OUR RISKS ASSESSMENTS PROGRAM OUTLINED
The 5 metrics that have potential to increase workers vulnerability to risk are seen as.
Country of operations and workers countries of origin.
The level and type of work they are employed in: covering Skilled, Semi-skilled or Unskilled.
Category of employment, Permanent, Casual or Seasonal.
Established Industry issues including Gender Discrimination.
Abilities to address Supply Chain Risks.
Our most recent Country and Sector Risk Analysis as set out below provides us with a breakdown of risks across our updated Supply Chain sourcing program which currently includes China, Bangladesh and India (under review) where we work with our Supply Chain Partners and Worker Committees/Representatives to establish Root Causes for each identified Risk and work together across agreed mitigation and ongoing improvement programs. Identified and rated Risks shown in the presentations and our ongoing Risk assessment programs following are not solely based on Audit Data and include input and external information from external sources including:
· Ergon Associates reports including Global Risk Assessments, Country Risk Analysis and Grievance and Remedy programs. Note that Ergon Associates supported SEDEX re the development of Self Auditing Questionnaire model for service providers.
· The International Trade Union Confederation Global Rights index Global Rights Index - International Trade Union Confederation (ituc-csi.org)
US Department of Labour.
Amnesty International.
Human Rights watch.
Thomson Reuters Foundation.
Country Risk World Bank.
US Customs & Border Protection.
Transparency International
And others.
The Country and Sector Risk Analysis shown as follows shows detailed analysis of Risks compiled from SEDEX and various external sources which are listed above .Our Compliance and Sourcing Teams work together in extracting updated reports for our China and India ( under review ) and Bangladesh Supply Chains and share them with our Supply Chain Partner Factories and Worker Representative/Committees to establish Root Causes for identified Risk and work together across Ongoing Improvement and Mitigation Projects.
The second Commodity Risk report shown below ; where we have selected GARMENT Production within BANGLADESH shows the principal RISKS reported within BANGLADESH in detail .Similar reports are also produced for China and India which we include together with the Country and Sector Risk analysis detailed above for evaluation and Risk Assessment of new potential sourcing countries and to further support Action and Ongoing Improvement programs across our current Supply Chain sourcing partners.
Our Calculated Risk Assessment Matrix as shown below gives us the ability to track and highlight the range of risks within our Supply Chain Partners factories ( China was selected ) where we work with our Supply Chain Partners to identify Root causes and develop appropriate improvement programs which are jointly actioned and monitored to ensure satisfactory progress.
SALIENT RISKS: MITIGATION AND IMPROVEMENT PROGRAMS
SALIENT HUMAN RIGHTS RISKS
Freedom of association and effective worker voice mechanisms.
Health, safety and wellbeing.
Child labour – India and Bangladesh.
Low wages -
Forced labour = excessive working hours.
Gender and discrimination – India and Bangladesh.
References
· Ergon Associates reports including Global Risk Assessments, Country Risk Analysis and Grievance and Remedy programs. Note that Ergon Associates supported SEDEX re the development of Self Auditing Questionnaire model for service providers.
· The International Trade Union Confederation Global Rights index Global Rights Index - International Trade Union Confederation (ituc-csi.org)
Salient Human Rights Issues
The UNGP Guiding Principles on Business and Human rights together with the OECD Due Diligence Guidance for Responsible Business Conduct refers to the likelihood and severity of negative human rights impacts/risks to people connected to a business’s operations, Salient human rights risks exist where severe adverse impacts affect people within these operations.
Identifying our Salient Human Rights Issues
We have taken steps to identify human rights risks across our Supply Chain partners and our own operations utilizing various reports via our SEDEX programs as presented and where these were not solely based on Audit outcomes but included input and reference to a wide range of reports and findings from external sources as previously listed in our Risk Assessments Program outlined.
This process is based on both qualitative and quantitative information and reports from both SEDEX and the listed and other organizations and is further supported by our ongoing consultations and work with our Supply Chain Factory Management Worker Committee/Representatives and internally within our business operations where we have currently identified within our China based Supply Chain and more recently our recently onboarded Bangladesh and India (under review) Supplier factories the following current Salient Human Rights issues which are presented below together with our policies and procedures to address these.
|
Identified Risks |
Projects and Procedures to address risks |
Risks to workers and where risks are most prevalent |
|
Occupational Health and Safety:
|
Continue roll out of SEDEX and Elevate eLearning modules with review of ongoing improvements. Increase in unannounced audits and site visits. |
Across all Tiers of Supply Chain where most vulnerable include young workers, children, and female workers: Increased Risk of Injury or death and loss of income directly affecting families. |
|
Excessive Working Hours linked to Forced Labour:
|
Overtime Improvement Action Plan policy to be extended from China use to include Bangladesh and India: End Qtr. 2, 2025. |
Across all Tiers of Supply Chain with migrant workers at greatest risk: Breakdown in health, personal and family life standards. |
|
Wages and Social Security:
|
Social Insurances action plan policy to be modified and extended from China use to include Bangladesh and India: End Qtr. 2, 2025. |
Across all Tiers of Supply Chain with migrant workers, female workers, temporary workers and low skilled workers most vulnerable: Pressures to work longer hours and no adequate protection for access to Social Security benefits directly affecting individuals and family life standards. |
|
Discrimination including Gender:
|
Action consultation programs regarding a information project with ETI teams in India and Bangladesh: End Qtr. 2, 2025. |
Most focus on female workers and migrant workers plus minority groups. Isolation within and across Supply Chain workers; can lead to lack of access to advancement within the business. Directly affecting individual workers and family life standards. |
|
Freedom of Association and Collective Bargaining:
|
Extension of our Worker Representative/Committee Project including Suggestion Box requirements, approved procedures and meeting minutes. |
Presence across all Tiers of Supply Chain plus outsourcing where vulnerable groups include worker representatives and migrant workers: Subject to unacceptable working practices and requirements, poor wages and dangerous working conditions. Directly affecting Individual worker and Family life . |
|
Child Labour:
|
Action consultation regarding information project with ETI teams in India and Bangladesh by end Qtr. 2, 2025. |
Current projects focus on Bangladesh and India linked to poverty and access to education with focus on lower Tier levels including farming (growing) and raw material supply: Damage to a child’s health and development and access to education. |