On p.3 of its statement, Google says: "As part of the due diligence process, higher-risk suppliers complete a self-assessment questionnaire about their working conditions and management systems. The due diligence process also includes supplier background checks, examination of labor-related red flags that appear in publicly available databases and media sources, and a review of higher-risk suppliers’ names against human trafficking watch lists. If we discover red flags, we conduct extensive and documented follow-ups to address these issues."
It is clear that the higher-risk suppliers must do self-reported audits, so the requirement of self-reporting audit of suppliers is fulfilled. However, there is no explicit mention of any on-site visits occurring, so those requirements of this metric are unfulfilled.
Additionally on p.3, "In 2020, we hired an independent party to oversee an enterprise-wide modern slavery risk assessment, which aims to review Google against modern slavery indicators to help us understand potential gaps and opportunities for improvement, or identify new potential modern slavery risks that have emerged in our business operations and supply chains"
Google also hired an independent audit of the entire enterprise, which includes its supply chains, so this fulfills the independent audits of suppliers requirement. It should be noted that this independent assessment has not yet reported its findings. Google has indicated within the statement that findings will be reported in 2021. The reason this audit has not been categorized as "in development" is because this metric calls for continuous monitoring of suppliers. The third party is continuously auditing the company over time, it was being audited in 2020, so the date of release of the findings does not impact the fact that a third party is performing a continuous audit of suppliers.
Upon further review, I missed the paragraph that further details independent third party audits on p.4: "We perform periodic independent third-party audits at higher-risk suppliers’ facilities. The audits include in-depth facility review, meetings with management, on-site worker interviews, document reviews, and assessments of related areas, such as dormitories, cafeterias, wastewater treatment facilities, and warehouses. The audit protocol is designed to assess suppliers’ performance in the areas covered by our Supplier Code of Conduct, including modern slavery risk"
Therefore, we can conclude that Google does have independent auditors performing on-site visits to high-risk facilities. However, there is no mention of self-reporting on-site visits.
We perform periodic independent third-party audits at higher-risk suppliers’
facilities. The audits include in-depth facility review, meetings with
management, on-site worker interviews, document reviews, and
assessments of related areas, such as dormitories, cafeterias, wastewater
treatment facilities, and warehouses. The audit protocol is designed to
assess suppliers’ performance in the areas covered by our Supplier Code of
Conduct, including modern slavery risk. p. 4
In 2020, our audit team developed and launched a remote audit protocol we
call “Targeted Desktop Audits” to continue their work during COVID-19
pandemic travel limitations. These remote audits, in addition to our Supplier
Code of Conduct on-site audits mentioned above, enabled us to continue
robust supply chain site assessments. The development of the remote
audit protocol included the creation of an in-depth methodology, assessor
guide, and document review protocol. We also trained our independent
auditors and worked closely with certain of our suppliers on the new
process. p. 4
We also perform periodic third-party audits during office fit-out construction
projects in some regions. With these audits, we strive to ensure that
construction workers have a safe working and living environment (in those
cases where housing is provided for workers) and are paid their wages in a
timely fashion commensurate to the work performed. This is achieved by
announced and unannounced visits to relevant facilities, interviews with
workers, and inspection of personnel files. Appointed general contractors
are contractually bound to allow similar audits of their subcontractors, as
appropriate. p. 4