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The Assent Compliance Platform How to Mitigate Human Trafficking & Child Labor Risk in Your Supply Chain

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The Assent Compliance Platform How to Mitigate Human Trafficking & Child Labor Risk in Your Supply Chain THE ASSENT COMPLIANCE PLATFORM HOW TO MITIGATE HUMAN TRAFFICKING & CHILD LABOR RISK IN YOUR SUPPLY CHAIN 1 THE ASSENT COMPLIANCE PLATFORM HOW TO MITIGATE HUMAN TRAFFICKING & CHILD LABOR RISK IN YOUR SUPPLY CHAIN ABOUT ASSENT Assent takes a multi-tiered approach to providing Assent provides a full compliance program capturing online tools, applications and consulting to clients in due diligence expectations to satisfy a company’s a variety of sectors. We combine a foundation in IT legal and internal policy requirements towards an- with regulatory consulting and project management ti-human trafficking measures. This full compliance to provide solutions that address the ever-changing program can be used to satisfy other anti-human landscape of regulatory compliance needs. We are a trafficking laws (i.e. California’s Transparency in the progressive organization that stays on the forefront Supply Chain Act and the UK Modern Slavery Act). of fluid regulations in order to help our clients adapt their strategies quickly and cost effectively. Our goal This compliance program has been developed using is to implement solutions that allow our clients to specific subject matter expertise from Verité – the focus their resources on their core business rather leading anti-human trafficking NGO that is preparing than compliance issues by instituting proactive ini- the Federal Acquisition Regulation (FAR) Guidance tiatives that simplify the compliance process. for the U.S. Government. CORE AREAS OF EXPERTISE APPROACH TO MONITOR » Regulatory Compliance and Consulting & DETECT » Ethical Sourcing, Conflict Minerals, Restricted The Federal Acquisition Regulation requires that Substances and Inspections firms develop a system to monitor and detect human » IT Solutions and Development trafficking activities pursuant to clauses 52.222-50 / 52.222-56. It is Assent Compliance’s position that » Project Management and Solution Integration to be compliant with FAR 50/56 it is essential that a firm is proactive in their due diligence. ABOUT HUMAN TRAFFICKING The Assent Compliance program and methodology outlined in this guide was developed in conjunction Human trafficking has become a global epidemic. with industry leading experts, including Verité. The dramatic increase of these illicit activities world- wide has led to the Department of Defense (DOD), The Assent program is proactive and preventative in the National Aeronautics and Space Administration nature rather than being a reactive program similar (NASA) and the General Services Administration to a world information crawler that provides alerts. (GSA) to publish the final anti-human trafficking rule We are preventative in that our system preemptively amending the current Federal Acquisition Regulation creates risk profiles of your suppliers. It acquires data (FAR) provisions. These amendments increase re- from your global supply chain based off of a credible sponsibilities for companies doing business with the and consistent process developed with guidance U.S. Government. 2 from partner NGOs, internal subject matter experts Assent will gather subcontractor declarations of and government guidance. It also narrows the focus conformity for identified subcontractors, provide of monitoring and detection, allowing you to focus verification analysis and convert proprietary sub- resources and energy on real risks. contractor declaration information into a single, client-based format. This allows our clients to accept Relying solely on reactive detection through the media a wide range of different subcontractor formats (pdf, and sanction lists only ensures human traffickers word, excel, etc.), while still being able to generate the time and space needed to securely conduct their risk analysis reports and cross-reference different illicit activities. One of the benefits of the Assent subcontractor information. These features enable program is the built-in mitigating factors that varying subcontractor declarations to be rolled up authorities will be looking for in the case of a potential into prime contractor and contracting officer level violation. Demonstrating that you actively pursued reporting needed for anti-human trafficking verifica- your supply chain for information in an effort to tion requirements. uncover any issues, alongside passively monitoring the world sanctions lists, will be viewed extremely All of the information above is made available inter- favourably if demonstration of your due diligence is nally in Assent’s system and through report extracts required. for proof of due diligence as required for anti-human trafficking audits. Assent Compliance believes that our program of active and passive monitoring and detection is vital for compliance with the FAR clauses, California Transparency in Supply Chains Act and the UK’s Modern Slavery Act. SOFTWARE & SUPPORT SERVICES The Assent Compliance Platform is a fully customizable, cloud-based software solution which enables our clients to achieve regulatory compliance, monitor and maintain their regulatory compliance status and implement a wide range of anti-human trafficking control programs. This allows for automatic updates as regulations are revised and new products are added to the system in order to provide real-time documentation of due diligence and regulatory conformity. All of the information generated by the Assent system can be fully integrated with your existing PLM/ERP systems. Assent will provide education and training via As- sent University to internal users and subcontractors regarding anti-human trafficking compliance and introduce subcontractors to a portal where they can submit their declaration information directly to As- sent’s database. 3 ANTI-HUMAN TRAFFICKING MODULE INTERFACE OVERVIEW The Assent Compliance Platform Anti-Human Traf- ficking Module was designed to ensure all aspects of our clients programs have clear visibility into the operations, activities and hiring practices, including migrant worker recruitment, of their supply chain. The following images provide a sample of the module’s various included features. LOGIN & HOME SCREEN On initial login to our system you are presented with a comprehensive dashboard view, showing up-to-date data on how your campaigns are performing for survey send-outs to your supply chain. 4 ANTI-HUMAN TRAFFICKING SUPPLIER LIST & DETAILED SUPPLIER VIEW This screen displays a list of every one of your suppliers who are in-scope for Assent’s Modern-Slavery and Anti-Human Trafficking survey. The Detailed Supplier View gives you a deep look at every supplier in your supply chain. With a heads up view of their stage in our survey process, overall sta- tus of company for risk level, user and audit logs, and our monitor and detection report for each company. 5 USER TAB & AUDIT LOG TAB The User tab shows you who at the supplier’s company has received an email and filled it out. The Audit Log tab shows you the record* of all actions taken to determine the risk calculation. * Data has been simulated as representation of actual data. 6 SUPPLIER SURVEY (PARTIALLY COMPLETED) This is what suppliers see when they accept the link emailed to them to take our survey. Suppliers can comment and ask questions on each of our survey questions. In case something is unclear, they want more details, and/or further details on how to respond, they can click the chat bubble and post a question related directly to that survey response. EMAIL ALERTS & NOTIFICATIONS Our system has many controls for setting up email alerts based on the responses you receive from our survey as well as our monitor and detection methods. You can customize the frequency of alerts via: » As-it-happens alerts; » Daily rollup; » Weekly rollup; » Monthly rollup. As well as customize via severity of alert, for example: » Notify me as-it-happens for High Risk cases; » Notify me with a Monthly rollup for Low Risk cases; » Notify me with a Weekly rollup for Medium Risk cases; » Notify me as-it-happens for monitor and detection alerts of medium or higher risk. 7 that the relevant supplier go through a more in-depth ANTI-HUMAN assessment process with one our partner NGOs. TRAFFICKING The survey assesses risk of modern slavery and SURVEY GUIDANCE human trafficking using the following framework: Assent Compliance’s anti-human trafficking and The supply chain environment: modern slavery risk and compliance assessment survey enables clients to track compliance and to » Geographical location(s)/countries identify areas in their supply chain where there is » Industry or sector likely a higher risk of human trafficking and forced labor occurring, and/or remaining undetected, linked » Workplace characteristics to supply chain environment and characteristics Practices and policies (locations, industries, workforce characteristics, industry/sector) and to the practices, policies, agree- A supplier/service provider’s internal practices and ments and requirements in place within the supply policies around: chain. Assent Compliance has developed this risk a. Recruitment practices and use of labor recruiters assessment survey based on reports, research and b. Auditing resources from recognized expert sources in the field of forced labor and human trafficking such as the c. Prohibition of withholding employee ID and International Labor Organization, the U.S. State De- immigration documents partment Trafficking in Persons reports, Verité and d. Employee grievance mechanism/reporting others. These resources provide guidance on prac- process tices and conditions
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