Human rights due diligence is a key concept in the UN Guiding Principles on Business and Human Rights. Due diligence processes should include ‘assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed.’ (See the UN Guiding Principles). Part of due diligence processes is not just assessing initial risk through questionnaires or having in place policies, but monitoring this risk through continuous engagement with suppliers.
For further information on this metric please refer to the Home Office Guidance, pp. 32-33, and the Walk Free Foundation Guidance, pp. 37-39.
Does the company manage the risk of modern slavery by continuously engaging with suppliers?
Select as many examples of continuous engagement as apply*
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conducting audits of suppliers (including high risk suppliers) - self reporting & independent
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conducting on-site visits of suppliers - self reporting & independent
In some instances, these mechanisms are conducted by the suppliers or company themselves, or are conducted independently. If these are conducted by the company itself or the supplier, please select the value with (self-reporting). If conducted by a third party, or an external, independent agency, please select (independent) value.
If no such continuous engagement is described, then please select “No”.
If the business indicates it is developing continuous engagement mechanisms, or planning to implement these in the future, please indicate “In Development”.
For each value, please include a comment that copies relevant information from the statement. If the example of continuous engagement that you wish to include is not listed among the answer options, please add a comment and flag the section for review.
BHP Billiton p. 13
"Suppliers were selected for a third-party independent audit from the following high-risk taxonomies: wear consumables and conveyor belting and parts (e.g.industrial machinery), bulk materials (e.g. explosives)and tyres, wheels and rims. In FY2022, a third-party independent audit was completed for 11 suppliers with 18sites (e.g. manufacturing plants) across nine countries."
Siemens Ltd p. 14
“Future: In addition to the on-boarding qualification and monitoring process of all high-risk suppliers, in FY22 commence desktop audits of at least 25% of medium to high risk suppliers (selected using a risk based approach) to provide an additional layer of assurance.”
ADT Group Holdings Pty Ltd, Pg. 9
“Suppliers are required to complete a pre-audit questionnaire and undergo either an annual internal audit conducted by our in-country compliance teams or provide a reputable third-party audit conducted in the past 12 months.
“During the reporting period, we conducted 59 audits (internal and third party), on both an announced and unannounced basis.”
The mention of announce and unannounced infers that these are onsite audits.
* Note on choosing the Year of your answer
Read the MSA Statement carefully to find out what year it covers.
When a statement is referring to a Financial Year (FY) ending in Q1 or early Q2, it should be labeled with the previous year. Example:
- Statement for FY2018/19 ending in April 2019 = 2018
- Statement for FY2018/19 ending in May 2019 (or later) = 2019