A/HRC/35/37 74. The assurance programme must not only be based on third-party audit mechanisms but also use monitoring schemes that include workers and trade unions as an alternative source of information to allow an ongoing assessment of compliance with the labour-related standards. If necessary, multi-stakeholder initiatives should develop specific guidance to ensure that potentially vulnerable workers, such as migrants, young people and women, are not excluded from monitoring mechanisms. 75. The assurance programme must require that, during auditing exercises or alternative monitoring mechanisms to assess indicators of labour exploitation, sufficient time be allocated for auditors to interview workers, that any necessary interpretation services be provided, that any arrangements necessary to address gender concerns be made, that interviews be held outside the workplace if possible, and that sufficient time be allocated for document review, management interviews, interviews of other relevant stakeholders, such as local trade unions and communities, and report writing. 76. Multi-stakeholder initiatives should define indicators to assess the risk level of clients and determine the intensity and frequency of audits. Such indicators should take into account elements such as State ratification and enforcement of relevant international conventions on human rights and labour standards; the existence of regulatory regimes that regulate recruitment activities in accordance with international standards and guidelines; the level of informality within the economic sector in which the client operates; the percentage of vulnerable groups in the client’s workforce, including the number of migrant, temporary, seasonal, contractual or home-based workers; the level of complexity of the client’s labour supply chains; and client’s previous record on these issues. 77. Multi-stakeholder initiatives should ensure that an evaluation of labour recruiters, when such recruiters are used by the supplier to recruit workers or as employment agents, is included in the assurance process and that the abovementioned criteria and indicators that are under the control of those intermediaries, as recruitment or employment agents, are applied. The results of the evaluation of the labour recruiters’ compliance should be made an integral part of the evaluation of the company’s compliance and have an effect on the determination of certification status. 78. Multi-stakeholder initiatives should ensure that assurance providers and auditors have demonstrated knowledge and experience in assessing compliance with labour-related standards and in interviewing workers on an ongoing basis. When risk indicators are identified, the initiatives should consider requiring the collaboration of assurance providers and auditors with civil society organizations that are specialized in victim identification and that provide specialized services for trafficked persons. Multi-stakeholder initiatives should ensure that specialized services address gender concerns and that services are offered to both men and women. They should also consider including forced labour and human trafficking experts in oversight bodies. 79. Multi-stakeholder initiatives should provide specific training to auditors and assurance providers on trafficking in persons to improve their skills in risk detection and evaluation of risk indicators; the training should also cover how to interview workers and should raise awareness of worker vulnerabilities, including those related to gender or migration status. 80. Multi-stakeholder initiatives should consider engaging with auditors and other monitoring mechanisms when designing and establishing auditing protocols and monitoring modalities to ensure that they are effective for identifying risk indicators in practice. 81. Multi-stakeholder initiatives should develop specific deep dive audit protocol modules on trafficking in persons indicators and guidance to be used when predefined red flags of trafficking and forced labour are first detected, allowing auditors to enlarge the audit scope and uncover the full extent and depth of the problem. 82. Non-conformity with human trafficking and forced labour standards should entail suspension of certification or any other envisioned sanction of a similar nature 16

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