6. Complaints
Contract clause
Supplier shall enable stakeholders such as rights-holders, their representatives and environmental and human rights defenders to submit complaints if they have concerns about actual or potential adverse impacts in Supplier’s operations or supply chains. Supplier shall address the submitted complaints.
a) Enable complaints
You shall enable stakeholders such as rights-holders, their representatives and environmental and human rights defenders to submit complaints if they have concerns about actual or potential adverse impacts in your operations or supply chains.
Complaints procedures serve two key functions:
- They help identify adverse impacts by providing affected parties with a channel to report issues.
- They enable swift handling and remediation, preventing further harm or escalation of complaints.
Complaints procedures shall be designed to be accessible and relevant to affected stakeholders, taking into account the specific circumstances of the business.
Own operations
You may base your complaints procedure on traditional communication channels such as telephone, mail and email, which is common when addressing impacts on surrounding communities. Increasingly, digital platforms that enable anonymous communication are also being used, particularly for a company’s own workers.
If you have at least 50 employees, you are subject to the Swedish Whistleblowing Act (2021), which requires you to have internal reporting channels and follow-up procedures. Under the Act, you must ensure that reports can be made in writing, orally and, as needed, through a physical meeting. However, the Act does not require anonymity. You must also ensure that the channels are accessible to workers and other relevant roles within the organisation, such as trainees, self-employed persons, board members and shareholders.
Some companies have opened their whistleblowing channels to a broader range of misconduct and persons than required by law, but it is important that you clearly communicate what is covered by the Act’s protection against retaliation.
For the largest companies, the Corporate Sustainability Due Diligence Directive also introduces new requirements for notification mechanisms and complaints procedures relating to human rights and the environment. We have developed templates for these requirements, which are available under Templates process requirements 6. There is no requirement to use our templates.
Supply chains
Enabling complaints in the supply chain is often more complex than in your own operations. For example, you may receive complaints via email, telephone or another function that enables individuals to submit complaints. There is no requirement to use a digital platform or offer anonymity, although this is recommended.
You shall ensure that information about how to submit complaints is made available in the supply chain, for example through a code of conduct, contract clauses or other communication with the sub-supplier or the factory’s worker representatives. You shall also ensure that the information is available in relevant languages.
Where it is practically feasible and does not place an undue burden on the sub-supplier, you may also make the information available at the sub-supplier’s facilities, for example through posters displaying QR codes or contact details. Such visibility measures require the sub-supplier’s consent and should be adapted to local circumstances.
You may also join multi-stakeholder initiatives that provide access to independent complaints mechanisms, such as amfori BSCI. There are also sector-specific initiatives, for example:
Roundtable on Sustainable Palm Oil (palm oil)
Forest Stewardship Council (forest products)
Fair Labor Association (apparel)
Fair Wear Association (apparel)
International Accord for Health and Safety in the Textile and Garment Industry (clothing and textiles)
Effectiveness criteria for complaints procedures
The following criteria serve as a guide for designing, revising, or evaluating complaints procedures, with the aim of ensuring their practical effectiveness. The eight criteria are from the UN Guiding Principles.
A well-functioning complaints procedure should be:
| Legitimate | Enabling trust from the stakeholder groups for whose use they are intended and being accountable for the fair conduct of grievance processes. |
| Accessible | Being known to all stakeholder groups for whose use they are intended, and providing adequate assistance for those who may face particular barriers to access. |
| Predictable | Providing 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 | Seeking 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 | Keeping parties to a grievance informed about its progress and providing sufficient information about the mechanism’s performance to build confidence in its effectiveness and meet any public interest at stake. |
| Rights-compatible | Ensuring that outcomes and remedies accord with internationally recognized human rights. |
| A source of continuous learning | Drawing on relevant measures to identify lessons for improving the mechanism and preventing future grievances and harms. |
| Based on engagement and dialogue | Consulting the stakeholder groups for whose use they are intended on their design and performance and focusing on dialogue as the means to address and resolve grievances. |
PAGE CONTENT
Templates process requirement 6
PROCESS REQUIREMENTS DUE DILIGENCE
1. Policies and responsibilities
3. Prevent and mitigate (causation/contribution)
4. Prevent and mitigate (linkage)
RELATED LINKS SUPPLIERS
3. Supplier’s reporting obligation
RELATED LINKS BUYERS
Suggested verifications
- Instructions describing how you enable complaints in your own operations and in your supply chains.
- Links to, screenshots from, or other documentation of the channels used to submit complaints, such as digital platforms, email addresses or telephone numbers.
- Codes of conduct or other communications containing information about complaints channels.
- Photographs of posters displaying information about complaints channels that have been made available in your own operations or at sub-suppliers’ facilities.
- Links to the complaints procedures of multi-stakeholder initiatives.
Guidance for auditor
Fulfils requirement
The company has one or more channels that rights-holders, their representatives, human rights defenders and others can use to submit complaints within its own operations, and these channels are accessible to the respective stakeholder groups.
The company enables complaints from rights-holders in the supply chains of sample products, for example by:
- Providing information on grievance channels in the code of conduct, such as links or QR codes to digital channels or email addresses and telephone numbers.
- Making information on complaints channels available at sub-suppliers’ facilities, for example through posters displaying links or QR codes to digital channels or email addresses and telephone numbers.
- Participating in multi-stakeholder initiatives that provide accessible complaints mechanisms.
Note that there is no requirement that those who make complaints shall be able to remain anonymous.
Does not fulfil requirement
The company lacks channels that rights-holders, their representatives, human rights defenders, etc. can use to submit complaints within its own operations, or the channels are not accessible to the respective stakeholder groups.
The company does not in any way enable complaints from rights-holders in the supply chains of sample products.
b) Address complaints
You shall address the submitted complaints.
By addressing complaints according to established procedures, you can prevent harm from worsening and complaints from escalating. In our template for complaint procedures, which is available at Templates process requirements 6, there is support for how you can:
- Receive complaints, including registering and categorizing them.
- Verify complaints, including prioritizing serious and urgent complaints.
- Investigate complaints and determine measures, including guidelines for the procedure.
- Establish remedy, including rules for cause/contribution and different types of remedy.
- Implement and follow up on the remedy.
- Close complaints, including assessing satisfaction.
- Handle feedback and evaluate results.
There is no requirement to use our template.
Suggested verifications
- Instructions describing how you address complaints in your own operations and supply chains.
- Documented addressed complaints, for sample products.
Guidance for auditor
Fulfils requirement
The company has instructions or equivalent documentation describing how it addresses complaints in its own operations and in its supply chains.
It is sufficient that the company can show that there are procedures for addressing complaints – proof of actual implementation is not required. However, such documentation can strengthen the company’s claim that procedures exist. Examples include documented handled complaints.
Does not fulfil requirement
The company lacks instructions or equivalent documentation describing how it addresses complaints in its own operations and in its supply chains.
The company also lacks evidence of actual implementation, which could strengthen the company’s claim that procedures exist.
Templates process requirement 6
- Notification mechanism template
- Complaints procedure template
- Responsible sourcing instruction template
- Text to include in your supplier code of conduct, to be displayed in local languages at sub-suppleirs’ facilities:
CONTACT [COMPANY NAME]
If your employer violates any part of this code of conduct, we want to know about it. Please report the issue by contacting us at [phone number], [email address], or through [QR code].
You are welcome to write in your own language. All information provided will be treated with strict confidentiality.