Ethics and Behavior
This section focuses on the role that Ethics and Behavior play as critical components of corporate governance. Companies are expected to act with integrity and in an ethical manner, and good corporate governance helps to promote these values. An example of the topics covered in this section would be grievance mechanisms, as a way through which companies can promote ethical behavior. Transparency about practices and operations, and employee representation are also key aspects included in this section.
Helpful Resources
- OECD Corporate Governance
- EU Corporate Sustainability Due Diligence Directive
- UN Guiding Principles on Business and Human Rights (OHCHR, 2011)
- Forced Labour (US Customs and Border Protection)
Important disclaimer:
Please note that there are no applicabilities in the questionnaire, this means that even if a user answers “no” to a question, the follow up questions will still apply to the user and result in a point loss. In particular, if you answered “no/none” to the questions in this section asking if targets have been formally set and approved for a specific impact and/or topic area, the N/A answer option is not available for the related questions asking whether annual milestone targets have been met and whether those have been publicly reported, and you must answer “no”.
About this question
Transparency means being open and honest and disclosing information externally. It is considered a core practice in good corporate governance for companies to disclose all relevant information publicly so that others can make informed decisions about them. Value chain transparency in this question refers to systems by which a company identifies what is happening, and where, at the different levels of its value chain. This is also known as ‘mapping’. It is likely that a company will begin with mapping its Tier 1 supply base and extend into lower tiers and other areas of its value chain as its ESG approach becomes mature. Visibility of value chain partners is seen as an important enabler of progress in ESG.
This question asks whether your company has established targets, processes, tools and systems in place to map its value chain. This could include, targets to map 100% of specific tiers, process documentation, and supply chain mapping software systems.
- Select one or more tiers if you can provide evidence that you have processes in place to identify and record data about the businesses that form part of your company’s value chain
- Select third party logistics providers if you can provide evidence of processes in place to identify and record data about in-bound, outbound and distribution centre providers.
- Select none if your company has no processes in place to map any part of its value chain
Applicability: Brand, Brand and Retailer
Reference ID: geb.MQ.b
Evidence
Either:
- Link to published outputs of value chain mapping process i.e., factory/facility list indicating which tiers are mapped, published on company website or disclosed in a third party website such as Open Supply Hub
and
- Published or non-published documentation explaining the status of value chain mapping i.e., which tiers are completely mapped (e.g., ESG report, ethical trade report, update on corporate website)
or
- Internal outputs of value chain mapping process (i.e., factory/facility list indicating which tiers are mapped)
and
- Published or non-published documentation explaining the status of value chain mapping, i.e. which tiers are completely mapped (e.g., ESG report, ethical trade report, update on corporate website)
- Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, board meeting papers)
Topic areas
Transparency
About this question
Product traceability enables companies to identify, track and trace elements of a product as it moves along the supply chain from raw materials to finished products and beyond. Product traceability systems provide visibility of product provenance, enable the investigation and trouble-shooting of issues related to a component or support good practice in ESG. The value of traceability in regards to sustainability comes from the reliability of the information coming from a traceable system. When material sources and production techniques are verifiable, third-party certifications are able to confirm any claims being made. This question asks whether your company has implemented any product traceability systems to support the tracking of its products through the value chain.
- Answer yes if you can provide evidence of a product traceability system that covers your company’s value chain from raw material to finished product
- Answer partial yes if you can provide evidence of a product traceability system that covers part of its value chain
- Answer no if there is no product traceability system in place
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.Mg
Evidence
Provide:
- Documents giving details of the product traceability system used and its functionality
and
- Screenshots that demonstrate how data is collected and recorded, enabling the tracking of products from raw material through the value chain
Additional supplementary evidence:
- Training materials or guidelines for traceability system users explaining how products should be tracked
- Link to any third-party traceability system
Topic areas
Transparency
About this question
Data Privacy is centered around how data should be collected, stored, managed, and shared with any third-parties, as well as compliance with the applicable privacy laws (e.g., California Consumer Privacy Act – CCPA or the General Data Protection Regulation – GDPR).
This question asks whether your company has taken steps to embed understanding of the need to protect individuals and your company from breaches of data privacy. We are seeking evidence of a culture of promoting data privacy, exemplified by employee training that has taken place during the reporting period. It is expected that different levels of training will be provided for employees in different roles (e.g, IT departments, governance, customer support, facilities, human resources, and so on). Online interactive training or in-person training is required. The provision of written statements or guidelines is not sufficient.
- Answer yes if you can provide evidence that employees were trained on data privacy during the reporting period
- Answer no if no training took place or if there is no record of training taking place
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.Mw
Evidence
Provide:
- Training records or reports indicating who received training on data privacy during the reporting period
and
- Copies of training materials, induction materials. Can include screenshots from online training
- Evidence of leadership oversight (e.g., board report)
Additional supplementary evidence:
- Examples of internal communications raising awareness of data privacy requirements (e.g., posters, intranet posts)
- Data Privacy Guidelines published internally – not sufficient evidence of training alone but can be used as additional evidence
Topic areas
Data privacy
About this question
Companies should provide safe and effective mechanisms for all stakeholders, not just employees, to raise complaints, comments, suggestions, or grievances. In some jurisdictions it is also a legal requirement to apply these protocols (e.g., EU Whistleblower Protection Directive). To achieve this, companies should ensure public accessibility, confidentiality, impartiality, responsiveness, follow-up, continuous improvement, and feedback. Public, accessible mechanisms such as confidential hotlines, online reporting systems, third-party confidential reporting platforms, trade union led grievance mechanism, or NGO monitored worker hotline, can be used to provide a safe and effective way for any stakeholders to raise complaints or grievances.
This question asks if your company has implemented one or more mechanisms to provide more than one stakeholder group (e.g., employees) with a safe and accessible way to raise concerns.
- Answer yes if you can provide evidence of one or more public transparent, impartial, confidential and accessible grievance mechanisms that your company has in place
- Answer no if there is no grievance mechanism in place, or if your company’s grievance mechanism/s cannot be described as transparent, impartial, confidential and accessible. For example, an employee suggestion box or a manager’s ‘open door policy’ is not considered to be sufficient grievance mechanism
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.NA
Evidence
Either
- Copies of agreements with third-party organizations engaged to provide safe and effective grievance mechanisms for your company’s stakeholders (e.g., Trade Union, NGO, third-party providing a confidential whistleblowing service or other)
and
- Links to all the grievance mechanisms/whistleblowing systems provided to stakeholder groups by your company
and
- Screenshots or other evidence to demonstrate how stakeholders can access these systems (e.g., a ‘Speak Up’ page on company intranet, or details of a Trade Union supported reporting mechanism for workers)
and
- Documented evidence of processes and controls in place to ensure user safety and confidentiality
and
- Evidence of Board oversight (e.g., board committee minutes, report on issues raised from director/senior leader)
or
- Documents including policies and processes describing grievance mechanisms offered and who is responsible for operating them effectively (e.g., human resources employee, company secretary etc.)
and
- Links to all the grievance mechanisms/whistleblowing systems provided to stakeholder groups by your company
and
- Screenshots or other evidence to demonstrate how stakeholders can access these systems (e.g., a ‘Speak Up’ page on company intranet, or details of a Trade Union supported reporting mechanism for workers)
and
- Documented evidence of processes and controls in place to ensure user safety and confidentiality
- Evidence of Board oversight (e.g., board committee minutes, report on issues raised from director/senior leader)
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
Companies should provide safe and effective mechanisms for all stakeholders, not just employees, to raise complaints, comments, suggestions, or grievances. In some jurisdictions it is also a legal requirement to apply these protocols (e.g., EU Whistleblower Protection Directive). To achieve this, companies should ensure public accessibility, confidentiality, impartiality, responsiveness, follow-up, continuous improvement, and feedback. Public, accessible mechanisms such as confidential hotlines, online reporting systems, third-party confidential reporting platforms, trade union led grievance mechanisms, or NGO monitored worker hotline, can be used to provide a safe and effective way for any stakeholders to raise complaints or grievances.
This question provides an opportunity to demonstrate the breadth of your company’s feedback mechanisms – which stakeholders are able to provide feedback or raise concerns in a safe and accessible manner?
- Select one or more from the list of stakeholders, where you are able to provide evidence of a safe and accessible feedback/grievance mechanism (e.g., employees may have a third-party whistleblowing helpline, value chain workers have access to a trade-union grievance mechanism)
- Select none if your company has no feedback mechanisms of this kind in place
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.NQ
Evidence
Provide:
- Copy of an agreement with any third-party organization engaged to provide a safe and effective grievance mechanism
- Internal documents describing the mechanism, process, and persons responsible for oversight
- Links to publicly accessible mechanisms
- Screen shots of communications materials informing each group of stakeholders on how to raise a grievance/concern (e.g., website, intranet, posters)
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
To foster transparency and integrity, and detect misconduct, it is essential that stakeholders raising grievances (‘whistleblowers’) feel confident that they will be protected from any negative consequences. In the majority of OECD countries, there are legal protections in place for people raising concerns about their business in good faith.
This question asks about actions your company takes to protect whistleblowers and stakeholders, including policies and processes, regular communication to stakeholders about the protections in place, and oversight by senior leaders to ensure that confidentiality and protections are upheld.
- Answer yes if you can provide evidence that your company had procedures in place to protect stakeholders using grievance mechanisms from retaliation or negative consequences
- Answer no if you cannot provide evidence of systems and procedures in place to protect stakeholders using grievance mechanisms from retaliation or negative consequences
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.Ng
Evidence
Either
- Link to published strategy or program describing the process by which stakeholders raising grievances, and whistleblowers, are protected from negative consequences
or
- Internal policies, processes, strategy or implementation program documentation
and
- Evidence of oversight by board/senior leadership (e.g., Audit committee reports, Board papers)
Optional supplementary evidence:
- Examples/screenshots of communications with employees explaining how the internal process protects those using the grievance mechanism
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
This question asks companies to demonstrate more advanced practice, namely ensuring that provision of grievance procedures for indirect workers is in place with business partners/value chain partners (e.g., manufacturing suppliers, third-party logistics providers, etc…). We are looking for a systematic governance approach to ensuring that business partners provide this facility, rather than an example of one or two business partners that do so.
- Answer yes if you can provide evidence that your company routinely required commercial partners to provide appropriate grievance procedures for their employees
- Answer partial yes if you can provide evidence that your company made this requirement from specific types of suppliers only (e.g., third-party logistics companies, Tier 1 manufacturing suppliers)
- Answer no if there was no requirement for any supplier or business partner to provide its workforce with a suitable grievance mechanism
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.Nw
Evidence
Provide:
- Procurement guidelines specifying the requirement for suppliers/partners to provide grievance or complaints mechanisms
and
- Documents or reports that clarify the company’s position on which types of suppliers/business partners are required to have a grievance procedure in place (e.g., Tier 1 manufacturing suppliers, third-party logistics providers, customer care services providers, temporary worker agencies)
and
- An example of standard contractual terms between the company and business partners specifying the requirement to have a grievance procedure in place
Additional supplementary evidence:
- Guidance for suppliers explaining your company’s requirements related to grievance/complaints mechanisms
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
This question is an opportunity to indicate the extent to which business partners or suppliers are covered by your requirement to provide appropriate grievance mechanisms for employees/stakeholders.
- Select one or more categories of business partners or suppliers that were covered by your company’s trading requirements to provide a grievance mechanism, during the reporting period
- Select none if there was no requirement for any category of business partner or supplier to provide a suitable grievance mechanism during the reporting period
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.OA.b (For: Brand, Brand and Retailer)
Reference ID: geb.OA.r (For: Retailer)
Evidence
Provide for each category selected:
Either
- Third party assurance report / audit confirming data on which partners/value chain stages have grievance mechanisms in place
and
- Internal reports or dashboards demonstrating proportion of suppliers/business partners operating a grievance procedure as required
or
- Screenshot of extract from relevant commercial agreements, highlighting relevant contractual term
- Internal reports or dashboards demonstrating proportion of suppliers/business partners operating a grievance procedure as required
or
- Supplier Code of Conduct specifying requirement for grievance/complaint mechanism
- Internal reports or dashboards demonstrating proportion of suppliers/business partners operating a grievance procedure as required
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
It is important that grievance mechanisms are not just about reporting, but lead to remediation of issues and concerns raised. There is a very wide range of issues that may require remediation ranging from those that can be addressed through dialogue and engagement or mediation, to issues like fraud where investigation and potential criminal cases may be involved.
This question is intended to discover if your company’s grievance procedures are working effectively, and if there is evidence that leaders of the company respond appropriately to stakeholder feedback.
- Answer yes if you can provide evidence that your company has changed its practices or behavior as a result of an issue raised through a complaints/grievance mechanism
- Answer no if you cannot provide any evidence that your company has made a change to its practice as a result of a stakeholder complaint
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.OQ
Evidence
Evidence should include at least one example of an occasion when your company changed its practices as a result of an issue raised through a grievance mechanism as follows:
Provide:
- Documented evidence of the issue raised via a grievance mechanism (anonymised)
- Evidence that the issue was addressed according to your company’s remediation process (e.g., reports, meeting minutes)
- Evidence of senior leadership consideration and changed practice (e.g.,meeting minutes, reports, new processes or policies)
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
A robust complaints and grievance mechanism includes the assessment of the entire process in order to address any systemic issues that may be leading to complaints and grievances, and to ensure the process continues to remain fair, effective and works to continually reduce risk for the company.
Companies should look at how accessible the complaints process is for all stakeholders. They should also look at responsiveness (e.g. timeframes for resolution), impartiality (e.g. is the process free from bias), confidentiality (e.g. is privacy protected throughout), effectiveness (e.g. are complaints resolved well), and feedback (e.g. what learnings can be made to reduce risk).
- Answer yes if you can provide evidence that your company formally reviewed effectiveness of the grievance process
- Answer no if there is no evidence of a review of the effectiveness of grievance mechanisms, if reviews were carried out informally, or if the board does not have oversight of this issue
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.MTA
Evidence
Either
- Third-party reports/audits of grievance process including KPIs for responsiveness, impartiality, confidentiality, effectiveness of resolution and learnings (e.g., reports from internal auditors, an assurance organization, NGO, Trade Union)
or
- Corporate governance reports on grievance procedure effectiveness, including KPIs for responsiveness, impartiality, confidentiality, effectiveness of resolution and learnings (Board committee reports, internal audit, Annual Report and Accounts)
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
The right to freedom of association is a core element of the International Labour Organization (ILO) Base Code, and is typically included in Supplier Codes of Conduct for the protection of value chain workers. Collective bargaining is a key means through which employers and their organizations and trade unions can establish fair wages and working conditions. It also provides the basis for sound labor relations. Typical issues on the bargaining agenda include wages, working time, training, occupational health and safety and equal treatment. The objective of these negotiations is to arrive at a collective agreement that regulates terms and conditions of employment. This question aims to establish how far your company supports and enables freedom of association and collective bargaining for its own employees.
- Answer yes if you can provide evidence that your company supports and enables freedom of association and collective bargaining for its own employees
- Answer partial yes if your company supports and enables freedom of association and collective bargaining for some groups of employees only
- Answer no if there is no evidence that your company supports and enables freedom of association and collective bargaining or if your company does not support these principles
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.MTE
Evidence
Either
- Links to published human resources policies, or reports, indicating the Freedom of Association and Collective Bargaining programs/strategies which your company implements (e.g., strategy document, internal audit, annual review, responsible persons)
and
- Evidence of oversight by board/senior leadership (e.g., human resources director’s report to the board, board papers and minutes
and
- Any agreements made between your company and trade union/s to represent direct employees
and
- Any collective bargaining documentation from the reporting period (e.g., meeting minutes, reports, agreements)
or
- Internal human resources documentation, policies, or reports, indicating the Freedom of Association and Collective Bargaining programs/strategies which your company implements (e.g., approved strategy document, internal audit, annual review, responsible persons)
and
- Evidence of oversight by board/senior leadership (e.g human resources director’s report to the board, board papers and minutes)
and
- Any agreements made between your company and trade union/s to represent direct employees
and
- Any collective bargaining documentation from the reporting period (e.g., meeting minutes, reports, agreements)
Topic areas
Stakeholder engagement, grievance mechanisms
About this question
The right of workers to join a trade union of their choice is a key principle for the International Labour Organization (ILO). The right to freedom of association also includes the right to independence from government and employer interference. Collective bargaining is a key means through which employers, their organizations and trade unions can establish fair wages and working conditions. It also provides the basis for sound labor relations. Typical issues on the bargaining agenda include wages, working-time, training, occupational health and safety and equal treatment. The objective of these negotiations is to arrive at a collective agreement that regulates terms and conditions of employment. This question aims to establish how far your company supports and enables freedom of association and collective bargaining in areas of the value chain where it has appropriate influence, such as within third-party logistics partner operations.
- Select yes to any value chain stage where you can provide evidence that your company supports and enables freedom of association and collective bargaining
- Select none if you cannot provide any evidence of your company supporting freedom of association and collective bargaining in the value chain
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.MTI.b (For: Brand, Brand and Retailer)
Reference ID: geb.MTI.r (For: Retailer)
Evidence
Provide evidence for each value chain stage selected as follows:
- Any agreements made between your company’s value chain partner and trade unions
and
- Any collective bargaining documentation from the reporting period (e.g., meeting minutes, reports, agreements)
Topic areas
Stakeholder engagement
About this question
This question examines how well your company engages with potentially under-represented stakeholder groups to gain a wider range of perspectives for informed decision-making. These could be employee groups (for example, part-time employees, people with disabilities, under-represented genders, people of a particular national origin or ethnicity, LGBTQ groups, etc.).
What steps does your company use to ensure that the voices of all stakeholders are heard as part of good governance and effective decision making?
- Answer yes if you can provide evidence that your company had an effective process to engage with under-represented stakeholder groups during the reporting period
- Answer partial yes if there are some examples of stakeholder engagement with underrepresented groups but no formal process in place
- Answer no if there was no stakeholder engagement, or there is no evidence of effective engagement with underrepresented stakeholder groups
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.MTM
Evidence
Either
- Partnership agreements with e.g., Trade Union, NGO, expert advisor, consultancy or other third-party engaged to carry-out stakeholder consultation and engagement work (e.g., focus groups)
and
- Internal documents describing process and outcomes of consultation – verified by senior leader
or
- Link or screenshot demonstrating mechanisms used for stakeholder consultation/engagement (e.g., survey, grievance mechanism platform)
and
- Internal documents describing process and outcomes of consultation – verified by senior leader
Optional supplementary evidence:
- Screenshot of documents or other materials demonstrating examples of stakeholder feedback
Topic areas
Stakeholder engagement
About this question
Stakeholders are individuals, groups, organizations or other entities that can be affected by, or affect a company’s activities. It is important to recognize the importance of all stakeholders, including those who may have no voice, in decision-making processes in order to achieve sustainable and equitable outcomes. These include future generations, the climate, and the natural world.
This question examines how your company incorporates the ‘voice’ of these in its strategy and decision-making. Examples could include a formal partnership with an NGO or academic institution to provide ‘critical friendship’ – challenging the board/senior management on behalf of these non-vocal entities.
- Answer yes if you can provide evidence that your company had a means to represent the stakeholder perspectives of future generations, the climate, and the natural world in decision making
- Answer no if you cannot provide evidence that the stakeholder perspectives of future generations, the climate and the natural world were represented in decision making
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.MTQ
Evidence
Provide:
- Partnership agreements with an NGO, expert consultancy or other independent third-party engaged to represent stakeholders that have no ‘voice’ (such as the climate, the natural world)
and
- Internal documents describing the consultation process, its business context, and the outcomes of this consultation – verified by senior leader
Topic areas
Stakeholder engagement
About this question
Transparency is the practice of being open and honest and disclosing information externally. It is considered a core practice in good corporate governance for companies to disclose all relevant information publicly so that others can make informed decisions about them. Where a company has mapped its value chain, it is considered good practice to demonstrate transparency by putting this information in the public arena.
This question is an opportunity to demonstrate the transparency of your company’s value chain mapping, by demonstrating how far it has made its supplier lists public.
- Select one or more value chain tiers where you can provide evidence that your company has mapped and published its facility list
- Select none if no value chain information is published by your company
Applicability: Brand, Brand and Retailer
Reference ID: geb.MTU.b
Evidence
Provide:
- Link to most recent published factory/facility list on your company’s website or disclosed in a third party website (e.g., Open Supply Hub)
and
- Clarification of value chain tiers covered by the above list
and
- Information on how often the information is updated (e.g., every month)
Topic areas
Transparency
About this question
Making a list of value chain suppliers and their information available to customers is an important step for companies to build trust with customers, identify and manage risks in their supply chain, and comply with regulatory requirements. Where a company has mapped its value chain, it is considered good practice to demonstrate transparency by putting this information in the public arena. Providing a list of manufacturers and their information can help a company comply with regulatory requirements related to supply chain transparency, such as the California Transparency in Supply Chains Act or the UK Modern Slavery Act.
This question is an opportunity to demonstrate the transparency of your company’s value chain mapping, by demonstrating the depth of information your company aims to collect about its value chain in the public arena. Please note that we are not asking about the share of the supply chain for which your company has this information but rather the comprehensiveness of your transparency framework.
- Select one or more of the information types that your company has gathered and published
- Select none if none of this information has been published
Applicability: Brand, Brand and Retailer
Reference ID: geb.MTY.b
Evidence
Provide:
- Link to most recent published factory/facility list on your company’s website
and
- Date of publication
Note: The page linked to should include each of the categories of information selected in your response
Topic areas
Transparency
About this question
This question provides an opportunity to demonstrate that your company takes a collaborative approach to drive transparency in the textile, apparel and footwear industry – by working with other businesses, civil society and stakeholders. Examples could include participating in roundtables, cross-sector working groups or global collaborations to make progress for a more transparent sector, including work with sector relevant organizations such as the Cascale or working to improve regulatory requirements within the regions that you operate.
- Answer yes if you can provide evidence that your company has taken part in a joint or collaborative action
- Answer no if your company has not participated in joint or collaborative work of this nature or you cannot evidence your actions publicly
Applicability: Brand, Retailer, Brand and Retailer
Reference ID: geb.MTc
Evidence
Either
- Link to membership/signatory page, update or annual report published on the website of the relevant multi-stakeholder initiative/s related to transparency. Pages linked to should indicate the topics addressed and your company’s logo/name and signatory/membership level or contribution during the reporting period
or
- Membership/signatory agreement/s including company’s name and level of commitment to the MSI
and
- Document or link to information indicating how the topic of transparency is addressed by the multi-stakeholder initiative/s
Optional supplementary evidence:
- Screenshots/examples of your company’s data/reporting submission required by the MSI
- Examples of reports or materials produced collaboratively to address transparency
- Feedback from an NGO on your company’s contribution to the MSI
Topic areas
Stakeholder engagement