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Course Survey

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What is the purpose of the Forced Labor Due Diligence Program?

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The purpose of the program is to enable suppliers of all sizes and maturity in their due diligence processes to conduct risk screening for potential connections to forced labor in their supply base. The program helps to identify and mitigate risks of supply chain disruption and supports responsible sourcing. It provides affordable access to technology solutions and an aligned reporting tool to provide findings to customers.

Who developed this program?

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Ford, General Motors, Honda, Nissan, Stellantis, and Toyota collaborated through AIAG to create the program and the aligned reporting tool, the Due Diligence Reporting Template (DDRT). The DDRT can be implemented by 'customers' at any tier in the supply chain. Other OEMs, suppliers, and industry alliances are welcome to endorse the program and become supporting members.

How does the program benefit suppliers?

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Suppliers gain access to vetted technology providers at a reduced cost, streamlined reporting templates, and extensive resources to assist with compliance, including training, expert insights, and system support.

What are the key components of the program?

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There are three major components to the AIAG Forced Labor Due Diligence Program:

  1. Vetted Technology Solutions: Trusted providers for cost-effective compliance tools.
  2. Standardized Reporting: Use of the common Due Diligence Reporting Template (DDRT) accepted by customers and coordinated by Tier 1s.
  3. Training & Resources: Access to training, legal insights, and webinars to stay informed on compliance standards.

How do suppliers get started with the program?

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Suppliers can begin by visiting the AIAG marketplace at www.aiag.org to select a vetted provider from the program list, familiarize themselves with the DDRT, and utilize the training resources offered by AIAG.

Who are the technology solutions providers?

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After an open request for proposals, four companies – Kharon, Altana, SUPPLIERASSURANCE, and Resilinc – have been selected and are available at a reduced cost through AIAG. All four will utilize the expertise of Kharon, an industry-leading risk screening company that combines technology with expert research. Either as a stand-alone product or integrated into one of the three participating platforms, Kharon’s products enable identification of many supply chain risks, including potential connections to forced labor. On the AIAG Marketplace, Kharon is offered at a significantly reduced price as it provides screening limited to UFLPA risk. This option is not available elsewhere. Kharon is utilized by U.S. Customs and Border Protection, U.S. Department of Homeland Security, and U.S. Department of the Treasury.

Platform companies (Altana, SUPPLIERASSURANCE, and Resilinc) incorporate Kharon’s UFLPA screening functionality to enable supplier batch screening and produce automated reports to support customer requests.

Is participation in the program mandatory?

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Supplier requirements will be set by participating customer(s).

What is the OEM expectation for the frequency of reporting?

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OEMs are launching an aligned annual cadence for reporting, similar to Conflict Minerals reporting. In addition, suppliers are required to conduct additional risk screening when new companies are added to the UFLPA Entity List or other publications citing potential connections to forced labor. If any new potential connections are identified throughout the year, suppliers must re-submit an ad-hoc DDRT to affected customers immediately.

How does using the Due Diligence Reporting Template (DDRT) improve communication between suppliers and customers?

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The DDRT enables a consistent approach for communicating risks related to potential forced labor across all tiers of the supply chain. It allows Tier 1 suppliers to consolidate and share relevant data directly with customers to reduce duplicated efforts, streamline responses, and help customers address risks more efficiently.

How are suppliers expected to manage due diligence regarding identified supply chain risks?

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Suppliers are encouraged to function as the primary communicators of potential forced labor risks, gathering insights from sub-tier suppliers and reporting them directly to impacted customers. This process ensures customers receive standardized, relevant information, reducing the need for suppliers to respond uniquely to each customer about the same risk.

What resources are available for suppliers who need help identifying forced labor risks in their supply chain?

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AIAG provides comprehensive support through webinars, expert-led training sessions, and legal insights on forced labor risk. Suppliers can also access guidance on compliance tools and industry best practices, making it easier to stay informed and be proactive about identifying potential risks. Links to all of these resources are located on AIAG’s website: Forced Labor Due Diligence

What reporting is expected from sub-tier suppliers?

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While Tier 1 suppliers take the lead in communication with OEMs, sub-tier suppliers are expected to provide relevant information to their direct customers, if requested, as part of the due diligence process. This collaborative approach helps build a clearer picture of potential risks throughout the entire supply chain.

What should suppliers do if they identify a potential forced labor connection in their supply chain?

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Information regarding potential connections will be used by customers to initiate further investigation to illuminate the existing supply chain and validate whether actual connections to forced labor exist. If a forced labor risk is identified, suppliers should report this information immediately to their impacted customer(s) via email to both their buyer and the due diligence team listed below or on the “Instructions” tab in the DDRT. Once the risk is identified, please work with your customer(s) to conduct further due diligence to make a final determination and corrective action plan (if needed).

How is data privacy managed within the program?

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All participating technology providers adhere to strict data privacy standards, ensuring that sensitive information related to supply chain risks is managed securely and in compliance with applicable laws. Suppliers can feel confident that their data is protected throughout the reporting process.

Does this due diligence process replace existing requests from customers?

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No. If you have received a request from one of your customers, continue to work with them to answer their request for information. The Forced Labor Due Diligence Program is intended to provide access to due diligence tools and an aligned reporting process. 

Does the DDRT track which parts a supplier provides?

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The DDRT gives suppliers the opportunity to provide the number of parts that are potentially impacted, but additional information is not required at this phase of the investigation.

Can you explain how the platform providers will prepare the DDRT? Will they prepare one DDRT for a company, or one specific to each of the company’s customers?

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The platform providers enable suppliers to provide a customer-specific response to ensure that the information submitted is particular to that customer’s supply base, providing an additional layer of supply chain privacy for suppliers.

How do I obtain pricing for these platforms?

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Technology provider pricing is determined by annual company revenue, desired functionality, and other program features.  AIAG will work with the providers to determine pricing that best meets a company’s needs. 

Do the customers have a process for updating a sub-tier company’s risk level based on updated supply chain data and/or potential involvement with forced labor?

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Customers will accept updated DDRTs at any time during the reporting year. 

How many tiers do suppliers need to include in their due diligence?

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Initial expectations are that suppliers conduct risk screening on all their Tier 1 suppliers only. Suppliers can also include sub-tier suppliers if they have been confirmed in the customer’s supply chain. Please do not include suppliers identified with supply chain transparency software. Increases in the number of confirmed sub-tier suppliers is an opportunity for suppliers to improve the quality of their response over time.

If my supply chain is in the United States only, does my company need to submit a DDRT?

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Yes. All suppliers must complete DDRTs as requested by their customer. Supply chain risks are not dependent on the location of a manufacturer.

How should suppliers submit their completed DDRT forms?

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Forms must be submitted to your requesting customer via email to the due diligence team email listed below or directly through your third-party platform, depending on customer instructions. Should your customer not be listed below, please contact them for specific instructions.

Ford cmineral@ford.com

General Motors ethicalsourcing@gm.com

Honda honda_na_purch_sustainability@na.honda.com

Nissan SupplierDueDiligence@nissan-usa.com

Stellantis stellantishumanrightsoffice@stellantis.com

Toyota TEMACSR@toyota.com

Who should suppliers contact for support or questions about the program?

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Suppliers can contact the AIAG team via email (stopforcedlabor@aiag.org) for questions about selecting providers, reporting, or utilizing program resources.