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  • 1. Structure, business and supply chains
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4: Due diligence processes

Contents

Key Content

Level 1

  • 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)

Level 2

As Level 1, plus:

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

Level 3

  • 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

Suggested information to include

  • 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
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