Factory vetting process step — grievance mechanism check
In brief: The grievance mechanism check during Bangladesh buying house factory vetting tests four signals: an anonymous channel emptied by a third party, a written response protocol with 7-14 day acknowledgement and 30 day resolution timelines, real cases logged over the last six months with dispositions, and worker awareness verifiable by asking three workers at random.
3 workers
Random Interviews
I ask three workers at random whether they know how to file a grievance.
7-14 days
Acknowledge Window
A documented protocol should acknowledge a complaint inside this window.
6 months
Case Log Depth
I want to see real cases logged over the last six months, not a blank book.
Most grievance mechanisms I see in Bangladesh garment factories are suggestion boxes. A wooden box bolted to the wall near the canteen, often with a lock, often with the key held by the same HR officer the workers would be complaining about. The box is not the mechanism. The mechanism is what happens to a complaint after it leaves the worker's hand — and that is what my grievance mechanism check during the factory vetting process is built to test.
What does a real grievance mechanism look like inside a Bangladesh factory?
A real mechanism has four parts. First, an anonymous channel — a hotline number printed on the wage slip, an SMS line monitored by an external worker rights organisation, or a locked box emptied by a third party who does not work for the factory. Second, a written response protocol with timelines: acknowledgement inside 7-14 days, full resolution inside 30 days. Third, an active case log with dispositions over the last six months. Fourth, worker awareness — if I ask three workers at random how to file a grievance and none of them can answer, the mechanism does not exist regardless of what is bolted to the wall. I learned to ask the workers, not the HR officer, because the HR officer's job that morning is to tell me the mechanism works.
How do I run the grievance mechanism check during a site visit?
I do it in a specific order. Before I walk the floor, I sit with the HR officer and request the grievance log for the last six months. I look for date stamps, complaint type, who handled it, response time, and final disposition. A log with one entry from eight months ago is a failed check. A log with twelve entries handled inside the documented timeline is a passed check.
Then I walk the floor and I do not announce that I am checking the grievance mechanism. I stop at three sewing lines and I ask three workers — not the line leader — a single question: if you had a problem with your wage or your supervisor, what would you do? If the answer is "tell my supervisor" or "I do not know," the mechanism has failed at the worker awareness step. If the answer references a hotline, a box, or a name, I confirm it against the documented mechanism. The factory vetting process step is not the inspection of the box. It is the verification that the box does work the workers know about.
Real Mechanism vs Suggestion Box
Anonymous channel emptied by third party
Written response protocol with timelines
Cases logged over the last six months
Worker awareness verifiable on the floor
Disposition recorded for each case
Escalation path when the factory cannot resolve
Complaint book on the supervisor's desk
No written response timelines
Empty log presented as proof of harmony
Workers cannot describe how to file
No record of what was done with cases
No escalation beyond factory management
What does CSDDD require for grievance mechanisms in Bangladesh?
The EU Corporate Sustainability Due Diligence Directive is specific on this point. It requires in-scope brands to ensure operational-level grievance mechanisms exist along their supply chain, including Tier 2 factories. Effectiveness criteria the directive references — drawn from the UN Guiding Principles on Business and Human Rights — include legitimacy, accessibility, predictability, equitability, transparency, and rights-compatibility.
That language sounds abstract. Operationally it means three things a brand can document. The mechanism is reachable by the worker without going through her direct supervisor. There is a written record of how complaints are handled and how long it took. The brand can demonstrate the system was tested during factory engagement, not assumed from a certificate. A BSCI audit ticking "grievance mechanism: present" does not satisfy this. BSCI audit scores do not predict delivery reality, and they do not predict the strength of a grievance system either.
Why does an empty grievance log fail the check?
This is the most common pushback I get from factory owners. The grievance log is empty, they say, because the workers are happy and the management style is open-door. I have heard that sentence in Gazipur, in Narayanganj, in Chittagong. It is wrong every time. A factory with 1,500 workers and zero grievances logged in six months is a factory where workers either do not know how to file, do not trust the process, or have learned that filing creates a problem for them, not a solution.
The contrast between what a brand currently has on file and what CSDDD-grade evidence looks like is the gap I am closing on every Bengal Origin Co process for factory vetting.
| Element | Suggestion box theatre | Real grievance mechanism |
|---|---|---|
| Channel | Box near HR office | Anonymous SMS or hotline, third-party emptied |
| Acknowledgement timeline | None documented | 7-14 days written into protocol |
| Resolution timeline | None documented | 30 days written into protocol |
| Case log depth | Empty or 1-2 stale entries | 6 months of cases with dispositions |
| Worker awareness | Workers say "tell supervisor" | Workers name the channel by description |
| Escalation path | Stops at factory management | Routes to brand or buying house |
Source: Bengal Origin Co. factory vetting protocol, applied across 120+ Bangladesh factory engagements 2022-2026.
What This Means for European Brands
If you are sourcing from Bangladesh through a buying house, ask one question: what does your grievance mechanism check during factory vetting actually test? If the answer is "we check that the factory has one," that is not a check. The check is whether the mechanism produces records, whether the timelines hold, and whether the workers know it exists. Run the same four-signal test on your current sourcing partner's process. If they cannot describe the test, they are not running it. CSDDD will not accept that gap. The Bengal Origin Co. process for factory financial and operational vetting makes the grievance mechanism check a written step, not an inspection day formality.
If your current Bangladesh sourcing partner cannot show you how their grievance mechanism check works in practice, I am happy to walk through what an evidence-grade four-signal check looks like on the factory floor.
Start a conversation →