CASE STUDIES
Monitoring social compliance in the Gulf
What was at stake
Our client, a major UAE real estate developer, sought independent assurance that its worker welfare programme was effective and that contractors met our client’s social performance requirements. With a significant migrant workforce on site, the risks to both rightsholders from poor contractor performance, and the reputational risk for our client’s business, were real.
Our client’s challenge
The Gulf’s construction and infrastructure sectors rely heavily on low-wage migrant labour and the risks to workers are well-documented; recruitment fees, passport retention, wage theft, and substandard accommodation. A shortage of available labour, driven by rapid economic diversification and shifting migration patterns, has intensified these pressures, particularly among manpower contractors supplying workers to large-scale projects.
The client already had a strong worker welfare programme in place. However, due to operating in this environment, they recognised the need for independent oversight – both to manage ongoing risks to workers on site and to demonstrate to external stakeholders that its programme was delivering in practice.
What we are doing
As part of a quarterly monitoring programme, we are measuring the performance of the client’s own worker welfare management system, through on-site assessments of the project’s contractors. The assessments combine reviews of the client’s welfare team, the performance of the project supply chain incorporating a risk-based sample of employers and workers in line with the UNGPs and OECD guidance, and reviews of employer-provided accommodation. Within our assessment of the system, we follow the worker’s journey from recruitment through to deployment and demobilisation.
Our assessment prioritises a focus on contractors with higher rates of potentially vulnerable workers and on areas where risks in the region are most acute. In particular, fair recruitment practices, transparency of employment terms, and indicators of coercive conditions.
Rather than applying a audit checklist, our approach is built on triangulation: testing what contractors do in practice against what workers experience. This is critical in a context where rehearsed audit responses are common and where the gap between policy and practice is often where real risks sit.
Through this approach, we identify gaps and risks that would not have surfaced through desk-based review or a conventional audit. The on-site presence and direct engagement with workers in their native languages provide a level of insight that remote monitoring alone cannot deliver.
The difference it makes
The assessments provide the client with a clear, evidence-based picture of contractor performance and worker conditions on site. Where gaps are identified, the client is able to follow up directly with contractors and put corrective measures in place.
Beyond individual findings, the assessments inform practical recommendations to strengthen the client’s wider worker welfare programme, helping to address systemic issues rather than only responding to individual non-compliances.
We work with clients to move beyond desk-based assessments by providing on-the-ground, evidence-based insight in challenging operating environments. In this case, that meant:
- Enabling the client to identify and act on real risks to workers
- Strengthen the client’s welfare programme based on what was actually happening on site
- Build a credible basis for reporting to external stakeholders.
