Working Time
Business Case
Brand reputation
Financial resilience
Legal and regulatory compliance
Operational continuity
Productivity and quality
Strategy & Planning
Assessment
Identify procurement categories and sourcing regions with elevated risk of excessive working hours and inadequate rest, based on:
- legal limits on working hours and overtime in sourcing countries
- sectors with systemic overtime (e.g. peak driven industries)
- use of temporary, migrant or agency workers
- production models relying on tight lead times
- use of piece-rate pay
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 geography, industry trends and supplier behaviour:
- history of excessive overtime
- business model dependency on seasonal peaks
- labor cost structures, wage levels and contract structures such as zero-hours contracts or piece-rate pay
- persistent or systemic risk requiring enhanced due diligence
Identify gaps in monitoring across high-risk supplier portfolio and develop action plans to address unmonitored categories, regions or supplier groups.
Policy
Establish commitment to fair working time practices in supply chains, requiring suppliers to comply with applicable working time laws and respect ILO standards, covering:
- maximum working hours not exceeding legal limits or 48 hours per week (whichever is lower), with overtime not exceeding 12 hours per week except in clearly defined extraordinary circumstances
- all overtime is voluntary and compensated at legally required premium rates
- adequate rest, breaks and holidays as per industry and legal standards
- accurate and transparent recording of all working hours
Integrate working time risk criteria into sourcing decisions for high-risk categories, requiring enhanced due diligence on working time as a condition of supplier approval or contract renewal.
For existing suppliers, while focusing on remediation before termination decisions are made, establish a working time escalation protocol with:
- triggers (recurring violations, falsified records, major incidents)
- escalation steps (enhanced audits, CAP requirements, commercial consequences)
- decision‑making responsibilities
- defined consequences
Set mandatory due‑diligence standards for strategic suppliers, including data quality controls and independent verification and require strategic suppliers to implement their own working time due diligence processes and to cascade working time requirements to their suppliers.
Targets
Set targets for percentage of suppliers with a stated policy on working time compliance.
Set targets for percentage of high-risk suppliers assessed on working time practices.
Set targets for percentage of high-risk suppliers with verified working time verification procedures in place.
Supplier Selection
Screening
Add working time questions to pre qualification and RFP processes:
- maximum weekly hours policy
- overtime compensation practices
- rest day policy and work-life balance measures (including parental leave or flexible working arrangements)
- time tracking systems in place
- compliance with legal working time limits
- history of labour violations related to working hours
Request evidence such as:
- recent audit reports including working hour findings
- timekeeping records samples for both regular and peak periods,
- overtime payment records and pay slips
- policies on leave, rest and protection of workers from excessive hours
- grievance data related to working time
- comparison of attendance logs to payroll totals or other records proving data consistency
To respond to RFPs, request documentation on:
- working time due diligence policy covering own supply chain
- evidence of monitoring at sub tier level
- multi‑year data trends for overtime, rest‑day compliance and peak‑period hours
- independent verification of timekeeping data for high‑risk categories
Selection
Select only suppliers confirming compliance with legal working hour limits, overtime pay requirements and minimum ILO standards.
Allocate points in selection criteria for suppliers demonstrating:
- working hours consistently within legal and ILO limits
- functioning timekeeping systems with transparent and auditable records
- low overtime dependency and evidence that overtime is genuinely voluntary
Select suppliers demonstrating:
- transparent timekeeping systems or integrated digital systems linking scheduling, attendance and payroll
- cascaded working time standards to sub suppliers
Contracts
Include clauses on:
- compliance with working time laws and ILO standards
- maximum working hours
- voluntary overtime
- accurate time recording
- right to audit
Include the following clauses:
- enforceable corrective action requirements and an escalation clause defining actions for repeated or serious violations
- notification in case of any violations
- define consequences for falsified time records
- require suppliers with overtime peaks to provide an explanation and preliminary corrective plan
Require cascading of working time clauses to their own suppliers, with sub‑tier monitoring results, findings and remediation follow‑up and include multi‑year improvement commitments tied to commercial incentives.
Supplier Engagement
Goal Setting
Work with suppliers to understand their current working time practices and, where issues are identified, determine appropriate goals for improvement.
Set goals with suppliers on specific strategies to address identified working time issues with defined milestones.
Set goals with Tier 1 suppliers on cascading working time management programs to their own suppliers (Tier 2+) and establish multi-year targets for verified compliance across the extended supply chain.
Capacity Building
Provide guidance and basic training to suppliers on working time legal requirements and ILO standards and share resources on implementing effective timekeeping systems.
Train suppliers on analyzing working time data to identify patterns and root causes of excessive hours and developing working time improvement roadmaps with measurable milestones.
Provide detailed training on conducting working time due diligence within their own supply chains and identifying working time risks at sub-supplier level or facilitate cross‑supplier learning sessions and sector‑specific working‑time communities on working time topics.
Data
Request baseline data from suppliers in topics such as: average weekly working hours (regular vs. overtime), compliance rates with weekly rest day requirements and records of any working hour incidents.
Support suppliers in developing structured wage and hour management systems to enable systematic monitoring of hours, overtime patterns and rest day compliance.
Work with suppliers to develop integrated reporting systems that capture working time data across their own supply chains, including audit findings, incident data, remediation outcomes, Worker‑voice inputs (interviews, surveys, anonymous grievance channels), etc.
Advisory
Provide guidance to suppliers on identifying root causes of excessive overtime, such as analysing production processes to find inefficiencies and areas for improvement and on making improvements to working time policies, including work-life balance measures.
Consult and work with suppliers on how to assess working time violation risks in their own supply chains, including screening their own suppliers.
Consult and work with suppliers in embedding working time violation due diligence and supplier engagement into their own procurement practices, including developing their own supplier codes, screening processes and engagement programs, in alignment with SA8000, ILO mapping frameworks and recognised sector standards.
Financial Support
Identify funds or support suppliers in applying to financing for workforce planning resources, working time management guidance and timekeeping system tools.
Provide commercial incentives to suppliers for improvements in working time improvement performance, such as price, volume, duration and preferred supplier status.
Link commercial incentives (contract extensions, volume increases, pricing adjustments) to verified progress on eliminating working time violations across the supplier's own supply chain.
Audits
Require suppliers to complete self-assessment questionnaires on working time practices, covering timekeeping systems, overtime policies, rest day and leave provision and compliance with legal working hour limits.
Include working time checks in supplier audit programs as part of human rights due diligence with corrective action plans as needed, including verification on topics such as:
- requiring excessive or compulsory overtime or exceeding maximum working hours set by law or ILO standards
- denying or failing to provide legally mandated rest days, breaks, meal periods, annual leave, sick leave or public holidays as required by law
- falsifying timekeeping records to conceal actual hours worked
- penalizing workers for refusing overtime
- failing to compensate overtime at legally required premium rates
- not tracking or recording working hours accurately
- denying maternity, paternity or other legally required leave
- grievance systems and procedures
- anonymous worker interviews or surveys to verify that recorded working hours reflect actual hours worked
Work with strategic suppliers to conduct their own supplier audits on working time violations and share audit findings.
Project Partnerships & Innovation
Launch pilot projects with suppliers to test practical tools and technologies that improve visibility into working time practices, such as digital time-tracking systems, automated alerts for excessive hours or shift scheduling tools that ensure compliance with rest period requirements.
Co-invest with suppliers in implementing technologies and approaches that strengthen working time management, such as integrated workforce scheduling platforms that optimize shifts while respecting legal limits.
Lead industry collaborations with suppliers, technology providers and sector peers to develop and scale solutions for responsible working time management across shared supply chains, such as industry-wide working time monitoring standards or sector-specific tools for managing seasonal demand without excessive hours.
Continuous Improvement
Metrics
Track:
- percentage of suppliers assessed and/or trained on working time practices
- percentage of suppliers with working time policies and working time assessments
- percentage of suppliers that implemented required corrective actions
Track percentage of suppliers engaged in working time supplier engagement programs, including:
- percentage of suppliers actively implementing improvement plans
- percentage reduction in overtime violations within high‑risk categories
- frequency of non‑compliance recurrence
Track:
- percentage of supplier workers cascading working time policies and due diligence
Scorecards
Introduce basic working time criteria into yearly supplier evaluation forms, starting from onboarding:
- self-assessment on working
- checklist for existence of basic policies
Include working time metrics in category business reviews and track progress on wage improvement plans, using results to influence sourcing decisions and renewal discussions.
Weigh working time performance in supplier scorecards, with top performers receiving preferential weighting in tenders with commercial incentives and bottom performers required to submit improvement plans.
Impact Verification
Gather feedback from suppliers on effectiveness of engagement programs.
Assess whether supplier engagement initiatives are improving working time outcomes (including corrective‑action closure rates and whether problem types repeat across suppliers), cross-checking supplier-reported outcomes with additional independent data source such as worker surveys, grievance channel data or third-party assessment.
Measure improvement in working outcomes attributable to engagement programs. For example, consider:
- percentage of suppliers demonstrating year‑on‑year improvement in excessive‑hour risk indicators
- comparing incident rates and audit findings before and after interventions
- mixed-methods evaluation combining quantitative tracking of hours and incidents with qualitative worker experience data
- tracking remediation outcomes and recurrence rates over time
- commissioning independent evaluations of program effectiveness
- worker‑voice data (interviews, digital grievance systems, survey results) to validate outcomes
Sources consulted
- https://bhr-navigator.unglobalcompact.org/issues/working-time/
- https://www.ilo.org/publications/guide-developing-balanced-working-time-arrange…
- https://www.ethicaltrade.org/eti-base-code/6-working-hours-are-not-excessive#:~…
- https://sustainabilitymag.com/top10/top-10-ethical-labour-practices-in-supply-c…
- https://www.responsiblebusiness.org/media/docs/RBAPracticalGuide.pdf
- https://www.researchgate.net/publication/381107843_Ethical_Procurement-_Ensurin…
- https://www.walkfree.org/global-slavery-index/