Recommended actions

Country assessment

Build understanding of the risk to workers in the sourcing or production country:

1. Legal compliance:
   1. Ratification of ILO conventions 87 Freedom of Association and Protection of the Right to Organise Convention, and 98, Right to Organise and Collective Bargaining Convention.
   2. Transposition into national regulation including governance institutions – for example, a department of labour
   3. Historical and current complaints raised via the ILO complaints mechanism
   4. Country rating on ITUC global rights index.
2. Trade union verification:
   1. ITUC affiliations with national centres and federations
   2. Global union federation affiliations for sector specific trade unions aligned to ETI category groups.
      1. Food & farming: The International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations (IUF)
      2. Hard goods: Building and wood workers international (BWI)
      3. Apparel & textiles and manufacturing: IndustriALL
      4. Logistics and transport: International Transport Workers’ Federation (ITF)
      5. Commercial, beauty and services: UNI global
3. Campaigning information:
   1. ITUC and global union federations (regional or campaign pages)
   2. Labour NGOs and campaign organisations (for example Amnesty International, Banana Link and Justice for Colombia)
   3. Human Rights Watch
   4. Transparency International
   5. Solidarity Centre.

Site assessment

1. Using the RED FLAGS for suppliers - map risks relating to suppliers throughout your supply chain, prioritising strategic suppliers. Additional consideration should be given to repressive countries.

2. Consult widely with trade unionists and other labour stakeholders.

3. Request evidence ranging from policies, management standards, collective bargaining agreements and election processes to minute of meetings.

4. Consider a workplace risk matrix (ranking risks according to traffic light-style system).

Developing your action plan

1. Avoid contributing to harm in the supply chain: Policy commitment, company behaviour and narrative can create an enabling dialogue on freedom of association. Sharing your commitment to workers being able to freely associate, organise, elect independent representatives and where appropriate, bargain collectively ought to be reflected in your policy in the first instance with a transparent grievance mechanism or complaints process where these rights and protections are denied or interfered with. Particular attention should be in countries where freedom of association and collective bargaining are denied; for example, acknowledge any direct connections to rights violations, and if the company is indirectly connected to an oppressive government, acknowledge the state’s sub-optimal human rights record.
2. Implement internal measures to mitigate risks.
   1. Prequalify suppliers through a robust supplier assessment
   2. Consolidate suppliers: increase control over the supply chain and concentrate resources in order to prevent impacts among a smaller number of suppliers    
   3. Know your suppliers: long-term relationships with suppliers and understanding the local operating context equips you to deal with systematic labour standards abuses
   4. Establish business incentives: reward direct suppliers that perform well on quality and responsible business conduct   
   5. Leverage your influence with suppliers to prevent or mitigate harm – this is particularly relevant to preventing anti-union practices
   6. Support suppliers in preventing or mitigating adverse impacts by providing guidance or training; engage with other stakeholders – global union federations – as well as company level unions
   7. Engage with governments, including through open letters, sharing information and/or engaging in dialogue, arbitration or conciliation brokered by ETI.
3. Implement and monitor your action plan.
   1. In order to prioritise opportunities to improve freedom of association within your company’s supply chain:
   2. Verify that actions were conducted within the agreed period
   3. Progress should be monitored and measured against goals
   4. Monitor and assess progress at a corporate and supplier level. Many larger enterprises have developed systems of supplier audits to measure compliance with their required level of performance on social and environmental issues. While these systems can work well to monitor suppliers’ performance on issues such as greenhouse gas emissions, they are typically less effective in monitoring human rights violations in the supply chain.
4. Consult and communicate your requirements and plans.
   1. Businesses should communicate and disclose their due diligence steps and report on the actions taken to prevent and mitigate negative impacts to their stakeholders, including recognised trade unions.
5. Implement continuous improvements mechanisms for more effective monitoring.
   1. Ensuring suppliers’ ongoing commitment to freedom of association and collective bargaining requires a process of continuous improvement and monitoring. Provide constructive feedback to suppliers on any changes required to managers’ attitudes and practices.
6. If all fails - discontinue your business relationship with the supplier. If after various attempts at remediation, a supplier is unwilling or unable to comply, companies should end their business relationship with the supplier in question in a responsible manner.