4: Due diligence processes

Contents

Key Content

Details of existing HRDD approach, policies and processes including consideration of how they relate to modern slavery
Outline of how the existing HRDD approach aligns with relevant expert guidance (such as ETI’s Base Code)
Results of HRDD impact assessment
Plan to manage and mitigate priority risks (as identified in risk assessment process described above)

As Level 1, plus:

Measurement of progress against risk management and mitigation and remedy plan using specific KPIs

Evidence of ongoing monitoring and revision of risk management and mitigation plan
Description of incidents of modern slavery found, mitigation measures taken and outcomes for affected workers

Changes in operational practices or in business relationships designed to minimise modern slavery risks
Description of specific cases of modern slavery (risk) discovered and what steps were taken
Description of any programmes or initiatives undertaken to manage and mitigate modern slavery risk
Evidence of direct engagement with suppliers and with workers – going beyond audits and contractual compliance
Description of grievance mechanisms for workers or other ways in which they can access remedy – in the core business, among contractors and in the supply chain – aligned with relevant best practice
Evidence of participation in peer-learning groups or other collaborative initiatives for sharing lessons learned and best practice and for taking forward specific programmes
Evidence of developed incident response plans to be implemented in the event that a case of modern slavery is discovered within the business or its supply chain
Evidence of stakeholder engagement in responding to specific instances of modern slavery