Global Trace

Appendix G. Traceability Guidance from the Global Trace Protocol Project

Traceability for Improved Labor Conditions

Purpose: The Global Trace Protocol guidance is designed to assist manufacturers, brands, and industry groups in tracing products through a supply chain between raw materials and finished good. It also provides guidance on data management and data sharing for associated supply chain data collected during traceability implementation.

Use: The Protocol is to be used in the design, implementation and evaluation of traceability efforts, grounded both in labor rights principles and supply chain due diligence procedures. The Protocol may be used to assist in documenting the reliability of an organization’s sustainability claims and demonstrating appropriate responses to risks and adverse impacts identified through traceability efforts. The Global Trace software tool has been designed to be aligned with this protocol.

Traceability Definition: The ability to identify and trace the history, distribution, location and application of products, parts, and materials, to ensure the reliability of sustainability claims, in the areas of human rights, labor (including health and safety), the environment and anti-corruption, among others.

Scope: This protocol is meant to be commodity and geographically agnostic. It builds on the piloted use of the tool, primary focus on child and forced labor and related exploitative practices; designed to be flexible, scalable and expandable on labor rights and social responsibility, ability to expand to environmental standards and criteria.

Due Diligence Management Systems and Trace Strategy

  • Responsible Sourcing Policy: Develop or edit this policy so that it specifically prohibits Child Labor and Forced Labor throughout Supply Chain Extend your commitment beyond direct (tier 1) suppliers to all tiers of your supply chain to address the potential for hidden exploitation deeper within the supply chain.
  • Commitment to Supply Chain Transparency: Make a public commitment to supply chain transparency to uphold labor rights and environmental protections within the company’s supply chain. Integrate the commitment into the company’s responsible sourcing policy and reference applicable laws.
  • Prioritize traceability for high-risk and high importance inputs. Identify and focus on tracing inputs known to present the highest risk of labor abuses within the organization’s final products. If a company sources from a specific region known to be associated with forced labor, the company should prioritize tracing the origin of its raw material from that region. This approach ensures that resources are allocated effectively to address the most pressing issues. Senior Management Accountability: Ensure senior management is accountable for implementation and oversight of traceability within the companies supply chain due diligence system. Assign a management representative with responsibility and authority to enforce commitments.
  • Staff Training and Responsibilities: Identify and train all staff involved in supply chain traceability, ensuring they understand their responsibilities and the purpose of the system. Clearly define responsibilities and link them to specific workstations and tasks. Annex One of the Protocol has suggested Roles and Responsibilities.
  • Resource Allocation: Ensure sufficient material and digital resources are available to support the implementation and maintenance of the traceability system.
  • Detailed Procedures: Develop detailed procedures for implementing traceability, either as new standard operating procedures (SOPs) or integrated into existing frameworks. Specify the Chain of Custody model/s to be used across tiers.
  • Regular Review and Updates: Conduct regular internal reviews to identify shortcomings and areas for improvement. Update the system to accommodate new regulations, market demands, and technology.
  • Supplier Information: Gather minimum profile information for each supplier, including name, address, facility locations, product/service type, worker numbers. Supply Chain Mapping: Map all tiers of the supply chain, including direct suppliers, their suppliers, and the origin of raw materials. The map should encompass and be able to describe the whole supply chain from [Raw Material 1] to [Raw material x], in terms of name of the supplier and production address.
  • Supply Chain Mapping: Mapping should begin with Tier 1 and the organization should progressively build their map over time. Suppliers should be separated by production tiers and arrows should be drawn accordingly from supplier to supplier to identify manufacturing/process flow. If the registered name of the supplier and factory is different from each other, both names should be provided.
  • Sustainability Claims: Clearly define and agree internally about the sustainability claims your company intends to make, ensuring they are specific, measurable, achievable, relevant, and time bound. Utilize recognized standards and certifications to substantiate these claims whenever possible. If employing the Mass Balance Chain of Custody model, clarify that the model does not permit claims related to physical traceability for specific products.

Identifiers, Events, and Data Elements

  • Unique Identifiers: Utilize standardized, unique identifiers for companies, products, locations, and shipments to facilitate accurate tracking throughout the supply chain, and support information interoperability. Examples of these include (GLN, GTIN, HS Code, DUNS, SSCC, LEI, ISO/IEC 15459).
  • Identification of Critical Tracking Events (CTEs): Define the critical tracking events where data will be collected in your supply chain such as production, processing, and shipping to ensure full transparency in the movement and transformation of materials. Use the GS1 Supply Chain Standards for CTEs whenever possible.
  • Definition of Key Data Elements (KDEs): Define the key data elements that will be collected at each CTE, including such items as batch numbers, production dates, material descriptions, and unique identification numbers across the supply chain. Use the GS1 Supply Chain Standards for KDEs whenever possible.
  • Risk Indicators: Indicators of risk related to labor rights, working conditions, and the environment must be included as KDEs i. These indicators should be aligned with international best practice guidelines and the needs of the sector. Including these as KDEs will allow a company to track and report on these aspects systematically, aligning traceability efforts with broader sustainability and corporate due diligence goals. These include ILO Conventions 29, 132 and 182 , OECD Due Diligence Guidance, EU Due Diligence regulations, and the requirements of the U.S D.H.S. More info on risk found in section IV.
  • Indicators should include type, indicator and sub-indicator definition and should include risk ratings (on a scale from no risk to extreme risk).
  • Internal Batch Traceability: Maintain a system that allows for tracking product batches internally from raw material reception to finished product delivery. Assign unique identification numbers for each stage. This system should record key events like production, processing, and shipping.
  • Definition of Automatic Conversion Ratios: Define any automatic conversion ratios that are used when raw material is transformed from input to output form at each supplier. Update these ratios regularly based on results of transformation and testing.
  • Linking Purchases to Suppliers: Ensure that whenever a purchase or delivery is tracked within your traceability system it is linked to specific supplier records to help establish clear accountability within the supply chain. This includes certificates of origin, purchase orders, invoices, and proof of payment, packing lists, payment records, shipping records, including manifests and bills of lading, and inventory records supporting production.

Data Management and Digital Tools

  • Digital Tool Deployment: Identify and deploy appropriate software and hardware for data collection and management.
  • Automated & Structured Data Entry: Use mechanisms like automatic entry, structured lists, and mandatory fields to minimize errors, support data accuracy and minimize manual data manipulation risk.
  • Data Carriers: Utilize automated data capture and tracking in traceability system. Utilize barcodes, QR codes, or RFID tags to store and transmit key data elements like batch numbers, production dates, and unique product identifiers.
  • User Roles and User Rights: Define specific user Roles according to user type and the system administrators. User types can include such Roles as Pproducer, Aassessor, or Aadministrator. Assign user rights and Role-based access controls tailored to the needs and boundaries of each Role to protect sensitive information and prevent data leakage.
  • The “Least Privilege Principal” should be utilized when Role-based access controls are developed, which maintains that a user or entity should only have access to the specific data, resources and applications needed to complete a required task.
  • Traceability Data Management: Ensure data integrity by maintaining one updated version of data. Use appropriate databases for large data volumes and minimize manual data operations.
  • Third-Party Data Integration: Ensure compatibility and integration with external data sources for enriched contextual, risk, and traceability information.
  • Data Modification History: Be able to track and record who entered or modified data and when to ensure accountability. Retain this history as part of the recordkeeping process.
  • Secure Data Storage: Implement measures to protect traceability information from loss or corruption, including appropriate backups. Secure storage and minimization of manual data operations are vital for protecting data integrity.
  • Data Retention: Maintain up-to-date records covering all applicable requirements for a minimum of ten years, or as long as national regulations require, whichever is longer. This ensures access to historical data for verification and audits. Use secure erasure tools to remove data permanently once the data retention period has passed.
  • Data Security Requirements: Classify data based on its sensitivity and put in place access control mechanisms to protect sensitive data. Ensure security of data at rest and in transit using encryption.
  • Data Sharing: Facilitate secure and efficient data exchange between supply chain actors using tools like EDI and standardize data exchange through APIs using ISO 22095:2020 for common data structures.
  • System Accessibility: Ensure the traceability system is low-cost, easy to use, and capable of handling different sizes of transactions, from small to large. It should be technically compatible and able to integrate with other systems and databases to enhance its effectiveness and reach.
  • Interface localisation: Ensure the traceability system can be used by suppliers by localising interfaces to suit context of use, including: linguistic adaptation; adapting date, numbers, formats, and units of measurement; responsive UI design; and cultural adaptation.

Risk Assessment and Supplier Risk Management

  • Map the labor supply chain: Build out your supply chain map to also identify the labor providers, recruiters, and labor practices across each tier, using new identifiers where needed.
  • Country-Level Risk Factors: Evaluate legal and policy protections, political stability, crime levels, corruption, and socioeconomic factors in each country of operation.
  • Sector-Based Risk Factors: Analyse industry-specific features, like labor demands and workforce vulnerabilities (migrant labor, temporary work, child labor) to assess risk.
  • Cross-Sector Risk Factors: Consider the impact of broader issues like gender inequality and environmental degradation, which can worsen labor conditions.
  • High-Risk Identification: Combine country, sector, and cross-sector risk assessments to identify specific geographic regions and suppliers with elevated risk.
  • Existing Sets of Resources: Consult other existing resources including publicly and private sector databases for guidance in assessing risks.
  • Production Seasonality: Document whether production levels fluctuate seasonally, as this may indicate increased reliance on temporary labor and potential risks. Ensure that risk assessments are undertaken across the different points in the season, to obtain a complete understanding of workplace conditions at the facility.
  • Job Type Analysis: Identify the types of jobs at each worksite, focusing on facilities with higher concentrations of low-skilled, low-paid, hazardous, or undesirable work.
  • Automated Screenings: Utilize software solutions to automatically screen suppliers for potential risks, such as inconsistencies in data, sanctions violations, or adverse media coverage.
  • Labor Recruiter Screening: Implement procedures for vetting and monitoring labor recruiters, including background checks.
  • Supplier Assessments & Interviews: Use questionnaires, interviews, and direct engagement to gather information about supplier labor practices.
  • Assess Suppliers’ Systems: Take stock of the current information management systems used in by supplier organizations (databases, spreadsheets, hardcopy files, apps, servers, etc.).
  • On-Site Assessments: Verify supplier information through site visits, document reviews, worker interviews, and observations.
  • Establish Grievance Mechanisms: Create accessible channels for workers and communities to report concerns related to labor rights, environmental issues, and other ethical violations within the supply chain. Ensure confidentiality, protection against retaliation, and transparent processes for addressing complaints [previous conversation].
  • Risk Mitigation Plans: Develop and implement tailored mitigation plans to address identified labor risks. Plans can include supplier training, worker grievance mechanisms, and improved recruitment processes.

Stakeholder Engagement and Supplier Support

  • Multistakeholder Collaboration: Engage with suppliers, government agencies, NGOs, and other stakeholders to build comprehensive traceability and address labor concerns collaboratively.
  • Feedback Mechanisms: Establish ways to gather feedback from various stakeholders and incorporate it into system improvements.
  • Worker & Community Involvement: Involve workers and local communities in the traceability process, providing necessary training and education to empower them.
  • Support Government Systems: Support the development of government-run traceability systems and make private traceability systems interoperable with government systems to enhance overall effectiveness.
  • Develop Tiered Supplier Requirements: Categorize suppliers based on their risk profiles and capacities. Establish different levels of requirements, with higher expectations for suppliers in high-risk categories or those with greater resources.
  • Provide Resources and Capacity Building: Offer financial assistance, technical expertise, training programs, and access to tools to support upstream partners in meeting sustainability requirements. This might include:
    • Financial incentives: Subsidize the cost of certifications, technology upgrades, or provide premiums.
    • Training: Provide educational resources on sustainable practices, labor rights, and environmental protection.
  • Technology Transfer: Facilitate access to digital traceability tools and data management systems to your suppliers and sub-suppliers as needed.

Reporting and Compliance

  • Quota System: Define and implement a quota system to manage the volume of materials sourced from different suppliers, and justify these quotas based on production capacities to avoid over-harvesting or exploitation.
  • Delivery Volume Monitoring: Implement alerts or periodic checks to verify delivery volumes against established quotas and identify discrepancies.
  • Non-Compliant Procedures: Establish clear procedures for handling non-compliant suppliers or materials, including improvement actions and documentation of the steps taken.
  • Due Diligence Statements: Prepare and submit Due Diligence statements (including any required by regulations) demonstrating compliance with traceability and sourcing requirements. These statements should be in a form ready to be uploaded to relevant registries (e.g. EU DDDS Registry and EU Deforestation) and shared with authorities and supply chain partners.
  • Transparency and Communication: Publicly disclose key information about the company’s sustainability efforts, including its traceability systems, supplier requirements, and progress towards meeting sustainability goals. Regularly communicate with stakeholders about the company’s commitments and performance.
  • System Updates: Regularly update the traceability system to adapt to new regulations, market demands, and technological advancements and regularly refresh data.

Roles and Responsibilities

  • Supply Chain Manager: Manages the implementation of the traceability protocol, ensures suppliers are meeting their obligations to the traceability system, and coordinates with teams to resolve compliance issues.
  • System Administrator: Manages technical infrastructure, including server maintenance, data integrity, system updates, user access, and security.
  • Producers: Adhere to supplier requirements and protocols, provide accurate production data, and help to facilitate on-site assessments to verify compliance with established standards.
  • Assessors and Auditors: Conduct independent assessments and audits, verify compliance at production sites, and produce detailed compliance reports.
  • Compliance Team: Analyzes data and reports, ensures adherence to regulations, and recommends corrective actions to improve supply chain integrity.

References and Resources

The protocol draws upon reports and guidance from multiple sources, including the U.S. Department of Labor (DOL), United Nations Economic Commission for Europe (UNECE), UN Centre for Trade Facilitation and Electronic Business (UN/CEFACT), GS1, U.S. Agency for International Development (USAID), Food and Agriculture Organization (FAO), U.S. Customs and Border Protection (CBP), U.S. Forest Service (USFS), International Labour Organization (ILO), Organisation for Economic Co-operation and Development (OECD), and the European Union (EU). It drew from EU-specific frameworks like the EU Battery Regulations, the EU Timber Regulation, and the EU Conflict Minerals Regulation.

The protocol drew on work from leading organizations and initiatives such as GS1, FishWise, the Fair Labor Association, the Global Reporting Initiative (GRI), Business for Social Responsibility (BSR), International Organization for Standardization (ISO). The protocol also took into account the work of certification and initiatives such as the Responsible Minerals Initiative (RMI), London Bullion Market Association (LBMA), Rainforest Alliance, Responsible Jewelry Council (RJC), Marine Stewardship Council (MSC), Roundtable on Sustainable Palm Oil (RSPO), International Tin Supply Chain Initiative (ITSCI), Better Cotton Initiative (BCI), Global Organic Textile Standard (GOTS), Responsible Mica Initiative, Forest Stewardship Council (FSC), and Fairtrade International. It also incorporates insights from new and proposed standards, such as the SSI Supply Chain Traceability Standard and GS1 guidance on deforestation traceability.

Field-based guidance was drawn from interviews and consultations with over 20 traceability solution providers, alongside reports such as ELEVATE’s “Supply Chain Tracing Project Context Analysis” and U.S. Department of Labor’s “2024 RST Base Tool.” The protocol also explores technological solutions for enhancing supply chain transparency, including blockchain for traceability, electronic data interchange (EDI) systems, and remote sensing tools. Together, these sources underpin the protocol’s comprehensive approach to addressing labor risks, environmental concerns, and sustainability within global supply chains.

The protocol especially drew on the following sources, worth reviewing in their own regard:

Last updated on 6 Jan 2025
Published on 6 Jan 2025