EVALUATE & MONITOR:
Information on how to: assess risk of forced labor and modern slavery in supply chains, and assess risk from recruitment
Action:
Assess the risk of human and labor rights violations
STEP 1:
assess risk of forced labor and modern slavery in supply chains

BUYER STEPS:
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Conduct a risk assessment of suppliers using publicly available resources to determine high-risk suppliers.
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For suppliers identified as high-risk, collect data directly from suppliers and conduct a detailed risk assessment.
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Conduct this analysis for both current and prospective suppliers.
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When possible, conduct an onsite visit.
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EMPLOYER STEPS:
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Conduct an internal assessment of own company operations to identify potential human and labor rights risks.
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Maintain updated documentation about working conditions and labor rights in supply chains to provide to upstream/downstream operations upon request.
SUPPORTING GUIDANCE
1. Understanding the indicators of forced labor:
Understanding the indicators of forced labor, as defined by the International Labour Organization (ILO) is a critical first step for being able to identify risk in supply chains.
2. Visualizing risk:
Use the links below to better understand country risk for child and forced labor for fishing and aquaculture through tools produced by the Responsible Sourcing Tool, the Global Slavery Index, and the Seafood Slavery Index.
3. Conducting a risk assessment:
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Companies should start by assessing risk at the highest level first - beginning at the country level - and then assessing down through suppliers and labor providers.
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Publicly available information may not go down to the level of individual suppliers; however, it often provides data on countries of production, countries of labor supply, and particular types of supply chains or fisheries within a country of production.
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When information is not publicly available, companies can gather it directly from suppliers via self-assessments or questionnaires, or through working with consultancies who can specialize in this field. Though there are limitations with self-assessments, they can be a good starting place.
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Based on the results of a risk assessment, companies can prioritize which products require further investigation based on severity and scale of risk.
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Companies can then conduct a detailed risk assessment on high-risk products to understand supplier social responsibility practices, identify what the exact issues are and what improvements are needed.
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An assessment of social risks can be conducted simultaneously with an assessment of products at risk of being illegally harvested or mislabeled.
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Conducting a high-level risk assessment of human and labor rights conditions in supply chains involves gathering information from a variety of sources, including:
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Gather information on social responsibility practices directly from existing suppliers.
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This can be done through vendor surveys with questions specifically targeted to identify what social responsibility practices suppliers have in place. Information received from surveys can be used to determine suppliers' risk for human rights abuses, identify gaps in social responsibility practices, and work with the supplier to create a plan of next steps.
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Supplier self-assessment questionnaires are an additional tool for collecting information from suppliers.
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International and national government-produced reports which focus on risk at a country, region, or commodity level.
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Public tools and risk assessment guides.
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Third-party consultancies.
Conduct an internal assessment of own company operations to identify potential human and labor rights risks:
In order to understand the risk for labor and human rights abuses, a company must determine whether it has practices in place to:
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Assess risks that may be present due to its sourcing regions and specificities (e.g. distant water fishing, subcontracted facilities, etc.).
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Mitigate and address those risks through company practices intended to unearth and respond to issues that arise.
Additional guidance, tools, and resources to help assess risk
STEP 2:
assess risk from recruitment

BUYER STEP:
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Assess risk from recruitment at each tier of supply chains, through the following:
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Require complete disclosure of labor recruiters used, and the recruitment policies and practices of each supplier, including: name of recruiter, address, license number, and license date of expiration.
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Collect data to assess whether suppliers are complying with company recruitment policies, and assess risk arising from responsible recruitment processes of own company and suppliers.
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EMPLOYER STEPS:
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Assess risk arising from responsible recruitment processes of own company and suppliers.
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Maintain documentation demonstrating that workers are recruited ethically, without having paid illegal or unauthorized fees in order to attain employment.
UNDERSTAND HOW RECRUITMENT PRACTICES PUT COMPANIES AND WORKERS AT RISK
Risk to workers from unethical recruitment practices
Source: An Ethical Framework for Cross-Border Recruitment (Verite)