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Responsible Business Conduct

Responsible Business Conduct (RBC) includes promoting workers’ rights and safe working conditions, preventing human trafficking, and addressing other human rights-related risks. As the largest purchaser in the world, the U.S. Government has the potential to raise RBC standards globally by incorporating human rights into federal procurement processes. Moreover, the U.S. can advance a number of other key foreign policy goals, including poverty alleviation, gender equality, and freedom of assembly by centering human rights in procurement. This module provides a framework for how best practices and resources for responsible business conduct can be incorporated within procurements. It is especially important for contracts with a higher risk for adverse impacts on human rights (risk factors discussed below).

Federal Acquisition Regulation (FAR) Part 22 - Application of Labor Laws to Government Acquisitionsopens in new window sets forth general policies regarding contractor labor relations and prescribes contracting policy and procedures and contract clauses for implementing pertinent labor laws.

On procurements that entail sourcing products/services from a foreign country, recommend reviewing the below steps for practices to promote responsible business conduct.

Pre-Award Procurement Best Practices

To understand how human rights have been addressed on previous procurements, see Responsible Business Case Studies.

Post-Award Procurement Best Practices

Responsible Business Resources

Resources to help you ensure responsible business conduct for your project are listed below and can be found in the U.S. State Department’s Xinjiang Supply Chain Business Advisoryopens in new window and in Appendix A to the Burma Reporting Requirementsnon government site opens in new window

Resources related to Forced Labor

U.S. Customs and Border Protection (CBP) defines forced laboropens in new window as all work or service which is exacted from any person under the menace of any penalty for its nonperformance and for which the worker does not offer work or service voluntarily. To find out what imported goods are subject to a Withhold Release Order (WRO) or Finding, check the CBP’s Withhold Release Orders and Findings Listopens in new window for information on any merchandise that may be subject to exclusion and/or seizure.

The Uyghur Forced Labor Prevention Act (UFLPA)opens in new window establishes a rebuttable presumption that the importation of any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China, or produced by certain entities, is prohibited by Section 307 of the Tariff Act of 1930 and that such goods, wares, articles, and merchandise are not entitled to entry to the United States.

Veriténon government site opens in new window offers a Free Introductory Course on Forced Labornon government site opens in new window. This interactive e-learning course provides a brief overview of international frameworks and identifies some of the risky business practices that can lead to forced labor in supply chains (course length: 15 minutes).

Responsible Business Case Studies

Apparel and Uniforms

The city of Madison, WI established a cooperative contract in consultation with the Sweatfree Purchasing Consortiumnon government site opens in new window to address the human rights risks on their procurements for apparel and uniforms.
More Information: Uniform Management Program Cooperative Contractnon government site opens in new window

Coffee, Poultry and Surgical Instruments

Swedwatchnon government site opens in new window provides 3 case studies detailing how human rights can be addressed for coffee, poultry and surgical instrument procurements within their report “Agents For Change: How public procurers can influence labour conditions in global supply chains”non government site opens in new window.

Employing Persons With Disabilities and Combatting Illiteracy

The United Nations Environmental Programmenon government site opens in new window provides 8 illustrative case studies of procurements incorporating sustainable requirements in their report “The Impacts of Sustainable Public Procurement: Eight Illustrative Case Studies”.non government site opens in new window The responsible business conduct considerations include participation of companies employing persons with disabilities in the French case (Laser Printer Toner Cartridges) and the fight against illiteracy in the Scotland case (Consultancy & Temporary Staff Services).

Freedom of Association and Worker Safety

The Fair Labor Associationnon government site opens in new window provides a number of case studies illustrating how purchasers and companies can work with suppliers to ensure fair compensation, worker safety, and freedom of association when procuring products.
More Information: Strategic Projectsnon government site opens in new window

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