PART 4: HOW SHOULD BUSINESS RESPOND? Tracking the effectiveness of your response Monitoring and tracking activities are essential in helping your business to understand whether the measures you are taking to manage your human rights risks are effective.127 There are a variety of ways your business can track its response. Tracking can be undertaken internally, by third parties or a combination of both. Potential data sources include staff surveys and feedback to human resources, internal audits, supplier audits, grievance mechanisms and stakeholder feedback. When assessing effectiveness, it is important to engage with affected stakeholders to gain an understanding of whether their situation is improving and whether adverse impacts have been appropriately addressed. Although social auditing can be used To track performance, it is important to develop as a tool to monitor the due diligence practice indicators that draw on both qualitative and in the supply chain, this process alone is not quantitative data. Each type of data tells a sufficient to track human rights impacts.128 different part of the story. For example, a worker complaint hotline may only have had two complaints in the last month. At face value, one may conclude that there are no issues, and the business is fully compliant with all human rights and labour standards. However, it is important to interrogate the lack of complaints in order to understand whether this reflects the reality on the ground or whether there are barriers that are preventing individuals from making a complaint or identifying risks. This scenario highlights the Tracking Performance: TUI Group TUI Group is required to report under the UK Modern Slavery Act. To track the performance of its modern slavery efforts, the company has developed a number of indicators. These include: • importance of having qualitative data to tell the story behind the numbers and figures. • • • • • 48 | Number of customers staying in a Global Sustainable Tourism Council certified hotel Number of employees that have received human rights training Actions taken to strengthen the company’s policies Steps taken to strengthen supply chain due diligence and management Number of modern slavery cases reported, and actions taken in response Human right projects and partnerships in TUI Group’s destinations.129