5. Monitoring
Contract clause
Supplier shall monitor the measures to prevent and mitigate actual and potential adverse impacts, by
a) following-up established action plans for its own operations and risk suppliers, with a particular focus on the most significant risks identified,
b) engaging in meaningful consultations with rights-holders affected by its own operations, or their representatives, and to the extent possible in the supply chains of risk suppliers and
c) addressing deviations.
a) Follow-up action plans
You shall follow-up established action plans for your own operations and risk suppliers (or prioritised supply chains/purchasing categories), with a particular focus on the most significant risks identified.
Follow-up is necessary to evaluate the effectiveness of your measures to prevent and mitigate adverse impacts, both in your own operations and supply chains.
Own operations
Action plans established for your own operations in accordance with process requirement 3. Prevent and mitigate (causation/contribution), shall be followed-up. This can, for example, be done through annual internal due diligence and/or environmental management reviews, or through external reviews and audits.
In our template for due diligence instruction, available at Templates process requirement 5, we have incorporated annual internal due diligence reviews. There is no requirement to use our template.
If you comply with legislation such as the Swedish Work Environment Act, the Swedish Discrimination Act and the Swedish Environmental Code, follow-up of the issues covered by these laws is integrated into your operations. Monitoring carried out within the framework of certifications may also constitute evidence.
Risk suppliers (or prioritised supply chains/purchasing categories)
Action plans established for risk suppliers (or prioritised supply chains/purchasing categories) in accordance with process requirement 4. Prevent and mitigate (linkage), shall be followed-up. The action plans should include both:
- systematic measures that strengthen your due diligence, such as supplier assessments, contract clauses, supplier follow-up, and capacity-building efforts, and
- targeted measures tailored to the most significant risks that have been identified.
The follow-up may, for example, be carried out as part of annual internal due diligence reviews. This is incorporated into our templates for due diligence instruction and responsible sourcing instruction, which are available at Templates process requirement 5. There is no requirement to use our templates.
With regard to supplier follow-up, this typically includes screenings, questionnaires, site visits, inspections, and audits. Other methods that can be used include origin verification, open data, and databases.
Origin verification
To verify the origin of a raw material, you can use origin verification. The method is based on isotope analysis and can be used as a complement to the supplier’s own data, particularly for raw materials such as meat, cotton and wood.
The regions’ work on cotton
In 2024–2025, the regions carried out a joint pilot project to test isotope analysis of cotton in purchased products, such as medical consumables and workwear. The aim was to investigate whether the cotton could be linked to high-risk areas for state-imposed forced labour, in particular the Xinjiang Uyghur Autonomous Region in China.
After an initial mapping, a number of products were selected and sent for analysis to a reputable laboratory. The results varied: in some cases they pointed to high-risk areas, in other cases the origin was unclear. This was followed up by dialogue with suppliers on how they verify origin and what measures can strengthen traceability.
The project shows how isotope analysis can be used as a support in monitoring, especially in supply chains where traditional controls do not provide sufficient assurance.
Open data
Open data involves reviewing publicly available, unstructured information online, such as social media posts where rightsholders report on risks in the workplace or society, and public documents.
The review can be done manually or with the help of AI.
Examples can be found at Globalworks, including monitoring commissioned by the Swedish metropolitan regions’ traffic administrations.
Databases
A third method is to use databases. Here are four examples:
Forcedlabor.ai
This AI-based tool identifies companies that may be linked to state-imposed forced labour, based on open sources such as government data, research reports and media reviews. With a free account, you can perform simple searches on company names, products or regions. The results can be used as a basis for further analysis, dialogue with the supplier or decisions on in-depth follow-up. The tool has been developed in collaboration with organisations such as Slave-Free Alliance, Transparency International and Anti-Slavery Collective. Please note that hits in the database are indications of risk and should be followed up and verified.
Withhold Release Orders
U.S. Customs and Border Protection issues Withhold Release Orders (import bans) when there is sufficient evidence of forced labour in the production of a product. These decisions are published on the CBP’s website and can be used to monitor products.
US Customs and Border Protection – Withhold Release Orders and Findings List
Uyghur Forced Labor Prevention Act Entity List
The U.S. Forced Labor Enforcement Task Force is tasked with developing and updating a list of products subject to the import ban under the Uyghur Forced Labor Prevention Act. This legislation was enacted to strengthen the existing import ban on goods produced using forced labour and to stop the use of forced labour in Xinjiang, China.
Conflict Mineral Reporting to the U.S. Stock Exchange
To information on the origin of the minerals tin, tungsten, tantalum and gold (3TG), you can search the U.S. Security and Exchange Commission’s EDGAR database. Companies listed on the U.S. stock exchange are required by the Dodd-Frank Act to report how they are working to reduce risks in their 3TG supply chains. The database is particularly useful for the IT, medical technology and automotive sectors. To search, click + more search options, enter the company and check the box “SD” under Browse filing types.
Particular focus on the most significant risks
As with all due diligence, the focus shall be on the most significant risks, assessed based on likelihood and severity. The follow-up shall reflect these priorities. If you have assessed the risks based on likelihood and severity and then drawn up the action plan based on the same priorities, you will automatically focus on the most significant risks in the follow-up as well.
Once the most significant risks have been followed-up, focus shall shift to the next most significant risks and thereafter in order of priority.
For support on how to prioritise risks based on probability and severity, see Process requirement 2.
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b) Engage in meaningful consultations
Templates process requirement 5
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 the monitoring process.
- Internal or external reviews and audits.
- Action plans with implemented measures.
- Questionnaires, for sample products.
- Reports from site visits or inspections, for sample products.
- Third-party audits, for sample products.
- Results from origin verification, open data, databases, etc., for sample products.
Guidance for auditor
Fulfils requirement
The company has instructions or equivalent documentation/templates that describe how it follows-up action plans for the company’s own operations, including:
- How the follow-up is carried out (e.g. annual internal reviews, external reviews and audits, follow-up in line with legislation).
- How the follow-up has a particular focus on the most significant risks.
The company has instructions or equivalent documentation/templates that describe how it follows-up supply chain action plans, including:
- How the follow-up is carried out (e.g. annual internal reviews, follow-up of suppliers).
- How the follow-up has a particular focus on the most significant risks.
There is documented follow-up of action plans for the company’s own operations — If the company is subject to relevant legislations, follow-up shall at a minimum be carried out in relation to those requirements.
There is documented follow-up of supply chain action plans, for sample products.
Does not fulfil requirement
The company lacks instructions or equivalent documentation/templates that describe how it follows-up action plans for the company’s own operations, or they are incomplete:
- It is not clear how the follow-up is carried out (e.g. annual internal reviews, external reviews and audits, follow-up in line with legislation).
- It is not clear that the follow-up has a partiuclar focus on the most significant risks.
The company lacks instructions or equivalent documentation/templates that describe how it follows-up supply chain action plans, or they are incomplete:
- It is not clear how the follow-up is carried out (e.g. annual internal reviews, follow-up of suppliers).
- It is not clear that the follow-up has a particular focus on the most significant risks.
There is no documented follow-up of action plans for the company’s own operations — despite the company being subject to relevant legislations.
There is no documented follow-up of supply chain action plans, for sample products.
b) Engage in meaningful consultations
You shall engage in meaningful consultations with rights-holders affected by your own operations, or their representatives, and to the extent possible in the supply chains of risk suppliers (or prioritised supply chains/purchasing categories).
Consultation is important to ensure that the measures have been implemented. Requirements for cooperation and consultation are also set out in legislation such as the Swedish Work Environment Act, the Swedish Discrimination Act, and the Swedish Environmental Code.
If you have the capacity to follow-up risk suppliers through site visits and inspections, you should also be able to fulfil the requirement for consultation. If you obtain third-party audits, you shall ensure that they are based on interviews with rights-holders.
For more information on consultations, see process requirement 2. Risk assessments.
Meaningful consultations
The consultations you conduct shall be meaningful. This means that they shall be characterised by two-way communication and good faith of participants on both sides. It also means that the consultations shall be responsive and ongoing.
The four criteria are from OECD’s due diligence guidance.
| Two-way engagement means that both companies and rights-holders freely express opinions, share perspectives and listen to alternative viewpoints to reach a mutual understanding. It also means that relevant rights-holders have the opportunity to help design and carry out engagement activities themselves. |
| Both companies and rights-holders are expected to act in good faith in engagement activities. This means that companies engage with the genuine intention to understand how relevant rights-holders are affected by their activities. It also means that companies are prepared to address any adverse impacts they cause or contribute to, and that rights-holders honestly represent their interests, intentions and concerns. |
| Responsive engagement means that companies seek to inform their decisions by eliciting the views of those likely to be affected by the decision. It is important to engage potentially impacted rights-holders prior to taking any decision that may impact them. This involves the timely provision of all information needed by the potentially impacted rights-holders to be able to make an informed decision as to how the company’s decision could impact their interests. It also means there is following-through on implementation of agreed commitments, ensuring that adverse impacts to impacted and potentially impacted rights-holders are addressed including through provision of remedies when companies have caused or contributed to the impacts. |
| Ongoing engagement means that rights-holder engagement activities continue throughout the lifecycle of an operation or activity and are not a one-time endeavour. |
Suggested verifications
- Instructions describing consultations with rights-holders in the monitoring of action plans for your own operations and how these meet the requirement for “meaningful” consultations.
- Instructions describing consultations with rights-holders in the monitoring of supply chain action plans.
- Worker surveys and minutes from follow-up meetings, for sample products.
- Closed actions in action plans, including records of consultations, for sample products.
- Reports from site visits and inspections describing the consultations, for sample products.
- Third-party audit reports describing the consultations, for sample products.
Guidance for auditor
Fulfils requirement
The company has instructions or equivalent documentation/templates that describe how it engages in consultations with rights-holders or their representatives when following-up action plans for the company’s own operations, including:
- How statutory consultations are applied.
- How consultations are characterised by two-way communication, responsiveness, good faith and continuity.
The company has instructions or equivalent documentation/templates that describe how it seeks to engage in consultations with rights-holders or their representatives when following-up supply chains, including:
- worker interviews during site visits and inspections, or
- verification that third party audits are based on worker interviews.
There is documentation demonstrating that consultations have been carried out in the follow-up of action plans for the company’s own operations, such as worker surveys or meeting minutes from statutory consultations with a focus on follow-up.
There is documentation demonstrating that consultation has been sought in the follow-up of the supply chains of sample products, for example through worker interviews conducted during site visits or inspections, or by verifying that third-party audits are based on worker interviews.
Does not fulfil requirement
The company lacks instructions or equivalent documentation/templates that describe how it engages in consultations with rights-holders or their representatives when following-up action plans for the company’s own operations, or they are incomplete:
- Statutory consultations are not applied.
- Consultations are not characterised by two-way communication, responsiveness, good faith and continuity.
The company lacks instructions or equivalent documentation/templates that describe how it seeks to engage in consultations with rights-holders or their representatives when following-up supply chains, or they are incomplete:
- provisions regarding worker interviews during site visits or inspections are missing
- no verification is carried out to ensure that third-party audits are based on worker interviews.
There is no documentation demonstrating that consultations have been carried out in the follow-up of action plans for the company’s own operations, such as worker surveys or meeting minutes from statutory consultations with a focus on follow-up.
There is no documentation demonstrating that consultations have been sought in the follow-up of risk suppliers of the supply chains of sample products, for example through worker interviews conducted during site visits or inspections, or by verifying that third-party audits are based on worker interviews.
c) Address deviations
When following-up measures to prevent and mitigate adverse impacts, you shall address deviations.
This means that you shall address deviations relating to both the commitments and the due diligence process. As this is partly covered under a) Follow-up action plans, this section focuses on how severe deviations shall be managed.
In the Supplier Code of Conduct, severe deviations are defined as 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.
Severe deviations should be reported through your incident or deviation management system to ensure that they are handled at the appropriate level. This applies regardless of whether the severe deviation occurs within your own operations or in the supply chain.
In some companies, the incident or deviation management system does not cover severe deviations in the supply chain. In such cases, a separate system or process may need to be established.
Suggested verifications
- Instructions describing the deviation management process.
- Screenshots or printouts from the deviation management system.
- Action plans with implemented measures.
- Meeting minutes documenting deviation management.
Guidance for auditor
Fulfils requirement
The company has instructions or equivalent documentation/templates that describe how it addresses severe deviations in its own operations.
The company has instructions or equivalent documentation/templates that describe how it addresses severe deviations in the supply chain.
If severe deviations have been identified in the company’s own operations, evidence is available demonstrating that they have been reported and managed in accordance with the company’s instructions.
If severe deviations have been identified in the supply chain, evidence is available demonstrating that they have been reported and managed in accordance with the company’s instructions.
Please note that only the management of severe deviations is assessed here. The management of other deviations is assessed under a) Follow-up action plans.
Does not fulfil requirement
The company lacks instructions or equivalent documentation/templates that describe how it addresses severe deviations in its own operations.
The company lacks instructions or equivalent documentation/templates that describe how it addresses severe deviations in the supply chain.
Furthermore, the company lacks evidence of actual implementation, which could strengthen its claim that such procedures are in place.
Please note that only the management of severe deviations is assessed here. The management of other deviations is assessed under a) Follow-up action plans.
Templates process requirement 5
- Responsible sourcing instruction template
- Supply chain risk assessment template incl. action plans and remediation plan