Food and Beverage Compliance Tools
Creating Strong Policies in Food and Beverage Supply Chains
Creating the right policies and procedures provides a foundation for an effective management systems approach to combatting trafficking in your supply chain. Setting clear expectations in contracts and other agreements is an essential first step in changing behavior throughout supply chains, and models expectations for how suppliers should interact with their own suppliers and labor recruiters.
Tool 01: Sample Code of Conduct Provisions for Food and Beverage Supply Chains
A Code of Conduct establishes basic performance expectations for suppliers, contractors, subcontractors, and agents. Your company’s Code of Conduct or sourcing policy should explicitly prohibit human trafficking and lay out protections for workers.
Benchmarks are important for evaluating the labor and human rights performance of suppliers and labor agents; they can be used to demonstrate how anti-trafficking policies should be implemented. The benchmarks in Tool 1A are aligned with relevant guidance from the International Labour Organization, including the Safety and Health in Agriculture Convention (C 184), Plantations Convention (C 110), and the Tenants and Share-croppers Recommendation (R 132).
Tool 1B: Country-Level Review of Legal Protections Against Human Trafficking
Tool 1B provides guiding questions for conducting a country-level legal review of factors relevant to the prevention of human trafficking.
Tool 1C: Evaluating Voluntary Sustainability Systems on Anti-Trafficking Requirements
These voluntary sustainability standards can inform good practice in setting implementation benchmarks. Tool 1C includes guidance on assessing such standards for their relevance to the prevention of forced labor and human trafficking.
Tool 02: Sample Social Responsibility Agreement for Food and Beverage Supply Chains
A Social Responsibility Agreement formally records a subcontractor’s, supplier’s, or agent’s commitment to follow a customer’s Code of Conduct; this commitment is important for establishing accountability expectations for all parties.
Screening and Evaluation in the Food and Beverage Supply Chain
Screening suppliers and labor brokers on a regular basis can hep you assess the level of risk in your supply chains and determine robust responses to right any wrongs in business practices that may be facilitating human trafficking.
Tool 03: Supply Chain Mapping and Risk Assessment in the Food and Beverage Sector
Tool 03 guides you through mapping food and beverage product and labor supply chains and explains potential risks associated with each stage. Because your supply chain for each product will be unique, supply chain mapping should be conducted on a product-by-product basis.
Tool 04: Sample Food and Beverage Supplier/Subcontractor Self-Assessment
A supplier/subcontractor self-assessment questionnaire (SAQ) allows your company to gain preliminary insight into potential human trafficking risks in how a supplier recruits, selects, and hires workers, how it works with labor brokers, and how migrant workers are managed. An Appendix with interpretive guidance for company use is provided.
Tool 05 provides guidance on how to screen and evaluate labor recruiters, with special considerations for informal labor recruitment in order to establish reasonable confidence in their ability and willingness to comply with applicable legal requirements and your company’s ethical recruitment standards.
Tool 06: Monitoring the Performance of Labor Recruiters in Food and Beverage Supply Chains
After engaging a labor recruiter, regular monitoring of the recruiter’s performance against the company Code of Conduct and legal requirements is essential to help ensure ongoing compliance.
Tool 07: Conducting Migrant Worker Interviews
Compliance efforts, including those related to monitoring the behavior of suppliers and labor recruiters, must put worker input at their core. Carefully and ethically gathering information from migrant workers through interviews and other mechanisms can help identify instances and parameters of instances of abuse.
Tool 08 introduces and describes multiple models and frames for worker engagement, including examples of workplace communication, worker organization, and effective grievance mechanism.
Compliance Management in Food and Beverage Supply Chains
A continual improvement system is essential for fighting human trafficking in supply chains. Your company should establish and maintain a system based on systematic and on-going risk identification, solution implementation, and performance monitoring. The tools in this section help ensure continual compliance with the policies and management systems outlined above.
Tool 09: Role of Traders in Addressing Human Trafficking in Food and Beverage Supply Chains
Tool 09 explains the role traders play in food and beverage sector supply chains and highlights the importance of their involvement in ensuring compliance.
Tool 10: Sample Food and Beverage Supply Chain Assurance Program
Tool 10 describes the fundamental systems approach to risk management, known as “Identify, Evaluate, Control, and Monitor.” It provides underlying principles to follow when implementing a process for identifying human trafficking and executing solutions.
Tool 11: Food and Beverage Sector Compliance Plan Template
Tool 11 is intended for use specifically by companies that must demonstrate compliance with the Combating Trafficking in Persons requirements of the Federal Acquisition Regulation (FAR).
Additional Resources
PDF: Combating Human Trafficking in Food and Beverage Supply Chains Presentation
Webinar: Combating Human Trafficking in Food and Beverage Supply Chains
