CASE STUDIES
Laying the groundwork: Human Rights Risk Assessment in the Gulf
SUMMARY: A human rights risk assessment helps Gulf property developers identify labour and supply chain risks, including forced labour indicators, wage theft and poor living conditions. This case study explains how human rights due diligence, stakeholder engagement and system reviews can support a practical strategy for managing risks, meeting investor expectations and improving worker welfare in high-risk markets.
Kumi supported a property developer in the Middle East by undertaking a human rights risk assessment (HRRA) to identify risks associated with its operations and develop a human rights strategy. As a result of our engagement, the company gained a clear understanding of its human rights risk exposure and a three-year strategy to develop its management system to address adverse impacts identified. This included a roadmap for implementing its human rights programme.
Prior to our engagement, the company was facing increasing pressures from investors and other external stakeholders to disclose how it was managing human rights risks. While a human rights working group had been established, there was no strategy to manage potential human rights impacts in its operations and supply chain, including indicators of forced labour such as withheld passports, recruitment fees, wage theft, and poor living conditions.
To inform our work, we completed:
- Peer Benchmarking: Compared industry peers to highlight best practices and common gaps in human rights and worker welfare programmes.
- System Assessment: Evaluated the company’s human rights due diligence systems against leading frameworks (OECD RBC, UNGPs) to identify weaknesses.
- Risk Identification: Mapped key human rights risks across operations and supply chains, using research and external stakeholder input to uncover blind spots.
- Internal Engagement: Consulted widely within the organisation to build capacity, tailor strategy to business realities, and stress-test implementation.
As a result of the HRRA, we developed the company’s human rights strategy, which included clear actions for implementing the programme over the next three years, including timings, roles and responsibilities. Our risk assessment was completed within six months using Kumi’s HRRA methodology.
Human rights risks pose serious reputational business risks for companies operating in the Gulf region. As investors and civil society increasingly turn their eyes towards these challenges, it is vital that developers are actively engaged with human rights and worker welfare and can demonstrate that they are operating responsibly.
Get in touch to find out how our HRRA process equips you to meet investor expectations and operate responsibly in high-risk markets.
Frequently asked questions
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Do we need a human rights risk assessment in the Middle East?
Companies operating in or sourcing from the Middle East face elevated human rights risks, particularly related to migrant workers. Regulators and investors increasingly expect these risks to be identified and managed proactively.
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What human rights issues are most common in the Gulf?
Common risks include recruitment fees, poor working conditions, restrictions on worker movement, and weak grievance access. These risks often sit several tiers down the supply chain.
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How do you assess human rights risks where transparency is limited?
Risk assessments combine document review, stakeholder interviews, and contextual analysis rather than relying only on supplier data. Local expertise is critical where disclosure is limited.
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Is a desk‑based assessment enough?
Typically no. Desk‑based assessments help scope risks, but on‑the‑ground insight is often needed to understand how policies operate in practice.
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How does this support regulatory compliance?
Human rights risk assessments help meet expectations under due diligence laws and investor requirements by demonstrating a risk‑based, proactive approach.
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Can this approach be applied outside the Middle East?
Yes. The methodology is globally applicable and adapted to local risk contexts, making it relevant across high‑risk geographies.