Ethical procurement awareness and guidance
Identification, mitigation and remediation
Explore ways your business can identify, prevent, mitigate, and manage human rights impacts by exercising due diligence.
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Supply chain mapping
Supply chain mapping is the process of collecting information about actors in the supply chain, material sourcing, supplier relationships, areas of potential risk, and opportunities for growth.
Supply chain mapping may include:
- identifying your suppliers and their suppliers or subcontractors
- identifying the location of your suppliers and their suppliers
- integrating information on your suppliers from various sources into one database
- conducting an initial risk assessment
After supply chain mapping is complete, consider which areas need prioritizing. A large enterprise might take widespread action. Meanwhile, a small to medium enterprise could take significant targeted action by:
- adopting strong policies
- researching suppliers’ conduct before entering into partnership agreements
- engaging suppliers to commit to RBC
Additional resources
Risk identification
Identify and mitigate human rights risks in alignment with policy commitments.
Identify scope
- Conduct a scoping exercise to identify internal and external business areas at highest risk for human trafficking, forced labour, and child labour
- Map supply chain activity and locations to gain a clearer understanding of where risks may occur
- Use this insight to take appropriate action
Consider asking these questions:
- Are there high levels of poverty in the location of work?
- What is the location’s track record with the rule of law?
- Is the location prone to political instability and corruption?
- Does the location offer worker protections?
- What child labour protections exist in the location; is child labour endemic?
- Does this industry tend to attract migrant populations?
- Does this industry typically involve safety risks, such as operating with chemicals, minerals or potentially dangerous machinery (i.e., mining)?
- Are there high-spend areas or key ingredients which are high-risk?
Identify impacts
- Start with identified high-risk areas to focus efforts where potential harm is greatest
- Conduct iterative assessments of prioritized operations, increasing the level of detail at each stage
- Use findings to identify and assess specific actual and potential adverse impacts on your business
Assess influence
- Assess the influence of your business, suppliers, and other relationships on actual or potential adverse impacts
- Determine causality or contribution: Identify whether these actors have caused, contributed to, or could cause/contribute to the adverse impact
- Use this analysis to guide responses, ensuring actions are appropriate
Prioritize risks
Use the assessment’s insights to prioritize the most significant internal and external risk areas for human trafficking, forced labour and child labour.
Specific questions to help prioritize risks may include:
- Are poor labour practices, such as unpaid overtime or poor working standards, being widely applied?
- Is there a lack of awareness about human trafficking, forced labour, and child labour?
- Is there lack of awareness about vulnerabilities in the business structure that enable exploitation?
- Is there a lack of active commitment and action to combat human trafficking, forced labour and child labour?
- Is there a product requiring high input of low-cost labour within the business?
- Are there structures within the business practice that allow workers to fall into debt to the business?
Mitigation strategies
Once you identify areas of risk, you can implement mitigation activities such as the following:
- Stop activities that cause or contribute to human trafficking, forced labour and child labour, such as:
- supporting worker debt
- excessive overtime
- withholding wages
- Ensure the long-term prevention of these activities
- Prioritize plans to prevent or mitigate actual or potential adverse impacts of your business, your suppliers, or other business relationships
Appropriate, escalating responses to risks associated with business relationships may include:
- continuation of the relationship throughout the course of risk mitigation efforts
- temporary suspension of the relationship while pursuing ongoing risk mitigation
- termination of the business relationship if:
- attempts at mitigation failed
- you deemed mitigation is not feasible
- the adverse impacts are severe
A decision to terminate the relationship should take into account potential social and economic adverse impacts.
Mitigation plans should detail your actions, as well as your expectations of your suppliers, buyers and other business relationships.
Remediation
If your business identifies that it has caused or contributed to adverse impacts, it should provide for remediation through:
- immediate support
- medium and long-term support
The British Standards Institution provides detailed steps for businesses to follow at each stage.
Immediate support
- Take immediate action when an adverse impact is first identified
- Adopt a victim-centered (victim-led) approach, as recognized by international best practices
- Understand barriers to engagement: Victims may hesitate to seek support or report due to fear, shame, or concerns about being believed
Potential victims
Signs that may help identify potential victims within the workforce:
- Physical appearance: workers look unkempt, dirty, malnourished, or display signs of physical abuse
- Few or no possessions
- Isolation and control: workers have limited social interactions, are driven to and from work, and have someone speak for them
- Reluctance to seek help: distrust of authorities, fear of revealing their immigration status
- Restricted freedom of movement: worker documents held by someone else, unable to leave work premises
- Unusual travel times to and from work
- Poor working conditions: excessive overtime, inadequate pay, lack of protective equipment
- Poor accommodation: workers live with other workers even if they do not appear to be friends, they do not know their home address
Guidelines for supporting victims
The safety and welfare of potential victims should be the primary concern:
- If a victim discloses the incident, listen carefully and without judgment. Assure them you are taking them seriously. Do not push them to share more than they are comfortable.
- Reassure the victim and look after their welfare, for example offering food and water. Try to build rapport and trust.
- Protect the identity of the victim and the person reporting the incident (if they are not the same person). Keep the victim separate from potential suspects. The aim is to minimize further harm.
- Try to create a safe environment where the victim feels comfortable sharing details.
- Do not promise complete confidentiality. Explain that the incident has to be reported to a manager or someone else who can help with the individual’s protection.
- Where the victim or witness is in immediate danger, call the police immediately. Ensure the individual(s) is in a safe place until the police arrive.
Note: In locations prone to corruption, this may not always be the best approach. Remain informed and find out if local non-government organizations (NGOs) can help in these situations.
- When interpreting, use a professional service. Asking a friend or colleague of the victim to translate is strongly discouraged.
- Honour the wishes of the victim. For example, they may want to leave with the potential suspect or request that the police report does not include their name. However, someone should make a report, as indicated above.
- It is not your job to investigate. Note what details you can, but do not try to take a formal statement. Report the incident to the authorities who can investigate further.
Medium and long-term support
- Responsibility for remediation continues after identifying a potential victim; it does not end at identification
- Assess case-specific responsibilities: You may need to engage with the victim or relevant law enforcement authorities
- Support or participate in legitimate remediation mechanisms that allow affected stakeholders and rightsholders to raise concerns and seek resolutions
- Use legitimate remediation mechanisms to resolve disputes
Practical actions to support in remediation include the following:
Cooperate in good faith with judicial or non-judicial mechanisms
- Recognize legal implications: If an adverse impact constitutes a criminal or administrative offence, your business may face prosecution or sanctions
- Cooperate fully and act with honesty to mitigate legal and reputational risks
- Implement strong policies and due diligence structures to support engagement with judicial or non-judicial actors. This can demonstrate where and how your business is taking responsibility for its adverse impacts
- Comply promptly with judicial rulings, including compensation or payment of withheld wages
Establish operational-level grievance mechanisms
- Establish third-party and in-house worker reporting systems to allow individuals to raise potential cases of human trafficking, forced labour and child labour without fear of retaliation
- Guarantee non-retaliation: Assure workers that there will be no retaliation and that there are systems in place to protect from adverse consequences of reporting
- Continuously improve mechanisms, based on lessons learned from identified cases
Engage with workers’ representatives and trade unions
Establish a process through which they can raise concerns to your business.