Social – General

1. BRM Guide

2. Company Profile

3. Environment

a. General
b. Climate
c. Water
d. Waste
e. Chemicals
f. Biodiversity

4. Social

a. General
b. Workers
c. Employees
d. Consumers
e. Communities

5. Governance

a. General
b. Structure and Management
c. Ethics and Behavior

6. BRM Glossary

General

The Social General section focuses on a company’s management of social risks and its commitment to generating a positive impact on people.

Questions in this section focus on the risks, policies, and strategies related to human rights and the welfare of all stakeholders. Questions ask how the organization manages social risks and opportunities, including its policies and procedures on human rights. 

 

Helpful Resources

About this question 

By carrying out a business-wide risk assessment, companies can identify and prioritize the most significant human rights risks they face and take appropriate measures to prevent and mitigate those risks. This can help companies to avoid legal liabilities, reputational damage, and operational disruptions, while fulfilling their ethical responsibilities and meeting stakeholder expectations.

The UN Guiding Principles on Human Rights outlines that its a business responsibility to respect human rights as it relates to their operations. A human rights risk assessment of a company should include a thorough analysis of the potential human rights risks associated with the company’s operations, products, services, and supply chains. The assessment should consider the company’s impact on the rights of all stakeholders, and should also evaluate the effectiveness of the company’s policies, procedures, and due diligence measures to prevent and address human rights risks. The assessment should include input from internal and external stakeholders, including human rights experts, civil society organizations, and affected communities. The output of the assessment should be a prioritized list of the most significant human rights risks, along with recommendations for mitigating and managing those risks. To determine the most signification risks and impacts, companies should assess the scale, scope and irremediable character of the risks and impacts, where scale refers to gravity of the adverse impact, the scope to reach of the impact and the irremediable character to limitations on the ability to fully restore the adverse impacts.

  • Answer yes if your company has assessed actual and potential impact and risks and has prioritized the most salient risks and impact to be acted upon
  • Answer no if your company has not conducted a Human Rights Risk Assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MQ

Additional information

For further information, it is worth reviewing:

  • UNGP operational principle 18
  • Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

  • Link to published outputs of risk assessment process (e.g., ESG strategy or report, corporate website, Annual Report and accounts)

or

  • Internal risk assessment documentation 

and

  • Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, board meeting papers)

About this question 

Engaging meaningfully with stakeholders is an important part of the due diligence process of a risk assessment. The aim of this question is to measure to what extent your company has engaged with its stakeholders during the assessment and prioritization of impact and risks. To assess their human rights impacts and risks accurately, companies should understand the concerns of potentially affected stakeholders by consulting them directly, or where that is not possible, consult with credible and independent experts. During the engagement process, you should be mindful of potential language and cultural differences.

  • Answer yes if your company has involved a wide variety of stakeholder groups in the delivery of its risk assessment including those across the value chain
  • Answer partial yes if your company has only involved more than one stakeholder group (e.g., Employees or Shareholders) in the delivery of its risk assessment
  • Answer no if your company has only involved one internal stakeholder group in its risk assessment, or if you have not conducted a Human Rights risk assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.Mg

Additional information

For further information, it is worth reviewing:

  • UNGP operational principle 18
  • Paragraph on meaningful stakeholder engagement available in the introduction chapter of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

  • Partnership agreements with e.g., Trade Union, NGO, expert consultancy or other third-party engaged to carry out stakeholder engagement work

or

  • Link or screenshot demonstrating mechanisms used for stakeholder consultation (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

About this question 

This question assesses which stakeholders were involved in the assessment and prioritization risk assessment process. Involving stakeholders in the risk management process can lead to a more comprehensive understanding of potential risks and the development of effective risk management strategies. The stakeholders that should be involved in risk analysis include employees, value chain workers, consumers, and communities. Each of these groups can provide unique perspectives on potential risks that may not be apparent from a management perspective. A company should consult them directly, or where that is not possible, consult with credible and independent experts.

  • Select one or more groups that your company has engaged with during its risk assessment process
  • Select none if your company has not engaged with any stakeholders in your risk assessment process or you have not carried out a human rights risk assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.Mw

Additional information

For further information, it is worth reviewing:

  • UNGP operational principle 18
  • Paragraph on meaningful stakeholder engagement available in the introduction chapter and Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

  • Link or screenshot of the list of stakeholder groups that were included. This could be included in, or an annex to the agreement with the third-party, or an annex to the process or outcome document

About this question 

Conducting a comprehensive human rights risk assessment is critical to developing effective risk management strategies and promoting a corporate culture that values and respects human rights.The human rights risk assessment should cover risks that your company may cause or contribute to through its own activities, or directly linked to your company’s operations, products or services by its business relationships. This question provides an opportunity to demonstrate the depth of human rights risk assessment carried out.

  • Select one or more value chain stages that your company has assessed to develop your human rights risk assessment
  • Select none if your company has not included any of the listed value chain stages in its risk assessment process or you have not carried out a human rights risk assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.NA.b (For: Brand, Brand and Retailer)

Reference ID: sg.NA.r (For: Retailer)

Evidence

Provide:

  • Link or screenshot of the description of the target groups included in the stakeholder engagement. The description should clarify, where relevant, which tiers each of the stakeholders are part of (could be an annex to the agreement with the third-party, or an annex to the process or outcome document)

About this question 

International human rights standards should be assessed when creating a robust human rights risk assessment. The key standards include the United Nations Guiding Principles on Business and Human Rights, the International Labour Organization’s Core Conventions, OECD Guidelines for Multinational Enterprises, and the Universal Declaration of Human Rights.

The United Nations Guiding Principles on Business and Human Rights provide a framework for businesses to respect human rights throughout their operations. The Principles outline the responsibilities of companies to respect human rights, conduct due diligence to identify and address human rights risks, and provide remediation for any human rights abuses that may occur.

The International Labour Organization’s Core Conventions provide a set of standards for companies to follow regarding labor rights, including the elimination of child labor, forced labor, and discrimination in the workplace.

The OECD Guidelines provide recommendations for responsible business conduct in areas such as human rights, labor rights, the environment, and anti-corruption.

Finally, the Universal Declaration of Human Rights sets out a broad range of civil, political, economic, social, and cultural rights that should be protected and respected by all. In all cases reference should be made to the internationally recognised human rights expressed in the International Bill of Human Rights.

  • Answer yes if your company has assessed actual and potential impact and risks against key standards and frameworks
  • Answer no if your company has not assessed actual and potential impact and risks against key standards and frameworks

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.NQ

Evidence

Either

  • Link to published risk assessment demonstrating alignment with international standards (e.g.,ESG strategy or report, corporate website, Annual Report and accounts)

or

  • Internal risk assessment documentation demonstrating alignment with international standards, and  
  • Evidence of oversight by board/senior leadership (e.g.,ESG Committee minutes, board meeting papers)

About this question 

This question tests the robustness of your company’s human rights risk assessment process by establishing whether the views of value chain workers, as key stakeholders, were sought and incorporated. It is important to include worker feedback as a standard component of a worker-related human rights risk assessment for several reasons. Workers are often the most knowledgeable about the conditions and risks associated with their work, and their feedback can provide valuable insights into potential human rights risks that may be present in the workplace. Including worker feedback in the assessment can also help companies identify potential human rights violations that may not be apparent through other means of assessment, such as audits or inspections. Workers can be engaged in a human rights risk assessment through surveys, interviews, focus groups, and other forms of consultation to gather their feedback and insights.

  • Answer yes if your company has involved value chain workers in the human rights risk assessment process by collecting worker feedback in activities complementary to an audit or inspection such as focus groups, interviews or off-site feedback mechanisms.
  • Answer no if your company has not developed a way to incorporate worker views within the risk assessment process or if your company has not conducted a human rights risk assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.Ng

Additional information

For further information, it is worth reviewing:

  • UNGP operational principle 18
  • Paragraph on meaningful stakeholder engagement available in the introduction chapter and Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

  • Link or screenshot of the list of stakeholder groups that were included (could be included in, or an annex to the agreement with the third-party, or an annex to the process or outcome document)

and

  • Evidence of the consistent use of worker feedback in the human rights assessment such as notes of interviews, reports/data from online feedback tools

About this question 

Risk assessments in companies should be reviewed periodically, at least once a year or whenever significant changes occur in the company’s operations, supply chain, or regulatory environment that may impact human rights risks. This question asks if you have a mechanism or process in place to ensure these updates are undertaken regularly. Examples of changing circumstances include amongst others: opening a new sourcing country, entering a new market, new national or international regulation, (geo) political developments, and/or impact of climate change or other geographical crises.

  • Answer yes if your company has a process in place that defines how and when human rights risks assessments should be updated
  • Answer no if your company has no process in place for updating human rights risks assessments

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.Nw

Evidence

Either

  • Link to published risk assessment policy indicating how often and when risks assessments are carried out (e.g.,Corporate Governance section of company website, Annual Report and accounts)

or

  • Internal risk assessment policy and process documents, indicating how often and when risk assessments will be carried out

and

  • Evidence of oversight by board/senior leadership (e.g.,Director/General Counsel signature, ESG Committee minutes, Board papers)

About this question

Environmental sustainability and the protection of human rights are closely linked and together form the core of sustainable development. The interconnectedness between the environment and human rights underpins our approach, recognizing that ecosystems and their services—such as food, water, disease management, climate regulation, and spiritual fulfillment—are preconditions for the full enjoyment of human rights, including rights to life, health, water, and food.

Under the UN Guiding Principles on Business and Human Rights (UNGPs), businesses have a responsibility to understand and address how their activities and business relationships across their value chains can lead to negative impacts on human rights in connection with their operations, products, and services.

This integrated guidance asks whether your company recognizes the mutually supportive nature of the promotion of human rights and environmental sustainability. It inquires whether your company formally assesses human rights risks in the context of its environmental policies and strategies, specifically in relation to climate, water, waste, biodiversity, and chemical management, through a due diligence process that includes:

  • Assessing actual and potential human rights impacts (harms and risks) related to your company’s environmental policies.
  • Integrating and acting upon the findings, whether that is ceasing, preventing, or mitigating harm.
  • Tracking progress and results.
  • Communicating how impacts are addressed.
  • Supporting remediation.

This guidance specifically focuses on the assessment and subsequent prioritization of actual and potential human rights impacts (both harms and risks) in your company’s own operations and value chain.

  • Select one or more of the environmental impact areas listed, for which you have evidence that your company has also carried out an integrated human rights impact assessment
  • Select none if you are unable to provide evidence that your company integrates human rights into environmental assessments, or if no assessments are carried out

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.OA

Evidence

Either

  • Link to published outputs of risk assessment process (e.g.,ESG strategy or report, corporate website, Annual Report and accounts)

or

  • Internal risk assessment documentation

and

  • Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, board meeting papers)

About this question 

Once your company has identified the most salient risks, it should determine more specifically the details of these risks and whether there are actual or potential impacts. This question aims to measure to what extent your company is undertaking a more thorough analysis of the most salient risks. In certain cases, additional assessments are necessary to determine the exact scope, nature and incidence of risks and adverse impact. In addition it will inform the relationships to your company’s operations with the risks and impact (has your company caused or contributed to the risks and adverse impact).

  • Answer yes if your company has carried out more detailed assessment on identified key human rights risks to determine, amongst others, nature and scope
  • Answer no if your company has not carried out more detailed assessments for the identified salient risks

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.OQ

Additional information

For further information, it is worth reviewing:

  • Section 2 in the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

  • Link to published outputs of risk assessment process (e.g.,ESG strategy or report, corporate website, Annual Report and accounts)

or

  • Internal risk assessment documentation 

and

  • Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, board meeting papers)

About this question 

A human rights policy is a company’s public expression of its commitment to meet its responsibility to respect internationally recognized human rights standards. Policies that state a corporate commitment are a critical component of corporate governance. This question is looking for a high level human rights policy or commitment approved by the board or senior management, that describes how the company will identify, prevent and address human rights risks it has identified. At a minimum, this means the rights set out in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work (OECD).

The policy is likely to include an overview of the steps taken to develop the policy, information on priority areas, commitment to make resources available, allocating a responsible team, defining the process by which salient human rights risks will be assessed or mitigated, and how they will be reported on.

  • Answer yes if you can provide a link to your company’s published human rights policy as described above
  • Answer no if there is no human rights policy, if your company’s policy does not include commitment to the core principles outlined above, or if the policy is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTA

Additional information

For further information, it is worth reviewing:

  • UNGP operational principle 16
  • Section 1 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

  • Link to published policy, statement or group of policies on company website 

Note: Policies can be standalone or combined, for example a company’s published Human Rights Policy could be a standalone statement, but could also be part of a broader document, such as a company’s social impact strategy. The relevant section of the document should be indicated to the verifier, e.g., page or section number.

About this question 

A human rights policy is a company’s public expression of its commitment to meet its responsibility to respect internationally recognized human rights standards. A company’s responsibility for human rights covers (amongst others), all the people working in its value chain, across all types of employment, whether direct, in direct, freelance, contracted and others.

This question tests the breadth of your company’s human rights policy’s reach in this respect. It asks whether your company’s policy makes explicit recognition of its responsibility for human rights for workers employed or contracted within its wider value chain by its suppliers and business partners. Examples include third-party logistics workers, franchise workers, contractors, freelance workers and any other workers in the value chain who are not directly employed by your company.

  • Answer yes if you can provide a link to your company’s published human rights policy which describes its consideration of value chain workers as described above
  • Answer no if there is no human rights policy, if your company’s policy does not include commitment to value chain workers as described above, or if the policy is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTE

Additional information

For further information, it is worth reviewing:

  • UNGP operational principle 16
  • Section 1 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

  • Link to published policy, statement or group of policies on company website 

Note: Policies can be standalone or combined, for example a company’s published Human Rights Policy could be a standalone statement, but could also be part of a broader document, such as a company’s social impact strategy. The relevant section of the document should be indicated to the verifier, e.g., page or section number.

About this question 

A human rights policy provides the basis for publicly affirming company values and embedding the responsibility into company operations and the way it does business. However, to be effective, more detailed policies, codes of conduct or practice must be in place to describe how the company’s commitments are embedded into operations and the way it does business. A Supplier Code of Conduct (or equivalent) is a document that sets out your company’s expectations for value chain business partners, particularly in relation to implementation of employment standards and labor conditions for value chain workers. It is considered good practice for a company’s Code of Conduct to be publicly available.

  • Answer yes if you can provide a link to your company’s Supplier Code of Conduct
  • Answer no if there is no Supplier Code of Conduct (or equivalent), or if this is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTI

Additional information

For further information, it is worth reviewing:

  • Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

  • Link to published Supplier Code of Conduct or equivalent monitoring framework on company website

About this question 

A Supplier Code of Conduct is a document that sets out your company’s expectations for value chain business partners, particularly in relation to implementation of employment standards and labor conditions for value chain workers. Understanding what risk areas are covered by a company’s supplier code is important because it helps to assess the company’s commitment to respecting human and labor rights in its value chain.

The question asks your company to select specific areas of risk covered by their supplier code of conduct or labor rights policy, which can help to reveal strengths or weaknesses in the approach to managing these risks. The list of topics provided represent critical elements of internationally recognised codes of practice. Publishing your company’s Supplier Code of Conduct is considered a necessary demonstration of good governance and transparency.

  • Select one or more related risks covered by your company’s Supplier Code of Conduct or labor rights policy
  • Select none if you cannot provide evidence of a Supplier Code of Conduct or labor rights policy, if it does not cover any of the topics listed, or if it is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTM

Additional information

For further information, it is worth reviewing:

  • Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

  •  Link to published Supplier Code of Conduct or equivalent monitoring framework on company website

About this question 

For: Brand

Responsible purchasing practices by brands are a key driver for better social outcomes in the supply chain. Your company’s practices with regard to how it purchases goods and pays its suppliers can directly impact their ability to uphold labor standards and provide decent work for their employees. For instance late payments can directly impact payment of wages to workers. Other unexpected costs such as penalties that were not agreed, or prepayment of costs that can only be reimbursed later, also impact a supplier’s ability to make the necessary investments to remediate or further improve social and labor conditions.   

This question is looking for evidence of a policy approved by the board/senior management that demonstrates a corporate commitment to responsible purchasing practices.

  • Answer yes if you can provide a link to your company’s responsible purchasing practices policy
  • Answer no if your company does not have a responsible purchasing practices policy or if this policy is not in the public domain 

For: Retailer

Adopting responsible purchasing practices is a critical factor in achieving positive social outcomes throughout the value chain. Retailers have an opportunity to support good practice throughout the value chain by implementing positive purchasing practices in their relationships with third-party brands.  

This question is looking for evidence of a policy approved by the board/senior management that demonstrates a corporate commitment to responsible purchasing practices.

  • Answer yes if you can provide a link to your company’s responsible purchasing practices policy
  • Answer no if your company does not have a responsible purchasing practices policy or if this policy is not in the public domain 

For: Brand and Retailer

Adopting responsible purchasing practices is a critical factor in achieving positive social outcomes throughout the value chain. Your company’s practices with regard to how it purchases goods and pays its suppliers can directly impact their ability to uphold labor standards and provide decent work for their employees. For instance late payments can directly impact payment of wages to workers. Other unexpected costs such as penalties that were not agreed, or prepayment of costs that can only be reimbursed later, also impact a supplier’s ability to make the necessary investments to remediate or further improve social and labor conditions. At the same time, companies have an opportunity to further support good practice throughout the value chain by implementing positive purchasing practices in their relationships with third-party brands.  

This question is looking for evidence of a policy approved by the board/senior management that demonstrates a corporate commitment to responsible purchasing practices.

  • Answer yes if you can provide a link to your company’s responsible purchasing practices policy
  • Answer no if your company does not have a responsible purchasing practices policy or if this policy is not in the public domain 

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTQ.b (For: Brand, Brand and Retailer)

Reference ID: sg.MTQ.r (For: Retailer)

Additional information

For further information, it is worth reviewing:

  • Prevent contribution to harm through responsible purchasing practices Section 3 OECD Due Diligence Guidance for responsible supply chains in the garment and footwear sector
  • Principle 1 (Integration and Reporting) of The Common Framework on Responsible Purchasing Practices (CFRPP)

Evidence

Either

  • Link to published Responsible Purchasing Practices policy, statement of commitment or group of policies on company website 

or

  • Internal (unpublished) Responsible Purchasing Practices policy, statement of commitment dated and signed on behalf of the board/senior leadership 

and

  • Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question 

Many supplier contracts do not include human rights-related obligations. When buyers (e.g. brands, retailers) do include such obligations in their agreements with suppliers, they tend to employ traditional contracting techniques that are not fit for purpose when it comes to upholding human rights.

While traditional contracting techniques may be logical and effective for managing company risk, they are not effective for managing complex human rights risks in dynamic supply chains. Responsible contracting on the contrary, includes that both buyer and supplier commit, in cooperation with one another, to:

  1. effective human rights due diligence,
  2. a commitment to shared responsibility for upholding human rights standards and 
  3. commitment to prioritize remediation of human rights impact first (rather than exiting the business relation). 
  • Answer yes if your company’s supplier contract includes includes all three commitments.
  • Answer partial yes if  your company’s supplier contract includes 2 of the 3 commitments.
  • Answer no in all other cases.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.shared.resp

About this question 

Employment standards are essential to regulate the relationship between the company and its employees, to ensure safe, fair and decent work and compliance with the law. The topics listed are critical elements of good employment (human resources) practice. 

  • Select one or more of the topic areas listed that are covered by your company’s employment standards or policies
  • Select none if you cannot provide evidence that any of the topic areas listed are covered by your company’s employment standards or policies

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTU

Evidence

Provide:

  • Policies/regulations dated and signed on behalf of the board/senior leadership such as employee handbook, HR policies, pro-forma contracts of employment

and 

  • Screenshots demonstrating how these policies are made available to employees (e.g., employee intranet, contractual packages)

About this question

Employment standards are essential to regulate the relationship between the company and its employees, to ensure safe, fair and decent work and compliance with the law employment standards. This question is an opportunity to demonstrate more advanced practice by indicating that additional human resources (HR) policies are in place to address specific employment related risks and opportunities.

  • Select one or more of the listed topics if your company has a specific human resources policy or commitment in that area
  • Select none if you cannot provide evidence of human resources policies covering any of these topics

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTY

Evidence

Either

  • Link to published employment policies, statement of commitment or group of policies on company website 

or

  • Internal (unpublished) employment policies dated and signed on behalf of the board / senior leadership

and

  • Screenshots demonstrating how unpublished policies are made available to employers (e.g., employee intranet, contractual package)

Note: Policies can be standalone or combined, for example the employment policies can be part of a broader HR policies and regulation document The relevant section of the document should be indicated to the verifier, e.g.,page or section number.

About this question

This question looks at social and human rights impacts other than those related to labor and employment, and asks how your company embeds human rights commitments across the breadth of its operations – specifically in its approach to community rights, community contributions and interactions with consumers.

It asks for evidence of corporate policies and commitments related to: (1) protecting the rights of communities impacted by its operation, and/or (2) making community contributions (including fiscal, pro-bono and product donations, and cause-related marketing), and/or (3) providing accessible and inclusive products and services to its consumers, and/or (4) ensuring its marketing materials and campaigns, and corporate communications are responsible, inclusive, accessible and respectful.

  • Select one or more of the listed areas if you can provide evidence that your company takes a policy-led approach to this topic
  • Select none if your company does not have corporate policies related to any of the topics listed

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTc

Evidence

Either

  • Link to published policy, statement or group of policies on company website that cover the areas listed in the question

or

  • Internal (unpublished) policy dated and signed on behalf of the board / senior leadership that cover the areas listed in the question 

and

  • Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question

Human rights due diligence is a way for companies to proactively manage potential and actual adverse human rights impacts with which they are involved. The United Nations identifies four components of human rights due diligence as follows: (a) Identifying and assessing actual or potential adverse human rights impacts that the company may cause or contribute to b) Integrating findings from impact assessments across relevant company processes and taking appropriate action (c) Tracking the effectiveness of measures and processes to address adverse human rights impacts in order to know if they are working; (d) Communicating on how impacts are being addressed and showing stakeholders – in particular affected stakeholders – that there are adequate policies and processes in place.

This question is looking for evidence of a due diligence policy that sets out clearly how your company carries out appropriate due diligence, as defined above, throughout its operations and value chain.

  • Answer yes if you can provide evidence that your company has a human rights due diligence policy or process that applies across its own operations and value chain
  • Answer partial yes if your company’s human rights due diligence policy applies to either its own operations, or a limited part of the value chain
  • Answer no if your company does not have a human rights due diligence policy for any part of its operations or value chain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTg.b (For: Brand, Brand and Retailer)

Reference ID: sg.MTg.r (For: Retailer)

Additional information

For further information, it is worth reviewing:

  • Section 1 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

  • Link to published due diligence policy on company website 

or

  • Internal (unpublished) due diligence policy dated and signed on behalf of the board/senior leadership 

and

  • Screenshots demonstrating how unpublished due diligence policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question

A company’s responsibility for human rights covers all the people working in its value chain (amongst others) across all types of employment, whether direct, in direct, freelance, contracted and others.

This question tests the depth of your company’s human rights policy’s reach in this respect. It asks how far your company’s human rights related policies extend across its value chain from raw materials sourcing through to product manufacture, then its own operations and beyond to include third-party logistics providers, goods not for resale, wholesale and other retail partners.

  • Select one or more value chain levels covered by your company’s human rights policies
  • Select none if you cannot provide evidence of your company’s human rights policies covering any of the value chain stages listed

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MTk.b (For: Brand, Brand and Retailer)

Reference ID: sg.MTk.r (For: Retailer)

Additional information

For further information, it is worth reviewing:

  • Mechanisms to assess and address risks of harm beyond tier in Section 2 of the OECD Due Diligence Guidance for responsible supply chains in the garment and footwear sector

Evidence

Either

  • Link to published due diligence policy and if applicable implementation guidelines/regulations on company website

or

  • Internal (unpublished) due diligence policy and if applicable  implementation guidelines/regulations and signed on behalf of the board / senior leadership

and

  • Screenshots demonstrating how unpublished due diligence policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question

Subcontracting is often used in the apparel industry for different reasons, including for specialized processes or to temporarily increase production capacity. Subcontracting can increase flexibility and efficiency, but it is also associated with higher human and labor rights risks. To ensure that companies understand where and under which circumstances their products are made, a company should agree with its suppliers if and under which conditions suppliers can use which subcontractors. This question aims to measure to what extent your company has a written policy, shared with suppliers, that defines when and how subcontractors can be used.

  • Answer yes if your company has a policy that defines if and under which conditions subcontracting is allowed and if that policy is shared with all suppliers. If your company prohibits subcontracting, the policy should identify what additional measures your company takes to mitigate risk of illegal subcontracting
  • Answer no if your company has no subcontracting policy or if it has not been shared with all its suppliers

Applicability: Brand, Brand and Retailer

Reference ID: sg.Mtx 

Additional information

For further information, it is worth reviewing:

  • Mechanisms to assess and address risks of harm beyond tier 2 in Section 2 of the OECD Due Diligence Guidance for responsible supply chains in the garment and footwear sector
  • Information on subcontractors in Section 1 of the OECD due diligence guidance for responsible supply chains in the garment and footwear sector

Evidence

Provide:

  • Internal policy (or equivalent document) that defines if and under which conditions subcontracting is allowed  

and

  • Evidence that this has been shared with all suppliers e.g. in contracts, specific communication, code of conduct

and 

  • Evidence of oversight by board/senior leadership (e.g.,ESG Committee minutes, board/senior management resolutions, CSR/Sustainability Director report, Sourcing director report)

About this question 

Environmental sustainability and the protection of human rights are closely linked and together form the core of sustainable development. UNEP sets out a number of ways in which environmental and social objectives are connected including the following:

Ecosystems and the services they provide, such as food, water, disease management, climate regulation, and spiritual fulfillment, are preconditions for the full enjoyment of human rights, including rights to life, health, water, and food. At the same time, efforts to promote environmental sustainability can only be effective if they occur in the context of conductive legal frameworks, and are greatly informed by the exercise of certain human rights, such as the rights to information, public participation in decision making and access to justice.

This question asks whether your company’s environmental policies recognise the mutually supportive nature of the promotion of human rights and environmental sustainability.

  • Select one or more environmental policy areas where you can provide evidence that your company has also taken social impacts into consideration 
  • Select none if none of your company’s environmental policies include consideration of associated social impacts, or if your company does not have environmental policies in these areas

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg.MjA

Evidence

Either

  • Link to published environmental and human rights policies 

and

  • Clear indication of where consideration has been given within the policies to recognize the mutually supportive nature of the promotion of human rights and environmental sustainability

or

  • Internal (unpublished) environmental and human rights policies 

and

  • Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, Board papers) 

and

  • Clear indication of where consideration has been given to recognize the mutually supportive nature of the promotion of human rights and environmental sustainability