From commitments to construction sites: why human rights implementation falls short in practice

Globally, buildings and construction account for 32% of final energy use and 34% of energy-related CO2 emissions, placing the sector at the heart of decarbonisation and just transition efforts. The challenge is global: construction must continue growing while decarbonising at unprecedented speed. In the UK, the built environment accounts for roughly 25% of national emissions, with government-mandated targets requiring reductions of over 70% by 2035 alongside continued demand for housing and infrastructure. Similar pressures exist across Europe: in Germany, for example, the building sector must cut emissions to deliver a 65% reduction by 2030 while continuing to meet construction demand.

Construction is one of the world’s largest sources of employment, supporting over 270 million jobs globally. Yet in addition to meeting climate targets, the sector faces significant labour-related challenges. It remains structurally fragmented, delivered through layers of subcontractors, labour providers, and complex supply chains. Labour conditions are therefore often shaped less by legislation than by procurement decisions, contracting arrangements, and site-level management practices. 

It is within this governance gap, where regulation exists but cannot reach complex delivery systems, that guidance for the construction sector grounded in international standards, such as the UN Guiding Principles on Business and Human Rights (UNGPs) and ILO Labour Standards, have assumed growing importance. For example, initiatives such as Building Responsibly’s Worker Welfare Principles; IHRB’s Dignity by Design Framework; and the Labour Agency Vendor Accord (LAVA) have helped create practical guidance for companies working to implement their human rights commitments in the construction delivery. 

The translation problem: strong commitments and weak site-level traction 

Despite growing adoption of these initiatives, positive labour rights outcomes remain weak across construction supply chains. Corporate human rights commitments are often made at board level, while labour harms emerge in day-to-day delivery. The problem is not a lack of standards, but the failure to translate them into the decisions, incentives, and working practices that shape conditions on construction sites. 

Evidence from both the UK and international markets suggests that this implementation challenge persists across the sector. UK data consistently highlights construction as a high-risk industry, with Unseen’s 2025 data identifying 710 workers at risk of labour exploitation and modern slavery, a 44% increase from the previous year. Similar patterns are evident internationally: in Gulf construction markets, large programmes rely on predominantly migrant workforces, with studies indicating that 93% of workers report paying exploitative recruitment fees.

These findings reinforce the implementation challenge facing the sector: labour harms continue to emerge despite growing adoption of voluntary initiatives and international standards.   

This translation gap reflects what experts describe as ‘privatisation by absence’: where there is weak enforcement of state obligations, companies try to find their own strategies to respect rights and reduce risks. In construction, this often means pushing responsibility down supply chains into delivery tiers where oversight, leverage, and control are weakest. Responsibility for implementation, therefore, ends up with those least able to deliver on commitments.

The limits of standards without implementation 

Despite their limitations, international frameworks and initiatives can go beyond minimum legal requirements, helping establish shared expectations, support governance, and translate labour standards into procurement and contracting requirements. When embedded into contracts, and accompanied by clear governance, they can also drive outcomes in delivery. For example, in elements of Qatar’s 2022 World Cup construction programme, contractual requirements and oversight have been used to address labour risks, claiming to have protected over 200,000 workers.

Standards also fill gaps created by weak enforcement of existing legal standards. For example, under disclosure-based regimes such as the UK’s Modern Slavery Act 2015 and Australia’s Modern Slavery Act 2018, companies are required to comply through reporting on their actions. However, the absence of provisions relating to demonstrating due diligence, outcomes, as well as the lack of risk in facing financial penalties for non-compliance, has limited changes in business behaviour. Problems arise as well where such frameworks are not effectively translated into delivery. Where standards proliferate without changing how work is delivered, and compliance is demonstrated through policies and documentation rather than outcomes, performance is unlikely to improve. Over time, such approaches produce code fatigue: overlapping standards, misaligned requirements, and increasing burdens on disempowered supply chain actors, all result in limited impact on working conditions.

Translating commitments into outcomes 

Against this backdrop, businesses operating in the built environment should focus on translating existing commitments into delivery. This requires greater clarity from both businesses and framework designers on how commitments are embedded in site-level practice and a sharper focus on where leverage exists. In practice, this means rigorous due diligence processes and ongoing performance monitoring of labour agencies, alongside contractual requirements that clearly allocate responsibility and accountability for worker welfare. It also requires procurement and payment models that do not transfer excessive cost, programme, or performance pressures down supply chains in ways that increase labour risk. Finally, it requires independent verification of labour conditions through worker interviews and site-level assessments, alongside accessible and actively promoted worker voice mechanisms that workers trust and can use without fear of retaliation. 

Examples of efforts to operationalise these approaches are beginning to emerge at different levels of the sector. From a governance perspective, mechanisms such as the UK’s Procurement Policy Note 009 promote the use of government buying power to mitigate modern slavery risks, requiring in-scope organisations to consider these risks across procurement planning, supplier selection, and contract award and management. At company level, contractors such as Mace have strengthened supply chain oversight through contractual requirements, supplier prequalification processes, risk profiling, and due diligence of international suppliers. Finally, at project level, elements of the Qatar 2022 World Cup construction programme demonstrated the translation of labour standards into site-level delivery mechanisms. The programme embedded worker welfare requirements into contractual arrangements and mandated external audits, worker interviews, accommodation inspections, and pre-mobilisation approval processes.

Although evidence of sustained improvement in worker outcomes remains mixed, these examples represent a shift away from isolated commitments and towards embedding human rights considerations within the delivery mechanisms that shape conditions on construction sites.

Finally, progress depends on realism in how existing standards are applied. Scaled models, phased requirements, and continuous improvement pathways promise better outcomes for fragmented construction supply chains than uniform compliance expectations. Mandatory policy requirements can create an essential floor. Company focused frameworks and multistakeholder initiatives, when employed effectively, can provide a valuable complement, allowing flexibility that can progressively strengthen practice over time.

The failure of human rights commitments in the construction sector lies not in their design, but in translating these objectives into clearly defined delivery outcomes. If the gap between board level goals and site-level action persists, it risks fragile operations, dependent on disempowered actors unable to deliver meaningful change at scale. Closing the gap requires aligning responsibility with leverage and embedding human rights standards into procurement, contracting, and site-level decisions so that commitments are realised in practice. As construction faces growing demand alongside the rapid transition to a low-carbon economy, ensuring that human rights are embedded within delivery will be critical to achieving a transition that is both sustainable and just.