- 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
Supply Chain Mapping
Companies know who their direct suppliers are and where their suppliers are located. However, in many cases, companies source from vendors or agents who do not disclose the factories or other production facilities from which they in turn source. Oftentimes companies may be aware of the first-tier factories and production facilities in their supply chains, but know little or nothing about the practices of second, third and other tiers of suppliers down the line. Companies should know as much as possible about who supplies to them—at all levels of the supply chain, including producers of raw materials. The more comprehensively a company can map its supply chains, the more accurately it can identify those places along the chain with the greatest risks of labor abuses. It is therefore important to communicate with your company’s sourcing and/or supply chain management teams to obtain data about their own supply chains, and if more information is needed, to work closely with them to supplement that data.
If your company currently does not have access to information about suppliers beyond those from whom you directly source, the best way to obtain this information is to work with the legal department and/or other appropriate units in your company to create contractual requirements for disclosing comprehensive information about all of your suppliers.
“Mapping” includes knowing not only who your suppliers are (throughout the supply chain), but also where they are located. This information is essential for risk and impact assessment related to legal and regulatory environments, among other things. This exercise may also include maps showing seasonality of production or production cycles throughout the year, as these may be tied to times of greater risk for labor abuses.
The following are three examples of supply chain maps:
Example 1: Cocoa Supply Chains (Cote D’Ivoire and Ghana)
Example 2: Electronics Supply Chains - Cobalt (See page 44 of the PDF), Tantalum (See page 43 of the PDF), Tin (See page 42 of the PDF)
Example 3: Generic Import Supply Chain - Retail Model
Goods produced using agricultural or mineral commodities can be particularly difficult to trace, since the raw materials are harvested or mined in widely dispersed geographic areas and aggregated or co-mingled early in the supply chain. Some companies and industry coalitions have attempted “traceability” programs to track certain commodities from a finished product back through the supply chain to their point of origin.
To be clear, mapping supply chains does not necessarily imply that your company is responsible for all impacts and risks associated with every entity in the chain. As stated in the United Nations Guiding Principles on Business and Human Rights, “where business enterprises have large numbers of entities in their value chains it may be unreasonably difficult to conduct due diligence for adverse human rights impacts across them all. If so, business enterprises should identify general areas where the risk of adverse human rights impacts is more significant, whether due to certain suppliers’ or clients’ operating context, the particular operations, products or services involved, or other relevant considerations, and prioritize those for human rights due diligence.” This prioritization process is addressed below.
Fair Labor Association (FLA) Cotton Project: Tracing the Cotton Supply Chain
The FLA describes itself as “a membership-based organization of universities, civil society organizations and socially responsible companies whose mission is to protect workers’ rights around the world.”
According to the FLA, “Between 2008 and 2010, the FLA conducted a pilot exercise to transparently trace cotton along an entire supply chain. The initial phase of the FLA Cotton Project mapped the supply chain by tracing cotton goods backwards from cut and sew to fabric mill, cotton gin, cotton production and production of cottonseeds. Two supply chains (one organic and one conventional) were mapped. Tracing for the conventional chain was conducted by a monitoring organization, relying on verified documentation at each stage of the supply chain. One of the outcomes of the project was a mapping tool that can be used by any brand to map its cotton supply chain and to identify and rank risks. The final goal of the process was the full traceability of cotton with task and risk mapping.
Once brands could trace their cotton sources, the next phase monitored working conditions at different points along the supply chain. Internal discussion with relevant stakeholders occurred in order to develop a combined strategy for monitoring and remediation.
From lessons learned in the pilot, the FLA recommends that retailers and brands intervene before the production cycle begins to require documentation from suppliers before confirming or placing an order.”
Source: Fair Labor Association.
National Fisheries Institute Best Aquaculture Practices: Tracing the Seafood Supply Chain
An integral part of Best Aquaculture Practices (BAP) international certification is traceability—linking the aquaculture seafood production chain and allowing each processed lot to be traced back to the ponds and inputs of origin. All certified facilities must participate in the online BAP traceability system hosted by TraceRegister, Inc., which securely stores product information and makes it available to verified BAP program participants. Traceability assures purchasers that all steps in the production process comply with environmental, social and food safety standards.
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