Who owns social compliance roles and responsibilities? A practical RACI

Social compliance roles and responsibilities need to be assigned to an accountable executive and the functions that control working conditions. OECD guidance recommends assigning due-diligence oversight to relevant senior management and integrating implementation into management systems. [1]

In practice, this means appointing an accountable executive and clear responsibilities across the teams that influence working conditions. HR may coordinate workforce records and audit preparation, but operations controls production schedules, procurement selects contractors, finance processes payments and EHS manages safety controls. Each function needs to own the decisions and evidence within its control.

For a manufacturer or exporter, the gap often appears when a buyer asks a simple question: who checks that contract workers receive the right payment for the hours they work? HR has the wage sheet. Operations has the overtime approval. Finance has the contractor invoice. Procurement holds the agreement. None of those records, on its own, answers the question.

A practical responsibility model connects these pieces. It identifies who does the work, who makes the decision, whose input is needed and who receives the outcome.

What you need to know

• Appoint an executive who can resolve disagreements and approve resources.
• Assign ownership to specific activities, rather than giving one department a broad compliance label.
• Give each activity one clearly identified accountable role.
• Define evidence, deadlines and escalation alongside responsibilities.
• Preserve statutory duties, independent processes and confidentiality.
• Review the allocation when people, contractors, sites or operating conditions change.

Why assigning everything to HR leaves gaps

HR is often the first team asked to prepare for a social audit. It holds employment information, policies and training records, and may already coordinate buyer requests. That makes it a useful coordination point.

However, coordination does not give HR control over every source of risk. If production accepts orders that require excessive hours, HR cannot resolve the underlying capacity problem by updating a policy. If a contractor repeatedly submits unreliable records, HR needs procurement’s commercial involvement. If a safety correction requires capital expenditure, management must decide and finance must support implementation.

The result of unclear ownership is repeated chasing. One person collects documents while the decisions that shape those documents happen elsewhere.

The wider social governance framework explains how ownership, controls and evidence fit together. The practical next step is to attach those responsibilities to the activities your business actually performs.

What does RACI mean?

A RACI matrix is a responsibility table with four roles:

Role	Meaning	Practical question
Responsible	Performs the work or coordinates its delivery	Who carries out the check or action?
Accountable	Owns the decision and completion of the activity	Who answers for the result?
Consulted	Provides input before a decision or action	Whose expertise or information is needed?
Informed	Receives relevant updates or outcomes	Who needs to know what happened?

Use one accountable role for each clearly defined activity in this recommended model. Several people can contribute to the work, but the lead and handovers must be clear. In a small business, the same person may hold more than one role. Record the names and capacity needed rather than assuming a large organisational structure.

SVEGA recommends using RACI to make that ownership visible. Neither the cited OECD guidance nor the ETI Base Code prescribes the fifteen-row matrix below.

The matrix below uses a compact format, listing the people under each role instead of creating a wide column for every department. It is an adaptable management tool, not a prescribed legal allocation or an audit-scheme requirement.

Start with an executive who can make decisions

OECD guidance recommends senior-management oversight and responsibility for due diligence. [1] Choose a sponsor with authority over the teams involved. Depending on the business, this may be the managing director, COO or another senior executive.

The sponsor should approve the ownership model, resolve cross-functional disputes, review significant risks and ensure agreed actions have resources. Routine approval should remain with the relevant functional or site owner, so every small issue does not wait for the managing director.

Define who acts when the sponsor is unavailable. If an issue needs immediate protection for workers, the emergency or safeguarding process must operate without waiting for the next governance meeting.

Site leadership also needs a clear role. A corporate policy owner may define the procedure, while a site head is accountable for implementing it at a particular factory. Separate those activities in the local matrix.

What each function should own

HR: Workforce information and accessible processes

HR should maintain reliable employment and workforce information, coordinate relevant training and administer the processes assigned to it. It should also make sure workers understand the channels available to them.

The UN Guiding Principles recommend operational grievance mechanisms for affected people and set out effectiveness criteria, including accessibility and predictability. [3]

For grievances, define the appropriate receiving, investigation and decision roles. HR can administer access and tracking without becoming the decision-maker for every complaint. Sensitive or statutory cases must follow the appropriate process, including conflict-of-interest safeguards.

Operations: Hours, staffing and conditions of work

The ETI Base Code addresses working-hour controls, voluntary overtime and rest periods. [2]

Operations should own production planning, shift arrangements and the operational decisions that create working hours. It needs to reconcile actual work with approved schedules and act when demand exceeds available capacity.

If overtime exceeds an agreed or applicable limit, the response may require staffing, capacity or delivery decisions. Recording the exception in HR does not settle it.

Procurement: Contractors and supplier relationships

The ETI Base Code states that labour and social-security obligations should not be avoided through labour-only contracting or subcontracting. [2]

Procurement should build requirements into contractor and supplier selection, agreements and performance reviews. It should obtain the necessary cooperation and use the agreed commercial escalation route when records or remediation remain inadequate.

Supplier due diligence also needs input from people who understand workforce and safety risk. Commercial approval should not be based solely on a low price and a signed declaration.

Finance: Payment evidence and funded remediation

Finance should provide reliable payment evidence, review payment exceptions within its remit and support approved corrective-action budgets. Payroll responsibilities vary between businesses, so specify who calculates wages, who approves them and who confirms receipt.

Payment to a contractor is different from evidence that workers received the amounts due. Define how worker-level concerns move between finance, HR and procurement.

EHS: Safety expertise and operating controls

The ETI Base Code calls for a senior-management representative to hold safety responsibility and for regular, recorded safety training. [2]

EHS should lead the technical safety work assigned to it, including risk assessment, inspection, incident review and corrective-action verification. Operations and site management must implement the controls that affect daily work.

An EHS officer should not be left accountable for a major physical change without the authority or budget to deliver it. Assign approval and implementation separately.

Legal or compliance: Interpretation and review

Legal or qualified compliance support should clarify applicable obligations and review decisions that need specialist input. This role may sit internally or with an external adviser.

Advice does not transfer the organisation’s duty to implement the requirement. The relevant functional owner still needs to act, retain evidence and report exceptions.

A practical RACI for fifteen recurring activities

In this example, “coordinator” means the person maintaining the shared tracker, “sponsor” means the accountable executive, and “case owner” means the properly authorised role for that complaint. Replace role labels with named people or positions before adoption.

Activity	Responsible	Accountable	Consulted	Informed
1. Maintain the workforce register	HR administrator	HR head	Operations and contractor representatives	Site head and coordinator
2. Review staffing, shifts and overtime exceptions	Production planning and supervisors	Operations head	HR, EHS and legal where needed	Sponsor and coordinator
3. Reconcile wage calculations and payment exceptions	Payroll team	Designated payroll approver	HR, finance and legal where needed	Site head and coordinator
4. Reconcile applicable contribution records	Designated HR/payroll reviewer	HR head	Finance, contractors and legal	Coordinator and site head
5. Screen and appoint labour contractors	Procurement team	Procurement head	HR, EHS, operations and legal	Site head and finance
6. Review contractor workforce and payment evidence	HR and procurement reviewers	Site head	Finance, operations and contractor representatives	Coordinator and sponsor
7. Review suppliers and required remediation	Supplier-review lead	Procurement head	Relevant risk specialists and operations	Sponsor and coordinator
8. Deliver induction and task-specific safety training	Supervisors and trainers	Site head	HR, EHS and contractor representatives	Coordinator
9. Inspect safety controls and arrange corrections	EHS and operating teams	Site head	Relevant technical specialists	Sponsor and coordinator
10. Respond to incidents and track remedial actions	Designated incident-response team	Designated incident lead	EHS, HR, legal and relevant specialists	Sponsor through the appropriate reporting route
11. Maintain general grievance access and case tracking	Grievance administrator	Authorised grievance-process owner	Worker representatives, HR and legal	Management using restricted, anonymised reporting
12. Prepare and approve a buyer questionnaire response	Coordinator and evidence owners	Authorised submission approver	Commercial team and relevant specialists	Site head and sponsor
13. Coordinate social audit preparation and access	Coordinator and department owners	Site head	Approved auditor and relevant specialists	Sponsor and commercial team
14. Implement a specific corrective action	Named action owner	Manager with authority over that action	Affected functions and designated verifier	Coordinator and sponsor for significant issues
15. Review monthly risks, metrics and overdue actions	Coordinator and data owners	Sponsor	Functional heads and relevant specialists	Action owners and site leadership

This table does not allocate statutory sexual-harassment complaint determination to a general management role. Use the legally appropriate committee and process for those cases. Likewise, incident notifications and other statutory duties must follow applicable requirements. The POSH Act provides for Internal and Local Committee processes, while section 16 restricts disclosure of specified complaint, inquiry and identity information to the public, press and media. [4] Internal RACI assignments do not remove legal responsibilities or permit unauthorised access to confidential records.

For corrective actions, create a separate tracker row for each action. One general “CAP owner” cannot replace the manager responsible for a payroll correction, production change or safety investment. Where possible, use a verifier who did not carry out the action; external closure acceptance follows the relevant buyer or auditor process.

Define the handover as well as the owner

A responsibility table still leaves room for confusion if it does not explain when work moves between teams.

Take overtime as an example. Operations records and approves additional work. Payroll receives the hours by an agreed cut-off. HR or another designated reviewer checks exceptions. Finance provides payment evidence. The authorised approver resolves discrepancies before the process is treated as complete.

Define four things for each recurring activity:

1. The trigger and completion deadline.
2. The source record and reporting period.
3. The evidence needed to support completion.
4. The recipient and escalation route for exceptions.

For contractor oversight, use the record cross-check framework in How contract labour governance helps manufacturers prepare for buyer audits.

Set escalation triggers that lead to action

Management should agree which issues require immediate response and which can be reviewed through the routine cycle. Use triggers based on the site’s risks, legal duties and buyer commitments.

Trigger	Required response in the internal process
Immediate danger or serious worker harm	Activate the relevant emergency or protective process immediately and notify authorised leadership
Credible concern about coercion, retaliation or serious abuse	Use a confidential safeguarding route, preserve evidence and involve appropriate specialists
Confirmed wage shortfall or missing applicable contributions	Assess affected workers and scope, arrange remediation and assign a prompt deadline
Conflicting evidence in a buyer submission	Escalate before approval and resolve or disclose the uncertainty accurately
Repeated contractor failure	Procurement and site leadership review remediation and commercial options while protecting workers
Overdue action or insufficient budget	The accountable manager escalates the decision and records interim protection

These are recommended internal triggers, not legal notification deadlines or official audit severity categories. An escalation should state the issue, affected people, immediate protection, decision required and latest acceptable decision time.

Use the monthly meeting to make decisions

A governance meeting should examine exceptions and actions, rather than become a tour of departmental presentations.

Review workforce and contractor changes, hours and payment exceptions, safety concerns, anonymised grievance trends, buyer requests and corrective actions. Data owners should identify missing or uncertain information so an empty field is not mistaken for zero incidents or zero complaints.

OECD guidance includes tracking the implementation and results of due diligence. [1] Record the decision, owner, deadline and evidence expected. At the next meeting, verify what happened. Close an internal action only when its completion criteria are met, and keep any required external verification separate.

Routine monthly review does not replace immediate action on urgent issues. Set the cadence to fit the business, with more frequent follow-up during major remediation or an approaching audit.

Test the model before approving it

Use a hypothetical case: a contract worker reports that approved overtime was omitted from their pay.

Can the receiving person route the concern without sending the worker between departments? Can operations confirm the hours? Can payroll check the calculation? Can the contractor provide payment records? Does an authorised manager approve correction and resolve disagreement? Who checks whether other workers were affected?

If the answer is “HR will chase everyone,” the handovers need more work.

Then test a safety issue, a missing buyer-response record and an overdue corrective action. These exercises show whether the assigned people have authority, access and enough time to perform their roles.

Frequently asked questions about social compliance roles and responsibilities

Turn the responsibility table into a working process

Start with the activities that cause repeated chasing: overtime, contractor payments, grievances, buyer requests and corrective actions. Name the owners, agree the handovers and test whether a concern can reach a decision without depending on one person’s persistence.

SVEGA’s Social Governance System Build supports the design of ownership models, controls, reporting and review structures. Discuss where responsibilities are currently unclear and which decisions need a more reliable route.

References

[1] OECD. OECD Due Diligence Guidance for Responsible Business Conduct. 2018, section II, step 1.2 on embedding due diligence into management systems, and step 4 on tracking implementation and results. Read the guidance.

[2] Ethical Trading Initiative. ETI Base Code. Clauses 3, 6 and 8 address safety responsibility and training, working hours and employment relationships. Read the Base Code.

[3] OHCHR. Guiding Principles on Business and Human Rights. 2011, Principles 29 and 31 on operational grievance mechanisms and their effectiveness. Read the Guiding Principles.

[4] Government of India. Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. See sections 4, 6, 9–13 and 16 for committee processes, complaints, inquiry and confidentiality. Read the Act.

References checked: 5 October 2026. The RACI, handovers, escalation examples and monthly meeting structure are SVEGA’s recommended operating model. They are not a prescribed legal allocation of duties. The overtime scenario is hypothetical. Confirm applicable statutory duties when adopting the model.