Ethical and sustainable work practice due diligence

Guidance about how to prevent, identify and mitigate modern slavery and worker exploitation in your organisation, supply chain and the businesses you work with.

It is essential to have social practice due diligence systems and processes in place to identify, prevent and mitigate worker exploitation in your organisation and the organisations you engage with, for example, through your supply chain and business networks. These processes will help ensure you treat workers fairly, meet your stakeholders’ expectations and reduce risks to the viability of your business. 

Effective social practice due diligence can look different for different organisations. It will depend on things like the organisation’s size, the nature of their operations, and what is reasonable and proportionate to address or manage the modern slavery and worker exploitation risks they face. 

Below is list of due diligence actions that you could undertake as part of your end-to-end modern slavery and worker exploitation assurance approach. You should cross-check and compare the information you gather in each action so that you can verify your findings from more than one source.

1. Positioning Statements

  • Consider what your organisation’s vision, mission and values statements say about how your organisation values and treats workers. These statements set the scene for everything that happens in your organisation, so it’s important that they are clear. 

2. Workforce planning

  • Forecast what resources will be needed, for example, worker numbers, timeline and budget.

3. Pre-procurement planning

  • Decide on specific tender conditions to include in a request for tender or expression of interest (RFx) before engaging with suppliers and going to market. These should include labour rights, environmental standards and any further conditions or standards the procurer expects from their suppliers.
  • Think about how the procurer can influence positive assurance measures throughout their supply chain.

For more information, see:

Assuring ethical and sustainable work practices through procurement [PDF, 281 KB]

4. Supply chain mapping

  • Identify and record businesses, employers and suppliers across your entire supply chain — for example, tier 1 contractors and subsequent sub-contractors.

For more information, see: 

Step 1 of Assuring ethical and sustainable work practices through procurement [PDF, 281 KB]

5. Risk assessment

  • Identify labour rights risks within your business and throughout your supply chain, and what actions can be taken to mitigate these. 

For more information, see: 

Step 2 of Assuring ethical and sustainable work practices through procurement [PDF, 281 KB]

Risk factors to manage [PDF, 225 KB]

Mitigations to reduce risks [PDF, 210 KB]

6. Code of conduct — employer, procurer and supplier

  • Set out and document expected behaviours around business ethics, employment practices and treatment of workers — specific to human and labour rights, including employment standards and good worker conditions — and what actions will be taken if your code of conduct is not complied with.
  • Include a requirement for the employer to report any instances where they are being investigated by the Labour Inspectorate, or where they have been found by the Labour Inspectorate, Employment Relations Authority, or the Employment Court to have breached any of the listed legislation.

For more information, see:

Creating and communicating a code of conduct for your own business

7. Audit — self-audit and supply chain audit

  • Conduct agreed checks within the immediate business and across the wider supply chain and business network to confirm compliance with employment legislation and other expectations and identify any issues of non-compliance.
  • Conduct audits throughout the life of the engagement. Third party/independent audits are recommended over internal audits.
  • If a full audit is not possible, another option is an annual report where the supplier produces a report on what assurance systems they have in place, identifies any issues, and says what actions were taken to resolve these.

For more information, see the Employment Standards Employer self-assessment checklist and guide:

Employer self-assessment checklist [PDF, 654 KB]

Employer self-assessment guide [PDF, 934 KB]

8. Employee/worker voice platform

  • Conduct a survey or interview workers to gather feedback and identify potential employment issues, including employment standards breaches and areas of concern in the business and supply chain.
  • This can be included or used alongside an annual audit to verify findings of the audit or risk assessment, and to identify areas for further scrutiny.

9. Worker reporting channels

  • Provide a hotline or a whistleblowing channel, separate from an employee voice tool, which is available any time to report employment issues, including employment standard breaches, directly to a qualified or appropriate person to address the concerns.
  • This can be operated in-house or through an external agency.
  • Workers can be provided access to this through apps, websites or email services.

10. Complete data analysis, reporting and monitoring

  • Collect and analyse data from the above processes and any other relevant channels to provide a continuous and real-time picture of compliance in the business and supply chain.
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