Private Security Compliance Tools
Introduction to Private Security Compliance Tools
Creating Strong Policies in Private Security 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
A Code of Conduct establishes basic performance expectations for subcontractors, suppliers, and labor agents. Codes of Conduct and/or other sourcing policies should explicitly prohibit human trafficking and include protections for workers.
Benchmarks can be used to evaluate the labor and human rights performance of subcontractors, suppliers, and labor agents. The benchmarks included in this tool can help evaluate the implementation of the anti-trafficking policies laid out in Tool 01.
Tool 02: Sample Social Responsibility Agreement for Subcontractors and Suppliers
A Social Responsibility Agreement formally records a subcontractor’s, supplier’s, or labor 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 Private Security Supply Chains
Screening subcontractors, suppliers, and labor brokers on a regular basis can help 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: Country-Level Review of Legal Protections Against Human Trafficking
Tool 03 provides guiding questions for conducting a country-level legal review of factors relevant to the prevention of human trafficking, with special consideration paid to relevant international standards.
Tool 04: Labor Supply Chain Mapping and Initial Risk Screening
Tool 04 presents a guide for mapping labor supply chains in the private security industry and explains potential risks associated with different types of worksites and stages of recruitment.
Tool 05: Criteria for Screening and Evaluating Labor Recruiters
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: Sample Subcontractor/Supplier Self-Assessment
Tool 06 provides a sample subcontractor/supplier self-assessment questionnaire (SAQ) that will allow companies to gain preliminary insight into potential human trafficking risks regarding how subcontractors or suppliers recruit, select, and hire workers, how they work with labor brokers, and how migrant workers are managed. This tool also offers an appendix with interpretive guidance.
Tool 07: Monitoring the Performance of Labor Recruiters
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 provides a set of criteria that can be used in the ongoing monitoring process.
Tool 08: Guide to Conducting Migrant Worker Interviews
Compliance efforts, including those related to monitoring the behavior of contractors, 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 parameters of instances of abuse. Tool 08 provides a guide to conducting interviews with migrant workers and other personnel.
Compliance Management in Private Security 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 that management systems will support continual compliance with the policies and best practices outlined in other tools.
Tool 09: Sample Security Personnel Staffing Due Diligence Program
Tool 09 describes the fundamental systems approach to risk management, known as “Identify, Evaluate, Control, and Monitor,” and provides the underlying principles to follow when implementing a process for identifying human trafficking and developing solutions.
Tool 10: Compliance Plan Template
Tool 10 is intended for use specifically by companies that must demonstrate compliance with the requirements of the U.S. Federal Acquisition Regulation (FAR): Combating Trafficking in Persons.
Additional Resources
Private Security Industry Tools Launch Webinar
Private Security Industry Tools Presentation Deck
Managing Ethical Recruitment from East Africa to the Gulf States Webinar
