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Process requirements 6

Here we explain what is meant by enabling grievances. We describe the key functions of grievance mechanisms, for which stakeholders they shall be open, the need to address submitted grievances and the different requirements for the supplier’s own operations and its supply chains.

Excerpt from the contract terms

Supplier shall enable stakeholders such as rights-holders, their representatives and environmental and human rights defenders to submit grievances to Supplier if they have concerns about actual or potential adverse impacts in Supplier's operations or in its supply chains. Supplier shall address the submitted grievances.

Enable grievances

You must enable stakeholders such as rights holders, their representatives and environmental and human rights defenders to submit grievances to the suppliers, if they have concerns about actual or potential adverse impact in the suppliers’ operations or in their supply chains.

Grievance mechanisms perform two key functions:

  1. They support the identification of adverse impacts. They do so by providing a channel for those directly impacted by the supplier’s or its sub-suppliers’ operations, to raise concerns when they believe they are being or will be adversely impacted.

  2. They make it possible for grievances, once identified, to be addressed and for adverse impacts to be remediated early and directly by the supplier or the sub-supplier, thereby preventing harms from compounding and grievances from escalating.

Guidance process requirements 7

  • How to carry out a risk analysis
    Step 1: Mapping the supply chain The first step in a risk analysis consists of mapping the supply chain to find out its structure. This includes identifying in which countries the work is carried out, and if possible also in which regions. This is particularly relevant if the work is carried out in any region known to have high risks. Within certain industries such as food, textiles and IT there is a lot of information. For other industries such as pharmaceuticals, however, transparency is low. To obtain this information, you can ask the category manager, the category councils, ask questions of suppliers, find out import data, read audit reports and market analyzes for specific industries. It is also important to identify what type of work is carried out and what type of actors in the supply chain that performs it. Is it, for example, an industry characterized by low wages and health-hazardous processes? Does the workforce consist of migrant workers or seasonal workers? Is the supply chain complex with many subcontractors and a lack of transparency? This type of information is important as both geographical risks, industry risks and product risks need to be taken into account. Step 2: Gather information from credible and independent sources Once you have mapped the origin and the supply chain, the next step is to gather information about the situation of human rights, workers' rights, the environment and business ethics in the relevant countries where the work is carried out, that is, both for final manufacturing, component manufacturing and raw materials. For this you need to turn to credible and independent sources such as international organizations, authorities, voluntary and civil society organizations and global trade unions. Sources Step 3: Identify and assess negative impacts The last step involves assessing the actual and potential negative impact the supply chain is associated with, based on the information that has been compiled in steps 1 and 2. This is to be able to determine which concrete measures need to be taken to manage the risks. Often several risks have been identified and to prioritize them you need to make a seriousness assessment. The most significant risks are prioritized based on probability and seriousness ( read more under point d in process requirement 2 )

Suggested verifications

  • Process documents that describe the grievance mechanisms for your own operations and your supply chains.

  • Screenshots or printouts from digital grievance mechanisms.

  • Email addresses or phone numbers that serve as complaint mechanisms.

  • Screenshots or printouts from websites where the email addresses or phone numbers are available.

  • Copies of codes of conduct where e-mail addresses or telephone numbers   are included as well as photos of where they are posted in subcontractors' premises.

  • Links to multi-stakeholder initiatives.

Addressing grievances

You must deal with the complaints that are made.

By addressing grievances, you may prevent harms from compounding and grievances from escalating. Therefore, you shall address complaints according to established processes.

It should also be noted that a grievance mechanism will rarely be effective without adequate senior-level oversight and accountability within the enterprise. In a small enterprise, this can be solved through a simple reporting line from whoever handles submitted grievances to the head of the enterprise. In a larger enterprise, it will typically require more formal internal control and oversight systems.

If trust between the enterprise and affected rights-holders is low and the risks significant, it can be highly beneficial to provide for joint oversight of the mechanism. This can help ensure that the mechanism is trusted by its intended user groups, and that the mechanism’s accessibility and processes are tailored to their needs.

Suggested verifications

  • Process documents that describe the complaints mechanisms for your own business and your supply chains, including how grievances are handled.

  • Documented handled grievances, for sample products.

Templates for process requirements 6

  • Text to be added to the code of conduct, to be set up in local languages of subcontractors:



If your employer is violating anything in this code of conduct, we want to know about it.

Please bring the issue to our attention by contacting us at [phone number], [email address] or fill out the form at [link].

Please feel free to write in your local language. All information we receive will be kept strictly confidential.

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