- 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
Audit tool formats vary; some are on paper (later transcribed into an electronic system), while others are programmed into handheld electronic devices. Electronic tools are not necessarily superior to paper-based ones, but they do allow for greater efficiency and quicker reporting back to non-field-based team members.
Audit tools are essentially sets of questions that flow directly from the code of conduct; in a sense, they “translate” the broader statements in the code into specific data points that must be gathered to assess compliance with the code.
For example, with respect to child labor, a code of conduct might say:
- Suppliers shall not employ children under age 15 or the minimum age for work as defined by local law, whichever is higher.
Based on this code provision, the audit tool would then guide the auditor to examine issues such as:
- What proof of age documentation is required at the time of hire? How is this documentation verified? Where is proof of age documentation kept?
- If there are children under age 15 in the facility, are they working in a legal apprenticeship or training program? What documentation does the facility keep to verify that this is a legitimate apprenticeship or training program?
- Are they doing “light work” as defined in local law or international standards? How does the facility define and document “light work”?
- What are the working conditions of all persons under age 18? What specific tasks are they performing? What equipment are they using? Can any of these tasks or equipment be hazardous?
- How does the facility distinguish between hazardous and non-hazardous tasks, and how is the facility ensuring that persons under 18 do not engage in hazardous tasks in violation of international law?
Forced labor is an extremely complex labor rights violation that can take many forms. The below audit tool questions can help an auditor identify specific forms of forced labor. (Note: in the two-part typology of the International Labor Organization (ILO), the indicators listed in Tables 1-3 are indicators of “involuntariness,” and the indicators in Table 4 focus on penalties or threats of penalties to which workers may be subject.)
Table 1: Indicators of Forced Labor Through Recruitment Practices
- Were any workers born or descended into "slave" or bonded status?
- Were any workers abducted, confined during the recruitment process, or sold into this job?
- Were any workers recruited through some form of debt arrangement, such as an advance or loan, which they are working to pay off?
- At the time of recruitment, were any workers told they would be doing work of a different nature from the work they are currently performing?
- At the time of recruitment, were any workers promised certain working conditions, employment contract terms, living conditions, job locations, employers, or wages/earnings that are different from what they actually receiving?
- At the time of recruitment, were workers offered marriage as an incentive?
Table 2: Indicators of Forced Labor Through Work and Life Under Duress
- Are any workers working excessive overtime beyond legal limits?
- Are any workers forced to work “on call” (day or night)?
- Does the employer restrict workers’ freedom of movement or communication with others inside or outside the workplace?
- If workers’ lodging is provided by the employer, are the living conditions degrading?
- Does the employer force workers to engage in illicit activities, to work for his/her private home or family, or to take addictive drugs?
- Does the employer impose or inflate workers’ indebtedness through means such as falsifying work records, inflating prices for goods that workers are obliged to purchase, reducing the value of goods or services produced by workers, charging excessive interest on loans or advances to workers, etc.?
- Are any workers dependent on the employer for housing, food, and other necessities?
- Do any workers have dependency relationships with the employer that go beyond the job, e.g., personal relationship, dependency on the employer for family members’ employment, etc.?
Table 3: Indicators of Forced Labor Through Impossibility of Leaving
- Do any workers feel they do not have freedom to resign the job because of training other benefits they have received from the employer?
- Can workers terminate employment at any time, without penalty (except as provided by law)?
- Do any workers feel compelled to stay in the job because they are waiting for wages they are due?
- Are any workers working for an excessive or indefinite period of time in order to repay a debt or advance from the employer or recruiter?
Table 4: Indicators of Penalties or Threats
If any of the indicators listed above are present (note that any one indicator is enough; one is not needed from each table), the auditor should examine whether penalties or threats are being used to exact labor. If so, the situation may constitute forced labor:
- Does the employer (or recruiter) threaten to turn workers over to government authorities (e.g. immigration authorities)?
- Has the employer (or recruiter) taken possession of workers’ identity papers or travel documents?
- Does the employer restrict workers’ communication, such as by confiscating mobile phones, isolating workers from others, locking workers in the workplace or living quarters, or constant surveillance?
- Does the employer (or recruiter) perpetrate or threaten any physical or sexual violence against workers including violent punishment of one worker in front of other workers?
- Does the employer punish or threaten to punish workers through any other means, such as deprivation of food, water or sleep, or make threats against their family members?
- Does the employer (or recruiter) threaten to remove privileges such as promotion potential?
- Does the employer threaten further deterioration in working conditions?
- Does the employer (or recruiter) exploit religious or cultural beliefs to threaten workers?
- Does the employer (or recruiter) withhold workers’ assets, such as personal property, cash, etc.?
- Does the employer withhold workers’ pay?
- Does the employer threaten to fire/dismiss workers?
- Does the employer threaten extra work for workers who do not cooperate?
- Does the employer threaten financial penalties?
- Does the employer (or recruiter) threaten to withhold future employment opportunities, to impose financial penalties, to exclude workers from social or community activities, or use any form of blackmail to coerce workers?
The above tables are adapted from the ILO’s 2012 report, Survey Guidelines to Measure Forced Labor of Adults and Children. While the guidelines are intended for survey research, not for social auditing, they include a comprehensive set of indicators of forced labor, as well as guidance for analyzing and interpreting these indicators. The ILO’s Combating Forced Labour: A Handbook for Employers and Business, Booklet 4, also contains a useful checklist on forced labor.
Good audit tools are more than “checklists.” Good tools allow for recording information that auditors gain nonverbally, through observation of site conditions and workplace climate, interviewees’ body language and other cues. Auditors should research in advance any vulnerabilities that the worker population at the facility may experience, and should be attentive to subtle hints that workers may be subject to pressure or coercion. Audit tools should allow for recording information that may not be directly linked to the questions contained in the tool, but which the auditor still feels is important and relevant.
Many companies’ audit tools are proprietary, so it can be difficult to find samples to guide the development of your own. However, companies are increasingly pooling their expertise through initiatives such as the Global Social Compliance Program (GSCP). The GSCP’s Social Audit Process and Methodology Reference Tool contains a detailed table of “audit checks” that can be used to assess child labor and forced labor in production facilities.
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