Build a due-diligence request list around the questions management needs answered

A due-diligence request earns its place when the answer could change the next piece of review work. Start with the question management needs resolved, write down the evidence that could change your view, and then request it. This produces a list that can evolve as records arrive, rather than a folder that keeps growing without a clear stopping point.

This guide develops an original fictional document-review exercise. It helps organise requests and unresolved questions; it does not establish legal compliance, environmental performance, investment suitability or completion of due diligence. The company, records, dates and responses below are invented.

OECD’s 2018 guidance scales due diligence to the severity and likelihood of adverse impacts. It moves from broad risk scoping into progressively deeper assessment. The staged requests below are an original working method, not an OECD template.

Turn the management question into a test

At fictional Alder Works, management wants to identify wastewater-record gaps before assigning the next review work. A second washing line began operating on 1 August 2026. The initial question, Q1, is specific: which August and September records can be located for every operating wastewater outlet, and what still needs following up? The exercise examines record coverage, without judging discharge quality or the adequacy of monitoring.

Write the proposition that the first request will test: the summary indexes provide a usable route to records for every outlet and month in the operating map. Then write what would challenge it: an additional outlet, an unexplained label change, or a summary with an uncovered period. This counterevidence belongs in the reviewer’s plan before the response arrives, so a reassuring document title cannot quietly replace the test.

Ask for the records that distinguish the possibilities

R1, owned by operations, requests the outlet map effective from 1 August, its change history and the record identifying when Line B started. The purpose is to establish the population the summaries should describe. Ask for existing references and versions; a newly drawn diagram should be identified as a later explanation.

R2, owned by the environmental records coordinator, requests the August and September management summaries, their supporting-record indexes and the meaning of each outlet label. The index should identify the outlet, covered period, record reference and any stated omission. Copies of the entire environmental data room are unnecessary for this first coverage test.

Each request carries Q1, its responsible owner, the agreed response date and the requested version or period. Offer a clear unavailable response: identify the missing item, where it was sought, who may hold it and the proposed next step. An unexplained blank cannot tell the reviewer whether a record is absent, inaccessible or simply overlooked.

Define the next request before seeing the answer

Use three response paths for Q1. They are request-routing choices, not risk ratings:

Matching coverage: if the map and indexes identify the same operating outlets and months, select the referenced records needed to test the index’s accuracy. Record why that selection is sufficient for the narrow question and what it leaves unexamined.

Conflicting coverage: if an outlet or period appears in one record but not the other, ask for the specific cross-reference or explanation that could reconcile it. Preserve both versions. A general statement that the summary is complete does not resolve the difference.

Unusable response: if the map is missing or labels cannot be interpreted, ask for the missing basis first. Keep Q1 unresolved and tell management how that limits the planned review. Repeatedly requesting more summaries will not repair an unidentified population.

Original fictional workflow. The response changes the next request; locating one month’s reference does not close the other month’s record gap.

Let the response change the list

R1 produces map M2, effective 1 August, showing outlets O1 and O2, with the start record identifying Line B’s commencement on that date. R2 produces summaries S-AUG and S-SEP. Both indexes identify O1 only. The O1 references are available for examination, while Q1 remains unresolved for O2. The next request should target O2 rather than repeat the original broad request.

Issue R3 under Q1: identify the August and September supporting records, if any, for O2; explain whether O2 has another label in the supplied summaries; and provide the reference supporting that explanation. Ask for the original records separately from any retrospective reconciliation. The question now has a defined gap and a response capable of narrowing it.

The coordinator supplies record O2-SEP, a September entry in a separate records index. They state that O2 was omitted from both summary indexes and that no August record has been located. The reviewer can inspect the September reference and document the omission. August remains unresolved; the response does not establish that monitoring never occurred or that a discharge requirement was breached.

Next, ask whether an August record was expected and on what basis, where it could be located and who can check, with an agreed date. The exercise prescribes no sampling frequency. If no usable evidence is found by the review cut-off, carry that limitation into the management question. Do not manufacture a retrospective record or substitute September evidence for August. Any technical question about monitoring coverage needs a separately scoped review.

Close requests without losing the question

Keep two statuses. A request can be received while the question remains unresolved. For R3, the response was received, the September reference was identified, and the August gap remained open. Record those outcomes separately. Treating the arrival of a file as closure would hide precisely the uncertainty management asked the review to clarify.

Withdraw a request when its purpose has genuinely disappeared, but record the reason and the request that replaces it. Combine duplicates that seek the same evidence for the same period. Preserve links to every question the record serves. A smaller live list should reflect resolved or redirected work, rather than deleted difficult questions.

Keep the request sequence flexible. A record suggesting an immediate safety or environmental concern should reach the responsible operational lead through the agreed escalation route while the evidence is examined. An administrative response date is not a reason to postpone protective action or the assessment of a potentially urgent concern.

Run a short challenge before sending

For each live request, ask: which management question does this serve; what response would change the next step; what counterevidence are we looking for; and what happens if the answer is unavailable? Remove requests whose purpose cannot be explained. Keep authorised access arrangements explicit, and use restricted or redacted records where appropriate rather than requesting unnecessary personal information.

The useful output is a question-led request list with a visible history: the first ask, the response, the reason for the next ask and the remaining limitation. Management can then assign the next review work knowing exactly which questions have support and which still require attention.

For help structuring a question-led evidence review, contact Nitium Advisory with a non-confidential description of the scope and unresolved questions.

Source: OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, printed pages 17 and 25–26. © OECD 2018. Checked 14 October 2026.