Heightened Human-Rights Due Diligence as Risk Governance: Food-Retail Supply Chains in Wartime Ukraine

Abstract Armed conflicts create severe risks to human security, including food insecurity, often in contexts where state-based regulation is compromised. This paper examines how private actors – specifically food retailers in Ukraine – have become crucial de facto regulators in managing this risk during the war. We ask: in a regulatory vacuum, how do social expectations and corporate risk management practices shape the governance of essential goods? Drawing on thirty-six semi-structured interviews with Ukrainian residents and a thematic content analysis of 280 public social media posts and comments (Feb 2022 – Dec 2024), we investigate how social expectations function as a form of social regulation, shaping corporate conduct. We find that stakeholders expect companies not only to mitigate their own operational impacts but also to actively address the negative human rights consequences of the conflict itself. Based on these findings, we propose an empirically grounded model of “heightened human rights due diligence” (hHRDD) as an adaptive risk regulation framework. This model offers critical policy guidance for the implementation of instruments like the EU’s Corporate Sustainability Due Diligence Directive (CSDDD), particularly for defining corporate responsibilities in conflict-affected and high-risk areas.