Guidance on Answering Human Rights Questionnaire

This page is designed to help you answer the following Ethixbase360 due diligence questionnaires:

• Human Rights Questionnaire

Hint:  If you are looking for help with a specific question, use CTRL + F to search this page for the question text.

Corporate Entities

Question 1.3 

Are the answers you have provided to this questionnaire equally applicable in relation to the goods or services supplied to all of the selected entities?

Guidance: This question is asking whether your answers apply uniformly across all the entities you selected earlier in the questionnaire.

If you answer "yes," the questionnaire can likely proceed on a consolidated basis. If you answer "no," you may receive follow-up questions asking you to specify which answers differ and for which entities.

Reporting Obligations

Question 3.1

Are you required to report under modern slavery or human rights laws?

Guidance: This question asks whether your business falls within the scope of any legislation that imposes mandatory reporting or disclosure obligations relating to human rights, including modern slavery. In practical terms, it is asking you to confirm whether by reason of your business’s size, turnover, jurisdiction, or sector you are legally required to publish statements, reports, or disclosures.

Jurisdiction

Question 4.1

Where are all of your current business operations supporting the provision of goods or services to us? Please select all that apply.

Guidance: This question is asking you to identify the countries where your business carries out activities that are connected to the goods or services you supply to the customer. In practical terms, it is not limited to where your head office is located. It is asking you to disclose the locations across your operational footprint that play a role in the delivery chain, which could include manufacturing or production sites, service delivery centres, warehousing and logistics, subcontractor or outsourced operations. If a related corporate entity manufactures, in whole or part, a product supplied by you, include the jurisdiction of that entity.

Question 4.2

Where are your primary suppliers located that support the goods or services you provide to us? Please select all that apply.

Guidance: This question is asking you to identify the countries where your suppliers are based, insofar as those suppliers contribute to what you ultimately deliver to the customer. This could include raw materials or component suppliers.

Question 5.1

Does any part of the business operations of your corporate group intersect with the rights and interests (including land) of Indigenous people or the cultural heritage of Indigenous people in country? 

Guidance: This question is asking whether any entity within your corporate group carries out activities that impact or have the potential to impact Indigenous peoples' rights, interests, or cultural heritage. This could include land rights and native title, cultural heritage sites, water rights and environmental impacts, resource extraction and development.

Question 5.4

Does any part of the business operations of your corporate group currently, or is it likely to, adversely impact the rights and interests (including land, water, food, nature and health) of surrounding communities?

Guidance: This question is asking whether any entity within your corporate group carries out activities that currently cause, or are reasonably likely to cause, negative effects on the rights and wellbeing of communities (not just Indigenous communities) located in the vicinity of your operations, encompassing a broad range of environmental, social, and economic impacts.

The scope is broad in two respects. First, it captures both current adverse impacts and those that are likely, meaning you must consider foreseeable future harms, not only those already materialised. Second, it applies to the entire corporate group, so even if your contracting entity operates in a low-impact sector, you must disclose if related entities within the group have operations with community-level impacts (e.g., extractive industries, heavy manufacturing, large-scale agriculture, or infrastructure development).

Question 5.5

Have you had, or do you plan to have, a surrounding community relocated as a result of your business operations (such as due to a development project, land clearing or acquisition)?

Guidance: This question is asking whether your business has historically caused, or anticipates causing, the physical displacement or resettlement of a community as a consequence of your business activities. In practical terms, it is asking you to consider whether your business activities have involved or will involve:

• Involuntary resettlement: compulsory relocation of households or communities to enable a project, whether through legal mechanisms (e.g., compulsory purchase orders, eminent domain) or through economic pressure
• Development-induced displacement: relocation necessitated by construction of infrastructure, facilities, mines, plantations, energy installations, urban development, or contamination.
• Land clearing: removal of communities from land to enable deforestation, agricultural expansion, industrial zoning, or site preparation
• Land acquisition: purchase or appropriation of land (including through government intermediaries) where the practical consequence is that existing occupants must move, regardless of whether they hold formal title
• Economic displacement: situations where communities are not physically moved but lose access to land, resources, or livelihoods to such an extent that relocation becomes effectively unavoidable
• Planned future relocations: projects in the pipeline, under approval, or at feasibility stage that would require community displacement if they proceed

Activity

Question 6.2

Are any of the following materials contained in your products supplied to us?

Guidance: This question is asking whether the goods you supply to the customer contain, incorporate, or are derived from any of the specified raw materials or commodities. Consideration should be given to whether the materials are present as:

• Primary constituent materials: the product is made of or substantially composed of the material (e.g., an aluminium housing, a steel component, a timber product)
• Embedded components: the material is contained within a sub-component (e.g., cobalt in a lithium-ion battery, tantalum in a capacitor, tin in solder)
• Derivatives or processed forms: the product contains a substance derived from the raw material (e.g., oleochemicals derived from palm fruit, leather derived from cattle, rubber in seals or gaskets)
• Trace or ancillary materials: the material is present in minor quantities or used in manufacturing processes (e.g., mica in coatings or pigments, graphite in lubricants)

Question 6.4

Do you supply us with goods grown or goods manufactured or produced in another jurisdiction?

Guidance: This question is asking whether the goods you supply to the customer originate from a country other than the one in which you are contracting or delivering. That is, whether the goods were grown, manufactured, or produced in a different country from where the customer receives them.

In practical terms, it is asking you to disclose whether there is a cross-border element in the production of the goods you supply, which could include:

• Agricultural or horticultural products grown abroad: raw ingredients, foodstuffs, fibres, or botanical materials cultivated in another country
• Goods manufactured or assembled in another jurisdiction: products fabricated, processed, or assembled in a country other than the destination market (e.g., components manufactured in Southeast Asia, assembled in China, and delivered to the UK)
• Goods produced through extraction or processing overseas: minerals, chemicals, or refined materials sourced and processed in a different jurisdiction before being supplied
• Mixed-origin goods: products where some stages of production occur domestically and others occur abroad (e.g., raw materials sourced from one country, semi-finished goods processed in another, final assembly in a third)

Question 6.6  

Do you supply us with goods, raw materials and/or produce harvested, extracted, processed or manufactured, whole or in part (including components):

• in the Xinjiang Uyghur Autonomous Region (Xinjiang),
• within China but outside of Xinjiang by ethnic Uyghurs, Hui, Kazakhs, Kyrgyz, Tajiks, or Uzbeks as part of a government operated labour transfer program?

Guidance:  This question is asking whether any of the goods you supply to the customer have a connection to the Xinjiang Uyghur Autonomous Region of China or to the utilisation of ethnic minority workers transferred from any province in which they reside to other provinces as part of a labour transfer program. For example, if you provide us with shirts manufactured in Hong Kong but the textiles and manufactured in Xinjiang, the answer should be ‘Yes’. 

Question 6.7

Does your business, in supporting the provision of goods or services to us, engage security services (for example, security personnel)?

Guidance: This question is asking whether your business uses security providers: whether in-house personnel or contracted third-party firms in connection with the goods or services you deliver to the customer.

You are asked to disclose whether any of the following are engaged as part of, or in support of, your operations relating to the provision of goods or services to the customer:

• Private security companies: contracted firms providing guarding, site protection, asset protection, patrol, or surveillance services
• Private military and security companies: firms providing armed security, close protection, convoy escort, or security in conflict-affected or high-risk environments
• In-house security personnel: employees directly engaged by your business to perform security functions (e.g., site guards, loss prevention officers, access control staff)
• Public security forces used in a private capacity: arrangements where police or military personnel are engaged (formally or informally) to provide security for business operations, which is common in extractive industries in certain jurisdictions
• Technology-based security services: surveillance systems, drone monitoring, or electronic access control where managed by security personnel
• Maritime security: armed or unarmed teams protecting vessels or cargo in transit
• Security for supply chain logistics: personnel protecting warehouses, transport routes, or distribution networks

Workforce

Question 8.4  

Have any of the workers or contractors supporting the provision of goods or services to us, paid a recruitment fee or related costs to anyone, or incurred a debt, to secure work?

Guidance: The question is asking if anyone in your workforce paid to get their job. If a worker has had to pay fees to a recruiter, agent, or intermediary (or has taken on debt) to obtain their position, they may be trapped in exploitative conditions and unable to freely leave the employment. This includes anyone who goes into debt to get a job, which they repay once their employment commences. This is called a recruitment fee.

Question 8.6

Are workers or contractors supporting the provision of goods or services to us required to surrender passports or any other forms of original personal or travel identification to your business or any other third parties prior to commencing work?

Guidance: The term “surrender” means losing your right to access the original documents without the permission of the person holding them. Document retention is a well-recognised indicator of forced labour and human trafficking, because it restricts a worker's freedom of movement and ability to leave the job voluntarily.

This question is not intended to capture arrangements where documents are held voluntarily for safekeeping purposes, provided that the worker is free to request the return of their documents at any time and those documents are returned promptly and without condition upon such request. Where a business holds documents on this basis, the arrangement should be genuinely voluntary, clearly communicated to the worker, and subject to no penalty or adverse consequence for requesting their return.

Question 8.14

Are workers on site permitted to enter and exit as they wish (subject to workplace health and safety requirements)?

Guidance: This question is asking about the freedom of movement at the workplace. That is, whether workers can leave the premises voluntarily outside of legitimate health and safety restrictions (e.g. signing in/out procedures, wearing PPE in certain zones).

Question 8.16

Is the lowest paid person in your business or any part of your Group supporting the provision of goods or services to us paid a living wage for the location in which the worker resides?

Guidance:

A “living wage” is distinct from a statutory minimum wage. While a minimum wage is the legally mandated floor set by government, a living wage reflects the income necessary to afford a decent standard of living in a given location, covering essential needs such as food, housing, clothing, healthcare, education, with a modest allowance for unexpected events. In many jurisdictions, the statutory minimum wage falls below what is recognised as a living wage.

When assessing whether workers are paid a living wage, businesses should consider the cost of living in the specific location where the worker resides, not merely the location of the workplace. Recognised living wage benchmarks and methodologies may be used as reference points. Where no established benchmark exists for a particular location, businesses should undertake a reasonable assessment taking into account local housing costs, food prices, and other essential expenditure.

The following international instruments underscore the right of workers to remuneration sufficient to sustain a decent standard of living:

The Universal Declaration of Human Rights	Everyone who works has the right to just and favourable remuneration ensuring for himself and his family an existence worthy of human dignity, and supplemented, if necessary, by other means of social protection.
	(Article 25) Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services, and the right to security in the event of unemployment, sickness, disability, widowhood, old age or other lack of livelihood in circumstances beyond his control.
International Covenant on Economic, Social and Cultural Rights	Article 7: (a) Remuneration which provides all workers, as a minimum, with: (i) Fair wages and equal remuneration for work of equal value without distinction of any kind, in particular women being guaranteed conditions of work not inferior to those enjoyed by men, with equal pay for equal work; (ii) A decent living for themselves and their families in accordance with the provisions of the present Covenant;
International Labour Organisation (ILO)  C131 - Minimum Wage Fixing Convention, 1970 (No. 131)	Article 3: The elements to be taken into consideration in determining the level of minimum wages shall, so far as possible and appropriate in relation to national practice and conditions, include-- (a) the needs of workers and their families, taking into account the general level of wages in the country, the cost of living, social security benefits, and the relative living standards of other social groups; (b) economic factors, including the requirements of economic development, levels of productivity and the desirability of attaining and maintaining a high level of employment.

Controls and Policies

Question 9.5  

For which of these areas has your business implemented controls, adopted written codes or policies addressing the following subject matters?

Guidance:

This question is asking whether the business has documented controls in place. The existence of these controls demonstrates corporate governance maturity in connection with human rights issues.

Question 10.2

Does your business provide any of the following controls: 

a) providing appropriate personal protective equipment (PPE) to workers

b) maintaining workplace equipment and safety standards;

c) protective measures to avoid exposure to chemical, physical or biological substances; and

d) measures to prevent excessive physical and mental fatigue and mental, physical and social harm?

Guidance: The term "excessive physical and mental fatigue” should be considered in the context of the International Labour Standards on Working Time https://www.ilo.org/global/standards/subjects-covered-by-international-labour-standards/working-time/lang--en/index.htm. 

Question 13.2

To what extent do you have visibility into the supply chains of your key suppliers?[NRFA1] 

Guidance: Having "visibility" might include knowing:

• Who your suppliers' own suppliers are
• Where goods are being sourced or manufactured at each supply chain level
• What labour practices, working conditions, or ethical standards exist further down the chain
• Whether risks such as modern slavery, environmental harm, or regulatory non-compliance exist at sub-supplier level

The reference to "key suppliers" means the suppliers that are most significant or critical to your business, rather than every single supplier. 

What makes a supplier "key" can vary by context, but it generally refers to those that are:

• High-value: responsible for a large proportion of spend
• High-volume: providing goods or services at scale or frequency
• Strategically important: difficult to replace, sole-source, or critical to core operations

Question 13.3

Purchasing practices may unintentionally put pressure on your suppliers that could lead to modern slavery or other labour related exploitation. Does your business take into account any of the following factors when making purchasing decisions? (Select all that apply)

Guidance: This question is asking whether your business has considered whether it is inadvertently causing exploitation in your supply chain through the way you buy things.

If a buyer squeezes suppliers on price, makes unrealistic delivery demands or last-minute order changes, or imposes unfavourable payment terms, suppliers may cut corners by underpaying workers, using excessive overtime, engaging unauthorised subcontractors, or turning to exploitative labour practices to meet the demands.

Question 14.5

Does your business have a remediation framework in place to respond if human rights impacts, including modern slavery, are identified in your operations or supply chains?

Guidance: This question is asking whether you have a plan to respond in the event of an instance of actual or suspected adverse human rights impacts.  A remediation framework would typically cover:

• How victims are supported and provided with a remedy (e.g. repayment of recruitment fees, access to safe accommodation, counselling)
• How the root cause is investigated and corrected
• Who is responsible for decision-making and escalation
• How the business engages with the supplier (e.g. corrective action plans vs. immediate termination)
• How the business  ensures the harm does not recur