A/HRC/35/37 and level of severity. A stepwise plan should be established together with the companies to ensure that issues of non-conformity are corrected and workers are not negatively affected by the sanction applied. B. Recommendations to assurance providers and auditors 83. Assurance providers and auditing companies should ensure that auditors performing workplace assessments are trained in identifying and evaluating risk indicators of trafficking in persons, forced labour and labour exploitation, including risks related to unethical recruitment practices. 84. When performing an audit, assurance providers and auditing companies should ensure that sufficient time is allocated to interviews with workers and worker representatives, that gender concerns are appropriately addressed and that sufficient resources are allocated to engaging interpreters to support auditors when necessary. 85. In the event that the audited company uses labour recruiters, a specialized audit protocol should be in place to assess the risks in their recruitment practices. 86. Assurance providers and auditing companies should supplement information obtained through worker interviews and document reviews with alternative sources of information, including from trade unions and civil society stakeholders who are active in the sector and region. 87. Assurance providers and auditing companies should consider sharing aggregated data on audit results with governments and other relevant stakeholders to support government-level strategies in combating trafficking in persons for labour exploitation that are based on empirical evidence. C. Recommendations to companies 88. Companies should establish and implement a company policy on the elimination of trafficking in persons from the company’s supply chains or adhere to a multi-stakeholder initiative or industry coalition that addresses trafficking in persons and forced labour in accordance with the recommendations set out in the present report. The policy must be part of the company’s larger human rights policy commitment and the continuous human rights due diligence the company conducts in accordance with the framework established in the Guiding Principles on Business and Human Rights. Adherence to the policy must be recognized by the highest level of management in the company. A company establishing its own policy should seek the collaboration of workers, trade unions and civil society to formulate the policy and implementation measures that effectively address issues related to trafficking in persons. 89. In selecting new suppliers, companies should develop an evaluation mechanism that takes into account a supplier’s compliance with the policy the company has adopted or to which it adheres, by establishing risk indicators such as those mentioned in the recommendations set out above for multi-stakeholder initiatives on strengthening criteria and indicators. Companies should widely communicate among potential bidders the conditions for selection. 90. Companies should integrate their policies on trafficking in persons, forced labour and any other form of labour exploitation as a binding part of contracts with suppliers. Communication should be clear regarding the application of sanctions in the event of non-compliance by the supplier itself or issues of non-compliance found further down in the supplier’s supply chain, including in their labour supply chain. Sanctions may include the immediate termination of a contract where grave violations of workers’ rights are found. A stepwise plan should be established together with the supplier to ensure that issues of non-compliance are corrected and that workers are not negatively affected by the sanction applied. The plan should include specific 17

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