- 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
Independent third-party verification consists of an assessment of your company's complete social compliance system, to determine whether it is being implemented properly and thoroughly. This verification should be done at least annually.
Verifiers should be accredited Certification Bodies (CBs), complying with either ISO/IEC 17021 or ISO/IEC Guide 65, or other relevant systems. ISO/IEC 17021 contains principles and requirements for the competence, consistency and impartiality of an audit and the certification of management systems of all types and for bodies providing these activities. ISO/IEC Guide 65 contains the general requirements that a third party operating a product or service certification system shall meet in order to be recognized as competent and reliable.
Independent verification should include consultation with appropriate stakeholders, including unions where they exist. Verifiers should conduct witness audits, which consist of a verifier first accompanying and observing audits carried out the company’s existing auditors (internal, external or independent) and then testing audit data to confirm that company data systems are reliable. Announced witness audits are important when it is necessary to have access to specific personnel or documentation; unannounced witness audits may also be useful in verifying that company policies are being implemented appropriately. Verification should also include an examination of the company’s remediation policies and procedures, as well as specific cases of remediation, to examine whether they have been effective.
Verifiers should provide the company with a report identifying weaknesses found in the company’s system and system implementation. Verifiers may also suggest remediation measures the company may take to address the weaknesses.
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