How to Monitor Suppliers for Human Trafficking

[Document Dame]

Good day eveyone,
We’re a small AS9100 company that was recently informed by an aerospace customer that we must do the following:

Implement a compliance plan to prevent and prohibit activities described in clause 52.222-50, Combating Trafficking in Person, and to monitor, detect, and terminate the contract with a subcontractor engaging in prohibited activities.

I can flow-down the requirement in our Quality Clauses but how can we create, and implement, a plan to monitor our suppliers behavior in this area?

The customer also wants a copy of the plan.

Your guidence would be appreciated!

 

[joburum]

Do you flow down a supplier code of conduct? That and a supplier audit are two ways to cover. Have seen others send out a survey as well but we all know how well surveys are received.

 

[Sidney Vianna]

I can flow-down the requirement in our Quality Clauses but how can we create, and implement, a plan to monitor our suppliers behavior

Your guidence would be appreciated!

There are third party organizations which assess supply chains for many aspects of corporate social responsibility, human trafficking avoidance being one of the criteria.
If many customers start demanding something along these lines, it might be easier for the suppliers to attain some form of credible certification and present it to customers who can use that as means of monitoring their supplier base.

 

[Document Dame]

In our Terms and Conditions, we state:

COMPLIANCE WITH LAWS: The Supplier shall comply with all applicable federal, state and local laws and any rules, regulations and orders issued under such laws, including but not limited to, labor and employment laws, anti-kickback acts, worker’s compensation requirements, and hazardous communication laws.

In your experience, do you think that detailing the specific regulation in the T&C would be sufficient to replace a written Plan?

We’re a company with 47 employees and we use 30 suppliers. Except for 6 or 7 companies, site visits wouldn’t be feasible.

BTW Having sent and received a variety of surveys over the years, I know exactly how they are received.

Thanks

 

[joburum]

Those terms and conditions would be suitable in my view. For site visits you don't or wouldn't have to visit each site as of course its not feasible having that many suppliers. Only random 1 or 2 at least would work and show that you are meeting the requirement.

 

[normzone]

I kid you not, somewhere in a DFAR there is a clause that prohibits the use of child labor EXCEPT when it is subcontracted through the southern Sudan. Seriously, I have read it.

 

[Document Dame]

I appreciate your help and will start setting up a site visit.

Once again, the Cove's contributers come to my rescue!