Master OECD Due Diligence
Master OECD Due Diligence: Comprehensive Evidence Trail for All 6 Steps with Brand Supply Chain Management.
Effectively implementing the OECD Due Diligence Guidance for Responsible Business Conduct requires a robust evidence trail across all six steps, with particular emphasis on thorough risk assessments and effective mitigation strategies. Brand Supply Chain Management is engineered to help you centralize, organize, and present this evidence, demonstrating your commitment to identifying, preventing, and addressing adverse impacts in your operations and supply chains.
Feature Deep Dive: How Brand Supply Chain Management Empowers Your OECD Due Diligence
Embed Responsible Business Conduct (RBC) into Policies & Management Systems – Your Foundational Evidence:
The OECD Guidance starts with integrating RBC into company policies and management systems, establishing the framework for due diligence.
How Brand Supply Chain Management Helps:
- Centralized Policy Hub: Store and disseminate your RBC policies, supplier codes of conduct (aligned with OECD recommendations and relevant international standards), and statements of commitment from senior management.
- Role & Responsibility Mapping: Document roles and responsibilities for overseeing and implementing due diligence processes within your organization.
- Training Record Management: Track employee and supplier training on RBC policies, due diligence procedures, and specific risk areas (e.g., human rights, environment, anti-corruption).
Benefit Bullets for OECD Step 1:
- Clearly document your company’s commitment to RBC.
- Provide evidence of established management systems to support due diligence.
- Ensure policies are accessible and communicated throughout the organization and to relevant business relationships.
Identify & Assess Adverse Impacts in Operations, Supply Chains & Business Relationships – Crucial Risk Assessment Evidence:
This step involves mapping your supply chain, identifying areas of potential risk, and assessing the likelihood and severity of actual and potential adverse impacts. This is a cornerstone of the risk assessment process.
How Brand Supply Chain Management Helps:
- Value Chain Mapping & Visualization: Document and map your operations, supply chains (multi-tier), and other business relationships to understand where impacts may occur.
- Risk Identification & Prioritization Tools: Log results of risk assessments based on geography, sector, specific products/services, supplier profiles, or known industry issues. Capture inherent and residual risk scores.
- Supplier Self-Assessment Questionnaires (SAQs) & Audits: Deploy, collect, and analyze SAQs and track results of on-site or desktop audits, focusing on OECD-relevant risks (human rights, labor, environment, bribery, consumer interests).
- Stakeholder Engagement Records: Document consultations with potentially affected stakeholders or experts to inform your risk identification and assessment processes.
Benefit Bullets for OECD Step 2:
- Create a robust evidence trail for your risk identification and assessment processes.
- Demonstrate a risk-based approach to prioritizing due diligence efforts.
- Provide clear insights into where actual and potential adverse impacts lie within your value chain.
Cease, Prevent, or Mitigate Adverse Impacts – Demonstrating Effective Mitigation:
Based on risk assessment findings, companies must take action to cease activities causing harm, prevent potential harm, and mitigate impacts that cannot be immediately prevented or ceased. This is key for mitigation evidence.
How Brand Supply Chain Management Helps:
- Corrective and Preventive Action (CAPA) Management: Develop, assign, track, and verify the implementation of CAPAs with suppliers or internal operations to address identified adverse impacts or risks.
- Preventive Action Plan (PAP) Management: Document strategies and actions to prevent potential future impacts.
- Leverage & Disengagement Protocols: Record efforts to use or build leverage with business relationships to drive improvements, and document decisions regarding suspension or termination of relationships if impacts are severe and cannot be mitigated.
- Contractual Clause Management: Store and manage supplier contracts that include RBC expectations and requirements for cooperation in due diligence and mitigation.
Benefit Bullets for OECD Step 3:
- Provide clear, actionable evidence of your efforts to cease, prevent, and mitigate adverse impacts.
- Document the use of leverage and decision-making processes regarding business relationships.
- Showcase a systematic approach to risk mitigation and impact management.
Track Implementation & Results – Verifying Effectiveness:
Due diligence is an ongoing process. This step involves tracking the implementation and effectiveness of measures taken to address adverse impacts.
How Brand Supply Chain Management Helps:
- Performance Monitoring Dashboards: Monitor the progress of CAPAs, PAPs, and overall due diligence performance against set targets or KPIs.
- Audit Trail of Actions: Maintain a comprehensive log of all due diligence activities, decisions made, and actions taken, providing a historical record.
Effectiveness Review Documentation: Record periodic reviews of the effectiveness of your due diligence processes and mitigation measures, noting lessons learned and adjustments made.
Benefit Bullets for OECD Step 4:
- Demonstrate that due diligence is an ongoing and iterative process.
- Provide evidence that you are tracking the effectiveness of your actions.
- Support continuous improvement of your RBC management systems.
Communicate How Impacts are Addressed – Transparency & Accountability:
Companies should communicate externally on their due diligence policies, processes, and activities, including identified risks and how they are being addressed.
How Brand Supply Chain Management Helps:
- Report Generation Support: Compile data and evidence from the system to support the preparation of public reports (e.g., sustainability reports, modern slavery statements) aligned with OECD Guidance.
- Stakeholder Communication Log: Document communications with relevant stakeholders regarding identified impacts and mitigation efforts.
- Grievance Mechanism Records (see below) contribute to transparency.
Benefit Bullets for OECD Step 5:
- Facilitate transparent reporting on your due diligence efforts.
- Provide stakeholders with credible information on how you manage RBC risks.
- Build trust and accountability through clear communication.
Provide for or Cooperate in Remediation – Addressing Harm:
Where the enterprise identifies it has caused or contributed to an adverse impact, it should provide for or cooperate in legitimate remediation processes.
How Brand Supply Chain Management Helps:
- Remediation Case Management: Track specific instances requiring remediation, document the process undertaken (e.g., investigation, consultation, remedy offered/provided), and record outcomes.
- Grievance Mechanism Integration: Link grievance records that lead to remediation directly to the remediation case files, ensuring a complete evidence trail.
- Documentation of Collaborative Remediation: If cooperating with other entities in remediation, document the nature and extent of your cooperation.
Benefit Bullets for OECD Step 6:
- Document your commitment and process for providing or cooperating in remediation.
- Ensure a fair and transparent approach when harm has occurred.
- Demonstrate adherence to a critical component of responsible business conduct.
Cross-Cutting: Grievance Mechanisms & Stakeholder Engagement (Integral to all Steps):
The OECD Guidance emphasizes the importance of operational-level grievance mechanisms and ongoing stakeholder engagement.
How Brand Supply Chain Management Helps:
- Grievance Record Management: Securely log, track, investigate, and document the resolution of grievances from workers, communities, or other stakeholders.
- Stakeholder Engagement Module: Plan, record, and track engagement activities with various stakeholders, capturing feedback and how it informs your due diligence.
Benefit for OECD Compliance:
- Evidence a functional and accessible grievance mechanism.
- Demonstrate that stakeholder perspectives are integrated into your due diligence process.
Leveraging Your OECD Due Diligence Evidence Trail:
Brand Supply Chain Management allows you to compile evidence thematically or by OECD step into tailored packs for:
- Responding to inquiries from National Contact Points (NCPs).
- Informing discussions with investors, business partners, and civil society.
- Internal audits and management reviews.
Benefit: Significantly streamline the process of demonstrating adherence to the OECD Due Diligence Guidance, build a robust and defensible evidence trail (especially for risk assessments and mitigation), and confidently showcase your company’s responsible business practices.