Emergence of the notion of “due diligence” in labour law and how it is integrated into the legal system
- Cet article est une traduction de :
- L’émergence de la notion de « diligence raisonnable » en droit du travail et les formes de son intégration juridique [fr]
Résumés
La « diligence raisonnable » est apparue dans le domaine du droit du travail avant d’occuper le centre du débat international relatif à la responsabilité directe des entreprises en matière de respect des droits de l’homme. Cette notion étrange pose le défi d’en établir le sens et la portée, car divers instruments normatifs et jurisprudentiels y font référence sans la définir précisément. Cette absence de définition contraste avec l’impact potentiel de la diligence raisonnable sur notre discipline, si elle devenait l’instrument de mesure des obligations de l’employeur dans la relation de travail. Nous tenterons ici de lui donner un sens cohérent, en identifiant ses principales caractéristiques et en prenant comme point de départ ces textes juridiques épars. Nous nous posons également la question de savoir si le droit du travail pourra assimiler le concept, ou si celui-ci donnera lieu à des modifications profondes.
Entrées d’index
Mots-clés :
diligence raisonnable, droits humains au travail, système juridique, principes du droit du travailPlan
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- 1 But the origin of the duty of diligence seems to go back further, to the “sources of American publi (...)
1The real aim of this article is to analyse the appearance of “due diligence” in legal discourse and consider: a) the meaning of its use in labour law and b) how it is integrated into the legal system. At first sight, this seems to be a “shifting concept”: first appearing in international law in relation to States’ obligations concerning the most serious of human rights violations, due diligence has made a place for itself in the instruments of soft law, such as Declarations of Principles and Directives on multinational enterprises, to finally appear in draft binding treaties on business and human rights.1
- 2 M. García Elorrio, «Algunas consideraciones en torno a la naturaleza y alcance de la noción de dili (...)
2The international courts that apply the principle of due diligence acknowledge that it is a concept whose contours are too vague; they consider it as being part of a flexible category, which is not based on any reference standard in terms of compliance with the obligations.2 The aim here therefore is not to engage in an academic exercise that is of no practical interest, but rather to dig into the genealogy of the uses of the term and afterwards to try and identify the different possible forms of its application in labour law.
I - Genealogy of the notion of due diligence
3The search for a plausible origin concerning the use of the term “due diligence” must concern the branches of the law that recognised it first, in order to get a better understanding of the meaning and usefulness of this notion for safeguarding people’s rights. This notion is found in Inter-American human rights case law (A) and in the international instruments on human rights and multinational enterprises (B).
A - Case law of the Inter-American Court of Human Rights
4Due diligence appears, depending on the competent international courts, as a reference standard in terms of respecting human rights. Let us look at the case of Latin America.
5According to Inter-American Court of Human Rights (IACtHR) case law, due diligence constitutes an instrument that allows the measurement of compliance with the obligations contained in the American Convention on Human Rights. In particular, the obligation to respect the rights that are listed in it (abstain from violating rights through its agents) and the obligation to adopt all the measures and create all the conditions necessary to render those rights operative and effective (Articles 1 and 2).
6These duties of States translate into an obligation to investigate and to comply with certain procedural obligations. The emphasis is placed on situations such as extra-judicial executions, forced disappearances, torture, etc., on the basis of which the monitoring bodies have developed a doctrine and a body of case law that is relevant to the subject dealt with here.
- 3 G. De León, V. Kristicevic and L. Obando, «Debida diligencia en la investigación de graves violacio (...)
- 4 Ibid., p. 22.
7Thus, in the Velásquez Rodríguez v. Honduras case in 1988, it should be noted that the IACtHR, in its first judgment in a contentious case, established the existence of a State’s legal duty to “take reasonable steps to prevent human rights violations and to use the means at its disposal to carry out a serious investigation of violations committed within its jurisdiction, to identify those responsible, to impose the appropriate punishment and to ensure the victim adequate compensation.”3 This IACtHR case law has been systematised in the light of the provisions of Article 1.1 of the American Convention which demands the respect and protection of rights and freedoms, and that States “prevent, investigate, and punish every violation of rights protected by the Convention.”4 According to this logic, the State has a duty to “respect” human rights (negative obligation) and to guarantee them by procedural and judicial means (positive obligation).
- 5 M. García Elorrio, op. cit.
- 6 G. De León, V. Kristicevic and Obando, op. cit., p. 32.
8But it should be noted that, even in connection with the State’s obligation to investigate “serious” human rights violations, the IACtHR does not propose a doctrine and does not provide a definition of due diligence. This is why it has been said that there is no “consensus in case law” concerning the “legal nature” of the notion studied.5 As for the procedural aspects of due diligence, their content has been synthesised around the principles of rapidity, timeliness, competence, independence and impartiality, exhaustiveness and the participation of victims and their families.6
- 7 S. García Muñoz, “Informe sobre empresas y Derechos Humanos: estándares interamericanos” Special Ra (...)
9Finally, from the point of view of the Inter-American Commission on Human Rights and the Rapporteur on economic, social and cultural rights, the fundamental criteria concerning business and human rights include due diligence formulated as a right of prevention, according to García Muñoz.7
B - Socially responsible behaviour of companies in connection with international instruments
10Due diligence has also significantly influenced the non-binding instruments on the social or responsible behaviour of multinational enterprises, bringing it substantially closer to our field of labour law.
1 - The United Nations Guiding Principles and other non-binding instruments
11The most emblematic example of this soft law is the document entitled “Guiding Principles on Business and Human Rights. Implementing the United Nations “Protect, Respect and Remedy” Framework” of 2011.
12“Due diligence” is seen as a process that must be implemented by the enterprise in order to meet its obligation to respect human rights. According to the Interpretive Guide to the Guiding Principles, it can be defined as “an ongoing management process that a reasonable and prudent enterprise needs to undertake, in the light of its circumstances (including sector, operating context, size and similar factors) to meet its responsibility to respect human rights.”
13Guiding Principle no. 17 defines the specific obligations that business enterprises must respect in terms of due diligence as part of the evaluation of the real and potential impact of their activities on human rights:
14“Human rights due diligence
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should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships
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will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations
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should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.”
- 8 A. Guaman, “Diligencia debida en derechos humanos y empresas transnacionales: de la ley francesa a (...)
15To sum up, it has been stated that the Guiding Principles conceive of due diligence as an operational means enabling business enterprises to respect human rights, but do not say what options States have to guarantee the implementation of these due diligence processes by businesses. Nor do they establish, as indicated above, any legally binding obligation.8
16As for OECD Guidelines for Multinational Enterprises, they conceive of due diligence as “the process enterprises should carry out to identify, prevent, mitigate and account for how they address these actual and potential adverse impacts” on human rights.
- 9 Ibid.
17Adoración Guamán9 stresses that: “In light of the comparative analysis of De Schutter et al (2012), there are numerous examples of the application of the human rights due diligence obligations and the different ways of proceeding. First of all, States can demand that business enterprises introduce due diligence processes, either directly by passing a law, or indirectly by giving enterprises the possibility of using due diligence as a means of defence against allegations of criminal, civil or administrative violations. Secondly, the State also has the possibility of adopting rules that provide incentives and benefits to businesses in exchange for their ability to show due diligence. Thirdly, States can encourage the application of due diligence by transparency and disclosure mechanisms, and finally, there are obviously rules that allow all the aforementioned approaches to be combined.”
- 10 These paragraphs provide as follows:
18The OECD Guidelines seize upon the notion of “due diligence” to place it among the obligations of businesses. In concrete terms, it says in Chapter II “General Policies”, under A, no. 10, that Enterprises should “carry out risk-based due diligence, for example by incorporating it their enterprise risk management systems, to identify, prevent and mitigate actual and potential adverse impacts as described in paragraphs 11 and 12”.10
19Chapter IV “Human rights” emphasises that “States have a duty to protect human rights” and that “enterprises should: carry out human rights due diligence as appropriate to their size, the nature and context of operations and the severity of the risks of adverse human rights impacts” (no. 5).
20To sum up, the Guidelines establish that:
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multinational enterprises must carry out human rights due diligence;
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this due diligence includes a duty to identify, prevent and mitigate the adverse impacts of their operations (Ch. II, A, no.10);
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the scope of the due diligence depends on the circumstances (Ch. II, A, no. 10), namely the size, nature and context of the operations and the severity of the risks of adverse impacts (Ch. IV, no. 5);
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where adverse impacts do occur, enterprises have a duty to “address” them (Ch. IV, no. 2);
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adverse impacts are those caused by its own operations or directly linked to them by “business relationship” (Ch. II, A, nos. 11 and 12).
21The addition of certain parameters to evaluate the responsibility of a business in terms of respecting human rights (such as the size of the enterprise, the context, the seriousness of the situation etc.) may limit the guarantees of protection set out in the Guidelines, which makes the exercising and effectiveness of the rights dependent on factors that result from exemptions from responsibility.
22The amendment of the ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy also mentions due diligence, but without developing the OECD guidelines we have just discussed. The ILO has also incorporated the duty of due diligence in its Resolution concerning Decent work in global supply chains (2016).
2 - The focuses of the debate on due diligence in the planned binding treaty on enterprises and human rights
23Among recent initiatives, the process that has been ongoing since 2005 within the United Nations Commission on Human Rights (UNCHR) deserves our attention.
24That year, the Council was unable to reach a consensus on the responsibility of transnational corporations to respect human rights. The Commission then asked the United Nations Secretary-General to appoint a Special Representative on this issue. It appointed John Ruggie, a Professor at Harvard University. At the end of his mandate and following several pertinent reports, in 2008 Professor Ruggie produced a document entitled “Guiding Principles on Business and Human Rights. Implementing the United Nations “Protect, Respect and Remedy” Framework”, better known as the “Guiding Principles”.
- 11 D. Bilchitz, “El marco Ruggie: ¿una propuesta adecuada para las obligaciones de Derechos Humanos de (...)
25The main objective of Prof. Ruggie’s work was to remedy the lack of clarity on business enterprises’ responsibilities in terms of the protection of human rights, and to try and find a consensus through an approach based on “due diligence”.11
26The so-called “Ruggie Report” sees the concept of due diligence as an “obligation not to”, in other words enterprises must guarantee that their activities do not have adverse impacts on human rights.
27After that, and still in connection with the process of constructing a binding instrument, an initiative appeared led by a few countries, such as Ecuador and South Africa, and supported by a various organisations from civil society. This initiative aimed to draw up a draft treaty that would be directly and definitively binding in order to regulate the activities of transnational corporations, by guaranteeing “protection, justice and adequate compensation for victims of human rights violations”, as stated in one of the basic documents concerning the proposal.
28With its Resolution 26/9 of 26 June 2014, the Human Rights Council decided to “establish an open-ended intergovernmental working group on transnational corporations and other business enterprises with respect to human rights, whose mandate shall be to elaborate an international legally binding instrument to regulate, in international human rights law, the activities of transnational corporations and other business enterprises.” The task was entrusted to an Open-ended Intergovernmental Working Group (OEIGWG).
29The duty of due diligence is developed in detail in Article 6 of the second revised draft of the binding instrument, published in August 2020, which describes it as the obligation to “identify, monitor, take appropriate measures to prevent, inform and mitigate, to inform and consult”, etc.
- 12 Bold added by the author.
30Thus defining due diligence as an obligation that States should impose on enterprises, Article 8.8 defines the type of liability in the event of a failure to comply with these standards: “Human rights due diligence shall not automatically absolve a legal or natural person conducting business activities from liability for causing or contributing to human rights abuses or failing to prevent such abuses by a natural or legal person as laid down in Article 8.7. The court or other competent authority will decide the liability of such entities after an examination of compliance with applicable human rights due diligence standards.”12
31The absence of automatic exoneration from liability of enterprises that have respected the requirement for due diligence, has largely been seen as a positive step in the - still ongoing - discussions at the United Nations. However, conversely, if it must be acknowledged that there is no automatic exoneration from liability in the event of due diligence, the fact remains that a court will ultimately “decide liability” after having examined, precisely, compliance with this obligation. Violation of a human right matters less than the exemptions from liability based on due diligence.
32The problem with this proposal in general in terms of enterprises’ liability lies in the fact that due diligence leads to a sort of shift in the classic meaning of compliance with obligations, to occupy a central place, as Articles 6, 8.7 and 8.8 of the second draft of the binding treaty clearly show.
II - A duty of best endeavours or performance?
33By relying on a classic ordinary law distinction between “duties of best endeavours or performance”, it is possible to make a certain analysis of the meaning and scope of the notion of due diligence.
34If we look at the declarations of the IACtHR, it seems that since its first decision in the Velásquez Rodríguez v Honduras case, it has considered the obligation to prevent and investigate as a duty of best endeavours or conduct.
35For more clarity, it is necessary to quote from the 2008 Valle Jaramillo et al v. Colombia case, in which the IACtHR expressed itself in these terms: “However, the Court has also recognized that a State cannot be responsible for every human rights violation committed by individuals subject to its jurisdiction. In other words, even though the legal consequences of an act or omission of an individual is a violation of the human rights of another, that violation cannot be automatically attributed to the State, but must be considered in light of the particular circumstances of the case and the way the State has carried out its obligations as guarantor. Indeed, the nature erga omnes of the State’s Convention obligations do not entail its unlimited responsibility for every act of an individual, because the obligation of the State to adopt preventive measures to protect individuals in their relationships with each other is conditioned by its awareness of a situation of real and imminent risk for a specific individual or group of individuals, and on the existence of the reasonable possibility of preventing or avoiding that danger.”
36According to this strict conception of the duty of diligence, responsibility is confined to the knowledge of the risk, the identification of the party responsible and the possibilities of preventing the damage. This constitutes a return to subjective responsibility, which places the heavy burden of proof on the victim.
- 13 S. García Muñoz, “Informe sobre empresas y Derechos Humanos: estándares interamericanos”, op. cit., (...)
37Others consider due diligence as a rather wider obligation. This is what García Muñoz stated:13 “In its first decision in a contentious case, the Inter-American Court indicated that: Article 1.1 is essential to determining whether a human rights violation recognised by the Convention can be attributed to a State Party. Indeed, this article imposes on the States Parties fundamental duties of respect and protection, so that any violation of the human rights recognised in the Convention that can be attributed, according to rules of international law, to the action or omission of a public authority, constitutes an act attributable to the State and for which it is accountable under the conditions laid down by the Convention itself (...). In these cases, to establish that a violation of the rights enshrined in the Convention has taken place, it is not necessary to determine the guilt of the perpetrators or their intentions, nor to identify the agents to whom the violations are attributed individually. It is enough to demonstrate that the acts or omissions of the State have allowed the perpetration of these violations or that the State has violated one of its obligations.”
38According to the labour law standards of the Inter-American system, the Additional Protocol to the American Convention on Human Rights (Protocol of San Salvador) establishes that the States undertake to guarantee the exercise of the rights set forth therein, without discrimination of any kind (Article 3), which necessarily implies the introduction of protective measures against acts by third parties, in this case, business enterprises, which are fundamental actors in the area of economic and social relations.
39The real question is whether, in the event of a human rights violation, the emphasis will be placed on the objective responsibility due to the horizontality of the passive subjects (which is not limited to the State), or whether due diligence will be invoked as part of a subjective approach to the behaviour of the enterprise.
III - Final considerations
40After completing this journey on the path of “due diligence”, now is the time to draw some conclusions, which will necessarily be preliminary conclusions since due diligence is “evolving” and “shifting”. As we have seen, today it represents a controversial issue in the United Nations debate on the extent of business enterprises’ responsibility for their activities.
A - Terminological ambiguity
41This notion is an ambiguous one insofar as its definition and scope lack precision, as even the courts that apply it are agreed.
42This lack of a clear definition poses a problem insofar as due diligence being a form of evaluation of the degree of compliance with a concrete obligation, the choice of a “soft” or “hard” standard has significant practical consequences for the safeguarding of rights. The choice lies between: a) “doing what is possible” or “reasonable” with the “means available” or, on the contrary, b) demanding the effective application of workers’ rights.
43The lack of conceptual clarity prevents us from knowing to what extent the respecting of rights can be demanded. This may therefore lead us to fear that this notion will have the aim or effect of limiting the enterprise’s liability to a violation of a simple obligation to make an effort (duty of best endeavours). This fear is all the more founded if we observe the position taken in the case law of the IACtHR, according to which the “sole fact that a right has been violated” cannot lead to a conclusion of non-compliance with the obligation of due diligence.
44If the notion of due diligence were treated in this way by labour law, we would be facing a “Copernican shift” in the system of responsibility, a veritable transformation that would impose a new standard for proving the respecting of rights; a standard that would be situated below the duty of “compliance” with the regulations in force, since due diligence would be sufficient to avoid liability.
45Other conditions of the application of due diligence also call for severe criticism: a) its limitation to “serious” human rights violations only, and b) the fact that its effectiveness depends on elements outside the legal relationship, such as the context or size or business enterprises.
B - The inadequacies of the negative obligation
- 14 G. Bidart Campos and W. Carnota, Derecho Constitucional Comparado, Volume II, EDIAR, 2000.
46The Ruggie “framework”, which emphasises due diligence as an obligation to “respect” is insufficient in human rights matters. Indeed, these rights require positive measures on the part of States and individuals, given their immutable nature.14
47The liberal ideology underlying Ruggie’s conception frees passive subjects from their obligation not to do harm, whereas more should be demanded of enterprises in terms of respect for human rights due not only to the question of dignity involved, but also the potential and possibilities they have to contribute to economic, social and human development.
- 15 D. Bilchitz, “El marco Ruggie: ¿una propuesta adecuada para las obligaciones de Derechos Humanos de (...)
48David Bilchitz, quoting Henry Shue, examines what the criteria for identifying the positive obligations incumbent upon passive subjects should be, pointing out that from this author’s point of view two factors must be taken into account: firstly, the justification of the means in relation to the objective must specify the measures to be taken to ensure that a right is respected and, with that in mind, it is necessary to determine who is best placed to accomplish these tasks (...). Secondly, the distribution of the obligations also depends on the reasonable and fair nature of the duties imposed on specific agents.15
C - Due diligence in legal opinion on labour law
49It is to be hoped that this notion of diligence can be integrated into the legal culture of labour law without altering the meaning or the instruments of workers’ protection in the inherently unequal labour relationship.
50How can this legal integration of due diligence be effected?
51One of the possibilities would be to include this notion in the list of the employer’s obligations constituting the “good employer” paradigm.
52Such an “appropriation” of due diligence by a traditional notion in labour law would not alter the classic system of liability and constitutes a first hypothesis that should be considered. The implementation of the dynamic burden of proof in the procedural field could correct the difficulties of this “prudent person” approach applied to labour law, which very clearly has its origin in the dogma of civil law and therefore a long way from the particularities of labour law.
53It would seem to be preferable to focus on another route for the legal integration of the duty of diligence into our discipline and its inclusion as one of the Principles of labour law.
- 16 A. Plá Rodríguez, “Los Principios del Derecho del Trabajo”, Ed. al cuidado de Hugo Barretto Ghione, (...)
54The duty of diligence could appear as manifestation of certain principles, such as the principles of “good faith” or “reasonableness” as referred to by the most classic labour law doctrine and case law in Latin America.16 The obligation to behave with diligence would be a mark of compliance with a more general duty such as the obligation of good faith or acting in a reasonable way in the labour relationship. Due diligence would be one means among others in the components of these principles.
- 17 H. Barretto Ghione, “Obligaciones en el contrato de trabajo: Algunos problemas en la determinación (...)
- 18 I. Daugareilh, «La ley francesa sobre el deber de vigilancia de las sociedades matrices y contratis (...)
55Due diligence would not have any relevant effect on the interaction of contractual rights and obligations, a relationship that some regard as bilateral17 in spite of the blatant inequality between the parties. The strict liability of the employer would remain the only source allowing a perfect articulation between prevention and compensation.18
Notes
1 But the origin of the duty of diligence seems to go back further, to the “sources of American public and private international law and commercial law”; it is only later that it “migrates” towards continental European law. This shift “is also an opportunity to critically question the meaning and interest - political and economic - of exporting a legal concept to other legal systems, a movement which, far from being neutral, founds a political project under cover of a barely concealed technical dimension.” See I. Daugareilh, «La ley francesa sobre el deber de vigilancia de las sociedades matrices y contratistas: entre renuncias y promesas», in W. Sanguinetti and J. B. Vivero (dir.), Impacto laboral de las redes empresariales, Grenada, 2018.
2 M. García Elorrio, «Algunas consideraciones en torno a la naturaleza y alcance de la noción de diligencia debida en la Corte Interamericana de Derechos Humanos», 9 May 2011: https://revistas.psi.unc.edu.ar/index.php/recordip/article/view/286/284
3 G. De León, V. Kristicevic and L. Obando, «Debida diligencia en la investigación de graves violaciones a Derechos Humanos» Centro por la Justicia y el Derecho Internacional, Buenos Aires, 2010.
4 Ibid., p. 22.
5 M. García Elorrio, op. cit.
6 G. De León, V. Kristicevic and Obando, op. cit., p. 32.
7 S. García Muñoz, “Informe sobre empresas y Derechos Humanos: estándares interamericanos” Special Rapporteur on Economic, Social, Cultural, and Environmental Rights, November 2019.
8 A. Guaman, “Diligencia debida en derechos humanos y empresas transnacionales: de la ley francesa a un instrumento internacional jurídicamente vinculante sobre empresas y derechos humanos”, Revista Jurídica de los Derechos Sociales, vol. 8, no. 2, 2018, p. 237.
9 Ibid.
10 These paragraphs provide as follows:
Paragraph 11. “Avoid causing or contributing to adverse impacts on matters covered by the Guidelines, or through their own activities, and address such impacts when they occur.”
Paragraph 12. “Seek to prevent or mitigate an adverse impact, where they have not contributed to that impact, when the impact is nevertheless directly linked to their operations, products or services by a business relationship. This is not intended to shift responsibility from the entity causing an adverse impact to the entity with which it has a business relationship.”
11 D. Bilchitz, “El marco Ruggie: ¿una propuesta adecuada para las obligaciones de Derechos Humanos de las empresas?”, Revista Internacional de Derechos Humanos, vol. 7, no. 12, 2010, p. 209.
12 Bold added by the author.
13 S. García Muñoz, “Informe sobre empresas y Derechos Humanos: estándares interamericanos”, op. cit., p. 56.
14 G. Bidart Campos and W. Carnota, Derecho Constitucional Comparado, Volume II, EDIAR, 2000.
15 D. Bilchitz, “El marco Ruggie: ¿una propuesta adecuada para las obligaciones de Derechos Humanos de las empresas?”, op. cit.: “As far as the first factor is concerned, it is clear that, in many situations, enterprises will be able to contribute in a significant way to the respecting of fundamental rights. This is a powerful argument for imposing certain key obligations on enterprises in terms of the protection of fundamental rights, in particular when these fall within their sphere of competence and their capacity for intervention. The second factor identified by Shue allows the scope of the obligations incumbent upon enterprises to be limited: it would require, for example, that the positive obligations be divided equally between enterprises whilst still allowing them to achieve their economic objectives. However, the second factor in no way explains why enterprises could not have positive obligations imposed upon them to protect rights.”
16 A. Plá Rodríguez, “Los Principios del Derecho del Trabajo”, Ed. al cuidado de Hugo Barretto Ghione, FCU, 2015.
17 H. Barretto Ghione, “Obligaciones en el contrato de trabajo: Algunos problemas en la determinación y equivalencia de las prestaciones”, Rev. Derecho Laboral, no. 250, April-June 2013.
18 I. Daugareilh, «La ley francesa sobre el deber de vigilancia de las sociedades matrices y contratistas: entre renuncias y promesas», op. cit., p. 377.
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Hugo Barretto Ghione, « Emergence of the notion of “due diligence” in labour law and how it is integrated into the legal system », Revue de droit comparé du travail et de la sécurité sociale, 4 | 2021, 28-37.
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Hugo Barretto Ghione, « Emergence of the notion of “due diligence” in labour law and how it is integrated into the legal system », Revue de droit comparé du travail et de la sécurité sociale [En ligne], 4 | 2021, mis en ligne le 31 décembre 2022, consulté le 15 juin 2025. URL : http://journals.openedition.org/rdctss/2628 ; DOI : https://doi.org/10.4000/rdctss.2628
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