining features of contemporary business and human rights law and practice. It reflects the structural reality of global production systems, where economic value is created through fragmented processes involving multiple actors across different jurisdictions. A company may source raw materials from one country, process components in another, assemble products in Türkiye, and distribute them globally through third-party networks. At each stage, different human rights risks may arise, including unsafe working conditions, forced or child labour, discriminatory practices, environmental harm affecting communities, or abusive recruitment systems. In such a system, limiting responsibility to direct control would render most human rights risks invisible from a legal and compliance perspective.

The OECD framework reinforces this broader understanding by emphasising that responsible business conduct due diligence should cover not only a company’s own activities but also its supply chain and other business relationships (OECD 2024). This includes upstream activities such as sourcing, extraction, and manufacturing, as well as downstream relationships involving distribution, marketing, product use, and disposal. The Danish Institute for Human Rights and similar institutions have further developed this idea by introducing the concept of full value chain responsibility, highlighting that human rights impacts may arise at any stage of a product or service lifecycle. Together, these approaches make clear that a company’s human rights footprint must be assessed holistically rather than organisationally.

For businesses in Türkiye, this perspective is particularly relevant. The Turkish economy is deeply integrated into global value chains, especially in sectors such as textiles and apparel, automotive components, machinery, agriculture and food production, construction, and logistics. Many Turkish companies operate as suppliers to European or global brands, while others manage multi-layered subcontracting systems within Türkiye itself. In both cases, the company may be contractually responsible to a buyer or commercially dependent on a network of smaller suppliers. This dual position—as both a supplier and a principal—creates a complex risk profile in which the company may simultaneously be subject to due diligence expectations from above and responsible for risk management below.

One of the most persistent challenges in supply chain governance is lack of visibility. Companies often have relatively strong knowledge of their first-tier suppliers but limited insight into second- or third-tier actors. Yet many of the most serious human rights risks—such as informal workshops, undeclared labour, migrant worker exploitation, or hazardous raw material extraction—occur precisely in these less visible segments of the chain. The UNGP framework addresses this by focusing not only on direct control but also on leverage. Companies are expected to use their influence—contractual, economic, or relational—to prevent or mitigate harm where it is directly linked to their operations (OHCHR 2011). This may involve requiring supplier codes of conduct, conducting audits, supporting capacity-building, adjusting purchasing practices, or, in extreme cases, disengaging from relationships that cannot be brought into compliance.

However, reliance on formal tools such as codes of conduct and audits is not sufficient in itself. A company may require its suppliers to sign detailed human rights commitments, yet those commitments may have little practical effect if purchasing practices undermine compliance. For example, unrealistic delivery deadlines, aggressive pricing, last-minute order changes, or production surges can create structural pressure that pushes suppliers toward excessive overtime, informal subcontracting, or unsafe working conditions. In such cases, the company may be contributing indirectly to human rights harm, even if it does not intend to do so. This illustrates a key insight of the business and human rights framework: commercial decisions can generate human rights consequences, and due diligence must therefore extend into procurement, sourcing, and operational planning.

The Turkish context provides several concrete illustrations of these risks. In the textile and apparel sector, multi-tier subcontracting and informal workshops may create conditions where working hours, wage compliance, and worker safety are difficult to monitor. In agriculture, seasonal labour and intermediary recruitment systems may expose workers to poor living conditions, lack of social protection, and wage irregularities. In construction and infrastructure projects, layers of subcontractors may dilute accountability for occupational safety and working conditions. In logistics and delivery services, time pressure and performance-based systems may affect worker safety and welfare. In each of these cases, the supply chain is not merely a commercial arrangement; it is a risk transmission mechanism for human rights impacts.

Another important dimension is the role of contractual governance. Companies often attempt to manage supply chain risks through contractual clauses requiring compliance with labour standards, human rights policies, and applicable laws. While such clauses are necessary, they are not sufficient. Effective supply chain governance requires a combination of contractual tools and operational practices. This may include supplier onboarding procedures, risk-based segmentation of suppliers, regular and unannounced audits, worker interviews, grievance channels accessible to supplier employees, corrective action plans, and escalation mechanisms. It may also require collaboration with industry initiatives, civil society organisations, or multi-stakeholder platforms, particularly in sectors where systemic risks cannot be addressed by a single company acting alone.

The importance of grievance mechanisms in the supply chain context should also be emphasised. Workers in supplier facilities, especially those in lower tiers, may have limited access to formal complaint systems. Companies that rely solely on internal reporting channels limited to their own employees risk missing significant human rights issues occurring within their value chain. The UNGPs therefore encourage companies to establish or participate in grievance mechanisms that are accessible to affected stakeholders beyond the immediate workforce (OHCHR 2011). For Turkish companies, this may mean extending complaint channels to supplier workers, providing anonymous reporting options, ensuring language accessibility, and creating procedures for handling complaints originating outside the company’s direct organisational structure.

In addition to upstream supply chains, downstream impacts are becoming increasingly relevant. Companies may affect human rights through the way their products or services are used. For example, digital platforms may influence privacy and data rights, financial services may affect access to economic opportunities, and infrastructure projects may shape community environments. This broader value chain perspective reinforces the idea that human rights due diligence is not limited to procurement or production. It also requires attention to how business outputs affect individuals and communities over time.

For Turkish businesses engaged in international trade, supply chain risks also intersect with external regulatory and contractual expectations. European buyers, investors, and partners increasingly require suppliers to demonstrate compliance with human rights standards, conduct due diligence, and provide evidence of risk management. Failure to meet these expectations may lead to loss of contracts, exclusion from preferred supplier lists, or increased audit and monitoring requirements. In this way, supply chain governance becomes both a compliance obligation and a competitive factor.

Ultimately, supply chain and value chain risks illustrate why business and human rights cannot be confined to legal ownership or organisational boundaries. They require a broader understanding of how economic relationships create responsibility. For companies in Türkiye, this means that human rights compliance must extend into procurement strategies, supplier relationships, operational planning, and stakeholder engagement. It also means that the most serious risks may lie not where the company has the greatest control, but where it has the greatest impact through connection.

In this sense, effective supply chain governance is not simply about avoiding liability. It is about recognising that in a globally interconnected economy, responsibility follows influence. Companies that understand this dynamic and integrate it into their governance systems are better positioned to manage risk, maintain market access, and build resilient business relationships.

IX. Business, Human Rights and Vulnerable Groups in Türkiye

A defining feature of the business and human rights framework is its emphasis on the protection of individuals and groups who are particularly vulnerable to harm. The UN Guiding Principles explicitly require that businesses give special attention to the rights and needs of individuals or groups that may be at heightened risk of adverse human rights impacts (OHCHR 2011). This includes, among others, women, children, persons with disabilities, migrants, refugees, and those working in precarious or informal conditions. The Council of Europe’s guidance similarly underlines that effective human rights protection requires recognising structural inequalities and power imbalances that may affect access to rights, remedies, and protection (Council of Europe 2018).

In the context of Türkiye, the relevance of this approach is especially pronounced. The country’s economic structure, labour market dynamics, and demographic realities create a setting in which certain groups may face heightened exposure to business-related risks. These vulnerabilities may arise not only from legal status or economic conditions, but also from social, cultural, and institutional factors. As a result, a generic, “one-size-fits-all” compliance model is insufficient. Companies must adopt a risk-sensitive and context-aware approach that identifies where and how particular groups may be disproportionately affected by business activity.

One of the most significant dimensions in Türkiye is the presence of migrant and refugee populations, many of whom participate in the labour market, formally or informally. In sectors such as agriculture, textiles, construction, manufacturing, and services, migrant workers may face risks including underpayment, excessive working hours, lack of social protection, unsafe working conditions, language barriers, and dependence on intermediaries or employers. These conditions may create forms of vulnerability that go beyond standard labour law considerations and raise broader human rights concerns, particularly where workers lack effective access to complaint mechanisms or fear retaliation.

From a business perspective, this does not merely represent a humanitarian issue. It is a due diligence priority. Companies that employ or indirectly benefit from migrant labour must ensure that recruitment practices are transparent, wages are paid lawfully, working conditions meet safety standards, and grievance mechanisms are accessible and effective. Where labour is sourced through intermediaries, additional scrutiny is required to ensure that recruitment fees, documentation practices, and accommodation conditions do not create coercive dependency. UNDP’s work in Türkiye has emphasised the importance of integrating human rights considerations into both private sector operations and public policy frameworks, including in areas such as employment and procurement (UNDP Türkiye 2023).

Another critical area concerns gender-related risks in the workplace. Women may face specific challenges such as unequal pay, limited access to promotion, occupational segregation, harassment, discrimination related to pregnancy or caregiving responsibilities, and exposure to unsafe or exploitative working conditions. In some sectors, particularly those relying on informal or home-based work, these risks may be less visible but no less significant. From a business and human rights perspective, gender equality is not limited to formal non-discrimination policies. It requires active measures to identify and address structural inequalities, ensure safe reporting channels, and create an inclusive workplace culture.

Children and young workers also represent a group requiring particular attention. While child labour is prohibited under both international standards and Turkish law, risks may still arise in sectors involving seasonal labour, family-based work, or informal production environments. Beyond child labour itself, companies must also consider the broader impact of their operations on children’s rights, including access to education, health, and a safe environment. For example, long working hours of parents, hazardous working conditions, or community-level environmental harm may indirectly affect children’s well-being.

Persons with disabilities constitute another group that may face barriers to full participation in economic life. These barriers may include inaccessible workplaces, lack of reasonable accommodation, discriminatory hiring practices, or limited career development opportunities. In Türkiye, equality and non-discrimination in this area fall within the broader mandate of TİHEK, reinforcing the expectation that businesses should actively promote accessibility and inclusion rather than merely avoiding overt discrimination (TİHEK 2024/6701).

Beyond these specific categories, the concept of vulnerability also applies to workers in precarious or informal employment arrangements. Temporary workers, subcontracted personnel, platform-based workers, and those engaged through complex labour supply chains may lack the protections available to standard employees. They may have limited bargaining power, reduced access to social protection, and fewer effective channels for raising complaints. In such contexts, formal compliance with minimum legal requirements may not be sufficient to ensure respect for human rights. Companies must consider whether their business models, including outsourcing strategies and contractual arrangements, create or exacerbate vulnerability.

An important dimension of vulnerability in Türkiye is also regional and community impact. Business activities, particularly in sectors such as mining, energy, infrastructure, and large-scale agriculture, may affect local communities through land use, environmental impact, displacement, or changes in access to resources. These impacts may disproportionately affect rural populations, economically disadvantaged groups, or communities with limited access to legal or administrative remedies. From a human rights perspective, companies are expected to engage with affected communities, assess potential impacts, and take steps to prevent or mitigate harm. Failure to do so may not only create social conflict but also expose the company to legal, reputational, and operational risks.

The presence of vulnerable groups also has important implications for grievance mechanisms and access to remedy. A complaint system that is formally available but practically inaccessible to vulnerable individuals is unlikely to be effective. Barriers may include language differences, lack of awareness, fear of retaliation, cost, distance, or mistrust of institutional processes. The UNGP framework therefore emphasises that grievance mechanisms should be legitimate, accessible, predictable, equitable, transparent, and compatible with human rights (OHCHR 2011). For companies in Türkiye, this means designing mechanisms that are adapted to the realities of their workforce and stakeholders. This may include providing multilingual access, ensuring confidentiality, protecting complainants from retaliation, and enabling complaints to be raised through multiple channels.

From a governance perspective, addressing vulnerability requires more than identifying categories of risk. It requires integrating vulnerability-sensitive thinking into all stages of business decision-making. This includes recruitment, contracting, procurement, workplace management, community engagement, and product design. It also requires training staff to recognise vulnerability, collecting data in a responsible manner, and establishing escalation procedures for high-risk situations. In many cases, the most serious human rights risks arise not from deliberate abuse, but from structural blind spots—situations where the company has not fully considered how its operations affect those with the least power or visibility.

In the Turkish context, this approach is particularly important because vulnerability often intersects with multiple factors: economic disadvantage, migration status, gender, informal employment, regional disparities, and access to institutions. Companies that fail to recognise these intersections may underestimate their exposure to human rights risks. Conversely, businesses that proactively identify and address vulnerability are better positioned to build trust, maintain stable operations, and meet both domestic and international expectations.

Ultimately, the focus on vulnerable groups reinforces a central insight of the business and human rights framework: compliance is not achieved simply by applying general rules uniformly. It requires attention to who is affected, how they are affected, and whether they have the capacity to protect their own rights. In this sense, vulnerability is not a marginal issue. It is a lens through which the effectiveness of a company’s entire human rights compliance system can be assessed.

X. Access to Remedy and Corporate Accountability

The business and human rights framework is incomplete without effective mechanisms that allow individuals and communities to seek redress when harm occurs. The UN Guiding Principles explicitly recognise this by establishing access to remedy as the third pillar of the “Protect, Respect and Remedy” framework (OHCHR 2011). This pillar ensures that human rights compliance is not limited to prevention and policy commitments, but extends to accountability, enforcement, and corrective action. Where adverse human rights impacts arise, affected persons must have access to mechanisms capable of providing meaningful, timely, and fair outcomes. The Council of Europe likewise emphasises that remedy is essential to the credibility of the system, requiring not only formal legal rights but also practical accessibility, procedural fairness, and institutional effectiveness (Council of Europe 2018).

From a structural perspective, access to remedy operates through both judicial and non-judicial mechanisms. Judicial mechanisms include courts and tribunals capable of adjudicating disputes, awarding compensation, imposing sanctions, or ordering corrective measures. Non-judicial mechanisms include administrative bodies, national human rights institutions, ombuds-type processes, mediation platforms, grievance mechanisms, and international complaint procedures. The UNGPs stress that both types of mechanisms are necessary because reliance on courts alone may be insufficient, particularly where victims face barriers such as cost, delay, lack of legal representation, or imbalance of power (OHCHR 2011).

In Türkiye, judicial mechanisms form an important part of the remedy landscape. Individuals affected by business-related human rights impacts may seek redress through labour courts, civil courts, administrative courts, or criminal proceedings, depending on the nature of the harm. For example, workplace injuries, unpaid wages, discrimination claims, privacy violations, and contractual disputes may all be subject to judicial review. However, as in many jurisdictions, litigation can be time-consuming, resource-intensive, and procedurally complex. This underscores the importance of complementary mechanisms that can provide more accessible and timely avenues for addressing grievances.

One such mechanism is the Human Rights and Equality Institution of Türkiye (TİHEK), which has the authority to receive and examine complaints related to discrimination and human rights violations within its mandate (TİHEK 2024/6701). TİHEK represents an important institutional channel through which individuals may raise concerns about corporate conduct, particularly in areas such as employment, access to services, and equal treatment. While its powers differ from those of courts, its role in investigating complaints, raising awareness, and promoting compliance contributes to the broader accountability environment in which businesses operate.

At the international level, the OECD National Contact Point (NCP) mechanism provides an additional avenue for addressing business-related human rights concerns. The OECD explains that NCPs are established to further the effectiveness of the OECD Guidelines for Multinational Enterprises by offering a platform for resolving issues through dialogue and mediation (OECD 2024). In Türkiye, the NCP functions under the Ministry of Industry and Technology and may handle complaints involving Turkish companies or foreign companies operating in Türkiye. Although NCP decisions are not legally binding, the process can have significant reputational consequences and may influence investor perceptions, commercial relationships, and stakeholder trust. For companies engaged in cross-border business, the NCP mechanism represents an important dimension of non-judicial accountability.

Beyond state-based mechanisms, the UNGPs emphasise the importance of company-level grievance mechanisms. Businesses are encouraged to establish or participate in operational-level mechanisms that allow individuals and communities to raise concerns directly with the company. These mechanisms serve several purposes. They provide early warning of emerging risks, enable prompt resolution of issues before they escalate, and demonstrate a company’s commitment to accountability. However, their effectiveness depends on design and implementation. The UNGPs set out criteria for effective grievance mechanisms, including legitimacy, accessibility, predictability, equity, transparency, and compatibility with human rights (OHCHR 2011).

For businesses in Türkiye, designing effective grievance mechanisms requires attention to the specific characteristics of their workforce and stakeholders. A mechanism that is formally available but practically inaccessible—due to language barriers, lack of awareness, fear of retaliation, or complex procedures—will not meet UNGP standards. Companies should therefore consider multiple reporting channels, including anonymous options, ensure confidentiality, provide clear timelines and processes, and protect complainants against adverse consequences. In supply chain contexts, this may also involve extending grievance mechanisms to supplier employees or participating in sectoral or multi-stakeholder complaint platforms.

The concept of corporate accountability goes beyond the existence of remedy mechanisms. It concerns the broader question of how companies are held responsible for their impacts. Under the UNGP framework, accountability arises in different forms depending on the company’s involvement in the harm. Where a company has caused or contributed to an adverse impact, it is expected to provide for or cooperate in remediation (OHCHR 2011). Where the impact is directly linked through a business relationship, the company is expected to use its leverage to prevent or mitigate harm and, where appropriate, to support remediation efforts. This distinction is critical because it defines the scope of corporate responsibility and the nature of expected responses.

In practice, corporate accountability may take several forms. These include legal liability through court decisions, administrative sanctions imposed by regulatory bodies, contractual consequences such as termination or penalties, reputational damage resulting from public scrutiny, and loss of access to markets or financing. Increasingly, accountability is also shaped by disclosure requirements and stakeholder expectations. Sustainability reporting frameworks, such as TSRS in Türkiye, reinforce the expectation that companies should not only manage risks but also demonstrate how they address them in practice (KGK 2025). This creates a feedback loop in which governance, disclosure, and accountability are closely interconnected.

An important challenge in the Turkish context, as in many jurisdictions, is ensuring that remedy mechanisms are accessible and effective in practice. Barriers such as cost, procedural complexity, lack of awareness, or power imbalances between companies and individuals may limit the ability of affected persons to seek redress. This is particularly relevant for vulnerable groups, including migrant workers, informal workers, or individuals with limited access to legal resources. Addressing these barriers requires both institutional capacity and corporate commitment. Companies can play a role by designing user-friendly grievance mechanisms, supporting mediation or alternative dispute resolution processes, and cooperating with external mechanisms where appropriate.

The interaction between domestic and international mechanisms also deserves attention. A business-related human rights issue arising in Türkiye may be addressed through multiple channels simultaneously: domestic courts, TİHEK proceedings, company grievance mechanisms, OECD NCP processes, or even public campaigns and investor engagement. This multi-channel environment increases the visibility and complexity of corporate accountability. It also means that companies cannot rely solely on a narrow legal defence. They must consider how their actions will be assessed across different forums, each with its own standards, expectations, and audiences.

From a strategic perspective, access to remedy should not be viewed as a purely reactive function activated only after harm has occurred. It is also a preventive tool. Effective grievance mechanisms can identify risks early, provide insight into operational weaknesses, and enable companies to correct problems before they escalate into disputes or legal claims. In this sense, remedy is closely linked to due diligence: it provides the feedback loop necessary to ensure that risk management systems are functioning effectively.

Ultimately, the emphasis on access to remedy and corporate accountability reflects a broader transformation in the role of business in society. Companies are no longer judged solely by their compliance with formal legal requirements. They are increasingly expected to demonstrate that they can respond responsibly when things go wrong, that they provide avenues for affected individuals to be heard, and that they are willing to take corrective action. In Türkiye, this expectation is reinforced by a combination of domestic institutions, international frameworks, and market pressures.

For businesses, the practical implication is clear. A credible human rights compliance programme must include not only policies and risk assessments, but also effective mechanisms for addressing harm. Without such mechanisms, compliance remains incomplete, and accountability remains theoretical.

XI. Public Procurement, State-Business Nexus and State-Owned Enterprises

The relationship between the state and business occupies a particularly important place within the business and human rights framework. While the UN Guiding Principles clearly distinguish between the state duty to protect and the corporate responsibility to respect, they also recognise that these roles are often interconnected. This is especially the case where the state acts not only as regulator, but also as an economic actor—through public procurement, state ownership, public services, or financial support mechanisms. In such situations, the expectations placed on both states and businesses are heightened, and the boundary between public responsibility and private conduct becomes more complex (OHCHR 2011).

Public procurement represents one of the most significant points of interaction between the state and business. Governments are major economic actors, purchasing goods, services, and infrastructure on a large scale. The UNGP framework emphasises that states should promote respect for human rights by business enterprises with which they conduct commercial transactions. This includes taking steps to ensure that public procurement processes incorporate human rights considerations and that contractors respect applicable standards (OHCHR 2011). In practical terms, this means that procurement policies can be used not only to achieve economic efficiency, but also to advance social and human rights objectives.

In Türkiye, public procurement is a central feature of economic activity, particularly in sectors such as construction, infrastructure, energy, healthcare, transportation, and public services. Although the procurement framework is primarily designed around principles such as transparency, competition, and value for money, there is increasing recognition—both internationally and domestically—that procurement processes can also function as tools for promoting responsible business conduct. UNDP Türkiye has explicitly addressed this issue in its work on integrating human rights-based approaches into public procurement, highlighting the importance of embedding due diligence, risk assessment, and stakeholder considerations into procurement practices (UNDP Türkiye 2023).

From a business perspective, participation in public tenders and contracts introduces an additional layer of human rights expectations. Companies seeking to engage in public procurement should be prepared to demonstrate compliance not only with formal legal requirements, but also with broader standards relating to labour conditions, non-discrimination, occupational safety, and ethical conduct. In many cases, public authorities may include contractual clauses requiring compliance with labour laws, environmental standards, and anti-corruption rules. Increasingly, these clauses may also reflect human rights considerations, particularly where projects involve large workforces, significant community impact, or complex supply chains.

The concept of state-owned enterprises (SOEs) adds another dimension to this discussion. Under the UNGPs, states are expected to take additional steps to ensure that enterprises they own or control respect human rights. This reflects the fact that such enterprises operate under the authority or influence of the state and may therefore be seen as extensions of public power (OHCHR 2011). As a result, SOEs are often subject to higher expectations regarding transparency, accountability, and human rights compliance.

In Türkiye, state-owned or state-influenced enterprises play an important role in sectors such as energy, transportation, finance, and infrastructure. For these entities, human rights compliance is not merely a matter of corporate policy, but also a reflection of the state’s own human rights obligations. This creates a dual layer of accountability: the enterprise must meet corporate responsibility standards, while the state must ensure that its ownership or control does not result in human rights harm. In practice, this may require stronger governance structures, clearer reporting lines, enhanced due diligence processes, and closer oversight by public authorities.

The state-business nexus is also evident in situations where companies receive significant public support, such as subsidies, export credits, guarantees, or investment incentives. The UNGPs encourage states to consider human rights performance when providing such support, particularly in cases where the supported activities involve high-risk sectors or regions (OHCHR 2011). For businesses, this implies that access to public funding or support mechanisms may increasingly be linked to the ability to demonstrate responsible conduct, including effective human rights due diligence.

An important issue in this context is the potential transfer or dilution of responsibility through complex contractual arrangements. Large public projects often involve multiple layers of contractors and subcontractors. While the primary contractor may have a direct contractual relationship with the state, much of the actual work may be carried out by secondary or tertiary actors. This creates a risk that human rights responsibilities become fragmented or obscured. The business and human rights framework addresses this by emphasising that responsibility cannot be avoided simply by delegating activities. Both public authorities and primary contractors are expected to exercise due diligence over their partners and supply chains.

For Turkish companies, this has several practical implications. First, companies participating in public procurement should integrate human rights considerations into their bidding and project management processes. This includes assessing labour risks, ensuring compliance across subcontractors, and establishing monitoring and reporting systems. Second, companies should be prepared for increased scrutiny from both public authorities and external stakeholders, particularly in large-scale or high-profile projects. Third, businesses should recognise that public procurement relationships may expose them to reputational and legal risks that extend beyond the immediate contractual framework.

From a governance perspective, the integration of human rights into public procurement also has a broader systemic effect. It contributes to the creation of a level playing field in which responsible business conduct becomes a competitive advantage rather than a disadvantage. Companies that invest in compliance systems, due diligence processes, and ethical practices are better positioned to meet procurement requirements and maintain long-term relationships with public authorities.

Ultimately, the intersection of public procurement, state ownership, and business activity illustrates the evolving nature of human rights governance. The state is no longer only a regulator; it is also a market participant, a contracting authority, and, in some cases, a corporate actor. This multifaceted role creates both opportunities and responsibilities. For businesses in Türkiye, understanding this dynamic is essential. It highlights that human rights compliance is not limited to private market interactions, but is also embedded in the way companies engage with the state, participate in public projects, and operate within publicly influenced economic environments.

XII. Governance, Board Oversight and Internal Compliance Architecture

Human rights compliance is not sustainable unless it is embedded within a company’s governance structure. The UN Guiding Principles make clear that respecting human rights is not a peripheral function, but a responsibility that must be integrated into corporate policy, management systems, and decision-making processes (OHCHR 2011). This requires moving beyond isolated compliance efforts toward a structured internal architecture in which responsibility is clearly allocated, processes are formalised, and oversight is exercised at the highest levels of the organisation. The Council of Europe similarly emphasises that effective implementation depends on governance arrangements capable of translating legal principles into operational practice (Council of Europe 2018).

At the centre of this architecture lies the board of directors and senior management. Human rights risks can affect a company’s legal exposure, financial performance, operational continuity, and reputation. As such, they fall squarely within the remit of board-level oversight. The board should ensure that the company has an appropriate human rights policy, that due diligence processes are in place, and that risks are regularly reviewed and managed. This does not mean that boards must handle operational details. Rather, they must set the tone, approve strategic direction, allocate resources, and monitor performance. In the Turkish context, where sustainability reporting under TSRS is increasingly linked to governance disclosures, board-level engagement becomes even more important (KGK 2025).

A key element of internal architecture is the adoption of a human rights policy commitment. Under the UNGPs, such a policy should be publicly available, approved at the most senior level, informed by relevant expertise, and communicated internally and externally (OHCHR 2011). However, the effectiveness of a policy depends on its integration into business processes. A policy that is not reflected in procurement rules, employment practices, data governance, or operational procedures is unlikely to have practical impact. For Turkish companies, this means aligning the human rights policy with existing frameworks such as labour compliance, occupational safety systems, anti-discrimination measures, and data protection policies.

Beyond policy, companies must establish clear governance structures that define roles and responsibilities. Human rights compliance typically involves multiple functions, including legal, compliance, human resources, procurement, sustainability, internal audit, and operations. Each function may encounter different types of risk. For example, human resources may address workplace equality and grievance handling; procurement may manage supplier risks; legal teams may assess regulatory exposure; and sustainability teams may handle reporting and stakeholder engagement. Without coordination, these efforts may remain fragmented. A coherent governance model requires clear reporting lines, defined responsibilities, and mechanisms for cross-functional collaboration.

An effective architecture also requires the integration of human rights considerations into risk management systems. Companies should include human rights risks within their broader enterprise risk frameworks, ensuring that such risks are identified, assessed, prioritised, and monitored. This includes distinguishing between different levels of severity, likelihood, and potential impact. Importantly, human rights risk assessment should not be limited to risks that are immediately financial. As emphasised in the UNGPs, the focus should be on the severity of impacts on individuals and communities, even where financial consequences are not yet apparent (OHCHR 2011). Over time, however, such impacts may become financially material, particularly in light of disclosure requirements and stakeholder expectations.

Another critical component is training and capacity building. Policies and procedures are only effective if employees understand them and are capable of implementing them. Training should therefore be tailored to different roles within the organisation. Senior management may require strategic understanding of human rights risks; procurement teams may need guidance on supplier due diligence; human resources personnel may focus on equality and grievance handling; and operational staff may need training on safety and community interaction. In Türkiye, where awareness of business and human rights concepts may still be developing in some sectors, training plays a particularly important role in bridging the gap between international standards and day-to-day practice.

The architecture must also include internal reporting and escalation mechanisms. Employees should be able to report concerns or risks through secure and accessible channels, including whistleblowing systems where appropriate. These mechanisms should ensure confidentiality, protect against retaliation, and provide clear procedures for investigation and response. Importantly, internal reporting should not be treated solely as a compliance requirement. It is also a source of information that can help the company identify systemic issues, improve processes, and prevent future harm.

Closely linked to reporting is the need for monitoring and documentation. Companies should maintain records of risk assessments, due diligence activities, training sessions, complaints received, actions taken, and outcomes achieved. This documentation serves multiple purposes. It supports internal management, enables external reporting, and provides evidence of compliance in case of audits, investigations, or disputes. In the context of TSRS and other sustainability frameworks, the ability to demonstrate structured governance and documented processes is becoming increasingly important (KGK 2025).

An often overlooked aspect of internal architecture is the alignment between corporate culture and formal systems. Even well-designed policies and procedures may fail if they are not supported by organisational culture. Incentive structures, performance metrics, and leadership behaviour all influence how seriously human rights considerations are taken. For example, if procurement teams are evaluated solely on cost reduction and speed, they may overlook supplier risks. If managers prioritise output over safety, workplace risks may increase. Effective governance therefore requires aligning incentives with human rights objectives, ensuring that compliance is not perceived as an obstacle to business performance but as an integral part of it.

In the Turkish context, the integration of human rights into governance is also influenced by evolving regulatory and market expectations. Sustainability reporting requirements, international supply chain pressures, and stakeholder scrutiny are pushing companies toward more structured and transparent governance models. This creates both challenges and opportunities. Companies that proactively develop robust internal architectures are better positioned to adapt to regulatory changes, meet investor expectations, and maintain competitive advantage.

Finally, governance architecture should include mechanisms for continuous improvement. Human rights risks are dynamic, and business environments change over time. Companies should therefore periodically review their policies, processes, and performance, taking into account new risks, stakeholder feedback, and evolving standards. This may involve internal audits, external assessments, benchmarking against industry practices, or participation in multi-stakeholder initiatives. Continuous improvement ensures that human rights compliance remains effective and relevant rather than static and outdated.

In conclusion, governance, board oversight, and internal compliance architecture form the backbone of effective human rights compliance. They translate abstract principles into practical systems and ensure that responsibility is embedded throughout the organisation. For businesses in Türkiye, developing such an architecture is not only a matter of aligning with international standards, but also a strategic necessity in an increasingly complex and interconnected regulatory environment.

XIII. Sector-Based Risk Mapping for Türkiye

A credible business and human rights programme in Türkiye cannot rely on abstract principles alone. It must be grounded in sector-specific risk mapping. This is because human rights impacts do not arise uniformly across the economy. They are shaped by workforce structure, production models, supply-chain design, community interface, land use, data intensity, outsourcing patterns, and the degree of reliance on temporary, seasonal, migrant, or subcontracted labour. In Türkiye, this need for sector sensitivity is particularly important given the country’s strong position in manufacturing, agrofood, mining and metals, infrastructure, logistics, and services, as well as its continued integration into international investment and supply chains.

1. Textiles and Ready-Made Garments

The textiles and ready-made garments sector should be treated as one of the highest-priority areas for human rights risk mapping in Türkiye. The sector’s importance to exports and international supply chains makes it especially exposed to buyer scrutiny, audit systems, and reputational risk. At the same time, the commercial structure of the sector often involves layered subcontracting, seasonal or fluctuating demand, tight lead times, price pressure, and dispersed workshop-based production. In business and human rights terms, these characteristics can create elevated risks around excessive working hours, underpayment, informal labour, gender-based vulnerability, barriers to worker voice, and hidden subcontracting. Because many Turkish textile producers are linked to European and global brands, even non-listed firms may face due diligence expectations through contractual and value-chain relationships rather than direct legislation alone.

2. Agriculture and Agrofood

Agriculture and agrofood also require close attention, especially where production depends on seasonal labour, temporary migration, labour intermediaries, or family-based harvesting systems. ILO materials relating to Türkiye specifically identify seasonal agriculture and hazelnut harvesting as priority areas in efforts to eliminate the worst forms of child labour, and they also stress the need for public-private partnerships in northern Türkiye to address child labour risks in agriculture. These sources are significant because they show that certain agricultural segments in Türkiye are already recognised internationally as higher-risk environments for labour-rights abuse. In practical compliance terms, this means companies operating in or sourcing from Turkish agriculture should prioritise risks linked to child labour, recruitment practices, accommodation conditions, wage payment, transport, occupational safety, and access to grievance mechanisms for seasonal workers.

3. Construction and Infrastructure

Construction and infrastructure projects are another high-risk category. Türkiye’s official investment materials continue to emphasise the scale and strategic importance of infrastructure, while labour and safety materials from the Ministry of Labour and Social Security underline the importance of occupational health and safety governance in Turkish working life. In human rights terms, the risks in this sector commonly arise from multi-layered subcontracting, mobile or temporary workforces, tight project schedules, worksite accommodation, and serious occupational safety exposure. Large infrastructure works can also generate community-facing risks involving access, noise, pollution, land-use conflict, or local disruption. For these reasons, construction and infrastructure businesses in Türkiye should map not only direct workforce risks, but also subcontractor safety performance, dormitory and transport conditions, local community impacts, and emergency response capability.

4. Mining and Metals

Mining and metals should be treated as a sector with heightened human rights sensitivity because of the combination of labour risk, environmental exposure, land-use implications, and community impact. The official Investment Office materials describe mining and metals as an important and growing sector in Türkiye and present the country as having significant geological and investor potential. From a business and human rights perspective, that same economic importance increases the need for careful due diligence. Mining-related risks may include occupational safety, contractor dependence, environmental contamination, water use, community consultation, livelihood disruption, and disputes connected to land access or local opposition. The sector therefore illustrates a point central to the broader framework: where operations involve significant physical, environmental, and territorial footprints, the company’s human rights exposure extends well beyond workplace compliance and into community rights, environmental health, and access to remedy.

5. Logistics and Transportation

Logistics and transportation merit distinct treatment because Türkiye’s location and infrastructure make it a major regional movement corridor for goods and services. The human rights risks in this sector often differ from those in factory-based production. They may involve excessive working time, road safety, warehouse conditions, subcontracted delivery chains, performance-based pressure, worker surveillance, and limited access to complaint channels for outsourced drivers or handlers. Where logistics operations are heavily outsourced or digitally managed, accountability can become diffused across contractors and platforms. In such settings, companies should map how delivery pressure, pricing structures, route expectations, and subcontracting arrangements may indirectly produce adverse impacts on safety, dignity, privacy, or fair working conditions. The sector’s strategic role in Türkiye’s broader investment and infrastructure environment reinforces the need for this analysis.

6. Manufacturing and Heavy Industry

More broadly, manufacturing and heavy industry in Türkiye should be mapped as a core human-rights risk area because of the country’s large industrial base and international production role. Official investment materials continue to highlight Türkiye’s strong manufacturing platform, while labour and occupational-safety sources stress the central role of workplace regulation and enforcement institutions. In human rights terms, the key risks may include health and safety, contractor management, discrimination, wage practices, worker participation, exposure to hazardous materials, and supply-chain opacity. The compliance challenge is especially acute where production schedules are aggressive, export dependence is high, or labour is segmented between direct and indirect workers. In these contexts, the distinction between legal compliance and human rights compliance becomes very important: a company may formally monitor its own payroll while still failing to understand the real conditions under which production targets are met.

7. Technology, ICT, Financial Services, and Data-Driven Sectors

Although labour-intensive sectors often dominate business and human rights discussions, technology, ICT, financial services, and data-driven sectors in Türkiye should not be underestimated. Official investment materials identify ICT, financial services, and startups among Türkiye’s priority sectors. In these sectors, the most significant human rights issues may involve privacy, data governance, algorithmic bias, employee surveillance, digital exclusion, fraud-prevention systems, and the human impact of automated decision-making. These risks are less visible than factory-floor abuses but may be equally serious, especially where large datasets, consumer profiling, workplace monitoring, or financial access decisions are involved. For companies in these sectors, human rights risk mapping should therefore include not only labour conditions, but also data handling, vendor access, information security, fairness in automated systems, and the accessibility of complaint and correction mechanisms.

8. A Risk-Based Compliance Approach for Turkish Businesses

The practical lesson for companies in Türkiye is that sector-based mapping should be used to prioritise action. Not every company faces the same level or type of risk, and not every risk can be addressed simultaneously. The most effective approach is to begin with the sectors, sites, relationships, and business models where harm is most likely to be severe, hidden, or difficult to remedy. In some cases, that will mean focusing on subcontracted labour and occupational safety. In others, it will mean seasonal agriculture, migrant labour, community impacts, or privacy-intensive operations. What matters is that the company can show that it has identified its highest-risk areas in a reasoned and documented way, and that it has aligned governance, supplier oversight, grievance mechanisms, and reporting with those risks. That is the essence of a serious business and human rights approach in Türkiye: not generic policy language, but risk-sensitive prioritisation tied to the actual structure of the business and the sectors in which it operates.

XIV. Practical Roadmap: How Businesses in Türkiye Can Build a Human Rights Compliance Programme

While the preceding sections have outlined the legal, conceptual, and sectoral dimensions of business and human rights, companies ultimately require a practical and implementable roadmap. Human rights compliance is not achieved through isolated policies or reactive measures. It requires a structured, continuous, and risk-based programme that integrates governance, due diligence, stakeholder engagement, and accountability mechanisms. The UN Guiding Principles provide the overarching logic for such a programme, emphasising policy commitment, human rights due diligence, and access to remedy as core elements (OHCHR 2011). Building on this foundation, the following roadmap translates these principles into a practical framework tailored to businesses operating in Türkiye.

1. Establish Board-Level Commitment and Policy Framework

The starting point of any credible human rights compliance programme is a clear commitment at the highest level of the organisation. The UNGPs require that companies adopt a policy commitment approved by senior leadership and embedded across the enterprise (OHCHR 2011). In practice, this means that the board of directors or equivalent governing body should formally endorse a human rights policy that reflects international standards and is aligned with the company’s operational context.

For Turkish companies, this policy should not be treated as a symbolic document. It should be linked to existing frameworks such as labour compliance, occupational safety, anti-discrimination policies, data protection, and sustainability governance. The policy should clearly define expectations for employees, suppliers, contractors, and business partners, and it should be communicated both internally and externally.

2. Conduct Risk-Based Human Rights Mapping

Once a policy framework is in place, the company must identify where its most significant human rights risks lie. This requires a risk-based mapping exercise covering:

• Operations (workforce, sites, processes)
• Supply chains (suppliers, subcontractors, intermediaries)
• Products and services (including downstream impacts)
• Geographic exposure (regions, communities, regulatory environments)

The UNGPs emphasise that companies should focus on the severity and likelihood of impacts on people, not only on financial risk (OHCHR 2011). In Türkiye, this may involve identifying sector-specific risks such as subcontracted labour in textiles, seasonal work in agriculture, safety risks in construction, or privacy risks in digital services.

Risk mapping should also take into account vulnerable groups, including migrant workers, women, temporary workers, and individuals in informal employment arrangements. This ensures that the programme addresses not only general risks but also those affecting the most exposed stakeholders.

3. Integrate Human Rights into Business Processes

A common failure in corporate compliance programmes is the gap between risk identification and operational integration. Human rights considerations must be embedded into core business functions, including:

• Human Resources: recruitment, contracts, equality, grievance handling
• Procurement: supplier selection, contractual clauses, audit rights
• Operations: safety management, production planning, community engagement
• Legal and Compliance: regulatory monitoring, investigation procedures
• IT and Data Governance: privacy, data protection, algorithmic fairness

The UNGPs require that responsibility for addressing impacts be assigned to appropriate functions and levels within the enterprise (OHCHR 2011). For Turkish companies, this means that human rights compliance should not be confined to a single department. It must become a cross-functional governance issue.

4. Establish Supplier and Value Chain Controls

Given the importance of supply chain risks, companies must implement mechanisms to manage human rights impacts beyond their direct operations. This may include:

• Supplier codes of conduct aligned with international standards
• Risk-based supplier screening and segmentation
• Contractual obligations on labour, safety, and non-discrimination
• Audit programmes and site visits
• Corrective action plans and follow-up processes
• Training and capacity-building for suppliers

However, as discussed earlier, formal controls alone are insufficient. Companies must also examine whether their own commercial practices—such as pricing, deadlines, and order volumes—create pressures that undermine compliance. Effective supply chain governance requires aligning commercial decisions with human rights objectives.

5. Develop Grievance Mechanisms and Reporting Channels

An effective human rights compliance programme must include accessible and trustworthy grievance mechanisms. The UNGPs set out criteria for such mechanisms, including accessibility, transparency, predictability, and protection against retaliation (OHCHR 2011).

For businesses in Türkiye, this may involve:

• Internal complaint systems for employees
• Anonymous reporting channels (whistleblowing)
• Mechanisms accessible to supplier workers
• Multilingual access for diverse workforces
• Clear procedures for investigation and response

Grievance mechanisms should not be seen only as compliance tools. They are also early warning systems that help identify risks before they escalate into disputes or legal claims.

6. Implement Monitoring, Metrics, and Internal Reporting

To ensure effectiveness, companies must track the performance of their human rights programme. This involves:

• Defining key performance indicators (KPIs)
• Monitoring incidents, complaints, and remediation outcomes
• Conducting internal audits and reviews
• Collecting feedback from stakeholders

Monitoring should be both quantitative and qualitative. For example, accident rates, turnover, or complaint numbers may provide useful data, but they should be complemented by worker feedback, site visits, and independent assessments.

Documentation is equally important. Companies should maintain records of due diligence activities, risk assessments, training, complaints, and actions taken. This supports both internal management and external accountability.

7. Align with Sustainability Reporting and Disclosure Requirements

Human rights compliance increasingly intersects with sustainability reporting. In Türkiye, TSRS requires companies within its scope to disclose material sustainability-related risks and governance practices (KGK 2025).

Companies should therefore ensure that their human rights programme supports:

• Identification of material social risks
• Integration into governance and risk management systems
• Consistent and accurate external reporting
• Alignment with investor and stakeholder expectations

This alignment helps companies move from informal commitments to structured and verifiable disclosure, enhancing credibility and transparency.

8. Provide for Remediation and Corrective Action

Where adverse impacts occur, companies must be prepared to respond effectively. The UNGPs require businesses to provide for or cooperate in remediation where they have caused or contributed to harm (OHCHR 2011).

In practice, this may involve:

• Compensation or financial remedy
• Correction of wage or contract issues
• Improvement of working conditions
• Disciplinary action or supplier disengagement
• Support for affected individuals or communities

Remediation processes should be fair, timely, and responsive to the needs of affected parties. They should also feed back into the due diligence system to prevent recurrence.

9. Ensure Training, Awareness, and Cultural Integration

Policies and procedures are only effective if they are understood and applied. Companies should therefore invest in training programmes tailored to different roles:

• Senior management: strategic oversight and accountability
• Operational staff: practical implementation and risk awareness
• Procurement teams: supplier engagement and due diligence
• HR teams: equality, grievance handling, and workplace rights

Beyond training, companies should foster a culture in which human rights considerations are integrated into everyday decision-making. This includes aligning incentives, performance metrics, and leadership behaviour with compliance objectives.

10. Commit to Continuous Improvement

Human rights compliance is not a static exercise. Business operations, regulatory environments, and stakeholder expectations evolve over time. Companies should therefore establish processes for periodic review and improvement, including:

• Regular risk reassessment
• Updating policies and procedures
• Benchmarking against industry practices
• Engaging with stakeholders and experts
• Learning from incidents and feedback

Continuous improvement ensures that the compliance programme remains effective and responsive to changing conditions.

In summary, building a human rights compliance programme in Türkiye requires more than adopting international language or isolated measures. It demands a structured, integrated, and risk-based approach that connects governance, operations, supply chains, and stakeholder engagement. Companies that implement such a programme are better positioned to manage risk, meet regulatory and market expectations, and operate sustainably in both domestic and international environments.

XV. Conclusion: The Future of Human Rights Compliance in Türkiye

The business and human rights landscape in Türkiye is undergoing a clear and irreversible transformation. What was once perceived as a voluntary, ethics-driven domain is rapidly evolving into a multi-layered compliance framework shaped by international standards, regional regulatory influence, domestic legal structures, sustainability reporting requirements, and market expectations. The UN Guiding Principles continue to provide the conceptual foundation of this system, while European regulatory developments, OECD mechanisms, and sustainability disclosure frameworks are reinforcing its practical application (OHCHR 2011), (EEAS 2025), (OECD 2024), (KGK 2025).

Although Türkiye has not yet adopted a single, comprehensive statute dedicated exclusively to business and human rights, the cumulative effect of its legal and institutional environment is significant. Labour law, occupational safety rules, anti-discrimination protections, data protection legislation, sustainability reporting standards, and institutional mechanisms such as TİHEK collectively create a functional compliance ecosystem. This ecosystem is further strengthened by international engagement and capacity-building initiatives supported by organisations such as UNDP (UNDP Türkiye 2023), (TİHEK 2024/6701).

Looking forward, several trends are likely to shape the future of human rights compliance for businesses in Türkiye. First, regulatory convergence will continue, particularly through the influence of European markets and international supply chains. Turkish companies engaged in export-oriented activities will increasingly be required to demonstrate compliance with human rights due diligence standards, whether through formal regulation or contractual expectations. Second, transparency and disclosure will become more central. Sustainability reporting frameworks such as TSRS are already pushing companies toward more structured governance and risk reporting, and this trend is expected to deepen over time (KGK 2025). Third, accountability mechanisms—both judicial and non-judicial—are likely to gain prominence, increasing the importance of grievance systems, remediation processes, and documentation.

At the same time, the evolution of this field should not be understood solely in terms of compliance burdens. Human rights governance also presents opportunities. Companies that proactively adopt structured due diligence systems, strengthen supply chain oversight, and integrate human rights into corporate governance are better positioned to maintain market access, attract investment, build resilient business relationships, and enhance long-term sustainability. In this sense, human rights compliance is not only about risk avoidance, but also about strategic positioning in a rapidly changing global economy.

In this complex and evolving environment, businesses require not only awareness but also specialised legal and strategic guidance. Bıçak Law Firm provides comprehensive services in the field of business and human rights, including:

• Development and implementation of human rights compliance programmes
• Design and execution of human rights due diligence (HRDD) processes
• Supply chain risk assessment and governance structures
• Advisory on labour law, anti-discrimination, and workplace rights
• Legal guidance on sustainability reporting (TSRS) and ESG compliance
• Structuring of grievance mechanisms and remediation processes
• Risk analysis related to international sanctions, export controls, and cross-border operations
• Support in corporate governance, internal policies, and compliance architecture
• Representation and advisory in disputes, investigations, and regulatory proceedings

Through these services, Bıçak Law Firm assists companies in translating complex international standards into practical, enforceable, and business-oriented compliance solutions tailored to the Turkish legal environment.

It is also important to underline that the author of this article, Prof. Dr. Vahit Bıçak, has played a foundational role in the development of the human rights institutional framework in Türkiye. As one of the founding figures of the Human Rights and Equality Institution of Türkiye (TİHEK), he has contributed directly to the establishment of a national mechanism dedicated to the protection and promotion of human rights and equality. This background informs the analytical and practical perspective reflected throughout this article.

In conclusion, the future of human rights compliance in Türkiye will be defined by integration rather than fragmentation. The interaction between international standards, domestic law, institutional oversight, and market expectations will continue to deepen, creating a more coherent and demanding compliance environment. For businesses, the key challenge—and opportunity—will be to move beyond reactive approaches and to build proactive, structured, and credible human rights governance systems. Those that do so will not only meet emerging legal and regulatory expectations, but also position themselves as responsible and competitive actors in both domestic and global markets.