Module 1: General Due Diligence Management

This module helps you to develop Due Diligence Management for Responsible Business Conduct (RBC). Due Diligence Management aims to avoid and/or address adverse impacts related to workers, human rights, the environment, bribery, consumers and corporate governance that may be associated with your own operations, supply chains and other business relationships.

Implementation of Due Diligence Management will be a huge step towards meeting the expectations and requirements of the ICSR covenant signed by KNSV on behalf of its members.

The guidelines presented in this module are based on the OECD Due Diligence Guidance for Responsible Business Conduct (RBC) and are illustrated in the following figure:

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The guidelines also draw from the OECD-FAO Guidance for Responsible Agricultural Supply Chains.

  • It is recommended that you also consult these background documents for additional and more detailed information.

  • In some cases it may be more effective and efficient to cooperate with others (e.g., other KNSV members, clients and/or suppliers, possibly in the context of the Sustainable Spices Initiative, SSI) to implement Due Diligence Management (e.g., for the development of policies and management systems, the execution of risk assessments and the implementation of risk management plans). In most cases you can establish such cooperation without risking breaching competition law. However, it is recommended that you fully understand competition law issues in your jurisdiction and avoid activities which could be seen as breach of competition law before such collaborative initiatives are actually implemented.

  • Please consult Module 2 of this toolkit for more information on due diligence specifically regarding child labour.

The general objective of due diligence is “to identify, assess, mitigate, prevent and account for actual adverse impacts and potential adverse impacts (risks) of a company’s own operations, supply chains and other business relationships”.

Due diligence concerns impacts related to human rights (including for workers and industrial relations), the environment, bribery and corruption, disclosure, and consumer interests (topics taken from the OECD Guidelines for Multinational Enterprises). A company’s responsibility to act varies by the nature of its relationship with the impacts. See also ‘What is Your Responsibility?’ in the introductory section of this toolkit.

  • Note that when talking about risks in this context, the focus should be primarily on risks to people, the environment and/or society (external risks), not primarily (internal) business risks! However, internal and external risks are often interdependent, with external harm coupled with reputational damage or exposure to legal liability.

    This implies that in the case of an adverse impact, the decision to
    discontinue operations or business relationships should only be taken as a last resort, only if the risk of an adverse impact is too high or because mitigation efforts have not been successful.

In general, when following the due diligence process, you must ask yourself the following questions:

  • How do I embed due diligence in my management processes and monitoring systems?
  • What and where do I produce? (mapping your supply chain)
  • What are RBC issues and the risks of adverse impacts related to my supply chains? (not only first tier suppliers!)
  • What is my relation to risks of possible adverse impacts?
  • How do I deal with these risks?
  • How do I assess whether my measures lead to improvement of the situation?
  • How can I be transparent about my activities?


Core characteristics of due diligence:

  • Consider all business relationships. Due diligence involves all types of business relationships linked to the company, including suppliers (not only first tier suppliers), contractors, joint ventures, investors and clients.

  • Do not treat it as an isolated exercise. Due diligence should be an integral part of decision-making and risk management. It must be on-going, responsive, iterative and include feedback loops so that the company can learn from what has worked and what has not.

  • Tailor it to your company. Due diligence may be tailored to a company’s circumstances. For example, to manage risks, large companies may need more formalised and extensive systems than smaller ones do. On the other hand, small companies may have limited market power to influence their business relationships and they may want to increase their leverage through collaboration with others.

  • Prioritise if necessary. If it is not feasible to address all identified impacts at once, a company should prioritise the order in which it takes action based on the severity and likelihood of the adverse impact. For example, in the case of risks to human rights, the severity of the potential adverse impact and whether a delayed response would make the impact irremediable must determine the action’s priority.

  • Apply internationally recognised RBC standards. The due diligence process is based on the OECD Guidelines for Multinational Enterprises. These Guidelines provide principles and standards of RBC consistent with applicable laws and internationally recognised standards. Where national law conflicts with international standards, companies are expected to explore ways to honour the principles of the relevant international standards.

  • Engage with stakeholders. Due diligence includes engagement with stakeholders (stakeholders are persons or groups who have interests that could be affected by an enterprise’s activities).

  • Be transparent. Communicate externally about your due diligence processes, findings and plans.

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In the first step of your Due Diligence Management process, you develop and articulate policies for responsible business conduct (RBC) with regard to your company’s own operations, supply chains and other business relationships.

  • When composing or reviewing and updating your RBC policies consider using policies developed by others.
    You may also want to use this tool Potential General RBC Themes as a source of inspiration. This tool is based on elements of the model for RBC presented in the OECD-FAO Guidance for Responsible Agricultural Supply Chains. Note that this model is to a large extent designed for companies operating themselves in countries with high RBC-related risks. Many KNSV members are, however, only linked to such regions through their supply chains. If your company does not operate directly in these regions, all themes may not be equally relevant. Consider rephrasing certain RBC requirements to tailor them to your company’s characteristics (e.g., expressing that supply chains must comply with the requirements). Make sure that when prioritising RBC issues, risks for potential victims of the company’s direct and indirect operations should prevail, not business risks!

     

  • For communication purposes consider framing your RBC policies in the context of the Sustainable Development Goals (SDGs), possibly in addition to the above. To further strengthen this, consider signing the SDG Charter. The focus of the SDGs is on realising positive impacts (doing good), but please be aware that in the context of due diligence you should at least concentrate on not causing harm!

  • Make sure your RBC policies are endorsed by the company’s CEO.

  • Consider including the fact the company is devoted to RBC with regard to its own operations, supply chains and other business relationships in the company’s mission statement.

  • Develop and implement procedures for periodic and systematic evaluation of these RBC policies and consider embedding them in your management systems. To facilitate measurable evaluation, define output and outcome indicators for the new policies.

  • Consider registering the company’s RBC achievements with Ecovadis, SEDEX or similar initiatives. These are increasingly used in the marketplace.

  • Make one person or team responsible for the practical implementation, monitoring and evaluation of the RBC policies (RBC coordinator). This coordinator should participate in regular meetings with the CEO and managers of departments. Add RBC as a fixed topic on the agenda of internal management meetings.

  • Clearly communicate your RBC policies with stakeholders. Make them publicly available, on your website, for example.

  • Develop a strategy for internal communication on RBC policies, including SMART communication objectives, target groups and tailored approach.

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In the second step of your Due Diligence Management process you embed RBC policies in your company’s management systems to make sure that these policies become part of your regular business processes.

  • Consider implementing the ISO 20400 guidance standards for Sustainable Procurement. This standard can be used to systematically incorporate recommended due diligence measures in management procedures. Alternatively, if relevant, and to the extent possible, make due diligence measures part of existing management systems (e.g., ISO 9001, BRC Food, FSSC 22000, ISO 14.001).

  • Assign responsibility for implementing aspects of the RBC policies across relevant departments within the company. Pay particular attention to workers whose actions and decisions are most likely to influence risks to adverse impacts.

  • Make sure that there are adequate communication channels between the RBC coordinator and implementing departments for sharing and documenting information on risk and decision-making and to discuss RBC-related dilemmas.

  • Develop or adapt existing record keeping systems to collect information on due diligence processes, and related decision-making and responses. For example, a vendor rating system in which suppliers’ RBC performance is systematically recorded (including a provision for possible agreements on mitigating measures) could be used. Also generate data about reserve or potential suppliers that may be needed in case of emergency procurement. Make sure such record keeping is compliant with EU regulations on the protection of privacy.

  • Develop a supplier code of conduct based on your RBC policies and let this be signed by current and future suppliers. Use codes developed by other companies as a source of inspiration, such as the OLAM Code of Conduct. Make clear how compliance with the code will be monitored and what the consequences of non-compliance will be. As much as possible explain the background, scope and contents of the code during personal conversations. If suppliers are not fully fluent in English, consider having this code translated into local languages. Try to avoid contract-language and do not try to seek liability or product recall indemnity. Excessive risk transfer to the supplier can have unintended consequences like the supplier’s choice to avoid sourcing from ‘difficult’ origins altogether. This could further aggravate the situation of local workers, communities and others.

  • Also add your company’s RBC requirements to the general purchasing conditions, purchase contracts/orders, product specifications and possible supplier self-audit questionnaires.

  • Explicitly include in the supplier code of conduct, purchasing conditions, purchase contracts/orders, product specifications and possible supplier self-audit questionnaires the expectation that first tier suppliers, as far as is reasonable, also conduct due diligence among their suppliers. Also include the expectation that suppliers are supposed to implement mitigating measures if violations are encountered (possibly in cooperation with your company). Written evidence of such due diligence must be provided to you and you should register this in your record keeping system.

  • Make the supplier code of conduct and (adjusted) purchasing conditions publicly available, for example, by publishing it on your website.

  • Consider encouraging suppliers to register their RBC performance with Ecovadis, SEDEX or similar initiatives.

  • Develop a template for supplier visit reports, including a section on supplier’s RBC performance. Use this information as input for your record keeping system.

  • Develop clear instructions and give training for procurement staff and other relevant workers on how to deal with due diligence, including the role of the supplier code of conduct, the purchasing conditions, product specifications and possible supplier self-audit questionnaires.

  • Develop incentives for workers and business units to actually apply due diligence. Consider assessing RBC-related key performance indicators (KPIs) for procurement staff and other relevant workers (possibly included in balanced scorecards). This could, for example, cover the number of suppliers conducting due diligence in their supply chains and/or the number of suppliers registered in systems such as Ecovadis or SEDEX. Explicitly address compliance with such KPIs in performance and assessment evaluations and consider linking this performance to salary increases and/or bonuses.

  • Include RBC expertise and/or evident RBC engagement as an explicit selection criterion in the recruitment processes for procurement staff and other relevant workers.

  • Address barriers arising from your company’s way of doing business that may make it more difficult for your suppliers and other business relationships to implement RBC policies (such as your purchasing practices and commercial incentives). For example, make sure that current bonuses for procurement staff and other workers do not frustrate procurement of sustainable spices.

  • If possible, reduce the number of suppliers and aim to establish long-term/permanent relationships with suppliers to address RBC challenges. Consider establishing an MOU with some long-term strategic suppliers confirming the ambition to conduct due diligence in supply chains, including implementation of any necessary mitigating measures.

  • Consider providing due diligence guidelines or training to direct suppliers. This may take place in the context of audits. If known, consider cooperating with other clients of these suppliers (e.g., within the context of the ICSR covenant and/or the Sustainable Spices Initiative (SSI)

  • Consider earmarking an annual budget to further RBC. Explicitly link decisions on the way this budget will be spent to priority actions identified by RBC risk assessment (see Step 4 of this due diligence document).

  • In the case of mergers / acquisitions, make sure to also include the RBC performance of the potential partner company in decision-making processes.

 

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In the third step of your Due Diligence Management process you consider developing a grievance mechanism that allows employees, suppliers, clients, local communities and other stakeholders to voice concerns about RBC issues. Examples include providing contact information for a company’s ombudsman, supplier relationship contacts, department contacts or a company’s ethics hotline. A collaborative grievance mechanism at the level of KNSV or the Sustainable Spices Initiative may be possible as well.

  • An effective grievance mechanism has the following characteristics:

    • Legitimate Enables trust from the stakeholder groups for whose use it is intended, and is accountable for the fair conduct of grievance processes.
    • Accessible Is known to all stakeholder groups for whose use it is intended, and provides adequate assistance for those who may face particular barriers to access.
    • Predictable Provides a clear and known procedure with an indicative time frame for each stage, and clarity on the types of process and outcome available and means of monitoring implementation.
    • Equitable Seeks to ensure that aggrieved parties have reasonable access to sources of information, advice and expertise necessary to engage in a grievance process on fair, informed and respectful terms.
    • Transparent Keeps parties to a grievance informed about its progress, and provides sufficient information about the mechanism’s performance to build confidence in its effectiveness and meet any public interest at stake.
    • Rights-compatible Ensures that outcomes and remedies are in accord with internationally recognised human rights.
    • A source of continuous learning Draws on relevant measures to identify lessons for improving the mechanism and preventing future grievances and harms.
    • Based on engagement and dialogue Consults the stakeholder groups for whose use it is intended on its design and performance, and focuses on dialogue as the means to address and resolve grievances.

  • If your company engages directly with farmers (e.g., in the context of projects) always make an effort to inform them about the existence of a grievance mechanism. Tailor your communication to the culture and capacities of the local communities. Note that if it concerns indigenous peoples specific guidelines must be considered (see annex B of OECD-FAO Guidance for Responsible Agricultural Supply Chains).

  • Encourage first tier suppliers to also set up a grievance mechanism that is open to farmers and other stakeholders. Stress that such a grievance mechanism may enable them to effectively obtain information for their own due diligence. Consider including this in the suppliers code of conduct and possible self-audit questionnaire.

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In the fourth step of your Due Diligence Management process you identify, assess and prioritise actual and potential adverse impacts associated with your operations, supply chains and other business relationships. In general, please note that it may take sometimes years of engagement and propagation of expectations through several tiers of the supply chain before the information on RBC issues and risks returned to you can be considered accurate and complete. However, what is most important is not that the information is completed immediately, but that the completeness of information improves over time!

  • Start with a Quick Scan to identify all business areas, including supply chains, where RBC risks are most likely and most significant. You may want to make use of a so-called heat map linking various RBC risks with various supply chains. You may also want to focus on priority or strategic suppliers first, recognising that obtaining adequate information from all suppliers may be time-consuming. Sources of information include reports from governments, international organisations, independent auditors, civil society organisations, workers' representatives and trade unions, National Human Rights institutions, media or other experts. Based on this Quick Scan identify the most significant red flag RBC-related risk areas and prioritise these as the starting point for a deeper assessment of potential and actual impacts (see below). Review the findings on a regular basis and make updates whenever your company makes significant changes.

  • Systematically monitor RBC related requirements and expectations of direct and indirect clients. Include these topics in the format of visit reports. Make sure sales people fill these in and report back to the RBC coordinator. Also include the company’s RBC performance as an item in client satisfaction surveys. Ask clients for suggestions for improvement. Consider including such input from clients in your assessment of red flags.

  • Subsequently, starting with the red flag RBC related-risks identified in the Quick Scan, carry out more in-depth assessments of prioritised operations, suppliers and other business relationships in order to identify and assess specific actual and potential adverse RBC impacts. Map supply chains relevant to the prioritised risk, if necessary also beyond first tier suppliers! Also include spices sourced from reserve or potential suppliers in this risk assessment approach. Review the findings on a regular basis and make updates whenever your company makes significant changes. Consider cooperating with others to conduct these in-depth analyses (for example within the context of the Sustainable Spices Initiative).

  • Consider cooperating with globally active NGOs specialised in RBC risks related to spice supply chains. Ask them to actively inform you if RBC risks in spice supply chains are encountered. In addition, periodically contact these NGOs yourself to identify possible new RBC issues and to validate findings of your own risk assessments and risk management plans (see Step 5 of the Due Diligence Management process).

  • As part of your in-depth analyses, monitor international RBC initiatives related to spice supply chains. If your supply chains/suppliers explicitly endorse and/or are audited by such initiatives, all or part of the RBC risks may be sufficiently addressed. These initiatives include:

  • Consider using the following practical tips to obtain RBC information from your suppliers:

    • Engage suppliers through in-person meetings and phone calls rather than by email.
    • Allocate longer lead times for suppliers to respond to data requests.
    • Increase the priority given to responses by escalating to senior procurement staff.
    • Use a third party to conduct regular and timely follow-ups with suppliers.
    • Create a yearly supplier excellence award for suppliers that are able and willing to provide requested data.
    • Use financial incentives (e.g., pre-finance of orders, shorter payment periods).
    • Collaborate with your customers to collect information from suppliers.
    • Consider terminating business relationships if information is not provided.
    • Work with supplier associations to help facilitate data transfer from their members.

  • Consider spot checks of the information provided by suppliers to assess the information they have provided (e.g., desk review, site visits or audits).
  • Assess your company’s involvement with the actual or potential adverse impacts identified in order to determine your responsibility to act. Specifically, assess whether the company: caused (or would cause) the adverse impact, contributed (or would contribute) to the adverse impact or whether the adverse impact is (or would be) linked to its operations, products or services by a business relationship. See also ‘What is Your Responsibility?' in the introductory section of this toolkit.

  • Based on the information obtained on actual and potential adverse impacts, prioritise the most significant RBC risks and impacts for action, where necessary. In general, prioritisation must be based on severity and likelihood of adverse impacts. Give priority to potential or actual impacts that may be addressed immediately and to activities that are causing or contributing to adverse impacts. Prioritisation will be relevant where it is not possible to address all potential and actual adverse impacts immediately. Once the most significant impacts are identified and dealt with, the company should move on to address less significant impacts.

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In the fifth step of your Due Diligence Management process you develop and implement risk management plans to cease, prevent and mitigate adverse impacts.

  • Consider using the following format for a Risk Mitigation Plan

  • If you are causing or contributing to adverse impacts, develop and implement plans to stop related activities and to prevent and mitigate potential (future) adverse impacts. Consult and engage with stakeholders to identify appropriate actions. Update your RBC policies to provide guidance on how to avoid and address the adverse impacts in the future and ensure implementation thereof. If necessary also update and strengthen relevant management systems.

  • If you are linked to adverse actual or potential impacts, develop and implement plans to prevent or mitigate these. Support or collaborate with relevant business relationships in developing such plans. If your company does not have sufficient influence to prompt business relationship(s) to prevent or mitigate adverse impacts or risks, consider ways to build additional leverage with the business relationship (e.g., through commercial incentives) or through cooperation with others (e.g., KNSV and other KNSV members, in the context of the Sustainable Spices Initiative or through engagement with governments). Appropriate responses to risks associated with impacts linked to business relationships may include:
    • continuation of the relationship throughout the course of risk mitigation efforts,
    • temporary suspension of the relationship while pursuing on-going risk mitigation or
    • as a last resort, disengagement with the business relationship, after either failed attempts at mitigation, or where the company considers mitigation not feasible, or because of the severity of the adverse impact. A decision to disengage should take into account potential adverse social and economic impacts.

  • Consider procuring certified spices or procuring from specific sustainability initiatives (see overview in Step 4: Assess Adverse Impacts of this module on Due Diligence Management).

  • Make sure that risk management plans are measurable, and that they include clear output and outcome indicators, in order to facilitate Monitoring and Evaluation (see Step 6 of Due Diligence Management).

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In the sixth step of your Due Diligence Management process you track the implementation and results of your due diligence activities.

  • Carry out periodic internal or third party reviews or audits to check if your plans and policies are effective. Communicate results at the relevant levels within your company. Also carry out periodic assessments of business relationships to verify that risk mitigation measures are being pursued or to validate that adverse impacts have actually been prevented or mitigated. Consider cooperating with others to conduct such periodic verification activities (for example within the context of the Sustainable Spices Initiative).

  • After implementation of a risk management plan, continue to conduct due diligence for the specific supply chain, even after the problem has been solved (the frequency of due diligence may be reduced when the problem has been proven not to have occurred for a long period). Consider cooperating with others to conduct such periodic verification activities. If the problem proves not to have been solved, develop and implement a new risk management plan.

  • Identify adverse impacts or risks that may have been overlooked in past due diligence processes and include these in the future.

  • Include lessons learned into your company’s Due Diligence Management process in order to improve the process and outcomes in the future.

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In the seventh step of your Due Diligence Management process you communicate externally relevant information on your due diligence efforts.

  • Develop a strategy for external communication including SMART communication objectives, target groups and a tailored approach. Make sure you are reaching the right stakeholders in a manner that is effective and that fits your company.

  • Publicly report relevant information on due diligence processes through, for example, your company’s annual sustainability or corporate responsibility reports or other appropriate forms of disclosure. Include RBC policies, information on measures taken to embed RBC into policies and management systems, the company’s identified areas of significant risks, the significant adverse impacts or risks identified, prioritised and assessed, as well as the prioritisation criteria and the actions taken to prevent or mitigate those risks. Also include, where possible, estimated timelines and benchmarks for improvement and their outcomes, measures to track implementation and results and the company’s provision of or cooperation in any remediation. Consider using the UN Guiding Principles Reporting Framework for guidance.

  • Publish this information in a way that is easily accessible and appropriate, for example, on your company’s website.

  • Communication should be carried out with due regard for commercial confidentiality and other competitive or security concerns.

  • Consider developing and implementing training for marketers and sales people on the company’s efforts in the area of RBC. Make clear why RBC is commercially relevant for specific client groups and make sure sales people systematically discuss with clients the possibility of using certified spices (e.g., Rainforest Alliance, Organic, Fairtrade, Fairwild).

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The eighth step of Due Diligence Management process is only applicable if you have identified that you cause or contribute to adverse impacts. You must then provide for or cooperate with remediation.

  • Try to restore the affected person(s) to the situation they would have been in had the adverse impact not occurred (where possible) and enable remediation that is proportionate to the significance and scale of the adverse impact. Comply with the law and identify international guidelines on remediation where available. Where such standards or guidelines are not available, consider a remedy that would be consistent with what has been provided in similar cases.

  • Engagement of stakeholders is particularly important if you are causing or contributing to adverse impacts. Stakeholders could be affected workers and communities or their representatives, intermediary organisations such as NGOs, trade unions and local governments and RBC experts. Stakeholder engagement is important to fully understand the perspectives of those who are or may be affected, to improve the quality of analysis of impacts and to prioritise and adequately manage impacts. Effective stakeholder engagement must include the right persons, address the right issues and be performed in the right way and at the right time.

  • When appropriate, provide for or cooperate with legitimate remediation mechanisms through which impacted stakeholders can raise complaints: operational-level grievance mechanism.

 

If your company is relatively small, the general principles for Due Diligence Management as described in this toolkit still apply. However, having said that, the OECD guidelines and other international principles acknowledge that due diligence should be tailored to the company’s circumstances, including its size. What does that mean?

  • In the first place, Due Diligence Management may be even easier if you are small. You may have more informal (and intensive) relationships with your workers, suppliers and other business relationships, your management systems may be more straightforward and therefore easier to adjust and decisions may be easier and faster to take. If you are small your main challenges will be (1) to devote sufficient time to set up and maintain Due Diligence Management and (2) to exert influence if there are adverse impacts.

  • The time investment needed for the development of RBC policies and management systems, Steps 1 and 2 of this module, should not be exaggerated. In most cases, it is mainly a matter of using examples developed by others and adding new attention points to existing management structures and documents, but this still takes significant time. It may be an idea to link up with other companies and develop such policies and management systems together. Another idea could be asking an intern/student to help you. This person could also help to conduct the Quick Scan, your first step in identifying RBC risks related to your operations, supply chains and other business relationships.

  • With regard to the other steps of your Due Diligence Management process it may be wise to seek cooperation with others (e.g., other KNSV members, suppliers, customers). Items to consider:
    • a sector-based grievance mechanism;
    • development and execution of sector-tailored training on RBC and due diligence;
    • execution of in-depth analyses to identify and assess RBC risks;
    • development and maintenance of a sector-based database on RBC related issues and risks;
    • execution of stakeholder engagement;
    • development and implementation of risk mitigating plans, including tracking of effectiveness thereof;
    • sector-based communication.

    Cooperation can enable sharing time investment, possible costs, information and expertise. Moreover, through cooperation you can increase your influence (leverage) in order to make an actual impact. The KNSV and/or the Sustainable Spices Initiative may be the right platform for such cooperation.

  • Other practical tips for small companies, partly based on the Guidance tool for Companies “Doing Business with Respect for Human Rights”:
    • Start your activities with a focus on a limited number of products and/or RBC-topics (e.g., child labour, see Module 2 of this toolkit).
    • Use the right moments to address RBC issues with suppliers and other business relationships (e.g., contract negotiation or renewal, setting RBC qualification criteria for bidding processes, disbursement of funds, monitoring and auditing processes, provision of technical or advisory assistance, processes for investigating complaints).
    • If possible, minimise your number of suppliers and try to establish long-term cooperation with one or two of the most strategic ones to work on RBC challenges.
    • Make use of training on RBC and due diligence offered by third parties (if this cannot be arranged within the sector). For example, ISO 20400 training on Sustainable Procurement offered by NEVI.
    • You may want to communicate about your RBC achievements, not necessarily report about them. Direct communication with workers and suppliers and inclusion of relevant information in existing information channels (e.g., annual reports, customer information) may be more appropriate. If you do want to report formally, consider only answering the eight overarching questions of the UN Guiding Principles Reporting Framework.

FAO = Food and Agricultural Organisation

(I)CSR = (International) Corporate Social Responsibility

ILO = International Labour Organisation

KNSV = Koninklijke Nederlandse Specerijen Vereniging (Royal Dutch Spice Association)

NEVI = Nederlandse Vereniging voor Inkoopprofessionals (Dutch Association for Procurement Professionals)

NGO = Non-governmental Organisation

OECD = Organisation for Economic Co-operation and Development

RBC = Responsible Business Conduct

SDG = Sustainable Development Goals

SSI = Sustainable Spices Initiative

UN = United Nations

It is important to report on the progress and impacts of due diligence efforts since companies are supposed to conduct on-going due diligence and to be transparent about it. For reporting, the following document can be used Reporting Checklist. This document can be used as a checklist for developing your Due Diligence Management process. It can also be used as a template to report on your achievements to stakeholders, for example to the Social Economic Council (SER) within the context of the ICSR covenant.