I am submitting this comment on behalf of Verité, an independent, non-profit, civil society organization (CSO) working to eliminate the most serious labor and human rights abuses in global supply chains. We believe LEED v.5 should not miss the opportunity to go beyond environmental impact assessments and ensure communities and workers are protected through LEED certification.  

Along with environmental impacts, human and labor rights violations on construction projects are a growing concern that can be tackled with LEED certification.  According to the International Labour Organization, 14.2 million workers in industries such as construction or construction materials production face risks of forced labor. In the United States, the construction industry has the highest prevalence of human trafficking and forced labor when compared with other industries. There are indications that this is also a growing problem for the construction industry In the United Kingdom. Globally, the construction sector is second highest in risks for forced labor after domestic work. Construction materials from supply chains around the world have regularly been included on the U.S. Department of Labor’s annual list of products produced with child or forced labor. The 2023 list includes 22 listings for bricks alone.

LEED v.5 should go beyond environmental due diligence to include human rights due diligence, aligned to international standards. (See https://www.oecd.org/investment/due-diligence-guidance-for-responsible-business-conduct.htm.) Verite has worked to find practical solutions to translate international standards into tools and management systems that can help the construction industry respect workers rights, including our HRDD construction toolkit and ethical recruitment tool. (See https://www.responsiblesourcingtool.org/solution/construction-toolset/ and https://verite.org/cumulus/.