FAQ

The Swedish Regions and Adda Central Purchasing Body have imposed due diligence requirements in different forms for over a decade. Most of the due diligence requirements focus on the supplier’s own policies and processes. A smaller number of requirements relate to contractual rights.

The requirements apply from the start of the contract, unless otherwise specified.

In practice, contract follow-up usually takes place some time after the contract has started, which gives suppliers time to prepare and strengthen their systems. The guidance explains what normally fulfils each requirement and what does not, and includes e-learning courses and templates to support suppliers.

The Swedish Regions also pay for the first two office audits. However, Adda Central Purchasing Body only pays if the supplier passes the audit.

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Due diligence guidance – husr.se (guidance for buyers and suppliers)

Key concepts are explained under Key terms and used throughout the guidance.

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Key terms – husr.se (guidance for buyers and suppliers)

The contract clauses focus on due diligence and include seven process requirements. For each process requirement, the guidance suggests verifications and explains what fulfils the requirement and what does not.

The guidance is based on the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct. This means that the guidance takes into account reasonable measures and best efforts, especially considering SMEs.

The Supplier Code of Conduct contains outcome-based standards. These are mainly followed up through incident management, which may include factory audits. Incident management focuses on severe deviations: forced labour, child labour, working conditions that pose a danger to life, serious environmental harm, grand corruption and attacks on environmental and human rights defenders.

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2. Supplier’s due diligence – husr.se (supplier guidance)

3. Manage contract – husr.se (buyer guidance)

The contract clauses apply to all operations connected to what is purchased, in line with the Swedish Public Procurement Act. This means that they apply throughout the life cycle of the supplies, works or services being purchased, including the entire supply chain.

However, the contract clauses distinguish between causation, contribution and linkage. Where a supplier causes or contributes to an adverse impact, the expectations are higher. Where the supplier is linked to an adverse impact through a business relationship, the focus is on using leverage to prevent or mitigate the adverse impact.

This approach is consistent with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct.

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3. Prevent and mitigate (causation/contribution) – husr.se (supplier guidance)

4. Prevent and mitigate (linkage) – husr.se (supplier guidance)

The contract clauses take a risk-based approach, meaning that suppliers are not expected to treat all first-tier suppliers in the same way. Suppliers are expected to identify risk suppliers and focus their due diligence efforts where the risks are most significant. Measures to prevent and mitigate adverse impacts are then applied to those risk suppliers. This means that the focus is not on all suppliers equally, but on those supply chains—or parts thereof—where the risks are greatest.

This approach is consistent with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct.

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2. Risk assessments – husr.se (supplier guidance)

4. Prevent and mitigate (linkage) – husr.se (supplier guidance)

The remediation requirement applies where the supplier has caused or contributed to an actual adverse impact. In those situations, the supplier shall, to the extent possible, restore affected rights-holders to the position they would have been in had the adverse impact not occurred, and enable remediation that is proportionate to the significance and scale of the adverse impact.

Where the supplier is only linked to an adverse impact through a business relationship, the contract clauses do not impose a remediation obligation. However, suppliers should use their leverage to encourage effective remediation. In practice, this may include working together with the Swedish Regions, Adda Central Purchasing Body and other buyers to increase leverage and encourage effective remediation.

This approach is consistent with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct.

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7. Remediation – husr.se (supplier guidance)

The reporting obligation applies only to severe deviations: forced labour, child labour, working conditions that pose a danger to life, serious environmental harm, grand corruption, and attacks on environmental and human rights defenders.

The supplier shall report such deviations within two weeks where there are reasonable grounds to assume that such a deviation has occurred. The report shall describe the factual circumstances, as well as implemented and planned measures.

For contracts with the Swedish Regions, the reporting obligation may be fulfilled by reporting to the National Secretariat rather than to each individual region.

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3. Supplier’s reporting obligation – husr.se (supplier guidance)

The report shall be based on the information available at the time of reporting, even if it is not yet complete or fully verified. The purpose of the reporting obligation is to enable the Swedish Regions and Adda Central Purchasing Body to use their leverage, together with the supplier and other buyers, to prevent, mitigate and remediate adverse impacts. The focus is on enabling dialogue and effective action, not on penalising suppliers.

Suppliers are encouraged to invite relevant public buyers to a joint meeting, where appropriate, rather than conducting separate dialogues with individual buyers.

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3. Supplier’s reporting obligation – husr.se (supplier guidance)

The four-week deadline applies to self-assessments, supply chain transparency and audits.

Self-assessments and office audits mainly concern the supplier’s own policies and processes. This is information the supplier is normally expected to be able to provide within four weeks. Office audits are usually preceded by an initial meeting, which gives suppliers additional time to prepare and involve relevant internal functions.

Supply chain transparency requests are based on the transparency requirement defined in the individual procurement. At a minimum, suppliers are expected to disclose final manufacturing sites.

Where information needs to be obtained from sub-suppliers or global corporate functions, the Swedish Regions and Adda Central Purchasing Body recognise that this may take longer. In practice, deadlines are handled pragmatically where the supplier is transparent, cooperative and can explain why additional time is needed.

The purpose of these deadlines is not to create disproportionate pressure, but to ensure that contract management can be carried out in a structured and predictable manner.

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3. Manage contract – husr.se (buyer guidance)

1. Prepare procurement – husr.se (buyer guidance)

The audit requirement should not be understood as a guarantee that access to sub-suppliers’ operations can always be secured.

Suppliers are expected to use their leverage and work to enable access. This may include incorporating corresponding requirements into supplier agreements, engaging with sub-suppliers, explaining the purpose of the audit, and cooperating with the Swedish Regions or Adda Central Purchasing Body to find practical solutions.

Gaining access to facilities, particularly further upstream in the supply chain, may take time and depend on the cooperation of several actors. The assessment therefore focuses on whether the supplier has taken reasonable measures and used its leverage to enable access, rather than on whether access could ultimately be secured.

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3. Manage contract – husr.se (buyer guidance)

The requirement to map supply chains (section 2.2 b) forms part of the supplier’s due diligence, while the supply chain transparency requirement (section 4.4) is determined by the buyer in each individual procurement.

Supply chain mapping is the basis for assessing risks across the entire supply chain. Suppliers are expected to know where final manufacturing takes place and to be able to make an overall assessment of where component manufacturing, smelters and refiners, and raw material extraction take place. Upstream, this assessment may be based on assumptions.

Supply chain transparency concerns what information the supplier is required to disclose. The level of transparency is determined in each individual procurement. Disclosure of final manufacturing sites constitutes the minimum level, while more extensive transparency requirements should only be used where proportionate.

Supply chain transparency is not the same as traceability. Traceability generally refers to the ability to follow a specific product, component or material through the supply chain.

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2. Risk assessments – husr.se (supplier guidance)

1. Prepare procurement – husr.se (buyer guidance)

3. Manage contract – husr.se (buyer guidance)

The level of transparency required depends on the complexity, risks and maturity of the industry. The Regions’ National Secretariat has developed recommended levels for certain products. These levels are considered proportionate.

Where there is no national recommendation for a prioritised purchasing category and the buyer cannot assess the complexity, risks and maturity of the industry, the transparency requirement shall be limited to final manufacturing facilities. This means that all suppliers shall know where their products are manufactured, but more extensive requirements shall only be used where justified.

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1. Prepare procurement – husr.se (buyer guidance)

Suppliers may in some cases be subject to confidentiality obligations or legal restrictions. Where this applies, the supplier shall explain what specific restriction applies, who is invoking it, what information cannot be shared, and what efforts have been made to obtain or disclose the information. Where full disclosure is not possible, suppliers may provide alternative forms of assurance. This can include aggregated information, summaries, descriptions of processes, third-party verification, or other relevant documentation.

In most procurements, the supply chain transparency requirement will only cover final manufacturing sites. Suppliers are normally entitled to share this information with their customers. The issue is more likely to arise in relation to upstream sub-suppliers.

In practice, confidentiality rarely prevents meaningful monitoring. Audits and follow-ups are normally conducted through dialogue, and in many cases it is sufficient for suppliers to present documentation during a meeting without providing copies.

If a third party requests access to documents held by the Swedish Regions, an individual confidentiality assessment is carried out in accordance with the Swedish Public Access to Information and Secrecy Act. Information concerning sub-suppliers will normally be protected where disclosure could cause commercial harm. Adda Central Purchasing Body is not in scope of this legislation.

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3. Manage contract – husr.se (buyer guidance)

Where a deviation from the Supplier Code of Conduct or the due diligence process has been identified, the supplier shall establish a time-bound corrective action plan for approval by the contracting organisation. The action plan should be proportionate to the severity of the deviation and describe how it will be addressed within the agreed timeframe.

The purpose is to ensure that deviations are addressed in a structured, realistic and timely manner. The focus is on improvement rather than arbitrary decision-making.

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3. Manage contract – husr.se (buyer guidance)

The focus of the contract clauses is to improve suppliers’ operations and supply chains. Termination only becomes relevant where breaches are persistent or severe. This may be the case if a supplier does not engage in monitoring, does not address identified deviations, or where a severe deviation is identified and the party causing the severe deviation does not take immediate action to prevent and mitigate it.

The guidance is based on the principle of remediation first. This means that the Swedish Regions and Adda Central Purchasing Body seek dialogue, corrective action and, where appropriate, remediation before termination of the contract.

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3. Manage contract – husr.se (buyer guidance)

The Swedish Regions publish summary information from coordinated follow-ups to promote transparency, support coordination between the regions and other public buyers, and avoid unnecessary duplication of audits and follow-ups. The purpose is not to rank suppliers or to “name and shame”.

The information does not include confidential business information. Full audit reports are subject to confidentiality assessment before any information can be disclosed.

Where corrective actions are ongoing, published summaries should be understood as a snapshot. Summaries are updated as the follow-up progresses and corrective actions are implemented.

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Revisionsrapporter – husr.se