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How often do you assess your suppliers on their business practices in relation to human rights?

What questions do you ask them?

How do you act based on the responses you get?

Taking the right approach to human rights supply chain risk management is challenging. Each company has their own set of unique needs, and due diligence standards vary across industries.

Biggest Hurdles to Overcome

  • Human rights assessments require suppliers to report on sensitive information. This makes it tough to get strong response rates, and receive accurate responses.
  • There are no standardized measurements of corporate supply chain human rights performance. Unless you have an entire department dedicated to the subject, your supplier assessments can have gaps and improper formatting that skews supplier response insights. (click here to get help with your assessment process)

How do you create and maintain a strong human rights program?

In short, ask the right questions. Global organizations and special interest groups have created “de facto” standards around human rights measurements that are included in regulations and followed by the world’s largest brands. The International Labor Organization (ILO) and the Organization for Economic Co-operation and Development (OECD) are two of the most prominent thought leaders in the space and have created globalized frameworks for workers rights and enterprise supply chain due diligence.

Each group has an extensive set of criteria they consider critical, but there are a few commonalities within each group’s focus areas. Here are 5 elements to be included in strong human rights assessments:

Keep in mind – this is a brief overview and a strong human rights due diligence program goes in depth on each one of the following topics. The Corporate Human Rights Benchmark Limited (CHRB Ltd.) recently published a 2018 key findings report on human rights in multi-national enterprise supply chains, which goes into detail on the following areas. Click here to view the report.

Regulation Guides:

California Transparency in Supply Chains Act – SB 657. Click Here

UK Modern Day Slavery Act. Click here

1. Worker Compensation

Historically, compensation structure has been a strong measurement of supplier risk in regards to human trafficking, specifically bonded labor.

Assessment Question Examples:

  • How and when is a worker paid?
  • Are there opportunities for a supplier to withhold part or all of an employee’s wage?
  • How is overtime identified and paid out?
  • What are some of the variables that factor into an employee’s paycheck?
  • How are expenses accounted for, and paid back to the employee?

2. Worker Restrictions

Understanding how a supplier structures employment contracts can help you identify instances of forced labor.

Assessment Question Examples:

  • Do your workers have complete freedom of movement outside of the workplace and during non-working hours?
  • Do you withhold any personal documents from a worker during the time of their contract?
  • Do you utilize labor agents that impose additional requirements for workers?

3. Workplace Safety

Depending on their geographic location, a supplier may have unique workplace safety codes, however it’s important to make sure standards are upheld.

Assessment Question Examples:

  • In the past year, have any of your workers been injured during their working hours?
    • How many?
    • What was/were the cause(s)?
    • What remedies do you have set in place to ensure a healthy recovery?
  • Do your employees have access to safety information in the event of a chemical spill, machine malfunction etc?
  • Do you have clearly defined exits in the event of a fire or need for evacuation?
  • Do you regularly monitor water quality and ensure cleanliness of your workplace environment?

4. Child Labor and Women’s Rights

A staple of human rights is to ensure there is no child labor present in supply chains and that women’s rights are upheld and equality is set in place. Countless NGO’s monitor data points around these topics and companies have faced monetary penalties for human rights violations with these topics.

Assessment Question Examples:

  • Do you verify the age of your workers? If so, how?
  • How do you ensure there is no discrimination of women at your company?
  • Is there a remedial process in the event of a woman reporting harassment, intimidation, or violence?
  • How do you ensure equality in the workplace?

5. Company Policies

This is a broad topic, and you can include a variety of questions, but the key is to get a high level understanding of a supplier’s commitment to the well-being of their workers.

Assessment Question Examples:

  • Do you have a code of conduct?
    • Do you ask each one of your employees to acknowledge they have reviewed your code of conduct?
  • Do your own purchasing decisions take supplier human rights accountability into consideration?
  • Do your workers have access to a whistleblowing service?
  • Is there a member of your senior staff who is in charge of ensuring human rights within your company?

The above are all elements of a strong human rights program. By no means are they the only measurable elements, and each element described above can go further into detail.

They are, however, starting points. If you’d like to learn more, follow the resources below to learn about the deployment of assessments, data collection best practices, drawing analytics, and reporting on your findings.

How To:

Design an ethical sourcing risk management program

Click here

Risk Management:

Desktop Assessments

Click here

Anti-Human Trafficking Compliance 101:

How to minimize risk

Click here

Enterprise Compliance Solution:

Anti-Human Trafficking

Click here

Compliance Program:

Whistleblower Hotline

Click here

Data Management:

Source Intelligence Platform

Click here

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