About this question 

By conducting a comprehensive, business-wide risk assessment, companies can identify and prioritize their most significant human rights risks and implement appropriate measures to prevent and mitigate those risks. This proactive approach helps companies avoid legal liabilities, reputational harm, and operational disruptions, while also demonstrating their commitment to ethical responsibilities and meeting stakeholder expectations.

The UN Guiding Principles on Business and Human Rights emphasize that businesses have a responsibility to respect human rights in all aspects of their operations. A thorough human rights risk assessment should analyze the potential human rights risks associated with the company’s operations, products, services, and supply chains. This assessment should evaluate the company’s impact on the rights of all stakeholders, including employees, communities, consumers, and supply chain partners, and assess the effectiveness of existing policies, procedures, and due diligence processes in preventing and addressing these risks.

The assessment process should involve input from internal and external stakeholders, such as human rights experts, civil society organizations, and affected communities. The output should be a prioritized list of the most significant human rights risks, along with actionable recommendations for mitigating and managing those risks. Companies should assess risks based on their scale, scope, and irremediable character. Scale refers to the severity of the adverse impact, scope considers the breadth of stakeholders affected, and irremediable character reflects the difficulty of fully restoring the harm caused.  It should be also assess whether adverse impacts are systemic (an inherent result of ongoing activities) or isolated incidents.

This robust assessment framework ensures that companies not only identify their most pressing human rights risks but also build resilience and accountability into their operations.

• Answer yes if your company has assessed actual and potential impact and risks and has prioritized the most salient risks and impact to be acted upon
• Answer no if your company has not conducted a Human Rights Risk Assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MQ

Additional information

For further information, it is worth reviewing:

• UNGP operational principle 18
• Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

• Link to published outputs of risk assessment process (e.g., ESG strategy or report, corporate website, Annual Report and accounts)

or

• Internal risk assessment process documentation. This documentation should include information on how the company has developed its understanding of how people with particular characteristics, in specific locations, or involved in particular activities , are at greater risk of harm.

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, board meeting papers)

About this question 

Engaging meaningfully with stakeholders is an important part of the due diligence process of a risk assessment. The aim of this question is to measure to what extent your company has engaged with its stakeholders during the assessment and prioritization of impact and risks. To assess their human rights impacts and risks accurately, companies should understand the concerns of potentially affected stakeholders by consulting them directly, or where that is not possible, consult with credible and independent experts. During the engagement process, you should be mindful of potential language and cultural differences.

• Answer yes if your company has involved a wide variety of stakeholder groups in the delivery of its risk assessment including those across the value chain
• Answer partial yes if your company has only involved more than one stakeholder group (e.g., Employees or Shareholders) in the delivery of its risk assessment
• Answer no if your company has only involved one internal stakeholder group in its risk assessment, or if you have not conducted a Human Rights risk assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_Mg

Additional information

For further information, it is worth reviewing:

• UNGP operational principle 18
• Paragraph on meaningful stakeholder engagement available in the introduction chapter of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

• Partnership agreements with e.g., Trade Union, NGO, expert consultancy or other third-party engaged to carry out stakeholder engagement work

or

• Link or screenshot demonstrating mechanisms used for stakeholder consultation (e.g., survey, grievance mechanism platform)

and

• Internal documents describing process and outcomes of consultation – verified by senior leader

Optional supplementary evidence:

• Screenshot of documents or other materials demonstrating examples of stakeholder feedback

About this question 

This question assesses which stakeholders were involved in the assessment and prioritization risk assessment process. Engaging stakeholders in the risk management process enhances the company’s understanding of potential risks and enables the development of more effective strategies for mitigating and managing those risks. Stakeholders that should be involved in risk analysis include employees, value chain workers, consumers, and communities at all relevant value chain stages. Each group brings unique perspectives that may highlight risks not readily apparent from a management-only viewpoint.

Companies should engage these stakeholders directly whenever possible. Where direct consultation is not feasible, credible and independent experts should be consulted to represent stakeholder perspectives effectively. Companies are advised to record how each group was consulted, and how the perspectives of the stakeholders consulted have informed their decisions or activities, mitigating actual or potential impacts.

When engaging with indigenous peoples, companies must take special care to respect their specific rights and ensure culturally appropriate engagement practices.

• Select one or more groups that your company has engaged with during its risk assessment process
• Select none if your company has not engaged with any stakeholders in your risk assessment process or you have not carried out a human rights risk assessment

Answer options: Employees, Value chain workers, Consumers, Communities.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_Mw

Additional information

For further information, it is worth reviewing:

• UNGP operational principle 18
• Paragraph on meaningful stakeholder engagement available in the introduction chapter and Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

• Documentation describing the process of risk assessment, including the stakeholder groups involved in the process.

and

• Link to, or screenshot of, the list of stakeholder groups that were included. This could be included in, or as an annex to the agreement with the third-party, or to the process or outcome document.

A comprehensive response should demonstrate:

1. Whether engagement occurs with stakeholders or their legitimate representatives directly, or with credible proxies that have insight into their situation;
2. The stage(s) at which engagement occurs, the type of engagement, and the frequency of the engagement;
3. The function and the most senior role within the company that has operational responsibility for ensuring this engagement happens, and that the results inform the company’s approach;
4. Where applicable, how the company assesses the effectiveness of its engagement with stakeholders, including, where relevant, any agreements or outcomes that result.

About this question 

This question provides an opportunity to demonstrate the depth of human rights risk assessment carried out. Conducting a comprehensive human rights risk assessment is critical to developing effective risk management strategies and promoting a corporate culture that values and respects human rights.The human rights risk assessment should cover risks that your company may cause or contribute to through its own activities, or directly linked to your company’s operations, products or services by its business relationships. This should include information about locations or business activities that carry a higher risk of human rights breaches, such as safety risks or forced labor. Companies should consider how workers, communities, employees and value chain workers are affected by activities at relevant value chain stages.

• Select one or more value chain stages that your company has assessed to develop your human rights risk assessment
• Select none if your company has not included any of the listed value chain stages in its risk assessment process or you have not carried out a human rights risk assessment

Answer options: Tier 4, Tier 3, Tier 2, Tier 1, Tier 0, Distribution & Logistics, Retail, Consumer Use, End of Life

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_NA_b (For: Brand, Brand and Retailer)

Reference ID: sg_NA_r (For: Retailer)

Evidence

Provide:

• Link or screenshot of the description of the target groups included in the stakeholder engagement. The description should clarify, where relevant, which tiers each of the stakeholders are part of (could be an annex to the agreement with the third-party, or an annex to the process or outcome document)

About this question 

International human rights standards should be assessed when creating a robust human rights risk assessment. The key standards include the United Nations Guiding Principles on Business and Human Rights, the International Labour Organization’s Core Conventions, OECD Guidelines for Multinational Enterprises, and the Universal Declaration of Human Rights.

The United Nations Guiding Principles on Business and Human Rights provide a framework for businesses to respect human rights throughout their operations. The Principles outline the responsibilities of companies to respect human rights, conduct due diligence to identify and address human rights risks, and provide remediation for any human rights abuses that may occur.

The International Labour Organization’s Core Conventions provide a set of standards for companies to follow regarding labor rights, including the elimination of child labor, forced labor, and discrimination in the workplace.

The OECD Guidelines provide recommendations for responsible business conduct in areas such as human rights, labor rights, the environment, and anti-corruption.

Finally, the Universal Declaration of Human Rights sets out a broad range of civil, political, economic, social, and cultural rights that should be protected and respected by all. In all cases reference should be made to the internationally recognised human rights expressed in the International Bill of Human Rights.

• Answer yes if your company has assessed actual and potential impact and risks against key standards and frameworks
• Answer no if your company has not assessed actual and potential impact and risks against key standards and frameworks

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_NQ

Evidence

Either

• Link to published risk assessment demonstrating alignment with international standards (e.g.,ESG strategy or report, corporate website, Annual Report and accounts)

or

• Internal risk assessment documentation demonstrating alignment with international standards, and
• Evidence of oversight by board/senior leadership (e.g.,ESG Committee minutes, board meeting papers)

About this question 

This question tests the robustness of your company’s human rights risk assessment process by establishing whether the views of value chain workers, as key stakeholders, were sought and incorporated. It is important to include worker feedback as a standard component of a worker-related human rights risk assessment for several reasons. Workers are often the most knowledgeable about the conditions and risks associated with their work, and their feedback can provide valuable insights into potential human rights risks that may be present in the workplace. Including worker feedback in the assessment can also help companies identify potential human rights violations that may not be apparent through other means of assessment, such as audits or inspections. Workers can be engaged in a human rights risk assessment through surveys, interviews, focus groups, and other forms of consultation to gather their feedback and insights.

• Answer yes if your company has involved value chain workers in the human rights risk assessment process by collecting worker feedback in activities complementary to an audit or inspection such as focus groups, interviews or off-site feedback mechanisms.
• Answer no if your company has not developed a way to incorporate worker views within the risk assessment process or if your company has not conducted a human rights risk assessment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_Ng

Additional information

For further information, it is worth reviewing:

• UNGP operational principle 18
• Paragraph on meaningful stakeholder engagement available in the introduction chapter and Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

• Link or screenshot of the list of stakeholder groups that were included (could be included in, or an annex to the agreement with the third-party, or an annex to the process or outcome document)

and

• Evidence of the consistent use of worker feedback in the human rights assessment such as notes of interviews, reports/data from online feedback tools

About this question 

Risk assessments in companies should be reviewed periodically—at least once a year—or whenever significant changes occur in the company’s operations, supply chain, or regulatory environment that may impact human rights risks. this question assesses whether your company has a mechanism or process in place to ensure these updates are undertaken regularly. examples of changing circumstances include, but are not limited to: opening a new sourcing country, entering a new market, implementing new national or international regulation, responding to (geo) political developments, implementing transition plans to reduce environmental impact and achieve climate neutrality, and/or impact of climate change or other geographical crises.

• Answer yes if your company has a process in place that defines how and when human rights risks assessments should be updated
• Answer no if your company has no process in place for updating human rights risks assessments

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_Nw

Evidence

Either

• Link to published risk assessment policy indicating how often and when risks assessments are carried out (e.g.,Corporate Governance section of company website, Annual Report and accounts)

or

• Internal risk assessment policy and process documents, indicating how often and when risk assessments will be carried out

and

• Evidence of oversight by board/senior leadership (e.g.,Director/General Counsel signature, ESG Committee minutes, Board papers)

About this question

Environmental sustainability and the protection of human rights are closely linked and together form the core of sustainable development. The interconnectedness between the environment and human rights underpins our approach, recognizing that ecosystems and their services—such as food, water, disease management, climate regulation, and spiritual fulfillment—are preconditions for the full enjoyment of human rights, including rights to life, health, water, and food.

Under the UN Guiding Principles on Business and Human Rights (UNGPs), businesses have a responsibility to understand and address how their activities and business relationships across their value chains can lead to negative impacts on human rights in connection with their operations, products, and services.

This integrated guidance asks whether your company recognizes the mutually supportive nature of the promotion of human rights and environmental sustainability. It inquires whether your company formally assesses human rights risks in the context of its environmental policies and strategies, specifically in relation to climate, water, waste, biodiversity, and chemical management, through a due diligence process that includes:

• Assessing actual and potential human rights impacts (harms and risks) related to your company’s environmental policies.
• Integrating and acting upon the findings, whether that is ceasing, preventing, or mitigating harm.
• Tracking progress and results.
• Communicating how impacts are addressed.
• Supporting remediation.

This guidance specifically focuses on the assessment and subsequent prioritization of actual and potential human rights impacts (both harms and risks) in your company’s own operations and value chain.

• Select one or more of the environmental impact areas listed, for which you have evidence that your company has also carried out an integrated human rights impact assessment
• Select none if you are unable to provide evidence that your company integrates human rights into environmental assessments, or if no assessments are carried out

Answer options: Climate, Water, Waste, Biodiversity, Chemicals.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_OA

Evidence

Either

• Link to published outputs of risk assessment process (e.g.,ESG strategy or report, corporate website, Annual Report and accounts)

or

• Internal risk assessment documentation

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, board meeting papers)

About this question 

Once your company has identified the most salient risks, it should conduct a more detailed analysis to determine the specific characteristics of these risks and whether they result in actual or potential adverse impacts. this question aims to assess the extent to which your company is undertaking a comprehensive evaluation of its salient risks.

In certain cases, additional assessments are necessary to determine the exact scope, nature and incidence of risks and adverse impacts.

For example, as part of this process, companies could clarify whether specific groups within stakeholder categories are disproportionately affected or if risks apply more broadly. For instance, certain age groups, individuals with disabilities, or those involved in specific stages of the value chain may face unique risks. Furthermore, the assessment could identify region-specific or operational risks, such as the likelihood of forced labor or child labor in particular geographical areas.

Additionally, these assessments should establish the relationship between your company’s operations and the risks or impacts—specifically, whether your company has caused or contributed to the identified risks and adverse impacts.

• Answer yes if your company has carried out more detailed assessment on identified key human rights risks to determine, amongst others, nature and scope
• Answer no if your company has not carried out more detailed assessments for the identified salient risks

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_OQ

Additional information

For further information, it is worth reviewing:

• Section 2 in the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

• A link to published outputs of the risk assessment process (e.g., ESG strategy or report, corporate website, Annual Report and accounts)

and

• Internal risk assessment process documentation, demonstrating more granular risk assessments identifying risks to specific groups, such as a specific affected community, employee group, type or location of value chain work, or specific customer groups

or

• Internal risk assessment process documentation as described above and the outputs of risk assessment process.

and

• Evidence of oversight by the board/senior leadership (e.g.,ESG Committee minutes, board meeting papers)

About this question 

A human rights policy is a company’s public expression of its commitment to meet its responsibility to respect internationally recognized human rights standards. policies that state a corporate commitment are a critical component of corporate governance.

This question seeks evidence of a high-level human rights policy or commitment approved by the board (or senior leadership) that outlines how the company identifies, prevents, and addressess human rights risks it has identified.

At a minimum,this policy should reference the rights set out in the International Bill of Human Rights, the principles concerning fundamental rights set out in the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, or OECD Guidelines for Multinational Enterprises.

The policy should outline the company’s commitments and general approach towards:

1. respect for the human rights of all stakeholders involved or affected by your company’s operations;
2. engagement with stakeholders, including affected communities, to understand and address their concerns; and
3. measures to provide and/or enable remediation for adverse impacts on human rights when they occur.

The policy is likely to include an overview of the steps taken to develop it, information on priority areas, a commitment to allocate resources and assign a responsible team, defining the process by which salient human rights risks will be assessed or mitigated, and a description of how these will be reported on.

• Answer yes if you can provide a link to your company’s published human rights policy as described above
• Answer no if there is no human rights policy, if your company’s policy does not include commitment to the core principles outlined above, or if the policy is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTA

Additional information

For further information, it is worth reviewing:

• UNGP operational principle 16
• Section 1 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

• Link to published policy, statement or group of policies on company website

and

• Evidence to demonstrate how the policy is communicated to stakeholders at all levels of the value chain

Note: Policies can be standalone or combined, for example a company’s published Human Rights Policy could be a standalone statement, but could also be part of a broader document, such as a company’s social impact strategy. The relevant section of the document should be indicated to the verifier, e.g., page or section number.

About this question 

A human rights policy is a company’s public expression of its commitment to meet its responsibility to respect internationally recognized human rights standards. A company’s responsibility for human rights covers (amongst others), all the people working in its value chain, across all types of employment, whether direct, in direct, freelance, contracted and others.

This question tests the breadth of your company’s human rights policy’s reach in this respect. It asks whether your company’s policy makes explicit recognition of its responsibility for human rights for workers employed or contracted within its wider value chain by its suppliers and business partners. Examples include third-party logistics workers, franchise workers, contractors, freelance workers and any other workers in the value chain who are not directly employed by your company.

• Answer yes if you can provide a link to your company’s published human rights policy which describes its consideration of value chain workers as described above
• Answer no if there is no human rights policy, if your company’s policy does not include commitment to value chain workers as described above, or if the policy is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTE

Additional information

For further information, it is worth reviewing:

• UNGP operational principle 16
• Section 1 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

• Link to published policy, statement or group of policies on company website

Note: Policies can be standalone or combined, for example a company’s published Human Rights Policy could be a standalone statement, but could also be part of a broader document, such as a company’s social impact strategy. The relevant section of the document should be indicated to the verifier, e.g., page or section number.

About this question 

A human rights policy provides the foundation for publicly affirming a company’s values and embedding the responsibility to respect human rights into its operations and business practices.

To be effective, more detailed policies, codes of conduct or practice must outline how  these commitments are implemented throughout the company’s operations and its value chain. A supplier code of conduct (or equivalent) sets out the company’s expectations for business partners across the value chain, particularly regarding employment standards and labor conditions for value chain workers. As a good practice, a company’s code of conduct should be publicly accessible.

Companies should align these policies with internationally recognized instruments, including the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises. Furthermore, companies should be ready to disclose instances of non-conformities with these instruments that involve value chain workers, detailing the nature of such cases.

• Answer yes if you can provide a link to your company’s Supplier Code of Conduct
• Answer no if there is no Supplier Code of Conduct (or equivalent), or if this is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTI

Additional information

For further information, it is worth reviewing:

• Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

• Link to published Supplier Code of Conduct or equivalent monitoring framework on company website

Note: The Supplier Code of Conduct or equivalent document should align with international frameworks as described in the guidance, and explicitly address all forms of forced labour, child labour, and human trafficking.

About this question 

A Supplier Code of Conduct is a document that sets out your company’s expectations for value chain business partners, particularly in relation to implementation of employment standards and labor conditions for value chain workers. Understanding what risk areas are covered by a company’s supplier code is important because it helps to assess the company’s commitment to respecting human and labor rights in its value chain.

The question asks your company to select specific areas of risk covered by their supplier code of conduct or labor rights policy, which can help to reveal strengths or weaknesses in the approach to managing these risks. The list of topics provided represent critical elements of internationally recognised codes of practice. Publishing your company’s Supplier Code of Conduct is considered a necessary demonstration of good governance and transparency.

• Select one or more related risks covered by your company’s Supplier Code of Conduct or labor rights policy
• Select none if you cannot provide evidence of a Supplier Code of Conduct or labor rights policy, if it does not cover any of the topics listed, or if it is not in the public domain

Answer options: Forced labor/Modern Slavery, Migrant workers, Child labor, Young worker policy, Living wage, Contracts, Working time, Freedom of Association, Collective Bargaining, Bipartite dialogue, Grievance systems, Harassment and abuse, Anti-discrimination, Diversity, Equity and Inclusion, Health and Safety, Training and development, Other human and labor rights issues.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTM

Additional information

For further information, it is worth reviewing:

• Section 2 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Provide:

•  Link to published Supplier Code of Conduct or equivalent monitoring framework on company website

About this question 

For: Brand

Responsible purchasing practices by brands are a key driver for better social outcomes in the supply chain. Your company’s practices with regard to how it purchases goods and pays its suppliers can directly impact their ability to uphold labor standards and provide decent work for their employees. For instance late payments can directly impact payment of wages to workers. Other unexpected costs such as penalties that were not agreed, or prepayment of costs that can only be reimbursed later, also impact a supplier’s ability to make the necessary investments to remediate or further improve social and labor conditions.

This question is looking for evidence of a policy approved by the board/senior management that demonstrates a corporate commitment to responsible purchasing practices.

• Answer yes if you can provide a link to your company’s responsible purchasing practices policy
• Answer no if your company does not have a responsible purchasing practices policy or if this policy is not in the public domain

For: Retailer

Adopting responsible purchasing practices is a critical factor in achieving positive social outcomes throughout the value chain. Retailers have an opportunity to support good practice throughout the value chain by implementing positive purchasing practices in their relationships with third-party brands.

This question is looking for evidence of a policy approved by the board/senior management that demonstrates a corporate commitment to responsible purchasing practices.

• Answer yes if you can provide a link to your company’s responsible purchasing practices policy
• Answer no if your company does not have a responsible purchasing practices policy or if this policy is not in the public domain

For: Brand and Retailer

Adopting responsible purchasing practices is a critical factor in achieving positive social outcomes throughout the value chain. Your company’s practices with regard to how it purchases goods and pays its suppliers can directly impact their ability to uphold labor standards and provide decent work for their employees. For instance late payments can directly impact payment of wages to workers. Other unexpected costs such as penalties that were not agreed, or prepayment of costs that can only be reimbursed later, also impact a supplier’s ability to make the necessary investments to remediate or further improve social and labor conditions. At the same time, companies have an opportunity to further support good practice throughout the value chain by implementing positive purchasing practices in their relationships with third-party brands.

This question is looking for evidence of a policy approved by the board/senior management that demonstrates a corporate commitment to responsible purchasing practices.

• Answer yes if you can provide a link to your company’s responsible purchasing practices policy
• Answer no if your company does not have a responsible purchasing practices policy or if this policy is not in the public domain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTQ_b (For: Brand, Brand and Retailer)

Reference ID: sg_MTQ_r (For: Retailer)

Additional information

For further information, it is worth reviewing:

• Prevent contribution to harm through responsible purchasing practices Section 3 OECD Due Diligence Guidance for responsible supply chains in the garment and footwear sector
• Principle 1 (Integration and Reporting) of The Common Framework on Responsible Purchasing Practices (CFRPP)

Evidence

Either

• Link to published Responsible Purchasing Practices policy, statement of commitment or group of policies on company website

or

• Internal (unpublished) Responsible Purchasing Practices policy, statement of commitment dated and signed on behalf of the board/senior leadership

and

• Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question 

Many supplier contracts lack explicit human rights-related obligations. When buyers (e.g., brands, retailers) include such obligations in their agreements with suppliers, they often rely on traditional contracting techniques that are not suited to addressing the complexity of human rights risks in dynamic supply chains. While these traditional approaches may effectively manage company risk, they fall short in addressing the nuances of Human Rights due diligence.

Responsible contracting requires a shift towards agreements where both buyer and supplier commit to:

1. Conducting effective Human Rights due diligence,
2. Sharing responsibility for upholding Human Rights standards, and
3. Prioritizing the remediation of Human Rights impacts over severing the business relationship.

Additionally, companies should apply the same Human Rights obligations to supplier contracts covering non-stock goods and services, including the employment of agency staff, freelancers, and workers employed by third-party companies (typically referred to as ‘non-employees’ or ‘indirect employees’).

• Answer yes if your company’s supplier contract includes all three commitments.
• Answer partial yes if your company’s supplier contract includes 2 of the 3 commitments.
• Answer no in all other cases.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_shared_resp

About this question 

Employment standards are essential to regulating the relationship between the company and its employees, ensuring safe, fair, and decent work while complying with applicable laws. These standards encompass critical elements of social protection, forming the backbone of good employment practices and responsible human resources management.

In responding to this question, companies may include social protection or employment standards that are supported by public programs in their countries of operation.

However, if there are countries of operation where your company’s employees are not covered by either public programs or internal standards, this should be clearly disclosed with supporting evidence.

• Select one or more of the topic areas listed that are covered by your company’s employment standards or policies
• Select none if you cannot provide evidence that any of the topic areas listed are covered by your company’s employment standards or policies

Answer options: ILO’s core conventions, Pay, Working hours, Provision of written statement of terms of employment, Annual leave (holiday, vacation), Paid leave for sickness, injury, acquired disability, Parental leave (maternity, paternity, adoption, fostering, other) and return to work, Dependents’ (parents, carers, family) leave, Flexible working, Stable Contracts, Redundancy protections (including transfer of undertaking), Unemployment protection starting from when the worker is working for the company, Grievance, disciplinary and dismissal procedures, A safe and healthy work environment, Protection for part-time, fixed-term and temporary workers, Protection for young workers, Protection from bullying and harassment, Protection from discrimination, Retirement support.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTU

Evidence

Provide:

• Policies/regulations dated and signed on behalf of the board/senior leadership such as employee handbook, HR policies, pro-forma contracts of employment

and

• Screenshots demonstrating how these policies are made available to employees (e.g., employee intranet, contractual packages)
• Internal documentation showing which types of employees are covered or not covered by these standards. If there are multiple countries of operation, include this information as percentages by country and a percentage overall.

About this question

Employment standards are critical for regulating the relationship between a company and its employees, ensuring safe, fair and decent work while complying with applicable laws. this question provides an opportunity for companies to demonstrate more advanced practices by highlighting additional human resources (HR) policies in place to address specific employment-related risks and opportunities..

Companies should disclose whether employment standards are consistently aligned across all employee groups, including those covered by a collective bargaining agreement (or other agreements), and those who are not.

• Select one or more of the listed topics if your company has a specific human resources policy or commitment in that area
• Select none if you cannot provide evidence of human resources policies covering any of these topics

CSRD: 

In responding to this question, companies may also reference social protections or employment standards supported by public programs in their countries of operation. However, if there are countries where your company’s employees are not covered by either public programs or internal standards, this should be explicitly disclosed with supporting evidence.

Policies relating to diversity, equity, inclusion, and anti-discrimination should comprehensively address the following characteristics: racial and ethnic origin, color, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction, or social origin, along with other forms of discrimination covered by applicable legislation.

Answer options: Freedom of association/collective bargaining, Employee voice and representation, Regular work and employment stability, Diversity, equity and inclusion, Learning and development, career development, Well-being (including mental health).

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTY

Evidence

Either

• A link to published employment policies, statements of commitment, or a group of policies on the company website

or

• Internal (unpublished) employment policies, dated and signed on behalf of the board/senior leadership.

and

• Screenshots demonstrating how unpublished policies are made available to employees (e.g., employee intranet, contractual package).

• Policies should include commitments related to inclusion or positive action for people from groups at particular risk of vulnerability in the company’s workforce.

Note: Where relevant, policies covering employment standards should make it clear whether there is alignment or non-alignment with collective bargaining or other agreements.

Policies can be standalone or combined, for example, the employment policies can be part of a broader HR policies and regulation document. The relevant section of the document should be indicated to the verifier, e.g., page or section number.

About this question

This question evaluates social and human rights impacts beyond those directly linked to labor and employment, focusing on how your company integrates human rights commitments across its operations. Specifically, it examines your company’s approach to community rights, community contributions, and interactions with consumers. It seeks evidence of corporate policies and commitments addressing:

• Protecting the rights of communities affected by its operation, and/or
• Making community contributions (including fiscal, pro-bono and product donations, and cause-related marketing), and/or
• Providing accessible and inclusive products and services to its consumers, and/or
• Protecting the rights of consumers and end users, and/or
• Ensuring marketing materials, campaigns, and corporate communications are responsible, inclusive, accessible and respectful.

Companies disclose the alignment between company policies, targets, and any established standards (e.g., codes of practice, certifications, sourcing policies, global frameworks, or industry codes).

• Select one or more of the listed areas if you can provide evidence that your company takes a policy-led approach to this topic

• Select none if your company does not have corporate policies related to any of the topics listed

CSRD:

In developing their approach, companies are advised to also consider

1. Their impact on specific groups within affected communities across their value change, including indigenous peoples.
2.  The potential impact on consumers and end users, including groups that are more vulnerable (e.g., due to age, disability)

Answer option: Social impacts of operations on rights of local communities affected by its operations, Community contributions (e.g., corporate charity partnerships), Provision of accessible and inclusive products and services to consumers, protecting the rights of consumers and end users, Commitment to responsible marketing and communication to consumers.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTc

Evidence

Either

• Link to published policy, statement or group of policies on company website that cover the areas listed in the question

or

• Internal (unpublished) policy dated and signed on behalf of the board / senior leadership that cover the areas listed in the question

and

• Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question

Human rights due diligence is a process for companies to proactively manage potential and actual adverse human rights impacts associated with their operations and value chain. The United Nations identifies four components of human rights due diligence:

1. Identifying and assessing actual or potential adverse human rights impacts that the company may cause or contribute to
2. Integrating findings from impact assessments across relevant company processes and taking appropriate action
3. Tracking the effectiveness of measures and processes to address adverse human rights impacts in order to know if they are working;
4. Communicating how impacts are being addressed and demonstrating to stakeholders – particularly affected stakeholders – that adequate policies and processes are in place.

This question is looking for evidence of a due diligence policy that outlines how your company implements this process across its operations and value chain. Companies should provide examples of how they consider their impacts on the human rights of workers, employees, consumers, and affected communities.

• Answer yes if you can provide evidence that your company has a human rights due diligence policy or process that applies across its own operations and value chain

• Answer partial yes if your company’s human rights due diligence policy applies to either its own operations or a limited part of the value chain

• Answer no if your company does not have a human rights due diligence policy for any part of its operations or value chain

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTg_b (For: Brand, Brand and Retailer)

Reference ID: sg_MTg_r (For: Retailer)

Additional information

For further information, it is worth reviewing:

• Section 1 of the OECD due diligence guidance for Responsible Supply Chains in the Garment and Footwear Sector

Evidence

Either

• Link to published due diligence policy on company website

and

• Evidence that the policy covers affected groups including value chain workers, employees, consumers and affected communities

or

• Internal (unpublished) due diligence policy dated and signed on behalf of the board/senior leadership

and

• Screenshots demonstrating how unpublished due diligence policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question

A company’s responsibility for human rights covers all the people working in its value chain (amongst others) across all types of employment, whether direct, in direct, freelance, contracted and others.

This question tests the depth of your company’s human rights policy’s reach in this respect. It asks how far your company’s human rights related policies extend across its value chain from raw materials sourcing through to product manufacture, then its own operations and beyond to include third-party logistics providers, goods not for resale, wholesale and other retail partners.

• Select one or more value chain levels covered by your company’s human rights policies
• Select none if you cannot provide evidence of your company’s human rights policies covering any of the value chain stages listed

Answer options: Tier 4, Tier 3, Tier 2, Tier 1, Tier 0 (indirect workers/non-employees), Third-party Logistics providers, Non product related suppliers/contractors (Goods Not For Resale), Wholesale customers, franchises, licensees and/or other business partners.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MTk_b (For: Brand, Brand and Retailer)

Reference ID: sg_MTk_r (For: Retailer)

Additional information

For further information, it is worth reviewing:

• Mechanisms to assess and address risks of harm beyond tier in Section 2 of the OECD Due Diligence Guidance for responsible supply chains in the garment and footwear sector

Evidence

Either

• Link to published due diligence policy and if applicable implementation guidelines/regulations on company website

or

• Internal (unpublished) due diligence policy and if applicable  implementation guidelines/regulations and signed on behalf of the board / senior leadership

and

• Screenshots demonstrating how unpublished due diligence policies are made available to stakeholders (e.g., employee intranet, supplier portal)

About this question

Subcontracting is a common practice in the fashion industry for different reasons, such as specialized processes or temporary increases in production capacity. While subcontracting can enhance flexibility and efficiency, it is also associated with heightened human rights, labor rights, and environmental risks. to ensure transparency and accountability in their supply chain, companies should establish clear agreements with their suppliers outlining whether, when, and under what conditions subcontractors can be used.

This question evaluates whether your company has a written policy that defines the conditions for subcontracting and ensures that this policy is effectively communicated to all suppliers.

• Answer yes if your company has a policy that defines if and under which conditions subcontracting is allowed and if that policy is shared with all suppliers. If your company prohibits subcontracting, the policy should identify what additional measures your company takes to mitigate risk of illegal subcontracting
• Answer no if your company has no subcontracting policy or if it has not been shared with all its suppliers

Applicability: Brand, Brand and Retailer

Reference ID: sg_Mtx

Additional information

For further information, it is worth reviewing:

• Mechanisms to assess and address risks of harm beyond tier 2 in Section 2 of the OECD Due Diligence Guidance for responsible supply chains in the garment and footwear sector
• Information on subcontractors in Section 1 of the OECD due diligence guidance for responsible supply chains in the garment and footwear sector

Evidence

Provide:

• Internal policy (or equivalent document) that defines whether and under which conditions subcontracting is allowed.

and

• Evidence that this has been shared with all suppliers, e.g., through contracts, specific communications, or a code of conduct

and

• Evidence of oversight by the board/senior leadership (e.g., ESG Committee minutes, board/senior management resolutions, CSR/Sustainability Director report, or Sourcing Director report).

About this question 

Environmental sustainability and the protection of human rights are closely linked and together form the core of sustainable development. UNEP sets out a number of ways in which environmental and social objectives are connected including the following:

Ecosystems and the services they provide, such as food, water, disease management, climate regulation, and spiritual fulfillment, are preconditions for the full enjoyment of human rights, including rights to life, health, water, and food. At the same time, efforts to promote environmental sustainability can only be effective if they occur in the context of conductive legal frameworks, and are greatly informed by the exercise of certain human rights, such as the rights to information, public participation in decision making and access to justice.

This question asks whether your company’s environmental policies recognise the mutually supportive nature of the promotion of human rights and environmental sustainability.

• Select one or more environmental policy areas where you can provide evidence that your company has also taken social impacts into consideration
• Select none if none of your company’s environmental policies include consideration of associated social impacts, or if your company does not have environmental policies in these areas

Answer options: Climate, Water, Waste, Biodiversity, Chemicals.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_MjA

Evidence

Either

• Link to published environmental and human rights policies

and

• Clear indication of where consideration has been given within the policies to recognize the mutually supportive nature of the promotion of human rights and environmental sustainability

or

• Internal (unpublished) environmental and human rights policies

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, Board papers)

and

• Clear indication of where consideration has been given to recognize the mutually supportive nature of the promotion of human rights and environmental sustainability

About this question 

Business and external circumstances change over time, requiring companies to establish a clear and systematic process to ensure their policies remain fit for purpose.

Companies should have (1) regular policy reviews and (2) processes to update policies following changes in business activity or external circumstances. This question asks whether a documented process exists to define when and how policies are reviewed and updated. An effective review process enables companies to adapt to regulatory changes, operational shifts, and best practices, ensuring both legal compliance and alignment with global frameworks.

Good practice includes a scheduled cycle of policy review (e.g., annually or as appropriate to the topic), supplemented by additional reviews triggered by significant changes, such as entering a new market, an acquisition or merger, or actions linked to transitioning to climate-neutral operations. This process should be overseen by an accountable individual, department, or board/management committee to ensure transparency and accountability.

The policy review process should also outline how stakeholders are kept informed of updates, fostering trust and engagement.

Policies must align with the UN Guiding Principles on Business and Human Rights, which refer to the International Bill of Human Rights, including the Universal Declaration of Human Rights and the associated Covenants. Companies should explicitly declare alignment with these instruments.

• Answer yes if your company has a documented process by which the board/senior leadership reviews and/or updates social policies to ensure they remain fit for purpose.

• Answer no if there is no policy review process in place.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: sg_Mh1

Evidence

Either

• Documents demonstrating a process by which a range of corporate policies are reviewed over time, and in response to changing circumstances
• Evidence of oversight by senior leadership (e.g., ESG Committee minutes, Board papers)

• A link to process documentation relating to policy review/update

and

• Evidence that demonstrates how updated policies are communicated to affected stakeholders, including employees, business partners and others responsible for implementing the changes.

Optional supplementary evidence

• Examples or explanations for significant changes to policies during the reporting year”.

Note: unscored question