human rights due diligence toolkit

Human Rights Due Diligence toolkit for sugarcane mills

Name of the project: Human Rights Due Diligence toolkit for sugarcane mills

Grant awarded: £150,000

Project budget: £300,000

Call for proposals theme: Collective action to strengthen human rights and promote decent work in the sugarcane sector

Project lead: Proforest

Co-leads: Imaflora, Nestlé, General Mills and Barry Callebaut

Proforest is non-profit group that supports companies, governments, civil society and other organisations to work towards the responsible production and sourcing of agricultural and forest commodities.

The project is run in partnership with Imaflora, a Brazilian NGO with a mission to encourage socio-environmental changes in forestry and agriculture, and end-user companies, including Nestlé, General Mills and Barry Callebaut.

Purpose of the project

Proforest, Imaflora and Nestlé will develop and implement a systematic approach to embed Human Rights Due Diligence* (HRDD) in sugarcane mills’ own operations, their suppliers and service providers, through a collaborative approach and stakeholder engagement. 

This will be carried out in four steps: 

  1. Creation of an HRDD toolkit** with guidance for mills on the practical steps of the due diligence process. It will focus on the Brazilian context and consider regional differences between the northeast and southeast of the country.
  2. Development of tools for the HRDD implementation process. This will include a template and guidance on the development of a risk saliency matrix and checklists for on-the-ground verifications.
  3. Capacity building on the guidance and tools in the HRDD toolkit to mills, producers, and service providers, via mills and producers’ associations in the northeast and southeast regions.
  4. Piloting the guidance and tools with 2 mills and 2 producers’ associations (from the southeast and northeast). 

Through this project, Proforest and its partners will provide practical tools for the interpretation of the UNGPs and the OECD guidelines, which are now part of Bonsucro’s Code of Conduct for members, for the Brazilian sugarcane sector. 

A tailored framework relevant to the sugarcane sector and regional context will allow for practical implementation guidance, reflecting the sector and region-specific salient issues.  This project will focus on building a sectorial reference in Brazil on how to monitor and strengthen respect for human rights in the sugarcane supply chain, by setting a common reference for the Brazilian sugarcane sector on the HRDD process, with the potential of expanding to other regions and commodities. 

*Human Rights Due Diligence is a process for identifying, preventing, mitigating, and accounting for human rights impacts. This includes both actual impacts occurring in the present and potential impacts that could occur in the future. Source: Business and Human Rights Resource Centre

**The toolkits are a guide to the various initiatives and tools available to help decouple commodity production and trading from deforestation, conversion of native vegetation and human rights violations. For more information: Our toolkits – Proforest


Brazil is one the world’s biggest sugarcane producing countries. It is consistently flagged as high or very high risk for human rights issues in global risk assessment data*; yet there is relatively little material available in Portuguese about practical implementation of HRDD.

The project will be implemented in sugarcane producing regions in the southeast and northeast of Brazil.

The two areas represent significantly different production systems, organisational models, and labour use conditions, which imply that they might be exposed to different human rights issues and will allow for testing adaptation of the tools in consideration of these regional differences.

For example, most sugarcane production in Brazil has been mechanized in the past decades. In 2022, more than 99% of cane production in São Paulo was mechanized**. However, adoption of mechanical harvesting was slower in the Northeast, where manual harvest still made up almost 90% of all harvest in 2015, attributed mostly to steeper slopes and a greater availability of labour***.

*Child labour in the primary production of sugarcane, May 2017, Brazilian plantations accused of forced labor supply Europe with sugar (

**Union of the Sugarcane Industry (UNICA). Agroenvironmental Protocol ‘Green Ethanol’ completes 15 years. (2022)

***National Supply Company (Conab). Profile of the Sugar and Ethanol Sector in Brazil – Edition for the 2014-2015 harvest (2017)

Why this project?

The Bonsucro Impact Fund supports collaborative, scalable projects that address the root causes of issues and accelerate sustainable sugarcane production.


This proposal builds on and extends the scope of current initiatives, leveraging action on the ground to build capacity in the whole sugarcane sector. The documents and recorded training sessions will be available permanently in the toolkit website for future consultation, remaining as a sectorial reference and scaling up the impact.

All documents will include general content that can be adapted to other contexts and regions, both within Brazil and beyond. Specific guidelines for the Brazilian sugarcane sector will be added in complementary sections. In the future, these documents can be supplemented with other sections referring to different producing regions and national contexts.

A systemic approach that connects to the root causes of the problem

One of the root causes of human rights issues is an inability for the private sector to know how to identify them and take action. Using an HRDD mechanism provides the opportunity for mills to identify not just when they need to take direct action, but also to engage in at-scale initiatives with others (e.g., government and NGOs) to address systemic action (e.g., providing support to migrant workers, or raising standards across the sector). The mills and supply chain companies themselves will be able to identify actions to address root causes as part of their HRDD.


Once developed, the outputs of the project (capacity building materials, HRDD methodology, implementation tools, etc.) will be used by mills in Brazil and will provide the foundation to expand the approach to other countries and contexts.

Additionally, the involvement of different actors through the entire project implementation period seeks not only to raise awareness in the sector but also to ensure the relevant stakeholders take ownership of the HRDD approach, increasing the prospects of its continual and wider implementation.

Expected outcomes

  • Practical resources and guidance on HRDD to identify real and potential human rights impacts in the supply base.
  • Strengthened ability to address worker’s rights and other social issues in sugarcane production and processes (e.g., working conditions, recruitment practices, adequate pay, basic rights, child and forced labour, gender equality, discrimination and harassment, conflicts with Indigenous Peoples and Local Communities).
  • Reduced risk in sugarcane volumes purchased from Brazil.
  • Compliance with current and upcoming relevant legislation in the US, Europe, Canada, and Japan.


Bonsucro Impact Fund

The Bonsucro Impact Fund invests in impact projects that address critical sustainability challenges in the sugarcane sector.

The Bonsucro Impact Funds uses income from the sale of Credits through the Bonsucro Credit Trading Platform.

All trades are charged a transaction fee, around 50% of which is invested into the Bonsucro Impact Fund.

Learn more about the Fund and check for grants available here.



Bonsucro Credit Trading


By purchasing Bonsucro credits for sugarcane, ethanol, molasses and raw sugar, companies support impact projects on the ground through the Bonsucro Impact Fund.

Visit the Bonsucro Credit Trading Platform.



Sign up to our newsletter

Get the latest industry insights, and stories from all corners of the supply chain straight to your inbox.