What Companies Must Do to Comply
Businesses have 36 months to build robust due diligence systems that map supply chains, monitor suppliers, maintain documentation, and implement remediation plans.
Companies will have 36 months to perform comprehensive due diligence on their supply chains, ensuring that they have identified and assessed any risks of forced labor. They need to establish robust procedures for mapping and maintaining transparency across their supply chains, including detailed records of their suppliers and the labor practices involved. Companies must also implement regular monitoring mechanisms to ensure ongoing compliance with the regulation.
Key compliance steps include conducting thorough supply chain monitoring and mitigation beyond tier-one direct suppliers, ensuring product traceability back to the primary extractives level, maintaining records of supplier progress, utilizing independent risk monitoring through third-party verification, and having remediation protocols to address violations anywhere in the supply chain. Additionally, businesses should have remediation plans in place to address any instances of forced labor and be prepared to maintain and submit documentation of their compliance efforts to regulatory authorities.
In cases where forced labor is identified, companies are required to take immediate action to rectify the situation. This includes developing and implementing remediation plans in collaboration with affected workers and relevant stakeholders. Remediation efforts should aim to eliminate forced labor practices and provide support to impacted workers. Companies with complex supply chains or those sourcing from high-risk regions are especially expected to implement robust due diligence processes to ensure their products are free from forced labor at any stage of production or distribution.