Overview · Web viewHowever, information collected or used to conduct the assessment (e.g., company policy documents, procedures, contracts, systems, or reports) may also help substantiate

Self-Assessment Tool for the Accountability Framework


© 2020 Accountability Framework initiative. All rights reserved.

DISCLAIMER: This work product is intended to be advisory only and is not intended to serve as a legal opinion or legal advice on the matters treated. The reader is encouraged to engage counsel to the extent required.

This tool is provided by the Accountability Framework initiative (AFi) to help companies and other users apply the Accountability Framework to assess company commitments and implementation systems for ethical supply chains. It is based on the full Accountability Framework version 1.0 (released in June 2019), which was created through a consultative process following applicable good practices for multi-stakeholder initiatives and which represents the consensus of the AFi Steering Group members that participated in its development. Current AFi Steering Group members (as of the publication date) include:

The AFi Backbone Team (secretariat) is co-led by the Rainforest Alliance and the Meridian Institute.

The AFi is funded by:

For more information on the AFi's governance and a full list of partners, please visit www.accountability-framework.org

http://www.accountability-framework.org/



ContentsOverview 1

1. Tool for Assessing Company Commitments and Policies 4 Commitments related to deforestation and conversion................................................................................................

Commitments to no-deforestation supply chains (Core Principle 1.1)......................................................................................Commitments to no-conversion supply chains (Core Principle 1.2)..........................................................................................

Commitments related to human rights.........................................................................................................................Commitments to respecting all human rights (Core Principle 2.1)...........................................................................................Commitments to respecting the rights of indigenous peoples and local communities (Core Principle 2.2)...........................Commitments to respecting workers’ rights (Core Principle 2.3)...........................................................................................

Specification of commitments.....................................................................................................................................

2. Tool for Assessing Company Implementation and Reporting Systems 15 Company systems and processes to drive effective implementation.........................................................................Supply chain assessment and traceability..................................................................................................................Management for supply chain compliance..................................................................................................................Land acquisition, development, and management.....................................................................................................Access to remedy and environmental restoration.......................................................................................................Collaboration for landscape and sector sustainability.................................................................................................Monitoring and verification of company operations and supply chains.......................................................................Reporting, Disclosure, and Claims...............................................................................................................................


Overview The Accountability Framework is a common approach to achieve supply chains that are protective of forests, other natural ecosystems, and human rights. Its principles, definitions, and guidance reflect the consensus of the coalition of leading environmental and social NGOs that is behind the Accountability Framework initiative (AFi).

Companies can apply the Accountability Framework to guide them in setting strong supply chain commitments, developing effective implementation systems, and credibly monitoring and reporting on progress in accordance with best practice. By doing so, companies can be confident that their approach to managing for responsible supply chains will meet the expectations and criteria of their product buyers, investors and financiers, civil society organizations, and other stakeholders.

This tool assists companies in applying the Framework by providing a structured way to assess company polices, systems, and practices against each of its elements. The tool includes two sections, which may be used separately or combined into a single comprehensive assessment:

1. Section 1: Tool for assessing company commitments and policies. The Accountability Framework’s Core Principles 1-3 define the elements of strong company policies to address deforestation, conversion, and human rights in agricultural and forestry supply chains. Use this section to determine the degree of alignment of your company’s existing supply chain policies with the Framework.

2. Section 2: Tool for assessing company implementation and reporting systems. The Accountability Framework’s Core Principles 4-12 address company systems and practices to implement and report on ethical supply chains. Use this section of the tool to benchmark your current systems and practices against the Framework.

Both tools are designed to provide a systems-level internal assessment of a company’s policies and practices for achieving ethical supply chains – not an assessment of progress toward meeting specific supply chain commitments or performance thresholds. For more information on progress monitoring and reporting, please see Core Principles 11 and 12 and the corresponding Operational Guidance.

Who can conduct the assessment?Companies are invited to conduct their own assessment or to seek assistance from a service provider. Some companies using this tool have found service providers to be helpful in conducting an objective assessment and in providing technical assistance to address any identified gaps.

Who will see the results of the assessment?

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This tool is a resource for companies to help inform decision-making related to policies, systems, and practices for ethical supply chains. Users may choose whether to internally assess on a strictly internal (confidential) basis or whether to share the assessment results with stakeholders or business partners to increase transparency or inform discussions about possible solutions to supply chain challenges.

The AFi is not an assessment or reporting initiative and does not expect to receive a copy of assessment results. However, the AFi welcomes feedback about this assessment tool and the Framework itself based on companies’ experience applying it.

Can I use this tool in lieu of reviewing the Accountability Framework itself? No, that is not recommended. To facilitate practical assessment, this tool provides an itemized and simplified presentation of the most substantive elements of the Accountability Framework. However, this simplified language does not substitute for the Framework itself, which provides greater specificity and should be the point of reference for conducting assessments. Therefore, it is recommended that before initiating an assessment, users read at least the Core Principles to understand the context and intent of the Accountability Framework material on each topic and the relationships among them. Once the assessment is underway, users should consult the Operational Guidance and Definitions associated with each Core Principle to find additional information as necessary to conduct a sound assessment. All these materials are accessible on the AFi online platform.

Can this tool also help my company develop plans to fill any identified gaps?The diagnostic that this tool provides is intended as a first step, to be followed by planning and prioritization to address gaps revealed by the assessment. For elements where the company is not fully aligned with the Framework, the Core Principles and Operational Guidance related to the given elements may be consulted for guidance on designing or improving company policies, systems or activities in accordance with global best practice.

Are all elements of the assessment tool applicable to all companies?No, not necessarily. While most of the Accountability Framework (and most of the corresponding elements in this tool) applies to all companies, some are relevant mainly to companies with specific supply chain roles. Where this is the case, the tool includes applicability notes (in italics) to identify the type of supply chain actor to which the given elements are most relevant. The supply chain actors referenced in these applicability notes include:

Companies that own, control, or manage land for commodity production or primary processing Companies that source material from one or more producers or suppliers

Companies that play multiple roles in the supply chain (e.g., primary production as well as trading) should assess all elements that are germane to any role that they play. The applicability notes are a general guideline. It is up to the user to determine

2


https://accountability-framework.org/definitions/

https://accountability-framework.org/contents-of-the-framework/

https://accountability-framework.org/core-principles/


which elements apply to the company being assessed. If an element is determined not to apply, it should be noted as ‘not applicable’ along with an explanation for this determination. This will help contribute to a clear and thorough assessment.

What is the scope of the assessment?That is up to the user to determine. While the AFi strongly encourages companies to set commitments and take effective action on deforestation, conversion, and human rights for all aspects of their business for which these issues are relevant, in some cases companies may wish to conduct an assessment based on a narrower scope. The most important thing is to clearly define the scope of the assessment so that there is no ambiguity in how the assessment is carried out and how the results are interpreted and applied. To this end, each section of the tool is preceded by a fillable table where the user can specify the scope of the assessment in terms of commodities, product origins, company functions and business units, or other components of the company’s business that are to be included or excluded.

Users applying Section 2 of the tool are encouraged to assess implementation and reporting practices relative to all topics within the AFi scope (i.e., deforestation, conversion, and human rights). However, companies that have distinct or stand-alone deforestation/conversion or human rights policies and programs may choose to carry out topic-specific assessments.

Can the assessment be used to support company claims?This tool is designed primarily to support companies to conduct internal assessments and develop improvement processes. However, information collected or used to conduct the assessment (e.g., company policy documents, procedures, contracts, systems, or reports) may also help substantiate external-facing communications about the degree to which the company’s policies and practices align with the Accountability Framework. Any communications or claims regarding alignment with the Accountability Framework must adhere to the AFi Policy on Communications and Claims.

3

https://accountability-framework.org/communications-claims/


1. Tool for Assessing Company Commitments and PoliciesThe Accountability Framework’s Core Principles 1-3 define the elements of strong company policies to address deforestation, conversion of other natural ecosystems, and human rights abuses in agricultural and forestry supply chains. This section itemizes the elements of these Core Principles to help companies assess the alignment of their policies with the Framework. It can also be used as a reference to guide the establishment of new policies. Assessment should follow the three steps below:

Step 1: Define the assessment scopeTo ensure clarity in how the assessment is conducted and interpreted, the assessment scope should be clearly defined at the outset. It is helpful to specify both the scope of any existing company commitments/policies and the scope of the assessment, if different.1 All elements in the assessment should then be evaluated with respect to the assessment scope specified here.

Aspect of scope Scope of company commitment(s) Scope of this assessmentCommodities included Company activities included (e.g., production, sourcing, and/or financing – state “all” or specify which are covered vs. excluded)

Locations of production, sourcing, or financing included (e.g., countries of origin – state “all” or specify which are covered vs. excluded)

Types of suppliers included (e.g., own production, direct suppliers, indirect suppliers, smallholder suppliers – state “all” or specify which are covered vs. excluded)

Business units or affiliates (state “all” or 1 Often these will be the same, but in some cases companies may have different commitments/policies for different commodities or contexts and may prefer to assess these individually. 4


specify which are covered vs. excluded)Please specify any other exclusions:

5


Step 2: Review the relevant Accountability Framework documents and assessment elementsTo understand the elements of the Accountability Framework against which company commitments will be assessed, the user should read the Core Principle cited in the References list in each sub-section as well as the “Framework elements” in the second column of each assessment table. Where definitions are cited in the “Framework elements” column, these definitions must be considered when assessing alignment. For ease of use, most of the referenced definitions are provided as footnotes. Users should refer to the additional materials in the References list as needed for more detail on the Framework’s expectation and guidance related to each element.

Step 3: Assess alignment and document the basis for the assessmentNext, the company’s existing commitments and policies related to each Accountability Framework element should be identified. References to these materials (e.g., links to sources on the company’s website) should be provided in the column entitled “Existing company commitments or policies.” Brief summaries of the relevant commitment or policy elements may also be helpful to provide. Degree of alignment for this section of the tool is typically based on documentary information (i.e., publicly available company commitment and policy documents), but other forms of relevant information, such as interviews with company staff, may also be included if relevant for the assessment.

Based on a comparison of the company’s existing commitments or policies against each corresponding Framework element, the level of alignment for each element (aligned, partially aligned, or not aligned) should be indicated using the checkboxes in the “Degree of Alignment” column. Degree of alignment should be assessed based on the scope identified in Step 1. For instance, if the company has chosen to assess only its commitments related to palm oil, then determination of alignment should be based only on this single commodity.

Finally, for any element where alignment was determined to be “partially aligned” or “not aligned,” the right-most column should be used to summarize the gaps or differences between the company’s existing approach and the Framework element that resulted in this determination. Optionally, this column may also be used to explain or justify determinations of “aligned” when these are not obvious based on the information already provided.

Step 4: Develop plans and prioritize actions to address identified gapsMost companies conduct an assessment to understand gaps and opportunities for improving their approach to ethical supply chains. Once the assessment is completed and these gaps are better understood, a next step is to develop plans and prioritize actions to address the identified gaps. The Accountability Framework is a key resource to help guide such improvement processes. Users are encouraged to consult the References in each sub-section of the assessment tool for guidance and best practice on achieving full alignment for the elements where gaps are found to exist. Additionally, the AFi is releasing a new set of user tools on its website, including a step-by-step guide for writing a strong supply chain commitment. Companies are also

6


welcome to contact the AFi team to discuss how best to apply the Framework to address specific needs highlighted in the assessment.

Commitments related to deforestation and conversionReferences:

Core Principle 1 Terms and Definitions Operational Guidance on Applying the Definitions Related to Deforestation, Conversion, and Protection of Ecosystems Operational Guidance on Cutoff Dates

Commitments to no-deforestation supply chains (Core Principle 1.1)Note: If the company has a no-conversion commitment that addresses conversion of natural forests and is specified in accordance with the Accountability Framework (see the next assessment table, for Core Principle 1.2), then that commitment also fulfils the following elements of a strong no-deforestation commitment.

Accountability Framework elementsExisting company commitments or policies

Degree of Alignment

ExplanationIf company is partially aligned or not aligned, describe specific gaps

1 Company has a public commitment to no-deforestation production and/or sourcing

Aligned Partially

aligned Not aligned

2 The meaning of deforestation2 is clearly specified and aligned with AFi definitions

Aligned Partially

aligned Not aligned

3 Company commits to taking appropriate Aligned 2 Deforestation is defined as conversion (whether legal or illegal) of natural forests to agriculture, tree plantations, livestock production, or other land uses, as well as severe or sustained degradation. To demonstrate full alignment, the company’s definition of deforestation should: a) be clear, specific, and substantively the same as the AFi definition; b) include both legal and illegal deforestation; c) include conversion to tree plantations [in the case of pulp or timber supply chains]; d) include severe and sustained degradation as a form of deforestation; and e) be clear that the definition refers to no gross deforestation [i.e., it should not mention “net” deforestation, nor provide for offsetting of new deforestation through restoration, compensation, or other means]. 7

https://accountability-framework.org/contents-of-the-framework/cutoff-dates/

https://accountability-framework.org/contents-of-the-framework/applying-the-definitions-related-to-deforestation-conversion-and-protection-of-ecosystems/


https://accountability-framework.org/core-principles/?core_principle=86



Degree of Alignment


measures to support the long-term protection of natural forests3 in the company’s area of influence, including protection of conservation and cultural values

Partially aligned

Not aligned

4 Company commits to carrying out or facilitating restoration and/or compensation where it has caused or contributed to deforestation

Aligned Partially

aligned Not aligned

5 Commitment specifies a cutoff date4 and this date is aligned with AFi guidance

Aligned Partially

aligned Not aligned

Commitments to no-conversion supply chains (Core Principle 1.2)


Degree of Alignment


6 Company has a public commitment to no-conversion production and/or sourcing

Aligned Partially

aligned Not aligned

7 The meaning of conversion5 is clearly Aligned 3 Natural forest is defined as a forest that is a natural ecosystem. See natural ecosystem definition in footnote 6.4 Cutoff date is defined as the date after which deforestation or conversion renders the production unit non-compliant with no-deforestation or no-conversion requirements.5 Conversion is defined as change of a natural ecosystem to another land use or severe degradation that results in profound change in the ecosystem’s species composition, structure, or function. To demonstrate full alignment, the company’s definition of conversion should: a) be clear, specific, and substantively the same as the AFi definition; b) include both legal and illegal conversion; c) include severe and sustained degradation as a form of conversion; and d) be clear 8



Degree of Alignment


specified and aligned with AFi definitions Partially aligned

Not aligned8 Company commits to taking appropriate

measures to support the long-term protection of natural ecosystems6 in the company’s area of influence, including protection of conservation and cultural values

Aligned Partially

aligned Not aligned

9 Company commits to carrying out or facilitating restoration and/or compensation where it has caused or contributed to conversion

Aligned Partially

aligned Not aligned

10

Commitment specifies a cutoff date and this date is aligned with AFi guidance

Aligned Partially

aligned Not aligned

that the definition refers to no gross conversion [i.e., it should not mention “net” conversion, nor provide for offsetting of new conversion through restoration, compensation, or other means].6 A natural ecosystem is defined as an ecosystem that substantially resembles – in terms of species composition, structure, and ecological function – one that is or would be found in a given area in the absence of major human impacts. This includes largely “pristine” natural ecosystems; regenerated natural ecosystems; managed natural ecosystems; natural ecosystems that have been partially degraded.9


Commitments related to human rightsReferences:

Core Principle 2 Terms and Definitions Operational Guidance on Respecting the Rights of Indigenous Peoples and Local Communities Operational Guidance on Free, Prior and Informed Consent Operational Guidance on Workers’ Rights

Commitments to respecting all human rights (Core Principle 2.1)


Degree of Alignment


11

Company has a public commitment to respect internationally recognised human rights, including to avoid causing or contributing to adverse impacts to human rights and to prevent or mitigate such impacts linked to its operations7

Aligned Partially

aligned Not

aligned

12

Company specifies that its human rights commitment applies equally for all persons, regardless of gender and without discrimination

Aligned Partially

aligned Not

aligned13

Company commits to active engagement with stakeholders and to respecting their right to meaningful and effective

Aligned Partially

aligned

7 Companies’ obligation to respect human rights is specified in the UN Guiding Principles on Business and Human Rights. This element is to assess whether the company has a general commitment to respect human rights. Assessment of the adequacy of the commitment to address the rights of indigenous peoples and local communities and the rights of workers are addressed in the next two sub-sections of this tool. 10

https://accountability-framework.org/contents-of-the-framework/free-prior-and-informed-consent/

https://accountability-framework.org/contents-of-the-framework/respecting-the-rights-of-indigenous-peoples-and-local-communities/





Degree of Alignment


participation in decisions that may affect them

Not aligned

14

Company commits to providing effective grievance mechanisms that are accessible to all rights-holders and stakeholders

Aligned Partially

aligned Not

aligned

15

Company commits to providing for remediation where it has caused or contributed to adverse impacts to human rights

Aligned Partially

aligned Not

aligned

16

Company commits to protecting the rights of environmental and human rights defenders, whistle-blowers, complainants, and community spokespersons

Aligned Partially

aligned Not

aligned

Commitments to respecting the rights of indigenous peoples and local communities (Core Principle 2.2)

Accountability Framework elements Existing company commitments or policies

Degree of Alignment


17

Company has a public commitment to respect the rights of indigenous peoples and local communities (IP/LC) in all production, sourcing, and financial investments

Aligned Partially

aligned Not aligned

1 Company commits to ensuring operations Aligned 11


Accountability Framework elements Existing company commitments or policies

Degree of Alignment


8 are carried out in accordance with the UN Declaration on the Rights of Indigenous Peoples

Partially aligned

Not aligned19

Applicable for companies that own, control, or manage land: Company commits to secure the free, prior and informed consent (FPIC) of IP/LC prior to any activity that may affect their rights, land, resources, territories, livelihoods, or food securityApplicable for companies that source material from one or more producers or suppliers: Company commits to ensure that FPIC has been secured across its supply base and to require suppliers to conduct an FPIC process prior to any activity that may affect IP/LC rights, land, resources, territories, livelihoods, or food security

Aligned Partially

aligned Not aligned

20

Company commits to justly and fairly compensate or accommodate IP/LC where activities impinge on their rights, land, resources, territories, livelihoods, or food security

Aligned Partially

aligned Not aligned

21

Company commits to taking measures to provide remediation through mutually agreed procedures where it has caused or contributed to harm to IP/LC

Aligned Partially

aligned Not aligned

12


Commitments to respecting workers’ rights (Core Principle 2.3)


Degree of Alignment


22

Company has a public commitment to respect the internationally recognized rights of workers8 in all production, sourcing, and financial investments, including:

a. No child labourb. No forced or compulsory labourc. Freedom of association and collective

bargainingd. No discriminatione. No abusive practices or undue

disciplinary proceduresf. Legal and decent working hours g. Safe and healthy workplacesh. Living wages and fair benefits

See the AFi Definitions and the Operational Guidance on Workers’ Rights for further detail on the contents of commitments related to each of the eight specified workers’ rights.

a. Child labour

Aligned Partially

aligned Not aligned

b. No forced or compulsory labour

Aligned Partially

aligned Not aligned

c. Freedom of association or collective bargaining

Aligned Partially

aligned Not aligned

d. No discrimination

Aligned Partially

aligned Not aligned

e. No abuse practices or undue disciplinary procedures

Aligned Partially

aligned Not aligned

f. Legal and decent working hours

Aligned Partially

aligned Not aligned

g. Safe and healthy workplaces

Aligned Partially

8 Worker is defined to include employees, contractors, temporary, seasonal, part-time, and other workers.13



Degree of Alignment


aligned Not aligned

h. Living wages and fair benefits

Aligned Partially

aligned Not aligned

23

Commitment specifies its applicability to all workers, including employees, contractors, temporary, seasonal, part-time, and other workers

Aligned Partially

aligned Not aligned

24

Company commits to due diligence to Identify and assess actual and potential negative impacts to human rights, including workers’ rights, as a result of business activities and business relationships

Aligned Partially

aligned Not aligned

25

Company commits to creating permanent mechanisms for engagement with labour organizations, unions, and other worker advocates

Aligned Partially

aligned Not aligned

Specification of commitmentsReference: Core Principle 3


Degree of Alignment


26 Commitments apply to all segments of the Aligned 14




Degree of Alignment


company’s9 business for which agricultural or forestry commodities may pose environmental or social risks as a result of company’s own operations, sourcing, and/or financing

Partially aligned

Not aligned

27 Any exclusions from commitments are clearly specified and justified based on credible risk assessment

Aligned Partially

aligned Not aligned

28 For each aspect of its commitments, the company publicly specifies time-bound, quantitative, and geographically-specific targets and milestones that can be objectively evaluated and verified These targets and milestones specify achievement as quickly as feasible and align with applicable international, sectoral, or place-specific goals and targets relevant to each aspect of the commitment

Aligned Partially

aligned Not aligned

29 Commitments utilize the common Aligned 9 Company is defined as an enterprise, firm, or other organisational or legal entity involved in the production, provision, trade, or sale of goods and services (including financial services). This definition encompasses all company ownership structures, including privately-held, publicly traded, and state-owned companies as well as companies in which states hold an interest. For the purpose of the Accountability Framework, a company is defined to include the corporate group of which it is part. Corporate group is defined as the totality of legal entities to which the company is affiliated in a relationship in which either party controls the actions or performance of the other. This includes the company’s subsidiaries, affiliates, joint ventures, and majority holdings. See the AFi Definitions for factors that are used to determine whether a company is part of a broader corporate group.15



Degree of Alignment


definitions of the Accountability Framework Partially aligned

Not aligned

16


2. Tool for Assessing Company Implementation and Reporting SystemsThis section is designed to guide companies in assessing the extent to which their systems and practices align with the Accountability Framework’s Core Principles 4-12. These Principles address implementation, monitoring, and reporting related to ethical supply chains. Assessment should follow the four steps below:

Step 1: Define the assessment scopeTo ensure clarity in how the assessment is conducted and interpreted, the assessment scope should be clearly defined at the outset. It is helpful to specify both the scope of any existing company commitments/policies and the scope of the assessment, if different.10 All elements in the assessment should then be evaluated with respect to the assessment scope specified here.

If the scope was already defined for Section 1 of the assessment tool and the same scope will be applied for this Section 2, then only the first row of the following table needs to be completed; the remainder of the table is the same as the one in Section 1.

Aspect of scope Scope of company commitment(s) Scope of this assessmentTopics included (e.g., deforestation, conversion, rights of indigenous peoples and local communities, workers’ rights)

Commodities included Company activities included (e.g., production, sourcing, and/or financing – state “all” or specify which are covered vs. excluded)

Locations of production, sourcing, or financing included (e.g., countries of origin – state “all” or specify which are

10 Often these will be the same, but in some cases companies may wish to assess implementation and monitoring systems for commodities or business units for which they have not yet made commitments. In other cases, a company may have issued a broad, multi-commodity commitment but may find it more useful to assess their implementation and monitoring systems for one commodity or context at a time.17


covered vs. excluded)Types of suppliers included (e.g., own production, direct suppliers, indirect suppliers, smallholder suppliers – state “all” or specify which are covered vs. excluded)

Business units or affiliates (state “all” or specify which are covered vs. excluded)

Please specify any other exclusions from this self-assessment:

Step 2: Review the relevant Accountability Framework documents and assessment elementsTo understand the elements of the Accountability Framework against which company implementation and reporting systems will be assessed, the user should read the Core Principle cited in the References list in each sub-section as well as the “Framework elements” in the second column of each assessment table. Where Operational Guidance references are included in the “Framework elements” column, these materials must be considered when assessing alignment. For ease of use, the referenced sections may be directly accessed through the links to the AFi online platform. Users should also refer to the additional materials in the References list as needed for more detail on the Framework’s expectation and guidance related to each element.

Step 3: Assess alignment and document the basis for the assessmentNext, the company’s existing policies, systems, and activities related to each Accountability Framework element should be identified based on documentary information, interviews with company personnel, or other relevant information. These should be summarized in the column entitled “Existing company policies, systems, and activities,” including reference or links to documentary information where relevant. Examples of the types of evidence that might be useful to include in this column include:

Documented policies or procedures regarding company operations and supply chains, such as supplier codes and policies on land acquisition.

Evidence or descriptions of systems and procedures that the company uses to manage the social and environmental aspects of its operations and supply chains, such as traceability systems, systems for monitoring and data collection, procedures for addressing non-compliant suppliers, or systems for identifying and managing compliance of indirect suppliers.

18


Documentation of activities or practices that the company undertakes, or investments that it makes, to help achieve ethical supply chains. These could include, for example, descriptions of support or training for smallholder suppliers, evidence of participation in landscape or jurisdictional initiatives, documentation of incentives for suppliers to improve compliance, results of auditing activities, remediation or environmental restoration activities, partnerships with NGOs or government, or others.

The scope of any cited activities, practices, or investments should be contextualized relative to the full scope of the assessment. For instance, if a commodity buyer provides technical assistance to 6,000 smallholders in its supply chain, this number should be put in the context of the total number of smallholders participating in the supply chains that are within the scope of the assessment (e.g., as a percentage of total).

Based on a comparison of the company’s existing policies, systems, and activities against each corresponding Framework element, the level of alignment for each element should be indicated (aligned, partially aligned, or not aligned) using the checkboxes in the “Degree of Alignment” column. Degree of alignment should be assessed based on the scope identified in Step 1.

Finally, for any element where alignment was determined to be “partially aligned” or “not aligned,” the right-most column should be used to summarize the gaps between the company’s existing approach and the Framework element that resulted in this determination. Optionally, the column may also be used to explain or justify determinations of “aligned” when these are not obvious based on the information already provided.

Step 4: Develop plans and prioritize actions to address identified gapsMost companies conduct an assessment to understand gaps and opportunities for improving their approach to ethical supply chains. Once the assessment is completed and these gaps are better understood, a next step is to develop plans and prioritize actions to address the identified gaps. The Accountability Framework is a key resource to help guide such improvement processes. Users are encouraged to consult the References in each sub-section of the assessment tool for guidance and best practice on achieving full alignment for the elements where gaps are found to exist. Additionally, the AFi is releasing a new set of user tools on its website, including resources for designing or improving implementation and reporting systems in accordance with the Framework. Companies are also welcome to contact the AFi team to discuss how best to apply the Framework to address specific needs highlighted in the assessment.

19


Company systems and processes to drive effective implementationReferences:

Core Principle 4 Terms and Definitions

Accountability Framework elements

Existing company policies, systems, and activities

Degree of Alignment


30

Company has senior leadership responsibility and accountability to stand behind its commitments, including at CEO and/or board level

Aligned Partially

aligned Not

aligned

31

Commitments are embedded into decision-making processes, systems, and performance metrics of core business units and company affiliates and subsidiaries

Aligned Partially

aligned Not

aligned

32

Company has effective systems to guard against providing financing or other support to suppliers (including but not limited to producers) involved in deforestation, conversion of natural ecosystems, or adverse human rights impacts, except where this support is to implement time-bound improvement plans towards fulfilling the company’s

Aligned Partially

aligned Not

aligned

20




commitment33

Company has a stakeholder engagement process to provide relevant information to stakeholders, and afford opportunities for input and engagement related to fulfilment of the company's supply chain commitments

Aligned Partially

aligned Not

aligned

Supply chain assessment and traceabilityReferences:

Core Principle 5 Terms and Definitions Operational Guidance on Supply Chain Management (SCM) Operational Guidance on Rights of Indigenous Peoples & Local Communities (IP/LC) Operational Guidance on Relationship Between Voluntary Commitments and Applicable Law (Applicable Law)



Degree of Alignment


34 Company assesses incidence or risk of deforestation and ecosystem conversion in its operations and supply chainsIf risk assessment is used, it follows good practice according to SCM Section 3

Aligned Partially

aligned Not aligned

35 Company assesses incidence or risk of violations to IP/LC rights in

Aligned Partially

21

https://accountability-framework.org/contents-of-the-framework/supply-chain-management/?guidance_topic=2

https://accountability-framework.org/contents-of-the-framework/voluntary-commitments-and-applicable-law/


https://accountability-framework.org/contents-of-the-framework/supply-chain-management/






Degree of Alignment


its operations and supply chainsThe process follows good practice according to IP/LC Annex 1 and 2. If risk assessment is used, it follows good practice according to SCM Section 3

aligned Not aligned

36 Company assesses incidence or risk of violations to workers’ rights in its operations and supply base, including those associated with migrant labour, vulnerable workers, child labour, and dangerous work tasksIf risk assessment is used, it follows good practice according to SCM Section 3

Aligned Partially

aligned Not aligned

37 Company conducts applicable law assessments to identify relevant legal obligations that pertain to ethical supply chains commitments and to clarify whether the legal framework within which it operates will facilitate - or place at risk - its fulfilment of these commitmentsThese assessments follow good practice according to Applicable Law Annex 1 and 2

Aligned Partially

aligned Not aligned

22

https://accountability-framework.org/contents-of-the-framework/voluntary-commitments-and-applicable-law/?guidance_topic=5

https://accountability-framework.org/contents-of-the-framework/voluntary-commitments-and-applicable-law/?guidance_topic=4



https://accountability-framework.org/contents-of-the-framework/respecting-the-rights-of-indigenous-peoples-and-local-communities/?guidance_topic=6




Degree of Alignment


38 Company maps its supply chains and achieves traceability sufficient to know or control the compliance of purchased materials:

Applicable for primary processor or first intermediary trader: company knows the origin of raw materials to the level of the production unit (or farmer group), except when these are sourced from areas that are low risk11

Applicable for buyer (e.g., manufacturers, retailers, or traders purchasing from other traders): company traces supply upstream to the point where compliance can be ascertained. The following approaches can be used: a) tracing material to the

Aligned Partially

aligned Not aligned

11 Low risk is defined as a conclusion, following a risk assessment, that there is negligible or insignificant risk that material produced in or sourced from a given context is non-compliant with one or more aspects of a company’s social and environmental commitments or obligations. A determination of low risk should be assessed per context and risk topic (e.g., aspect of a company’s social and environmental commitments or obligations). A given production region may be considered low risk for one aspect of a company’s commitment but higher risk for other aspects. Risk assessments (including any determination of low risk) should be based on good practice for risk assessment elaborated in Section 3 of the Operational Guidance on Supply Chain Management.23




Degree of Alignment


production unit; b) via a third-party

certification scheme that is aligned with company commitments and includes effective traceability;

c) via supplier systems that provide control back to the production unit level;

d) sourcing from areas documented to be low risk (see footnote 10)

39 Company documents its traceability system and present status of traceabilityThis documentation follows good practice according to SCM Section 2

Aligned Partially

aligned Not aligned

24




Management for supply chain complianceApplicability: This section is for companies that source commodities from one or more producers or suppliers.

References: Core Principle 6 Terms and Definitions Operational Guidance on Supply Chain Management (SCM) Operational Guidance on Respecting the Rights of Indigenous Peoples and Local Communities (IP/LC) Operational Guidance on Smallholder Inclusion in Ethical Supply Chains (Smallholders)

Accountability Framework elements Existing company policies, systems, and activities

Degree of Alignment


40

Company communicates to suppliers that it will only accept material produced and controlled in accordance with its commitments

Aligned Partially

aligned Not

aligned

41

Company engages with direct suppliers to support compliance of indirect suppliers through effective incentives, support mechanisms, and purchase control systems

Aligned Partially

aligned Not

aligned

42

Company has documented criteria for when to retain, suspend, or exclude non-compliant suppliers, and adheres to these criteria This follows good practice according to SCM Section 4

Aligned Partially

aligned Not

aligned

25


https://accountability-framework.org/contents-of-the-framework/smallholder-inclusion-in-ethical-supply-chains/


https://accountability-framework.org/contents-of-the-framework/supply-chain-management/





Degree of Alignment


43

Company engages with non-compliant suppliers to develop and implement time-bound plans to achieve compliance and/or remedy past or ongoing harms This follows good practice as described in SCM Section 5

Aligned Partially

aligned Not

aligned

44

Where the company maintains long-term or recurring buying relationships with producers or primary processors, it supports these suppliers in achieving compliance

Aligned Partially

aligned Not

aligned

45

Company provides support to smallholders to enable their participation in ethical supply chains and to achieve compliance with company commitmentsSmallholder inclusion should follow good practice as detailed in Smallholders

46

Company has supplier codes, engagement activities, management systems and/or assurance mechanisms to ensure that suppliers adhere to company’s commitments on deforestation, conversion, and human rights in

Aligned Partially

aligned Not

aligned

26

https://accountability-framework.org/contents-of-the-framework/smallholder-inclusion-in-ethical-supply-chains/




Degree of Alignment


relation to supplier’s site establishment and land management activitiesThese mechanisms should require suppliers to fulfil Accountability Framework elements 47-51 below

Land acquisition, development, and managementApplicability: This section is for companies that own, manage, or control production areas or primary processing facilities. Responsibilities of downstream companies to address site establishment and management issues are addressed in element 46, above.

References: Core Principle 7 and Core Principle 8 (see also Core Principle 2.1) Terms and Definitions Operational Guidance on Respecting the Rights of Indigenous Peoples and Local Communities (IP/LC) Operational Guidance on Free, Prior and Informed Consent (FPIC)


Degree of Alignment


4 Prior to site establishment12, Aligned 12 In addition to land use planning and development, site establishment also includes land acquisition, designation, and/or permitting (e.g., issuance of a concession license or harvest permit, or designating a site for plantation development when it was previously designated for something else). Such changes in legal status or designation that precede development are a critical stage for ensuring that proper planning is implemented to ensure protection of natural ecosystems and respect for human rights.27

https://accountability-framework.org/contents-of-the-framework/free-prior-and-informed-consent/








Degree of Alignment


7 company conducts integrated and participatory assessments and land-use planning processes to: a. determine potentially impacted

stakeholders (using a social baseline assessment);

b. identify conservation and community values of land;

c. assess land tenure and use (using a participatory land tenure and use study);

d. evaluate potential impacts of the proposed activities; and

e. design plans to minimize negative impacts and mitigate unavoidable impacts

These processes: use recognized and technically

sound approaches; consider social and

environmental aspects together and in relation to one another;

are transparent; and include engagement of

potentially affected IP/LC and other stakeholders

Examples of recognized and technically sound approaches are

Partially aligned

Not aligned

28



Degree of Alignment


listed in footnote 3 within Core Principle 7

48

Where IP/LC are in or around the area of production, or where activities may affect IP/LC, company conducts and secures the free, prior, and informed consent (FPIC) of these groups and bases any plans for such activities on the negotiated outcomes of the FPIC and land-use planning processesSuch processes follow good practice according to FPIC Sections 2-4

Aligned Partially

aligned Not

aligned

49

In the case of ongoing land conflicts, company ceases efforts to acquire or gain control of land or resources related to the conflicts until they are addressed and mutually agreedThis follows good practices as described in IP/LC Section 2.3

Aligned Partially

aligned Not

aligned

50

When acquiring interests in land or resources, company assumes responsibility to remediate past harms unless another party explicitly accepts or retains responsibilityThis element is addressed in Core

Aligned Partially

aligned Not

aligned

29


https://accountability-framework.org/contents-of-the-framework/respecting-the-rights-of-indigenous-peoples-and-local-communities/?guidance_topic=1

https://accountability-framework.org/contents-of-the-framework/free-prior-and-informed-consent/?guidance_topic=1





Degree of Alignment


Principle 9.451

Company conducts or supports management activities to ensure long-term protection of conservation values and rights on lands that they own, manage, or control, and on adjacent areas. If mechanisms for management, monitoring, and long-term protection were defined as part of the site establishment process, these are implemented. If not, the company develops management and monitoring plans to ensure effective long-term protection

Aligned Partially

aligned Not

aligned

Access to remedy and environmental restorationReferences:

Core Principle 9 Terms and Definitions Operational Guidance on Remediation and Access to Remedy (Remedy) Operational Guidance on Environmental Restoration and Compensation (Restoration)


Degree of Alignment

ExplanationIf company is partially aligned or not aligned,

30

https://accountability-framework.org/contents-of-the-framework/environmental-restoration-and-compensation/

https://accountability-framework.org/contents-of-the-framework/remediation-and-access-to-remedy/






describe specific gaps52 There is a company grievance

mechanism in place (consistent with the effectiveness criteria of the UN Guiding Principles on Business and Human Rights) to receive complaints and remedy adverse social and environmental impacts linked to its operations and/or supply chainThe mechanism is designed and operated in accordance with good practice as described in Remedy Annex 1

Aligned Partially

aligned Not aligned

53 Company assesses existing state and non-state grievance mechanisms and supports efforts to strengthen and facilitate access to them as necessary to address grievances in its own operations and supply chains

Aligned Partially

aligned Not aligned

54 Where the company has caused or contributed to adverse impacts to indigenous peoples or local communities, it provides or cooperates in providing fair and just remedy (remediation) Remediation plans and activities follow good practice as described in Remedy Sections 3.1-3.5

Aligned Partially

aligned Not aligned

55 Where the company has caused or contributed to adverse impacts to

Aligned Partially

31

https://accountability-framework.org/contents-of-the-framework/remediation-and-access-to-remedy/?guidance_topic=2




workers’ rights, it provides or cooperates in providing fair and just remedy (remediation)Remediation plans and activities follow good practice as described in Remedy Sections 3.1-3.5

aligned Not aligned

56 Where the company has caused or contributed to environmental impacts (i.e., deforestation, conversion, and associated environmental impacts) occurring after the applicable cutoff date, it provides or cooperates in providing environmental restoration and/or compensation commensurate with the values lost Environmental restoration and compensation follow parameters for effectiveness as described in Restoration Sections 2.1-2.3

Aligned Partially

aligned Not aligned

57 Where applicable, activities associated with remediation, restoration, and/or compensation (assessment elements #54-#56) are appropriately monitored and reported

Aligned Partially

aligned Not aligned

32

https://accountability-framework.org/contents-of-the-framework/environmental-restoration-and-compensation/?guidance_topic=1



Collaboration for landscape and sector sustainability References:

Core Principle 10 Terms and Definitions Operational Guidance on Achieving Commitments Through Collaboration (Collaboration)

Note: Core Principle 10 focuses on the need for companies to collaborate with other actors to address challenges beyond their full control. This can be done in many different ways depending on the company’s position in the supply chain and ability to contribute to broader solutions, as well as the specific context of the company’s operations, sourcing areas, or financing portfolio. The assessment table below identifies some main categories of actions that companies might take to help address sustainability challenges at a landscape, jurisdictional, or sectoral level, but these categories are not exhaustive. Assessment related to Core Principle 10 should therefore include any additional company activities that are not listed below but that align with the intent of this Core Principle. Please see the Operational Guidance on Achieving Commitments Through Collaboration for additional information and examples of possible actions that companies can take in alignment with Core Principle 10.


Degree of Alignment


58 Applicable for companies that develop, own, or manage land, as well as traders that have a significant production/procurement footprint in a specific landscape: Company participates in or supports multi-stakeholder planning and policy efforts to improve land governance, avoid deforestation and conversion, and prevent adverse impacts to human rights through action at a landscape or

Aligned Partially

aligned Not aligned

33

https://accountability-framework.org/contents-of-the-framework/achieving-commitments-through-collaboration/





Degree of Alignment


jurisdictional levelExamples of actions are found in Collaboration Section 2.2 Applicable for companies further downstream such as manufacturers and retailers: Company participates in the above processes when warranted by its position in the supply chain and the scale of procurement or influence in specific areas

59 Company works with government and other stakeholders to promote publication of maps and other relevant information that can help accelerate compliance with commitments

Aligned Partially

aligned Not aligned

60 Company participates in sector initiatives to create collective or aligned goals, commitments, standards, coordinated implementation processes, monitoring systems, or other measures to increase effectiveness, expand scale, and minimize leakage13

Aligned Partially

aligned Not aligned

13 This may involve, for example: sharing risk assessment methodologies, sharing traceability information, sharing information regarding non-compliant suppliers, investigating new deforestation alerts, engaging indirect suppliers to support fulfilment of commitments.34

https://accountability-framework.org/contents-of-the-framework/achieving-commitments-through-collaboration/?guidance_topic=1



Degree of Alignment


61 Applicable for companies that operate in, or source from, contexts characterized by moderate to high social or environmental risk or poor governance: Company remains engaged in these settings, using influence and collaborating with others to strengthen governance and promote wider compliance and implementation of improved practices

Aligned Partially

aligned Not aligned

62 Company communicates (either individually or at a sector level) requirements for ethical supply chains, and provides incentives and support to help fulfil them, to prospective suppliers in the areas from which they source14

Aligned Partially

aligned Not aligned

63 Company encourages partners, suppliers, customers, industry groups, and other stakeholders to follow or adopt elements of the Accountability Framework

Aligned Partially

aligned Not aligned

64 Company advocacy and governmental engagement is consistent with the company’s

Aligned Partially

aligned

14 Note: this element addresses prospective suppliers in the landscape that may not yet be in the company’s supply chain but that produce commodities or are involved in land speculation or land development that is likely to result in bringing new land into commodity production. As such, this element complements element #41, which focuses on communicating requirements to suppliers that are already part of a company’s supply chain.35



Degree of Alignment


commitments, applicable law, and the elements of the Accountability Framework

Not aligned

65 Company publicly discloses all political contributions and campaign expenditures at all jurisdictional levels

Aligned Partially

aligned Not aligned

36


Monitoring and verification of company operations and supply chains References:

Core Principle 11 Terms and Definitions Operational Guidance on Monitoring and Verification (M&V)


Degree of Alignment


66

Applicable for companies that own, manage or control production or primary processing operations, as well as traders that buy from these entities and have visibility to the supply-base level: 15 Company regularly monitors compliance with (or progress toward) each of its commitments at the supply base level, and according to the topical scope of its commitmentsSuch monitoring follows good practices as described in M&V Sections 2.1, 3, and Annex 1 and 2

Aligned Partially

aligned Not aligned

67

Applicable for buyers: Company conducts regular monitoring to determine compliance with (or progress toward) each of its commitments at the supply base level,

Aligned Partially

aligned Not aligned

15 The supply-base level includes: 1) production units, i.e., farms, plantations, farmer groups, forest management units, and the like; 2) primary processing facilities—such as mills, slaughterhouses, silos, and aggregation sites—and their associated supplysheds; and 3) groups of production units and primary processing facilities located in close geographic proximity and under common management.37

https://accountability-framework.org/contents-of-the-framework/monitoring-and-verification/?guidance_topic=4




https://accountability-framework.org/contents-of-the-framework/monitoring-and-verification/





Degree of Alignment


and according to the topical scope of its commitments Users are encouraged to describe how this is accomplished through use of the following approaches: a. Monitoring at supply base level b. Monitoring of sourcing areas or

jurisdictions c. Monitoring of supplier

management and control systems (including certification) that link purchased supply with supply origins

Such monitoring follows good practices as described in M&V Sections 2 and 3, and Annex 1 and 2

68

Company has documented monitoring metrics against which compliance and performance are assessed. These metrics address all elements of company’s commitments16

Selection and specification of metrics follows good practice in M&V Section 3.3 and is consistent with the Accountability Framework Definitions

Aligned Partially

aligned Not aligned

16 Metric is defined as an objective and verifiable measure used to assess conditions, actions, outcomes, or trends (e.g., in relation to a given land area, facility, supply chain, company, process, or system). The Accountability Framework uses this term, rather than the closely related term ‘indicator’, although the terms may often be used interchangeably.38









Degree of Alignment


69

Monitoring systems and practices incorporate information from local stakeholders and affected parties

Aligned Partially

aligned Not aligned

70

Verification17 is carried out to assess and validate monitoring results and to provide the necessary level of assurance for internal management and external stakeholders External third-party verification is used when: there is a higher level of risk

associated with the operations, the commodity and/or the region OR

the level of trust between the company and its stakeholders is low and/or still evolving or stakeholders do not have sufficient information to assess company performance OR

Claims merit substantiated evidence OR

Third party verification is required by sectoral or other initiatives in which the company is engaged

Aligned Partially

aligned Not aligned

7 All verification demonstrates: Aligned

17 See Box 2 of the Operational Guidance on Monitoring and Verification for a definition of “verification” and its relationship to monitoring. “Verification” can include 1st, 2nd, and 3rd party approaches, all of which are recognized in the Accountability Framework as having potential roles in validating compliance or performance information. 39



Degree of Alignment


1 Consistency through documented procedures

Rigorous methodologies, including appropriate audit intensity

Competent auditors Impartiality and independence Transparency through

stakeholder engagement, grievance management, disclosure of information

Linkages to improvement processes

Retention and documentation of evidence

These elements are further detailed in M&V Section 4.1

Partially aligned

Not aligned

72

Third-party verification reports (or summaries thereof) are made publicly available

Aligned Partially

aligned Not aligned

73

Company uses the results of monitoring and verification to help inform learning, decision-making, and continuous improvement

Aligned Partially

aligned Not aligned

40



Reporting, Disclosure, and Claims References:

Core Principle 12 Terms and Definitions Operational Guidance on Reporting, Disclosure, and Claims (RDC)


Degree of Alignment


74

Company publicly reports progress and outcomes related to the implementation of its supply chain commitments at least annually

Aligned Partially

aligned Not aligned

75

Reports include information on:a) the extent to which the origins of

materials in its supply chains is known or controlled

b) the degree of compliance with or progress toward commitments

c) reasons for non-compliance, where applicable

d) activities and systems involved in the implementation of commitments, as described in RDC Annex 1

e) monitoring methodology, data sources, and whether and how the information has been independently verified

Aligned Partially

aligned Not aligned

7 Metrics used in reporting are based on Aligned

41

https://accountability-framework.org/contents-of-the-framework/reporting-disclosure-and-claims/?guidance_topic=5


https://accountability-framework.org/contents-of-the-framework/reporting-disclosure-and-claims/





Degree of Alignment


6 clear and accepted terminology and align with common reporting systems and platformsAlignment with reporting systems is described in RDC Section 1.3 and associated Resource document

Partially aligned

Not aligned

77

Reports are made freely available in formats and languages that are accessible to all key stakeholders, as defined in the Framework

Aligned Partially

aligned Not aligned

78

The company discloses information on its suppliers, supply origins, and the nature and status of any associated non-compliances and grievances as appropriate to its role in the supply chainThe information disclosed follows RDC Section 3

Aligned Partially

aligned Not aligned

79

Claims and communications about company progress or performance include information on topical scope, extent, timeframe, performance level, degree of attribution, and supporting information, following RDC Section 4.1.1

Aligned Partially

aligned Not aligned

80

Claims and communications about company progress or performance are substantiated by public reporting and

Aligned Partially

aligned

42








Degree of Alignment


by verification consistent with RDC Section 4.1.2

Not aligned

43



Documents

Overview · Web viewHowever, information collected or used to conduct the assessment (e.g., company policy documents, procedures, contracts, systems, or reports) may also help substantiate