Components:
Tracking progress is how a company can know if its human rights due diligence systems are working to improve conditions for people affected by its operations and supply chains.
Overview
Every company should establish or participate in grievance mechanisms to provide channels for individuals and communities at risk or affected by human rights harms to raise concerns and have them addressed.
Grievance mechanisms provide a way for companies and their suppliers to learn of human rights issues in the regions where they operate and source. These mechanisms are crucial for stakeholders whose human rights have been violated to access remedy. For workers and community members to use a grievance mechanism, they must see it as trustworthy and fair, be able to access it easily, and have confidence that their complaints will be taken seriously and result in helpful outcomes. Grievance mechanisms should be available to all stakeholders, including migrant workers and seasonal and temporary workers. Grievance mechanisms should never replace other forms of supply chain monitoring, stakeholder engagement, and collective bargaining processes.
Maturity benchmarking
Basic
The company has a grievance mechanism in place for complaints related to its own operations and has personnel in place to receive and handle grievances. It also requires its suppliers to have grievance mechanisms.
How to get there:
- Engage stakeholders to determine which channel(s) they are most likely to use
- Determine who will manage and administer the grievance mechanism
- Establish channel(s) for receiving and systems for handling grievances
- Train responsible team(s)
- Promote mechanism among potential users
- Cascade requirement to suppliers to have their own grievance mechanisms
Established
In addition to “Basic,” the company makes its own grievance mechanism accessible to more stakeholders in its supply chains, including in the first mile. It conducts deeper oversight of suppliers’ grievance mechanisms and explores possibilities for collaboration with peers and multi-stakeholder partners on grievance mechanisms.
How to get there:
- Receive and process grievances from grievance mechanism
- Extend coverage of grievance mechanism to enable access to all affected stakeholders, including in the first mile, for high-risk commodity-geography contexts
- Provide guidance to suppliers on what types of grievance to report to the company and how to do so
- Evaluate the effectiveness of own grievance mechanisms and those of suppliers, engaging stakeholders to determine whether the systems are resulting in meaningful remedy
- Provide support to suppliers as needed
- Map any existing multi-sector or multi-company grievance mechanism initiatives
Leadership
In addition to “Established,” grievance mechanisms are in place in all high-risk commodities and geographies and are continually being improved. The company engages with industry peers, government, and/or civil society to promote access to grievance mechanisms and remedy for affected stakeholders. It actively engages relevant stakeholders to validate its approach and impact.
How to get there:
- Analyze and use grievance mechanism data to drive improvements (4.4 Continual Improvement of Human Rights Due Diligence) and report on impact (6.3 Public Reporting on Impact)
- Join existing collaborations on regional and/or sectoral grievance mechanisms, or work with partners to establish new collaborations
- Conduct outreach to workers and other relevant stakeholder groups to improve accessibility and effectiveness of grievance mechanisms
Further reading
A Study on the Implementation of Grievance Mechanisms: Reviewing Practice Across RA-Certified Farms and Groups
Access to Remedy: Practical Guidance for Companies
Remediation, Grievance Mechanisms and the Corporate Responsibility to Respect Human Rights
Grievance Mechanisms, Remedies and Trades Unions: a Discussion Document
Legal Guide for Setting up an Operational-level Grievance Mechanism
Palm Sustainability Dashboard: Managing Grievances
Unilever Palm Oil Grievance Tracker
Nossa Voz Grievance Mechanism in Brazil
Promoting Ethical Recruitment in the Coffee Sector of Minas Gerais, Brazil
Using Third Parties to Support the Design and Implementation of Grievance Mechanisms
Worker Engagement: Enabling Workplace Communication, Worker Agency, and Grievance Management
Overview
Monitoring to ensure that supplier human rights due diligence systems are working as intended is an essential aspect of a company’s own HRDD.
Supplier monitoring may take many forms and ideally combines a variety of sources of information and methods to generate insight. Monitoring activities should be determined by their objectives: i.e., what insights are needed, and how are they going to be used. Monitoring of suppliers should take into account the perspectives of managers, as well as external stakeholders such as civil society organizations. However, the views and experiences of workers in the supplier’s operations and supply chain are particularly important, especially those workers most vulnerable to human rights harms, such as women, migrants, ethnic minorities, and young workers.
Maturity benchmarking
Basic
The company has set expectations for suppliers and is collecting data on their performance. It uses this data, and other sources of information as needed, to identify suppliers that require further monitoring.
How to get there:
- Review audits (4.3 Farm Monitoring and Auditing) and supplier precontracting due diligence screening (1.3 Procurement Practices) to identify suppliers in at-risk sectors or geographies and those with limited capacity to manage risks adequately
- Consider use of supplier data aggregation provider
- Review findings from saliency assessment (2.2 Saliency Assessment) and in-depth assessment (2.3 In-Depth Assessment of Risks and Harms) on riskiest geographies and commodities
- Identify suppliers to target for heightened monitoring
Established
In addition to “Basic,” the company is actively carrying out additional monitoring activities on suppliers with limited risk-management capabilities and those linked to prioritized commodities or geographies.
How to get there:
- Develop tailored assurance approaches for different supplier risk profiles
- Select provider(s) if monitoring will be outsourced; assign and train responsible staff if done internally
- Implement supplier monitoring program, and engage suppliers to develop performance improvement plans (PIPs) to address gaps or weaknesses
- Communicate expectations to suppliers about the collection and reporting of HRDD data (both systems maturity and performance on salient issues)
- Incorporate supplier performance tracking into HRDD data systems
- Allocate ongoing budget for supplier monitoring efforts
Leadership
In addition to “Established,” active monitoring of suppliers is integrated into the company’s “business as usual.” Supplier performance data is regularly reviewed and used to inform supplier engagement and reinforce procurement decision-making.
How to get there:
- Review supplier HRDD performance at least annually
- Intensify engagement with (or consequences for) persistently problematic suppliers
- Reward good performers with larger volumes, longer term contracts, premiums, etc.
- Establish third-party verification of supplier HRDD data
- Use worker surveys or worker voice applications to gather input on supplier practices and systems for identifying and addressing human rights issues
Further reading
Sample Food and Beverage Supplier/Subcontractor Self-Assessment
Self-Assessment Questionnaire for Coffee Traders by Verité’s COFFEE Project
Self-Assessment Questionnaire for Coffee Producers by Verité’s COFFEE Project
Self-Assessment Questionnaire for Labor Brokers by Verité’s COFFEE Project
The Ethical Charter Implementation Project
Booklet on Monitoring Labor Brokers in the Coffee Supply Chain by Verité’s COFFEE project
Guidance on Monitoring Labor Brokers by Verité’s COFFEE project
Overview
Given the pervasiveness of serious labor rights issues in the production of agricultural commodities, a company’s supply chain monitoring and auditing must reach the farm level.
Where possible, companies should have their own internal monitoring staff conduct farm monitoring or support their suppliers to develop farm monitoring programs. If opting for third-party audits or certification, companies should ensure audit partners employ well-trained worker interviewers, robust sampling, and sufficient frequency.
All audits and other monitoring visits should include farm observation, document review, and interviews with management, supervisors, workers, and other stakeholders. The accuracy of findings from farm monitoring should be confirmed by comparing information from different sources. Companies may also wish to collaborate with a local civil society organization or other partner to check on the accuracy of insights from monitoring carried out by first mile suppliers.
Maturity benchmarking
Basic
The company makes key decisions about how farm-level monitoring will be done and secures necessary resources for monitoring. At the “Basic” level, a significant proportion of farm monitoring is often done through third party audits and/or certifications, prioritizing the company’s highest-risk commodities and geographies.
How to get there:
- Secure resources for monitoring/auditing program
- Decide whether to develop and deploy internal monitors, use external audits or certifications, or combine these approaches
- If using external audits, select auditing/certification provider(s)
- If using internal monitors, build monitoring program or collaborate with suppliers to build it; design data collection tools, hire and train monitors
- Ensure that any findings from audits or monitoring visits are followed up through a corrective action plan (5.2 Remediation of Harms)
- Ensure that monitoring/auditing covers all salient and prioritized human rights issues, geographies, and commodities
Established
In addition to “Basic,” farm monitoring/auditing is established and well-functioning, and the company increases the proportion of farm monitoring that is done internally. If the company continues to use third-party audits or certifications, it engages with providers to drive rigor in their approaches.
How to get there:
- Over time, increase the proportion of monitoring done internally by company or supplier staff
- Where internal monitoring is used, standardize data points gathered at the farm level, and align with other relevant frameworks (national/international)
- Continue to build the capacity of the company’s or suppliers’ internal monitors
- Where third-party audits are used, engage with audit/certification providers to understand their auditing approaches and push for improvements where needed
- Whenever human rights harms are found through monitoring visits or audits, ensure that corrective action plans are fully implemented and that affected persons receive remedy (5.2 Remediation of Harms)
Leadership
In addition to “Established,” the company has internal monitoring fully in place in its most at-risk commodities and geographies, shifting away from third-party audits and certifications. It engages an independent third party to verify the monitoring data.
How to get there:
- Secure permanent budget for comprehensive and effective internal monitoring
- Where internal monitoring is used, increase sample sizes, eventually reaching 100 percent coverage of all farms, and increase frequency of monitoring
- Expand internal monitoring to more at-risk supply chains and geographies
- Engage a third party to verify internal monitoring data; compare third-party data with internal data and adjust incentives and training for monitors as needed
Further reading
Taking Action to Eliminate Child Labor from our Leaf Supply Chain: Progress Update 2019
Sustainable Supply Chain Initiative (SSCI) Benchmark
Certification Red Flags
Comply Chain’s Auditing for Child Labor Guide
Celebrating 10 Years of the Agricultural Labor Practices Program
Conducting Migrant Worker Interviews
For the Better: Ferrero Group Sustainability Report 2019
Worker Interview Questions by Verité’s COFFEE project
Overview
An effective overall HRDD management system drives improvements in each of its elements and components, becoming increasingly comprehensive, effective, and efficient over time.
Improvements should happen in real time as weaknesses are spotted, but often also result from an annual review of the whole system, asking: Is our approach working the way we intended? Are we on track to meet our human rights objectives? Continual improvement requires understanding what isn’t working and why.
Maturity benchmarking
Basic
The company is taking steps to examine the HRDD programs and systems it has in place, what is working well, and what is missing or not yet sufficiently developed.
How to get there:
- Identify existing human rights-related programs and systems across the company’s functions and business units
- Review human rights data already being collected, including on supplier performance
- Interview relevant internal stakeholders to identify challenges, gaps, and needs
- Benchmark the level of implementation maturity for each component of the company’s HRDD system, and develop timelines for improvement of each as needed.
Established
In addition to “Basic,” the company is working actively to close gaps in its HRDD management systems, address recurring issues, build the capacity of internal and external actors, and broaden the reach of its HRDD coverage.
How to get there:
- Develop specific action plans to address internal HRDD system gaps or capacity needs, including indicators and time-bound milestones to ensure progress
- Establish prioritized list of persistent issues to tackle, conduct root cause analysis of them, and develop targeted action plans for each
- Provide tools, guidance, etc. for internal and external actors needing support
- Engage with and develop performance improvement plans for suppliers or other relevant actors needing support (such as auditors, certification organizations, recruiters, and farmers)
Leadership
The company is at an “Established” or “Leadership” level of maturity across all components of its HRDD system (benchmarked using this or a similar HRDD framework). It regularly reviews its progress and impact, seeking to drive the bar higher year on year.
How to get there:
- Carry out regular human rights audits and senior review of HRDD system performance
- Track and report on improvement over time of both system maturity and impact on salient issues (3.2 Indicators and Targets)
- Secure funding for any necessary investments in major system improvements
- Work to improve the quality of HRDD data by deploying targeted training or other support to relevant stakeholders
- Engage an independent third party to verify progress