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Completing the STRT Form

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Helen Christodoulou
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The Social Responsibility Alliance (SRA) provides an in-depth guide on filling out and completing an STRT. Please click [here] to download the Supplier User Guide PDF from their website. 

The STRT is separated into six sections, or tabs. These tabs are:

  • Introduction
  • Declaration
  • Countries
  • Sectors
  • Review
  • Glossary

This document explains each tab, along with instructions on how to complete each section.

Please Note: If you attempt to enter data into a protected cell, the template will generate a warning message referring to a 'protected sheet'. To continue, click into another yellow cell to enter your data:

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Introduction

When completing the STRT, you will begin on the Introduction tab. It includes an introduction to the STRT, an explanation of how it works, and an overview of each of the tabs so users are able to complete the template accurately.

Declaration

The Declaration tab represents the bulk of the STRT. In this section, you will respond to a series of questions designed to assess risks of slavery and human trafficking and non-compliance with human trafficking and slavery regulations.

The Declaration tab is separated into several categories. Each category contains questions pertaining to specific slavery and human trafficking-related topics.

ORGANIZATION INFORMATION

  • Organization Name: Input the name of the organization completing and submitting the STRT. Do not use abbreviations.
  • Organization’s Unique Identifier Number or Code (Optional): Input the DUNS number, VAT number, customer-specific identifier, or another number or code unique to your organization.
  • Organization Address (Optional): Input your organization’s mailing address. If your organization operates in more than one location, input the head office’s information.
  • Contact Person’s Full Name: List the full name of the primary contact person for any communications with regard to the information provided within the STRT.
  • Contact Email: List the contact person’s email.
  • Contact Phone Number: List the contact person’s phone number.
  • Authorizing Person’s Full Name: List the full name of the person authorized to declare the contents of this survey as true and accurate to the best of his/her knowledge. The authorizing person may be different than the contact person.
  • Authorizing Person’s Title: Enter the authorizing person’s title within the organization.
  • Authorizing Person’s Email Address: List the authorizing person’s email address.
  • Authorizing Person’s Phone Number: List the authorizing person’s phone number (country code + number).
  • Date of Completion: Enter the date upon which the survey was completed. Dates should be formatted YYYY/MM/DD.

Supporting Documentation

If you answer ‘Yes’ to any question regarding existence of a policy or document maintained by your organization, the Supporting Documentation Required column will indicate the file that is required in red.

Choose the ‘URL’ or ‘File’ option from the drop down in the URL or File field. Add the URL or corresponding file name(s) into the Insert URL to relevant document(s) or corresponding file name(s) field of the Declaration tab.

SCREENING & PRIORITIZATION

Q1: Where does your organization have operations? Please select all countries that apply on the ‘Countries’ tab.

  • This question requires users to identify if their company operates within any of the countries listed in the Countries tab.
  • Warning: You cannot enter information directly into cell F23 of the Declaration tab. To respond to this question, click to the 'Countries' tab. If your company operates in any of these countries, select or type ‘Yes’

Q2: Do your suppliers have operations in any of the countries listed as Tier 2, Tier 2 Watchlist, Tier 3, or Special Cases on the ‘Countries’ tab?

  • This question does NOT require you to select the countries on the Countries tab within which your suppliers operate.
  • To answer this question, refer to the list of countries on the Countries tab, and if you have suppliers operating in any of these countries, then select or type ‘Yes’ in the corresponding Response field on the Declaration tab.
  • If you do not have suppliers operating in any of the countries on the Countries tab, select or type ‘No’ in the Response field. If your organization does not work with any suppliers, select or type ‘N/A — We do not work with any suppliers.’

Q3: Does your organization have operations in any of the Chinese provinces and cities listed on the ‘Chinese Provinces and Cities’ tab?

  • If yes, please select all that apply on the ‘Chinese Provinces and Cities’ tab.
  • To answer this question, please refer to the list of Chinese provinces and cities in the ‘Chinese Provinces and Cities’ tab. If you have operations in any of these provinces or cities, type Yes in the corresponding Response field on the Declaration tab.
  • If you do not have suppliers operating in any of the countries on the Countries tab, select or type No in the Response field.

Q4: (A) Does your organization, or do your suppliers have operations in any of the sectors listed on the Sectors tab? (B) Do your suppliers have operations in any of the sectors listed on the ‘Sectors’ tab?

  • A) If Yes, please select all sectors that apply on the ‘Sectors’ tab. 
  • B) If Yes, please select all sectors that apply on the ‘Sectors’ tab. Select or type ‘Yes’ if your organization has employed or hired low-skilled foreign or domestic migrant workers, and ‘No’ if your organization has not in the Response field.

Q5: How many workers and agents does your organization employ?

  • This question requires you to identify the numbers of workers and agents employed within your organization and indicate it in the corresponding Response field on the Declaration tab.

Q6: Does your organization employ or hire low-skilled foreign or domestic migrant workers (directly or through recruiters)?

  • Select or type ‘Yes’ if your organization has employed or hired low-skilled foreign or domestic migrant workers, and ‘No’ if your organization has not in the Response field.

Q7: Does your organization use recruiters who hire subcontractors to recruit workers?

  • Select or type ‘Yes’ in the Response field if your organization uses recruiters to hire subcontractors to recruit workers.
  • Select or type ‘No, our recruiters do not hire subcontractors to recruit workers’ in the Response field if your organization’s recruiters do not hire subcontractors to recruit workers.
  • Select or type ‘We don’t know if our recruiters hire subcontractors to recruit  workers’ in the  Response field if your organization doesn’t know if its recruiters hire subcontractors to recruit workers. Select or type the answer ‘N/A — We do not use recruiters’ in the Response field if your organization does not use recruiters.

Q8: Do any of the goods, wares, articles, or merchandise that your organization produces, manufactures, or mines originate wholly or in part in the Xinjiang Uyghur Autonomous Region of China? 

  • If you have goods, wares, articles, or merchandise that your organization produces, manufactures, or mines wholly or in part in the Xinjiang Uyghur Autonomous Region of China, type ‘Yes’ in the corresponding Response field on the Declaration tab.
  • If you do not, select or type ‘No’ in the Response field.

Q9: Do any of your suppliers produce, manufacture, or mine goods, wares, articles, or merchandise that originate wholly or in part in the Xinjiang Uyghur Autonomous Region of China?

  • If you have goods, wares, articles, or merchandise that your suppliers produce, manufacture, or mine that originate wholly or in part in the Xinjiang Uyghur Autonomous Region of China, type Yes in the corresponding Response field on the Declaration tab.
  • If you do not, select or type 'No' in the Response field.

POLICY

Q10: Does your organization issue a policy/policies prohibiting workers and agents from the following:

  • Engaging in all forms of forced labour and human trafficking (also referred to as modern slavery)?
    • If your organization issues and enforces a policy/policies prohibiting workers and agents from engaging in all forms of human trafficking and forced labour, select or type ‘Yes’ in the Response field. If not, select or type ‘No’.
  • Engaging in child labour?
    • If your organization issues and enforces a policy/policies prohibiting workers and agents from engaging in all forms of child labour, select or type ‘Yes’ in the Response field. If not, select or type ‘No.’
  • Withholding worker identity or immigration documents?
    • If your organization has a policy in place prohibiting workers and agents from withholding employee identity or immigration documents, select or type ‘Yes’ in the Response field. If not, select or type ‘No.’
  • Using recruiters that do not comply with local labour laws of the country in which the recruiting takes place?
    • If your organization has a policy in place prohibiting the use of recruiters that do not comply with the local labour laws of the country in which the recruiting takes place, select or type ‘Yes’ in the Response field. If not, select or type ‘No.’ If your organization does not use recruiters, select the ‘N/A — We do not use recruiters’ option from the dropdown list.
  • Charging workers or potential workers recruitment fees, according to the definition provided in the Glossary? Please note: You must read the definition of recruitment fees to accurately answer this question.
    •  If your organization issues and enforces a policy/policies prohibiting workers and agents from charging workers recruitment fees, according to the definition provided in the Glossary tab, answer this question by selecting or typing ‘Yes’ in the Response field. If not, select or type ‘No.’
  • Procuring commercial sex acts during the length of the contract?
    • If your organization issues and enforces a policy/policies prohibiting the procurement of commercial sex acts during the length of the contract, select or type the option ‘Yes, broadly and/or only when required by law or contract’ in the Response field. If not, select or type ‘No.'

Q11: Does your organization issue a policy/ policies explicitly ensuring the following?

  • The provision or payment of return transportation for all foreign migrant workers at the end of their period of work if they were brought to the country for the purpose of working for your organization (directly or through recruiters) unless they fall under the exceptions outlined in the Glossary under ‘Return Transportation’?
    • If your organization issues and enforces a policy/policies ensuring the provision or payment of return transportation for all foreign migrant workers at the end of their period of work, if they were brought to the country for the purpose of working for your organization, select or type ‘Yes’ in the Response field.
    • If your organization has no such policy, or the worker(s) fall under the exceptions outlined in the Glossary under ‘return transportation’, select or type ‘No.’ If your organization does not hire foreign migrant workers, select the ‘N/A — We do not hire foreign migrant workers’ option from the dropdown list.
  • That housing provided or arranged for your workers meets host-country housing and safety standards?
    • If your organization issues and enforces a policy/policies ensuring the housing provided or arranged for your organization meets host-country housing and safety standards, select or type ‘Yes’ in the Response field. If you do not have such policies in place, select or type ‘No.’ If your organization does not provide or arrange housing, select the ‘N/A — We do not provide or arrange housing’ option from the dropdown list.
  • That workers, including migrant workers, can cancel their work contracts at any time with no financial penalty, subject to giving reasonable notice in accordance with local law or a collective agreement?
    • If your organization has a policy/policies in place ensuring migrant workers can cancel their work contracts with no financial penalty before they relocate for work, select or type ‘Yes’ in the Response field. If not, select or type ‘No.’
  • That wages meet applicable host country legal requirements or, if there is no legal minimum wage, wages are aligned with the prevailing sector wage?
    • If your organization has a policy/policies in place to ensure wages meet applicable host country legal requirements or, if there is no legal minimum wage, wages are aligned with the prevailing sector wage, select or type ‘Yes’ in the Response field. If your organization has no such policy in place, select or type ‘No.’
  • That workers, including those hired by recruiters, are provided with detailed and accurate work agreements or similar work papers, prior to relocation in cases where the worker must relocate to perform the work, and in a language understood by the worker?
    • If your organization has a policy/policies in place ensuring all workers, including those hired by recruiters, are provided with detailed and accurate work agreements  or similar work papers, prior to relocation in cases where the worker must relocate to perform the work, and in a language understood by the worker, select or type ‘Yes, and this applies to all workers whether required by law or by contract’, or ‘Yes, but only when required by law or by contract’ in the Response field. If your organization does not have such a policy in place, select or type ‘No.’
  • That there are document checks (including proof of age documents) of all workers before they begin working to confirm they are allowed   to work according to legal standards and applicable organization policies?
    • If your organization has a policy/policies in place to ensure document checks (including proof of age documents) of all workers before they begin working to confirm they are allowed to work according to legal standards and applicable organization policies, select or type ‘Yes’ in the Response field. If your organization has no such policy in place, select or type ‘No.’

Q12: Does your organization issue a policy/ policies to its suppliers covering the provisions you selected in Questions 7 and 8?

  • If your organization has a policy/policies regulating the use of foreign or domestic migrant workers, please indicate Yes in the Response field. If your organization does not work with suppliers, select the ‘N/A — We do not hire and foreign or domestic migrant workers’ option from the drop-down list.

SUPPLY CHAIN MANAGEMENT

Q13: Does your organization issue a policy/ policies to its suppliers covering the provisions you selected in Questions 10, 11, and 12? 

  • If your suppliers are required to comply with your policies listed in Questions 10 and 11, select or type ‘Yes’ in the Response field.
  • If your suppliers are not required to comply, select or type ‘No.’
  • If your organization does not work with suppliers, select the ‘N/A — We do not work with any suppliers’ option from the drop-down list.

Q14: If you answered ‘Yes’ to Question 13, does your organization have contractual terms and conditions that require its suppliers to affirmatively agree to its policy/policies (or equivalent)?

  • If you answered ‘Yes’ to Question 13 and your organization does have contractual terms and conditions that require your suppliers to affirmatively agree to your policy/policies (or equivalent), select or type ‘Yes’ in the Response field.
  • If you answered ‘Yes’ to Question 13 and your organization does not have contractual terms and conditions that require your suppliers to affirmatively agree to your policy/policies (or equivalent), select or type ‘No.’ If your organization does not work with suppliers, select the ‘N/A — We do not work with any suppliers’ option from the drop-down list.

Q15: If you answered ‘Yes’ to Question 13 and/ or 14, does your organization’s policy/policies (or the equivalent) and/or contractual terms and conditions include a flow-down clause? 

  • If you answered ‘Yes’ to Question 13 and/or 14 and your organization’s policy/policies (or the equivalent) and/or contractual terms and conditions does include a flow-down clause, select or type ‘Yes’ in the Response field.
  • If you answered ‘Yes’ to Question 13 and/or 14 and your organization’s policy/policies (or the equivalent) and/ or contractual terms and conditions does not include a flow-down clause, select or type ‘No.’ If your organization does not work with suppliers, select the ‘N/A — We do not work with any suppliers’ option from the drop- down list.

RISK IDENTIFICATION & MANAGEMENT

Q16: Does your organization perform formal screening and evaluation of prospective recruiters to determine if they (i) operate in compliance with the law and applicable organization policies, and (ii) observe the ‘‘employers pay’ principle of not charging a ‘recruitment fee’ to workers,  as  defined  in the Glossary?

  • If your organization does perform formal screening and evaluation of prospective recruiters to determine if they operate in compliance with the law and applicable organization policies, and (ii) observe the ‘employee pay’ principle of not charging a ‘recruitment fee’ to workers, as defined in the Glossary, select or type ‘Yes’ in the Response field. If your organization does not perform such formal screening of prospective recruiters, select or type ‘No.’

Q17: Does your organization engage in due diligence activities to identify, prevent and mitigate risks specific to slavery and human trafficking in the following areas? Your operations; your direct supply chain; Your indirect supply chain; your labour supply chain.

  • If your organization engages in due diligence activities to identify, prevent and mitigate risks specific to slavery and human trafficking in its operations and direct, indirect and labour supply chains, select or type ‘Yes’ or ‘No’ in the Response field where applicable.

Q18: If you answered ‘Yes’ to Question 17, does your organization use an independent third par- ty to conduct these due diligence activities?

  • If you answered ‘Yes’ to Question 17 and your organization uses an independent third party to conduct the due diligence activities mentioned in Question 17, select or type ‘Yes’ in the Response field .
  • If you answered ‘Yes’ to Question 17 but your organization does not use an independent third party to conduct said due diligence activities, select or type ‘No.’
  • Note: If you answered Question 17 with ‘No’, you are not required to provide an answer to Question 18.

Q19: Does your organization conduct a formal vulnerability assessment of its workers to slavery and human trafficking?

  • If your organization conducts a formal slavery and hu- man trafficking vulnerability assessment of its workers, select or type answer ‘Yes’ in the Response field.
  • If your organization does not conduct a formal slavery and human trafficking vulnerability assessment of its workers, select or type answer ‘No’ in the Response field.

TRAINING

Q20: Do your workers who have direct responsibility for supply chain management and recruitment receive training on how to mitigate risk of slavery and human trafficking?

  • If your organization provides training to workers who have direct responsibility for supply chain management and recruitment on how to mitigate risk of slavery and human trafficking, select or type answer ‘Yes’ in the Response field. If not, select or type ‘No.’

REPORTING & INTERNAL ACCOUNTABILITY

Q21: Does your organization have a process for workers and agents to report, without fear of retaliation, matters related to slavery and human trafficking?

  • If your organization has a process in place for workers and agents to report, without fear of retaliation, matters related to slavery and human trafficking, select or type answer ‘Yes’ in the Response field. If not, select or type ‘No.’

Q22: Does your organization maintain internal accountability standards and procedures to respond to a failure by workers and agents to meet organization policies regarding slavery and human trafficking?

  • If your organization maintains internal accountability standards and procedures for workers and agents who fail to meet organization standards regarding slavery and human trafficking, select or type answer ‘Yes’ in the Response field. If your organization does not maintain these standards and procedures, select or type ‘No.’

Q23: Does your organization prioritize the use of ethical recruitment agencies certified by credible assurance schemes?

  • If your organization prioritizes the use of ethical recruitment agencies certified by credible assurance schemes, select or type answer ‘Yes’ in the Response field.
  • If your organization does not prioritize the use of ethical recruitment agencies certified by credible assurance schemes, select or type answer ‘No’ in the Response field.
  • If your organization does not work with recruiters/recruitment agencies, select the ‘N/A — We do not use recruiters’ option from the drop-down list.

PUBLIC DISCLOSURE

Q24: Does your organization publicly disclose information on its efforts to address human trafficking and slavery? Note: Public disclosures may be compiled to comply with slavery and human trafficking-related regulations.

  • If your organization publicly discloses information on its efforts to address human trafficking and slavery, select or type answer ‘Yes’ in the Response field. If not, select or type ‘No.’

CERTIFICATION

Certification: Do you certify that all the answers provided in this document are true and accurate to the best of your knowledge and understanding, and commit to providing evidence to support all of your answers if and as required by your customer?

  • If you certify that all the answers provided in this document are true and accurate to the best of your knowledge and understanding, and commit to providing evidence to support all of your answers if and as required by your customer, answer ‘Yes’ to this section. If your answer is ‘No’, the STRT will be invalid.

Countries

The Countries tab contains the list of Tier 2, Tier 2 Watchlist, Tier 3, Special Case countries and North Korean workers according to the US Department of State’s Trafficking in Persons report (updated annually). This list is required in order to answer Questions 1 and 2 of the STRT.

Users may use this tab for reference to answer Questions 1 and 2. They may use the dropdown in the Se- lection column next to countries to select ‘Yes’ if their organization, or their suppliers, operate in those countries.

The default selection is ‘No.’ If  users answer ‘Yes’ to Question 1 of the STRT, at least one selection MUST be made on the Countries tab.

Sectors

The Sectors tab contains a list of sectors in which human trafficking activities are known to occur. This list is required in order to answer Question 3 of the STRT.

Before making a selection, users should refer to the Glossary to define each of the listed sectors.

Users may use this tab for reference to answer Question 3. They may use the dropdown in the Selection column next to the sectors to select ‘Yes’ if their organization, or their suppliers, operate in those sectors. The default selection is ‘No.’ If users answer ‘Yes’ to Question 3 of  the STRT, at least one selection MUST be made on the Sectors tab

Review

The Review tab can be used to verify all required fields of the STRT are completed. Required fields in red indicate information is missing. Required fields in green are complete.

If information is missing from a required field, the Review tab indicates which responses are missing and for which question or sub-question.

The Required Field column indicates which necessary field needs to be completed, as well as what response you have provided. The tab indicates what supporting documentation is required, and shows you what URL or file you have provided.

Click on the Go to Question column for the corresponding field to navigate to the appropriate field on the Declaration tab. By using these links on the Review tab, users can quickly navigate to missing fields on the Declaration tab in order to complete the STRT.

Glossary

The Glossary tab can be used to reference terms used throughout the STRT that may be unclear. This tab can be referenced at any time throughout the completion process for guidance, definitions or descriptions.

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