OPPORTUNITIES FOR IMPROVEMENT
Commitment & Governance
While the company discloses that it has supplier policies in place and communicates with its suppliers on sustainability topics, it is encouraged to develop and disclose a supplier code of conduct that includes all four rights outlined in the ILO Declaration on Fundamental Rights and Freedoms at Work, including the prohibition of forced labor and human trafficking. It is further encouraged to establish responsibilities and accountability for the implementation of such a standard and train internal staff and suppliers on this standard.
Traceability & Risk Assessment
To demonstrate a strong understanding of its supply chains, the company may consider disclosing the names and addresses of its first-tier suppliers, the countries of its below-first-tier suppliers, the sourcing countries of raw materials at high risk of forced labor, and information on its suppliers' workforce. The company is further encouraged to assess forced labor risks across its supply chains and disclose the risks identified.
The company may consider adopting and disclosing a supplier monitoring process to verify that its suppliers are compliant with its supply chain standards. Adopting specific practices, such as interviewing workers and conducting unannounced audits of suppliers may help the company detect forced labor risks in its supply chains. Disclosing information on the results of its supplier audits, such as the percentage of suppliers audited annually or a summary of findings, provides assurance to stakeholders that the company has strong monitoring processes in place.