Auditing as an Emerging Tool for Change
Audits can be used as a tool to understand and document abuses and to drive change in fundamental business practices. Audits should prioritize substantial, confidential worker input. Audits should always link to corrective action plans to correct for violations found during an audit, although it should be acknowledged that many problems (especially those associated with forced labor) are not easily remediated and require sustained engagement and new ways of conducting business that reward compliance rather than expect it, without changing underlying dynamics in that market.
Buyers should also note that many auditors are not well trained to spot forced labor risk, and that often the “scope of work” for an audit and the rigid procedures followed by many auditors result in few or even no findings of forced labor risk, even when suspect practices are widespread. Careful screening and on-going quality control of auditors is also vital.”
A Supplier Code of Conduct establishes basic performance expectations for subcontractors, suppliers, and agents.
It is important that your firm’s sourcing policy or Code of Conduct explicitly prohibits human trafficking and sets out protections and remediation for workers. A firm’s code should also address factors that are “enablers” or contributors to situations or risks of human trafficking. A subsequent Social Responsibility Agreement affirms compliance with contractors, suppliers, or agents to your Code of Conduct and applicable legal requirements. It can be a standalone document or included as an appendix to a contract.
Note: The Institute for Supply Management provides helpful steps in its Principles and Standards of Ethical Supply Management Conduct with Guidelines
To find Company Transparency Disclosures, TISC Report is a useful tool.