Charge Responsibly: Human Rights Risks in Tech and Battery Supply Chains
The world is entering a golden age of battery production, fuelled by the accelerating digitalisation and electrification of industry and transport and the growing demand for consumer technology. But a key issue for battery producers, and those who rely on them, is the human rights risk attaching to that supply chain. The surge in growth is increasing demand for critical minerals – notably cobalt, lithium, nickel and manganese – which are sourced through complex, and often opaque, supply chains.
These supply chains often intersect with conflict‑affected and high‑risk areas ("CAHRAs") – for instance, the Democratic Republic of the Congo ("DRC"), which is the world's leading producer of cobalt.1 In these contexts, human rights harms, such as child and forced labour, unsafe working conditions and adverse impacts on local communities, occur more commonly. Companies with supply chains involving batteries should be alive to these risks and implement credible, risk-based due diligence programs throughout their supply chains.
The supply of critical minerals is concentrated in the Global South, where less-developed human rights frameworks coincide with weaker enforcement capacity, often in contexts affected by conflict and political instability. Major producing regions – including the DRC (cobalt), Indonesia and the Philippines (nickel), and parts of Latin America (lithium) – face overlapping social, political and economic pressures. The OECD’s Guidance for Responsible Supply Chains of Minerals from CAHRAs2 recognises that extraction in these environments can fuel conflicts and serious abuses.
Upstream stages of battery‑mineral supply chains therefore carry acute human rights risks. In the DRC, child labour remains widespread in artisanal cobalt mining. Industrial sites continue to face allegations of unsafe conditions, excessive working hours and wages below legal minimums. Similar concerns arise in nickel‑producing regions of Indonesia, where rapid expansion has outpaced regulatory oversight. Local and indigenous communities may experience displacement and loss of livelihoods. Environmental degradation, including soil and water contamination, can have profound community health impacts. With the UN’s recognition of the right to a healthy environment, and the Inter-American Court of Human Rights' landmark 2024 decision affirming this right, such impacts now sit squarely within the global human rights framework.
For companies sourcing these materials, responsible practices may be hindered by limited structural visibility. Minerals typically pass through multiple intermediaries before reaching manufacturers, meaning companies often struggle to trace materials beyond tier‑1 suppliers. This lack of traceability heightens legal, commercial and reputational risks. As demand accelerates, stakeholders increasingly expect verifiable evidence of responsible sourcing. Allegations of labour abuses can prompt product seizures, market exclusion, investor pressure or litigation.
At the same time, regulatory momentum is shifting towards mandatory human rights due diligence. Emerging regimes, including the EU's Corporate Sustainability Due Diligence Directive ("CSDDD"), will require companies to identify, prevent and mitigate adverse human rights impacts across their supply chains globally. The EU Batteries Regulation introduces additional obligations on high‑risk raw materials, while forced labour product bans in the US and EU can block market access unless companies demonstrate that no forced labour was involved. Failure to implement credible measures to identify and combat human rights abuses, or otherwise prove that a product has not been produced by forced labour, may lead to withdrawal of products, exclusion by business partners, shareholder and stakeholder challenges, reputational harm as well as financial penalties.
Companies that lead on responsible minerals sourcing will not only meet rising regulatory expectations, they will also secure long‑term supply stability, build trust with investors and regulators, and position themselves at the forefront of the energy transition. In a market defined by scarcity, scrutiny and speed, credible human rights due diligence is fast becoming a competitive advantage.
Authors
Olivia Battcock
