Detection Modules
Systematically identifying potential risks in our supply chainMonitoring adherence to the requirements and principles of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries, and consequences of misconduct
We aim to minimize risks and leverage the opportunities in our network of suppliers to best effect. Our supplier management process therefore focuses not only on quality, costs and availability, but also on our suppliers鈥 ability to innovate, and sustainability aspects. In addition, we have developed a system of suitable processes (detection modules) that allow us systematically to identify potential risks in our supply chain. These detection modules consist of supplier evaluations and self-assessments, as well as on-site inspections (audits).
- Risk-based Approach
- Corporate Responsibility Self-Assessment
- Incident Driven Inspections
- Supplier Quality Audit
- External Sustainability Audits
To proactively identify sustainability-related risks in our supply chain we apply a risk-based approach. This framework makes use of both internal and external information sources that enable us to focus our risk mitigation activities where they are most needed. Within this framework a customized action plan for the future is drawn up for any supplier identified as high-risk. Possible actions include the initiation of a development plan, a sustainability audit or the phasing-out of the supplier.
Sustained adherence with the requirements and principles of the Code of Conduct for 德州扑克在线 Suppliers is checked using the following elements:
- Risk-based Approach
- Corporate Responsibility Self Assessment
- Incident Driven Inspection
- Supplier Quality Audits
- External Sustainability Audits
The internal approach systematically identifies those suppliers with potential risks that have been addressed through our supplier qualification process and regular supplier quality audits. Suppliers that perform below a certain predefined threshold are added automatically to a list of suppliers with potentially elevated risk. The list is shared with the responsible Procurement units at the Divisions, which then take further steps to clarify the situation.
We also make use of external sources to identify risk. Examples of such sources are non-governmental organization (NGO) databases, media reports or information channeled through our compliance ombudsman or听'Speak up' hotline.听Any report of a suspected breach of the requirements of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries undergoes a clarification process to determine the next steps to be taken, e.g. what is known as an incident-driven inspection. To achieve complete risk screening of our procurement portfolio, a risk mapping framework has been developed on the basis of external data. The framework includes country risk mapping and commodity risk ratings
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Country risk mapping
In order to provide an overview of sustainability-related risks, the country risk mapping framework comprises 15 sustainability risk indicators for each country. The indicators relate to areas such as water security, potential corruption, and human rights.听
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Commodity risk ratings
To assess the risks involved in sourcing different commodities, each of our commodity categories has been rated in terms of sustainability-related risks. The risks include environmental, labor practice & occupational health and safety matters.
The Corporate Responsibility Self-Assessment takes the form of an online questionnaire on our SCM STAR supplier portal.
As an essential module in our supplier qualification process it serves three important purposes:
- To communicate what sustainability at 德州扑克在线 means and what our minimum requirements are in order to become a 德州扑克在线 supplier
- To give our suppliers a method of identifying risks and opportunities for improvement at an early stage in our cooperation
- Based on the identified risks, to define corrective actions for mitigation as part of the 德州扑克在线 supplier development framework
Once the supplier qualification process has been initiated the supplier will receive an invitation to complete the Corporate Responsibility Self Assessment electronically in SCM STAR. The questions check a selection of basic requirements as set out in our Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries.
The result of the Corporate Responsibility Self-Assessment will be calculated in the supplier portal and displayed in the form of a traffic light.
- Category 'green': The supplier has met and implemented the requirements in a sustainable manner and does not present a corporate responsibility risk.
- Category 'yellow': The supplier shows minor deviations from the requirements of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries and presents a potential corporate responsibility risk.
- Category 'red': The supplier shows significant deviation from the requirements of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries and presents a potentially severe corporate responsibility risk.
The Corporate Responsibility Self-Assessment remains valid for 3 years after completion. When the questionnaire becomes due for renewal, the supplier will receive an automatic e-mail invitation to complete the questionnaire again. If discrepancies are identified in the questionnaire with regard to the requirements of the Code of Conduct, the system automatically generates a corrective action plan that needs to be confirmed by the supplier.
The Corporate Responsibility Self-Assessment follows a risk-based approach by focusing on suppliers whose main manufacturing base is located in non-OECD states. Nevertheless, if there is any suspicion of non-adherence to the Code of Conduct for 德州扑克在线 Suppliers, the Corporate Responsibility Self-Assessment can be executed regardless of the supplier's location.
While a green light indicates no sustainability risks, a yellow or red light indicates a potential sustainability risk and therefore requires action. Based on the identified discrepancies a corrective action plan will be created and automatically recorded in the supplier development module. Each of the corrective actions also has a defined time frame (grace period) for implementation.
Suppliers are able to access SCM STAR听and report on how implementation of the corrective actions is progressing. Once all corrective actions have been confirmed as implemented by the supplier, the mandated buyer can close the corrective action plan in the system.
德州扑克在线 may also initiate an external sustainability audit on the supplier's premises to ensure proper implementation of the corrective actions through an assessment by an independent sustainability auditor. If the required corrective actions, despite assistance from 德州扑克在线 Enery, are not implemented within the grace period, whether due to lack of commitment or ability, 德州扑克在线 will endeavor to resolve the problems in an escalation meeting together with the supplier.
If all efforts remain unsuccessful, 德州扑克在线 reserves the right to terminate the business relationship and phase out the supplier.
In the event of identified breaches of the requirements of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries, incident-driven inspections will be initiated to minimize risks in the supply chain.
An incident-driven inspection is an on-site inspection that focuses specifically on the investigation of specific breaches of the Code of Conduct.
During the inspection, a nominated specialist in the relevant topics will review the current status of the supplier鈥檚 site and define corrective actions jointly with the supplier in order to meet the 德州扑克在线 requirements in a sustainable manner. The implementation of these corrective actions has to start immediately and will be checked in a follow-up inspection once a reasonable time frame for implementation, defined by the nominated specialist, has ended.
The mandated specialist in the topics covered by the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries will be an in-house 德州扑克在线 employee trained in these topics or a specialist from an external,听certified company working on behalf of 德州扑克在线.
These inspections are carried out at the supplier's site if
- a strong suspicion exists that there has been a breach of the requirements of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries (e.g. media reports, information from recognized and reliable sources), or
- the Corporate Responsibility Self-Assessment produces a confirmed result of "Category red".
Should the nominated specialist find unrecoverable conditions at the site, or conclude that the proposed actions have not been implemented and/or that a commitment to improvement is lacking, he or she will recommend that business with the supplier be suspended. As a last resort 德州扑克在线 will terminate the purchasing contracts.
德州扑克在线 sustainability requirements are also checked within the regular supplier quality audit.
Within the scope of the regular supplier quality audit, compliance with the requirements of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries is checked through integrated sustainability questions.
The relevant questions about sustainability are included in all quality audits in both higher and lower risk countries.
Having experienced an increase in the number of agreed improvement measures, we have been encouraged to concentrate even further on our auditing and capacity-building efforts with our suppliers.
The agreed corrective actions do not predominantly reflect violations of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries, but apply mainly to structural improvements in the management systems for sustainable compliance with the requirements of the Code of Conduct (such as missing or incomplete policies, guidelines, information and training, or organizational provisions).
External sustainability audits (ESA) are intended to verify adherence to the requirements of the 鈥淐ode of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries鈥 and assess the sustainability performance of our supply chain. 德州扑克在线 has appointed internationally recognized auditing companies to conduct these on-site audits based on the universally valid principles of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries. The outcome is an in-depth assessment and report that enables 德州扑克在线 and its suppliers to identify and manage potential sustainability risks.
The suppliers in focus for external sustainability audits are selected in accordance with a risk-based approach. This evaluation identifies the parts of our supplier base that present potential sustainability risks, and which merit the more detailed inspection provided by an external sustainability audit.
In addition, an external sustainability audit can also be triggered if a potential sustainability risk has been indicated by a 鈥榬ed鈥 result in a Corporate Responsibility Self-Assessment. If the circumstances concerning the deviations from the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries, as declared in the Corporate Responsibility Self-Assessment, remain and the situation merits a more detailed investigation, an external sustainability audit should be initiated.
Suppliers undergoing an external sustainability audit will be asked to schedule an audit with the appointed auditor within a defined time window. The audits relate solely to the supplier's conformance and performance in relation to the six categories of the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries.
The audit process follows these steps:
- A kick-off meeting in which management is briefed on the audit scope, methodology and audit process, and interviewed regarding policies and topics with relevance for the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries
- A physical inspection of the factory/facility to cross-check the reported/documented non-conformances with the current situation
- Employee interviews to obtain information about employee work conditions in the facility and check the implementation of policies and procedures that ensure that the requirements of the Code of Conduct are met
- A final review of the reports to assess compliance with labor or pay guidelines
The auditor treats all information as confidential, to the extent that such information is not already published, generally available to third parties or otherwise already in the public domain.
The suppliers in focus for an external sustainability audit are selected in accordance with a听risk-based approach.听This framework systematically identifies suppliers with a high risk that have been evaluated within our supplier qualification process and in our regular supplier quality audit. An external sustainability audit can also be initiated if 德州扑克在线 identifies risk through external sources. Examples of such sources are non-governmental organization (NGO) databases, media reports or information channeled through our ombudsman or 鈥楽peak up鈥 hotline.
Any report of a suspected breach of the requirements of the Code of Conduct for 德州扑克在线 Suppliers may result in an external sustainability audit to assess the full scope of our Code of Conduct.
External sustainability audits also play an important role in the scheme of supplier development by improving the supplier's sustainability profile. In addition to the supplier assessment aspects, suppliers can enhance their awareness of 德州扑克在线鈥 sustainability requirements.
In the event of any discrepancies with the Code of Conduct for 德州扑克在线 Suppliers and Third-Party Intermediaries, corrective actions must be agreed between the auditor and supplier. A time frame (grace period) for implementation will be agreed for each corrective action which, depending on the nature and extent of the action, can cover a period of weeks or months. The agreed corrective actions are documented and monitored regularly.
A follow-up audit is scheduled at which the auditor checks whether the corrective actions have been implemented.
If the required implementation of corrective actions, despite assistance from 德州扑克在线, proves ineffective, 德州扑克在线 will endeavor to resolve the problems in a meeting together with the supplier. If all efforts remain unsuccessful, whether due to lack of supplier commitment or ability to develop the supplier, 德州扑克在线 reserves the right to scale back or terminate the business relationship.
How do you, as a supplier, actively ensure听us that the requirements of the Code of听Conduct are implemented and sustained?
We expect our suppliers to:
- Answer enquiries regarding compliance with the Code of Conduct within the requested time.
- Actively support the need for clarification and demonstrate active co-operation and willingness to improve, should a potential risk arise from the information in the Corporate Responsibility Self-Assessment, for example failure to check the age of young employees or non-implementation of corrective measures in the case of a well-known environmental incident.
- Permit the quality auditors access to the required documents and areas so that they can gain a full awareness of your compliance with the Code of Conduct.
Make competent employees available for confidential interviews at Regular Supplier Quality Audits, External Sustainability Audits and Incident Driven Inspections.
