Work with the relevant departments to identify the business processes where due diligence should play a role. Where are the opportunities to incorporate or strengthen due diligence? Consider areas such as the Code of Conduct, supplier selection, procurement procedures, payment terms agreements, and more. Enhance these agreements by including due diligence.

Risk analysis is a crucial element within the six steps of due diligence. Priority should be given to addressing risks that are large in scale and irreversible. The organisation needs to have a clear vision for managing such significant, impactful risks. This may involve choosing certification, changing suppliers, or participating in a collective initiative to address the risk. Module 4 will provide more insights into this.

Ensure that all colleagues know about changes in existing business processes and have knowledge of the approach to International Responsible Business Conduct. This can be achieved by incorporating it into regular communication with all employees and by providing training to relevant organisational units. Also, inform external parties and emphasise the benefits of excluding human rights violations and environmental damage in joint supply chains.

In smaller organisations, alignment between departments is usually more natural. This greatly facilitates the integration of due diligence into the organisation. When different functions and departments have regular meetings, they can quickly respond to new challenges. Consider, for instance, emerging risks such as human rights violations in the tomato sector, child labour in electronic factories, or new legislation that the company must comply with.

Ensure that everyone involved in the due diligence cycle knows precisely what they should do, what they will be evaluated on, and with whom they must collaborate to implement due diligence effectively.

When drafting a code of conduct, it is essential to consider suppliers' interests as well. An excellent example of implementing this is a buyer-supplier mutual way of conduct, also known as a two-way code of conduct. This results in a sustainable relationship with your supplier, where trust and stability are central. You can find an example on pages 30 and 31 of the document: ‘Guide to buying responsibly’ (ETI).

To determine whether the measures taken are effective, collecting information is important. Where possible, use existing information systems. It is crucial to set measurable goals to monitor the progress of the IRBC policy. For example, think of an agreed % of certified products or a specific % of suppliers signing the code of conduct. Formulating objectives using the SMART criteria (Specific, Measurable, Actionable, Relevant, and Time-bound) supports progress monitoring. This information helps the management to monitor progress and make necessary adjustments on time.

Access to remedy is an important aspect of due diligence. This means that individuals who have been victims of wrongdoing in the supply chain can seek legal action for recovery or compensation. Even for small and medium-sized businesses, it is important to have a straightforward procedure for reporting misconduct (grievance mechanism) and consider measures to compensate for potential harm. The ‘handbook effective grievance mechanisms’ provides relevant case studies, lessons learned, and practical recommendations for effective grievance mechanisms. Module 8 will teach you more about addressing and remedying negative impacts.

• This questionnaire by the SER (Social and Economic Council) helps companies in the textile sector gain insight into their due diligence process.
• Shesupplies has designed a roadmap for companies to ensure that gender equality plays a role in their procurement policies. A self-assessment is part of the roadmap.

After this assignment, you have a good understanding of the starting points for due diligence in your company's processes.