Risk Mitigation, Remedy, and Ongoing Monitoring

Objective

To implement appropriate and proportionate actions to mitigate and/or remediate identified risks, and to establish systems for ongoing monitoring to support continuous improvement.

Why this matters

Identifying risks is important, but effective due diligence requires appropriate follow-up action and ongoing supplier monitoring. Risk mitigation and remedy depend on the nature and severity of the issue, the company’s level of leverage, and the potential for positive change.

Key actions checklist

• Define your escalation and decision-making process
  Establish internal criteria for determining how the company will respond to different types and severities of risks, including when to engage, mitigate, escalate, or disengage.
• Engage suppliers to develop risk mitigation plans
  Collaborate with suppliers to address identified risks through realistic, time-bound corrective actions.
• Establish a remediation protocol for severe impacts
  For serious issues such as confirmed child labour or human rights abuse, develop or align with an appropriate remediation framework.
• Track progress and follow up regularly
  Implement a corrective action log or review calendar to track supplier progress, including dates for follow-up and re-assessment.
• Support continuous improvement
  Encourage suppliers to improve practices by providing clear expectations and access to capacity-building resources where possible.

Recommended Steps — Corrective Action Process

1. Verify the nature of the risk or impact (actual vs. potential).
2. Assess severity and urgency, prioritising risks involving vulnerable groups.
3. Determine company involvement — caused, contributed to, or linked to the harm.
4. Choose an appropriate course of action: remedy if harm has occurred; mitigation if risk is potential.
5. Engage with the supplier and/or affected stakeholders to identify root causes.
6. Develop and implement a Corrective Action Plan (CAP) with agreed timelines and responsible parties.
7. Monitor progress and verify effectiveness.
8. Escalate or disengage if no meaningful progress is made, particularly for serious risks.
9. Document the entire process for accountability and transparency.