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A CFO briefing: Ask the workers

Updated: Sep 4

This blog post is a briefing to the CFO for a budget to set up an Ask the workers pilot implementation. It is a template that can be used that includes a calculation of return on investment.


CFO briefing ask the workers

It covers:


  • Summary (1 page)

  • Supporting materials (4 pages)


The CFO already has a high level understanding of the issues involved in worker rights, and the current processes (and spend) involved in the ethical sourcing / responsible sourcing / corporate social responsibility team - for example:


  • current headcount and budget

  • external spend on social audits and surveys, consultants and legal supports

  • seeing the results that the teams produces as part of:

    • compliance reporting,

    • interactions with statutory auditors,

    • preparation of board reports, and

    • the provision of CSR supplementary data as part of the interim and annual financial accounts.


The balance of this document can be downloaded as a word file.



Summary: CFO briefing on Ask the workers


Context:


As a business, we do not set out to profit in situations where our activities or those of our suppliers cause immediate and current harms.


Today, whilst we do operate in line with general market practice, the systems and processes to monitor our locations and supply chains are not sufficiently effective in detecting whether worker labour rights are being abused.


That's in both our own locations where workers are provided by others (via sub-contractors or out-sourcing partners), and in our supply chains.


Such harms can include:

  • Forced labour including debt bondage

  • Illegally low wages

  • Health and safety breaches

  • Harassment and discrimination


We have systems already in place to manage our labour rights risks with our own employees. We have no effective monitoring in place for workers who contribute to our profits via their labour but who are not employed by us.


Legislation, court cases, social media, journalists, public attention is increasing across this space leading to increased risks that labour rights abuses in our locations and supply chains are detected and linked to us publicly.


Our defence in this situation will be to demonstrate that we have taken all reasonable efforts to detect and monitor our suppliers and locations for such abuses.


Our current approach is not at the right level.


Proposal:


  • Implement Ask the workers in a 6 month' pilot.

  • Ask the workers is a low-cost continuous monitoring system for workers which will deliver data to us on how labour rights are being observed by our supporting suppliers, in our own locations and our supply chain.

  • Validate the monitoring that such a system delivers.

  • Assess the effectiveness and potential to reduce our spend on other costly initiatives (reduce scope and frequency of supplier audits, increase the efficiency of our own teams in detecting issues and delivering / monitoring remedy).


Costs:


The cost of Ask the workers is low relative to the additional assurances we gain and the efficiencies that can be introduced into our existing processes:


  • 6 month' pilot, 20 sites: budget £7,000 - £10,000

  • enterprise-level implementation, 500 sites: annual budget £38,000-£68,000 depending on configuration


Once we have evaluated Ask the workers, we should be able to propose adjustments to our spend in this area that more than cover the cost of the platform.


Decision:


  • Approve the 6 month Ask the workers pilot.



Supporting commentary


These supporting materials include links to external sources and an analysis of the return on investment ("ROI") for an Ask the workers implementation.


The issue we need to address


Our current ESG and CSR policy has two levels:


  • Immediate harms: We monitor our business operations for any immediate harms that our enterprise activities (us, our locations, our supply chains) might be causing - and we take steps to remediate them straight away. As a business, we do not wish to profit from activities that are demonstrably based on harm.


  • Long term goals: We have long term goals to improve our business operations to reduce our carbon footprint, increase the circularity of our goods, improve conditions and prospects for employees, and improve our contribution to society generally.


The liabilities that we can have when we profit from activities that cause immediate harm are significant. This is why we specifically prioritise the monitoring of our operations and those of our suppliers in this respect.


What we need to improve


We need to improve how we monitor the treatment of workers who contribute to our profits. "Workers", in this context, are people who are not employees but work for us in our locations or in our supply chains.

Why?


  • Current worker monitoring processes generally fail to identify where we may be profiting from abuses of worker labour rights.


  • Our current processes rely on supplier self-certification (ineffective), social audits (not effective) and targeted but expensive surveys where we have specific concerns (poor value for money).


  • New tools are available that can monitor worker labour rights continuously, at scale and at low cost with high levels of authenticity - we have selected Ask the workers.


The business case


The business case is based on the following three pillars. These emerge from an upgraded approach to monitoring worker labour rights using "Ask the workers":


  • From attestations to evidence: We stop relying on supplier self-certification and we get continuous, anonymous worker-voice data across all our suppliers and across all our own sites where labour is provided externally. Instead of checking whether policies exist, we check whether they are implemented.


  • From point-in-time to real-time: Existing processes deliver point-in-time snapshots (certifications, audits, surveys). Real-time and continuous monitoring of workers directly can identify issues early and track remediation; this reduces disruption, adverse publicity, compliance risk and cost to remedy. Our current tools do not do this.


  • From cost centre to risk hedge: A small, fixed platform fee offsets large, volatile tail risks (adverse publicity, brand damage, shipment holds, product withdrawals, legal/regulatory actions).


What is "Ask the workers"?


Ask the workers enables us to monitor how workers are treated from a labour rights' perspective.


  • Workers are people who create value for our enterprise and who are not employed by us. They work for suppliers, sub-contractors, or are provided to us by labour providers. They might work in the supply chain or might be present in our own locations.


  • Worker labour rights are the rights of those workers as set out in local laws and international conventions (eg: International Labour Organisation, Ethicla Trading Initiative) - all of which we aim to abide by and we expect our suppliers to abide by them too.


In most businesses, the contribution of "workers" to enterprise value greatly exceeds the contribution of direct employees - often by multiples.


Ask the workers is a technology platform delivers continuous monitoring of workers - that's all the workers, all the time. It is an "always-on" system connecting all these workers directly to us, enabling workers to report their labour-rights' experiences to us anonymously and safely.


Risks if we continue as now (keep the status quo)


Increasing regulatory & legal exposure (eg: EU, UK, US)



Risks of external detection are increasing


  • Social media, NGOs and activists are driving a drumbeat of increasing focus on the abuse of labour rights in supply chains and in locations that we manage.


  • Risks are external detection are increasing, especially in our domestic locations where we employ workers via sub-contractor or via labour providers.


Remediation costs are higher when detection is later


  • Each month an abuse of worker rights continues is another month of potential remediation costs and compensation.


  • This is whether these costs are borne by us or our supplier - in the end, we have an exposure.


Audit & assurance blind spots


  • Social audits are widely documented as insufficient to detect systemic abuse and should not be treated as proof of due diligence.


  • Relying on them alone leaves a known detection gap — especially for agency and temporary workers on our own sites.


  • Sources: Human Rights Watch, Business & Human Rights Resource Centre


Commercial & financing risks


  • Customer requirements are converging on a requirement that we demonstrate robust due diligence and verifiable worker-voice mechanisms.


  • Claims enforcement (UK CMA): We back up our zero-tolerance public stance on forced labour and abuse of worker rights with ineffective monitoring. Claiming “responsible sourcing” without practical monitoring increases our exposure and the potential for CMA actions. Sources: Linklaters.com, The Wall Street Journal, The Guardian


Reputational, ethical & governance risks


  • Media/NGO investigations into forced or exploitative labour create immediate, material brand damage and management distraction.


  • Worker exploitation (eg: forced labour, harassment, withheld pay) is an immediate harm—not a distant ESG target. If we do not monitor, we risk profiting from exploitation that is occurring today.


Risk reductions from continuous monitoring (ATW)


If we implement continuous monitoring using a platform like Ask the workers, we get numerous upgrades and numerous benefits.


  • Defensible due diligence: For FLR/CSDDD, continuous worker-voice plus documented remedies evidences effective due diligence rather than box-ticking.


  • Early signal → cheaper fixes: Anonymous, always-on reporting surfaces problems before they escalate into public, regulatory or trade events. That shifts us left on the cost curve.


  • Built-in grievance channel: enables individual workers to raise issues they personally experience - so both systemic and individual situations can be identified.


  • Discourages labour-rights abuses: continuous monitoring delivers visible transparency which encourages better behaviour in 3rd party suppliers. Prevention is much cheaper than cure.


  • Audit substitution & rationalisation: Continuous monitoring allows us to reduce the scope and frequency of expensive audits — yielding direct savings that can fund the ATW platform from day one (outlined in ROI).


  • Own-site coverage where labour is provided to us: Monitoring extends to labour-providers at our own locations — a current blind spot. Reputational and regulatory risks from labour-rights abuses in our own locations are much higher than if they occur in distant suppliers.


ROI calculation (for the CFO)


Calculating the ROI for investments in ESG, CSR is difficult generally. Many of the factors involved are "soft" and hard to quantify.


Hard factors - we know what we spend:


  • External costs (technology, consultants, lawyers, auditors, surveys)

  • Business interruption costs (demurrage, investigations, delays)

  • Salaries of our own head count


Soft factors - do we know what we gain from better monitoring?


  • Better compliance as laws and regulations get tougher

  • Easier discussions with our auditors

  • Availability of direct worker data at scale for our reporting

  • Lower risks of reputational and brand damage

  • Lower costs to manage issues if they are found

  • Lower likelihood of business interruptions


The cost of Ask the workers is very low relative to the additional assurance we can gain and the efficiencies introduced into our existing processes:


  • 6 month pilot, 20 sites: budget £7,000 - £10,000

  • enterprise-level implementation, 500 sites: annual budget £38,000-£68,000 depending on configuration


These costs can be covered via better handling of a single incident in our supply chain - BUT, in fact there should be no requirement to increase the budget allocated to Ethical and Responsible Sourcing in order to implement Ask the workers because continuous monitoring can introduce efficiencies.


Efficiencies using Ask the workers arise because:


  • continuous monitoring reduces the frequency of issues arising,

  • we can reduce the scope and frequency of social audits,

  • remediation costs are lower because they issues are caught more quickly,

  • Ask the workers includes monitoring of sustained remediation delivery,

  • consolidated data is always available so reporting efforts are reduced.


We do not need to rely on the soft benefits to justify moving forward here.


Board-level statement you can stand behind


  • With ATW: “We have a continuous, anonymous worker-voice channel across priority suppliers and our own agency-staffed sites; we monitor, remediate, and verify effectiveness.”


  • Without ATW: “We rely on supplier attestations and periodic audits; we cannot verify day-to-day practice for non-employee workers.”The first statement is defensible under FLR/CSDDD scrutiny; the second is increasingly not (see EUR-Lex European Commission).


Recommendation


Proceed with the 6-month, 20-site pilot to quantify and prove savings in relation to our current budgets and assess the risk reductions achieved.


If the pilot goes well, scale to an enterprise-level.


The platform remains low cost relative to even a single disrupted shipment or labour-rights investigation, while aligning to our priority in CSR which is properly to monitor the risks that we are benefiting from immediate and current harms with workers’ realities.

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