A global leader in hospitality sought out Ksapa to develop a Duty of Vigilance plan. The Group formally requested the engagement include building out the corresponding internal capacities, by taking an active part on the development of their risk identification, mitigative measures and management tools.
Addressing the Group’s Duty of Vigilance legal requirements first requires outlining measures it put in place to remedy and ultimately prevent violations of Human Rights and fundamental freedoms, as well as the health and safety of people and planet. The French law requires businesses embed rightsholder perspectives to identify, remediate, monitor progress in their risk management program. These rightsholders typically include direct workers, suppliers, users and communities – to which the Group added seasonal workers and individual investors to fully reflect its operational realities.
A. Ksapa’s In-House Duty of Vigilance Implementation Methodology
Leveraging its in-house Duty of Vigilance methodology, Ksapa identified and mapped key priorities from a rightsholder’s perspective and conducted a Group-wide documentary review for further assessment. The scope of relevant risks was then narrowed down in order to assess high, moderate or low risks. Ksapa then assessed the relevance of Group risk mitigation tools against the Duty of Vigilance law, based on the following 5 core components:
- Risk mapping to identify, analyze and prioritize risks per the Duty of Vigilance law
- Procedures to oversee the regular assessment of subsidiaries, subcontractors or suppliers among other established business relationships, in the light of the risk map
- Appropriate actions to mitigate risks or prevent serious harm
- A mechanism for alerting and collecting reports on the existence or occurrence of risks, established in consultation with the trade unions representing the company
- A monitoring system design to track the implementation and effectiveness of mitigative measures.
B. Zeroing in on the Role of Procurement in Upholding the Group’s Duty of Vigilance
Recognizing the key role of procurement activities in relations to the corporate duty of vigilance, Ksapa assessed more than 100 procurement categories against the priority risks identified as a result of the previous phase. We for instance considered how buying sheets may involve key risks in terms of the working conditions of seasonal workers. We also evaluated how country-specific considerations as well as regulatory and reputational risks could warrant expanding procurement risk management beyond Tier 1 suppliers.
Ksapa proceeded to color-code procurement categories to streamline the action plan process. Our team indeed recommended risk mitigation measures structured around 4 key levers – namely operational tools, governance and management, supplier dialog and reporting. For example, we engaged the Group procurement team on the importance of actively supporting supplier-level risk mitigation through innovative financing and equipment.
RESULTS & NEXT STEPS
The results of these analyses will be cross-referenced through a stakeholder interview campaign with 30+ internal and external experts relevant to the Group’s brands, functions and countries. The end-goal of this engagement is for Ksapa to streamline a Duty of Vigilance plan for the Group. To that end, we will seek to allocate risk responsibilities (duty-bearers) as part of a corresponding action plan and supporting governance framework. This involves developing a RACI tool to outline the responsibilities specific to the Group, while developing a relevant stakeholder engagement strategy to curb risk together with external players. Finally, we expect to co-design a select list of performance indicators combining the Group’s obligation of means and of results. In other words, we will build on our initial Duty of Vigilance risk mapping to equip the Group with a credible action plan, complete with an impact monitoring system.