Evaluate & Monitor:

 

Information on how to: monitor and verify compliance

Action:

Verify compliance with human and labor rights policies and expectations

STEP 1:
monitor and verify compliance

BUYER STEPS:

  • Determine supplier compliance with expectations established through company policies, codes of conduct and supplier expectations.

  • Engage in the following on a regular basis:

    • Assess if suppliers have a code of conduct and review to ensure both supplier and company's own internal code of conduct are aligned with good practices.

    • Collect results of verification activities conducted by suppliers.

 

EMPLOYER STEPS: 

  • Demonstrate compliance through a combination of worker engagement mechanisms, social audits, seafood social certifications, and a combination of other tools.

  • Provide downstream buyers with information that demonstrates compliance with policies, codes of conduct and supplier expectations.

 

supporting guidance

Verification processes are a critical tool for evaluating whether suppliers and labor providers comply with company policies, codes of conduct, and expectations, to identify instances of non-compliance, and to determine where improvements are needed.

 

  • There are a variety of methods companies can use to gather and verify human rights and labor conditions within supply chains. These include supplier questionnaires, vendor surveys, worker engagement mechanisms, and social audits.

 

  • Robust certification programs incorporate a variety of due diligence mechanisms into their methodology and processes. This includes comprehensive standards, highly trained auditors, the incorporation of worker voice principles into audits, and processes for making improvements if needed. Furthermore, the audits and certification status should be conducted or reevaluated at regular intervals.

 

  • Companies should ensure that verification processes include hearing directly from workers (in a manner that fosters trust and protects workers from potential retaliation), in order to obtain an accurate representation of supply chain working conditions. 

 

Supporting Resources:

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This sample checklist is designed for compliance personnel operating in companies or third-party organizations providing services to companies. The aim of this checklist is to help compliance personnel perform better assessments. Such assessments are a key link in the implementation of corporate codes of conduct and enable auditors to identify forced labor at enterprise level and in global supply chains.

 

Benchmarks are vital in demonstrating how anti-trafficking policies should be implemented. Clear performance indicators enable companies and others to evaluate whether genuine changes are made in the labor and recruitment practices of suppliers. The suggested benchmarks in this tool are aligned with relevant guidance from the International Labour Organization, particularly the Work in Fishing Convention (C188), which sets standards around issues such as health, safety, and medical care at sea as well as requirements for work agreements. 

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Vessel monitoring systems, particularly in areas beyond national jurisdiction, play an important role in increasing transparency and addressing vulnerabilities that allow for the concealment of illicit activities, such as IUU fishing or human and labor rights abuses. Vessel monitoring systems, automatic identification systems, and International Maritime Organization numbers can be used to verify vessel activity and ownership.

Tool for verification: worker voice

Worker voice can be a powerful and effective means to support workers and business.

Engaging workers in reporting and providing feedback on working conditions is a critical component of effective verification practices. Companies can adopt worker voice mechanisms/tools/technologies to gather information and verify supply chain conditions from workers directly, and encourage company supply chains to adopt.

 

‘Worker voice’ is a communication of the priorities, needs, and concerns of workers to their management, for the purpose of eliciting a response from management to the voiced needs.  It is a term derived from the roots of the organized labor movement, and the classic example of worker voice are trade unions and collective bargaining agreements.

 

Worker voice mechanisms are needed because workers should always have a way to be heard by their employers - and employers should value being able to get honest feedback from their employees about how the business could improve.  Workers have visibility on a range of different issues and conditions within the day-to-day operations of a company’s different production units, which is an asset that can contribute to management decision making.

Issara Institute: What is Worker Voice in the Context of Global Supply Chains?

This brief presents 5 key questions that need to be asked, from the perspective of data integrity and worker empowerment, for worker reporting tools and programs

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Tool for verification: social audits

Audits play a role in a company’s overall due diligence program, and if done properly, can help surface problems. Social compliance audits can be particularly useful in assessing workplace health and safety conditions and document review, and provide a snapshot in time of what is happening. These are typically areas of assessment where workers receive little training and are sometimes unaware of their rights or legal requirements for workplaces.

 

However, while audits can be a helpful tool to understand issues in supply chains, they are not a “silver bullet”.

 

  • Understanding good practices for social audits:

    • The variability in quality of social audits requires that companies understand the potential limitations of social audits, and ensure they are conducted according to good practices for workers.

    • Audits can be conducted in a variety of ways, but should consistently assess legal compliance, working conditions, hours and wage records, health and safety conditions, and also include confidential worker interviews in a language the worker is proficient in.

    • It is critical that social audits include worker feedback to help validate the data collected through records review and from management.

    • It is imperative that there are processes in place so that worker respondents are safeguarded against reprisal.

    • Companies should be prepared to handle issues and make a commitment to remediation if issues are found during the social audit process.

 

  • Compliance that goes beyond social audits:

    • Social audits should be viewed as one tool for due diligence. Companies need to adopt a multi-pronged approach to identifying supply chain conditions in order to best understand the labor rights issues workers may experience.

    • These additional processes are critical components for accurately understanding labor conditions and responding to potential labor violations in supply chains.

    • Communication channels outside of audits can provide workers safe methods to report on their conditions, and reduce the potential for negative consequences or reprisals.

    • Companies should implement worker voice channels, which includes gathering data from workers themselves, and establishing robust, safe, and effective grievance mechanisms which are free from reprisal for workers. Worker voice channels should be credible, independent, and linked to remediation.

    • Third party service providers need to have strong ethical practices and ought to perform risk assessments to ensure no harm is done. 

 

 

Critical information to know about social audits
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From Audit to Innovation: Advancing Human Rights in Global Supply Chains (Shift)

 

This report explores innovative models used by leading companies, who themselves report their effectiveness, as a basis for further analysis and evaluation.  It begins by identifying 10 leading trends and elements that form this new generation of social compliance programs for supply chains. In the second part of the report, we highlight four company case experiences in more depth, whose approaches combine many of the elements identified above to address complex social performance challenges in supply chains. 

The tools below provide support for companies seeking to conduct social audits according to good practices
Verité Fair Hiring Toolkit
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Walk Free Foundation
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Seafood Taskforce
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Seafood Task Force: 

Vessel Auditable Standards

Tool for verification: certifications with social components

Companies can consider utilizing social certifications, and seafood certifications that include social components, as a tool to improve the social responsibility of seafood products.

It is important for businesses to understand the components of a social certification when choosing which program to adopt.

For the most part, certification standards in the seafood industry have been focused on improving ecological sustainability and traceability. However, some certification programs include social standards or are actively involved in developing them for the seafood industry.

 

Seafood certifications that include social standards and robust verification processes offer a number of potential benefits to companies that choose to adopt them:

  • Ensure products meet social criteria in the standard

  • Communicate product and facility integrity to civil society and the seafood industry

  • Improve company reputation and relationships

  • Build trust within global supply chains

  • Ensure safe, secure, and legal livelihoods for fishers and workers in the supply chain

As a best practice, companies should take time to understand the components addressed by a certification’s standard, the parts of the supply chain that they cover, and mechanisms for verification and enforcement.

Evaluating certification programs:

  • Robust certification programs incorporate a variety of due diligence mechanisms into an integrated program. Such certification programs should include comprehensive standards (referencing and aligned with ILO conventions and other key international labor rights protections) and highly trained third-party auditors; incorporate worker interviews into their audits; conduct unannounced audits at regular intervals; include robust and effective grievance mechanisms and include requirements for making improvements to practices when needed.

  • The ISEAL Alliance can be a useful reference for companies seeking to differentiate between certification programs. While many comprehensive certifications may not be ISEAL accredited, it is considered industry best practice, and any member must meet a demanding accreditation process that includes meeting ISEAL Codes of Good Practice.

  • Companies should seek to promote labor rights within certification systems by including fishers and workers themselves in the governance, implementation and oversight of the program.

  • Companies should seek to promote supply chain transparency by disclosing the location of their suppliers and reporting publicly on working conditions.

To learn specific social responsibility information collected by seafood certifications with social elements, please reference: FishWise: Social Responsibility Information for Seafood Supply Chains: A Compilation of Resources
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Click for a list of seafood certifications with social components