- Step 1: Engage Stakeholders and Partners
- Step 2: Assess risks and impacts
- Step 3: Develop code of conduct
- Step 4: Communicate and Train across your supply chain
- Step 5: Monitor compliance
- Step 6: Remediate violations
- Step 7: Independent review
- Step 8: Report performance
Assessing Internal Impacts and Risk Factors
Any risk and impact assessment process should begin with a thorough examination of your company’s processes and the ways in which you may be causing—or at risk of causing—child and forced labor abuse through your own practices.
For instance, it is widely acknowledged that rush orders and last-minute changes in specifications can cause problems in production facilities with respect to worker hours, working conditions, compensation issues and even forced labor. Similarly, companies may have social compliance systems in place that collect and track data on their suppliers’ compliance with their code of conduct, yet they continue placing orders with the lowest-cost suppliers, even those with poor compliance records. This sends a signal to suppliers that social compliance does not really matter, and negates any incentive to improve performance. The best way to mitigate these impacts is to integrate social compliance within all relevant units of your company. One resource that discusses this issue in depth is As You Sow’s Best Current Practices in Purchasing: The Apparel Industry.
As with assessment of external impacts (see below), this internally-focused assessment process should be ongoing, not a one-time exercise. Impacts and risks should be assessed prior to major business decisions or changes in operation, and at periodic intervals, especially when changes in the overall operating environment can be foreseen. It is often useful to engage external experts in such an assessment of your company’s internal processes and practices (see Information Gathering).
If, after examining these processes and practices, you discover abuses that you have already caused or to which you have contributed, you should actively engage in remediation. If you identify risks, these should be mitigated or prevented by engaging in a process of internal change with all relevant actors in your company.
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