Non-Discrimination

Business Case

Brand reputation

Demonstrating commitment to non-discrimination across the supply chain can strengthen brand credibility with customers, investors and employees, supporting business growth and long-term loyalty.

Legal and regulatory compliance

Proactive compliance with anti-discrimination and equal treatment standards across the supply chain helps reduce legal and regulatory exposure, addressing risks before they happen or reducing the risk of recurring violations that may trigger enhanced audits, sanctions or contract termination.

Productivity and quality

Suppliers that operate under fair and equitable working conditions tend to maintain more stable workforces and diverse teams that contribute to better problem‑solving, creativity and operational performance, contributing to higher productivity and more consistent delivery outcomes for the buyer.

Strategy & Planning

Assessment

Initial Action

Identify procurement categories, sourcing regions and supplier sites where supplier workforces may face risk of discrimination (acts which have the effect of nullifying or impairing equality of opportunity and treatment in employment or occupation), based on sectors with significant workforce segmentation by vulnerable populations or regions with weak anti-discrimination enforcement.

Intermediate Progress

Conduct an annual risk review with risk segmentation of suppliers based on the following criteria, updating category and supplier risk ratings and reflecting changes in data, industry trends and regulatory expectations:

  • sector or region history of discrimination findings
  • workforce composition patterns
  • presence of vulnerable worker populations including indigenous peoples, ethnic minorities and disadvantaged groups
Advanced Practice

Identify gaps in non-discrimination monitoring across the supplier portfolio and develop action plans to address unmonitored categories, regions or supplier groups, with multi‑year risk forecasting incorporating demographic trends and local regulatory developments.

Policy

Initial Action

Define protected characteristics in your supply chain based on international standards and establish commitment to non-discrimination in supplier code of conduct, covering equal treatment regardless of race, ethnicity, gender, age, disability, religion, indigenous status, national origin or any other protected characteristic, as well as consideration for intersectionality and discrimination based on overlapping characteristics.

Intermediate Progress

Require suppliers to implement their own non-discrimination due diligence processes, including monitoring equal treatment outcomes across their workforce and cascading anti-discrimination requirements to their own suppliers.

While focusing on remediation before termination decisions are made, establish an dscrimination escalation protocol with:

  • trigger criteria (retaliation incidents, repeated findings, falsified records)
  • defined consequences for escalated cases
Advanced Practice

Require suppliers to:

  • follow defined due‑diligence quality requirements
  • establish confidential and accessible grievance mechanisms for discrimination and harassment complaints
  • cascade non‑discrimination expectations and grievance mechanisms throughout supply chain

Targets

Initial Action

Set targets for percentage of suppliers or spend with suppliers with anti-discrimination policies and confidential grievance mechanisms.

Intermediate Progress

Set targets for percentage of high-risk suppliers assessed on discrimination practices.

Advanced Practice

Set targets for all medium and high risk suppliers to be assessed on discrimination practices.

Supplier Selection

Screening

Initial Action

Add non-discrimination questions to supplier pre-qualification and RFPs:

  • anti-discrimination and anti-harassment policies
  • equal opportunity policies in recruitment, promotion and pay
  • grievance mechanism for discrimination and harassment complaint
  • non-retaliation policy for workers who report concerns
  • any history of discrimination-related findings or legal actions
Intermediate Progress

Request evidence of non-discrimination practices from suppliers:

  • anti-discrimination, anti-harassment and equal treatment policy and training completion rates
  • grievance mechanism procedures and end lts for discrimination and harassment
  • data samples from grievance and complaint‑resolution processes to verify functionality
Advanced Practice

Require suppliers in high-risk categories to demonstrate:

  • documented anti-harassment training and enforcement
  • independent verification of grievance‑mechanism effectiveness (worker interviews, third‑party validation)
  • evidence that equal treatment practices are included in their existing third-party social audit programs
  • multi‑year trends on discrimination complaints, resolution quality and recurrence rates

Selection

Initial Action

Give preference to suppliers demonstrating commitment to equal treatment within their organizations and supply chains.

Intermediate Progress

Select only suppliers that commit to equal treatment, non-discrimination and grievance mechanisms.

Advanced Practice

Work only with suppliers that have active programs promoting equal treatment and verified non-discriminatory practices across their workforce, operations and supply chain.

Contracts

Initial Action

Include clauses requiring suppliers to maintain effective anti-discrimination policies and grievance mechanisms and to implement remediation actions.

Intermediate Progress

Include clauses requiring suppliers to:

  • report on programs and policies related to equal treatment
  • notify buyer of any discrimination or harassment findings or legal actions
  • take mandatory corrective actions for any verified discrimination violations
Advanced Practice

Require suppliers to cascade non-discrimination and equal treatment requirements to their own suppliers.

Supplier Engagement

Goal Setting

Initial Action

Communicate equal treatment requirements to suppliers and work with suppliers to establish targets for achieving equal treatment and non discrimination.

Intermediate Progress

Work with strategic suppliers to set targets and demonstrate progress on equality in the workforce, including measurable improvements in equal treatment across recruitment, pay, promotion, disciplinary practices, a reduction of discrimination findings and strengthening of reporting channels.

Advanced Practice

Set goals with suppliers on implementing grievance mechanism and promote non-discrimination requirements within their own supply chains, including monitoring equal treatment practices among their own suppliers.

Capacity Building

Initial Action

Provide basic training on anti-discrimination, equal treatment and anti-harassment, covering recognition of discriminatory practices and legal requirements.

Intermediate Progress

Train suppliers on analyzing complaint and discrimination data to identify patternsand on conducting pay equity analyses and bias-free recruitment processes.

Advanced Practice

Sponsor supply chain wide training programs on promoting equality and implementation of grievance mechanism.

Data

Initial Action

Support suppliers with obtaining baseline data on existence of anti-discrimination policies and any history of discrimination-related findings.

Intermediate Progress

If aligned to regulatory requirements, support suppliers in developing structured systems to track discrimination complaints, investigation outcomesand workforce composition data across relevant groups, as well as a tracking of root‑cause analysis for each discrimination case to identify systemic issues.

Advanced Practice

Support suppliers with tracking equal treatment metrics across their own supply chains, including grievance data, discrimination findingsand workforce composition.

Advisory

Initial Action

Provide best practices or advisory sessions to support suppliers with identifying discrimination within their workforce and operations.

Intermediate Progress

Provide best practices or advisory sessions to support suppliers in addressing stereotypes, developing and deploying policies to address them and handle the implementation challenges faced by implementation teams.

Advanced Practice

Consult and work with suppliers in embedding non-discrimination due diligence and supplier engagement into their own procurement practices, including developing their own supplier codes, screening processesand engagement programs on equal treatment.

Financial Support

Initial Action

Fund or co-fund supplier implementation of anti-discrimination programs.

Intermediate Progress

Provide commercial incentives to suppliers for improvements in equal treatment performance, such as price, volume, durationand preferred supplier status.

Advanced Practice

Link commercial incentives (contract extensions, volume increases, pricing adjustments) to verified progress on equal treatment across the supplier's own supply chain.

Audits

Initial Action

Require suppliers to complete self-assessment questionnaires on non-discrimination practices, covering anti-discrimination policies, equal opportunity in recruitment and promotion and complaint handling procedures.

Intermediate Progress

Review and audit the suppliers or refer to 3rd party audits for presence of policies on non discrimination and number of supplier employees trained and responsible to implement the policies.

Advanced Practice

Work with strategic suppliers to conduct their own supplier audits on non-discrimination and equal treatment and share audit findings.

Project Partnerships & Innovation

Initial Action

Host supplier events or conferences in partnership with worker advocacy groups, bringing suppliers together to learn from established non-discrimination practices and share experiences.

Intermediate Progress

Collaborate with international organizations, NGOsand industry peers to develop shared tools for addressing discrimination in supply chains, such as equal treatment assessment criteria, training curricula or guidance tailored to specific sectors or regions.

Advanced Practice

Lead cross-sector coalitions with suppliers, human rights organizations, international organizationsand industry peers to drive systemic change on equal treatment, such as establishing industry-wide standards for workforce equity, co-funding research on discrimination barriers in specific sectors or creating shared monitoring platforms.

Continuous Improvement

Metrics

Initial Action

Track percentage of suppliers with equality, anti-discrimination, anti-harassmentand grievance policies and training.

Intermediate Progress

Track number of discrimination-related findings in supplier assessments, grievance mechanism usageand corresponding resolution outcomes, with analysis of recurrence rates for similar discrimination findings to identify systemic weaknesses across categories.

Advanced Practice

Track percentage of suppliers cascading non-discrimination requirements to their own supply chains.

Scorecards

Initial Action

Introduce basic non-discrimination criteria into yearly supplier evaluation forms, including equal treatment commitments and checklist for existence of basic policies (anti-harassment, non-discrimination, grievance mechanism).

Intermediate Progress

Integrate non-discrimination KPIs into supplier scorecards and quarterly business reviews (including grievance mechanism usage, complaint resolution ratesand training completion) and apply differentiated consequences (additional audits, required corrective actions) for repeatedly low‑scoring suppliers.

Advanced Practice

Weigh non-discrimination performance in supplier scorecards, with top performers receiving preferential weighting in tenders and bottom performers required to submit improvement plans.

Impact Verification

Initial Action

Gather feedback from suppliers on effectiveness of supplier engagement programs on equal treatment.

Intermediate Progress

Assess whether supplier engagement initiatives are improving equal treatment outcomes across the supplier base, including verification through worker-voice mechanisms.

Advanced Practice

Measure improvement in supplier equal treatment outcomes attributable to engagement programs, such as reduction in discrimination findings, improved grievance mechanism effectiveness and evidence of barrier removal in supplier recruitment and subcontracting practices.

Sources consulted

Living Wage Gender Equality