INTERNATIONAL BUSINESS PAGES
whereby companies focus on their
most significant risks. As a result,
companies may not be required to
answer all questions across all sec-
tions, but rather would be directed
to follow-up questions based on
their key risks.Recommendations on public communication
under the OECD Garment Guidance
The enterprise should publicly communicate the following:
a. The enterprise’s RBC policy or policies. The enterprise should likewise
communicate any additional value statements to which the company sub-
scribes (e.g. through participation in sector initiatives, agreements with
trade unions or multi-stakeholder initiatives).Recommendations related to the 6
steps of the due diligence process
b. The enterprise’s due diligence management systems, including how due
diligence is incorporated into decision-making processes and information
management systems to support due diligence.Step 1. Embed Responsible Busi-
ness Conduct in enterprise policy
and management systems
-c. The most significant risks of harm in the enterprise’s own operations and
in its supply chain. The enterprises should likewise explain its processes
for assessing those risks. Where the enterprise has prioritised some risks
of harm for immediate attention, it should justify its prioritisation process.With respect to company policies,
the Higg BRM should strengthen its
evaluation of whether member com-
panies have policy commitments on
human rights, labour and the envi-
ronment and whether these policies
include recommendations under the
OECD Garment Guidance.d. The components of the enterprise’s plan to prevent or mitigate harm in its
own operations and in its supply chain and the effectiveness of those
measures.
e. Where relevant, the enterprise’s intent in policy engagement as well as
the outcomes of the engagement itself.
Step 2. Identify actual and potential
harms in the enterprise’s supply
chain
-
-
-f. The enterprise’s systems to provide access to remediation in its own
operations and its supply chain. Enterprises may also choose to disclose
cases that are brought against the enterprise and how they were resolved.
The Higg BRM should align its use
of the term ‘risk’ with the definition
included in the OECD Garment
Guidance to include risks of harm
to people and the environment but
not to the business itself.
The SAC should strengthen the
Higg BRM’s risk-based approach to
be based on the severity and likeli-
hood of impacts; incorporate the
use of assessment methodologies
that are appropriate to the nature
of the risk, the stage of the supply
chain and reflecting the nature of
the company’s business and sourc-
ing models; and incorporate mech-
anisms to update the company’s
understanding of risk.
The Higg BRM should include an
evaluation of how companies are
assessing their suppliers associat-
ed with more severe risks linked to
their raw material production as well
as mid-stream suppliers, including
those with whom the company
does not have a contractual rela-
tionship. This recognises that the
Facility Environmental Module
(FEM) and the Facility Social &g. How the enterprise engages meaningfully with its stakeholders.
h. If the enterprise is engaging with a sector or multi-stakeholder initiative
for the purposes of collaborating on due diligence and which specific
components the enterprise is collaborating on (e.g. collaboration on iden-
tification of risks, supplier assessments, etc.).
The enterprise should publicly communicate information annually at a mini-
mum. Communication may take a number of forms. However, in all cases,
information should be maintained and communicated in a way that is rele-
vant, accurate, current, clear and user-friendly and enables intended users
to access information. The enterprise is also encouraged to make informa-
tion available in plain language.
Labor Module (FSLM) are only rel-
evant for manufacturing and not cur-
rently applicable to agriculture.developed with meaningful engage-
ment with stakeholders.
-The Higg BRM should strengthen
questions related to purchasing
practices in order to reduce the risk
of subjective responses and align
with existing benchmarks and test-
ed approaches.
-The Higg BRM should evaluate the
actions that the company is taking
itself internally to gain control over
its supply chain. This may include,
for example prequalification of sup-
pliers, moving towards direct sourc-
ing, prequalifying buying agents,
consolidating the number of suppli-Step 3. Cease, prevent or mitigate
harm in the enterprise’s own opera-
tions and in its supply chain
-The Higg BRM should strengthen
its evaluation of the quality of a
company’s formal approach or strat-
egy to prevent or mitigate social and
environmental impacts. Quality
measures include whether the re-
sponse is proportionate to the se-
verity of the impact and appropri-
ate to the nature of the risk and
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