D6. Protection of Identity and Non-Retaliation

Code 7.0

Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained unless prohibited by law. Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

Elements to Demonstrate Compliance to RBA Code

1. Policy

Ensure adequate and effective policy and procedures ensuring protection of identity and non-retaliation are in place, including the following elements:

• a. Safeguards are in place to prevent reduced protection of identity and retaliation.
• b. Monitoring procedures related to protection of identity and retaliation are in place.
• c. Adequate and effective policy and procedures to ensure protection of whistleblowers and/or users of the grievance mechanism(s) (internal and external).

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. The gathering, follow-up, and investigation of reports of ethical or legal misconduct are done while protecting the identity of the reporting source.
• b. There are clear communications channels so that workers are comfortable reporting violations or issues of concern without fear of reprisal.
• c. There is adherence to policies that prohibit retaliation for worker reporting.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Investigation and sanctions findings are listed in D1.1.
• b. Findings on grievance mechanisms (internal and external) are listed in E8.1.
• c. Management can demonstrate how retaliation is prevented and monitored.
• d. Workers confirm management has assured them of non-retaliation and that they are unaware of any retaliation case.

4. Rating

• Major: No detailed and understandable policy and procedures implemented.
• Minor: Partial policy or procedures or implementation.

1.0.0 (2021-01-01)

Changed

• Initial historical baseline — Protection of Identity and Non-Retaliation (RBA Code of Conduct 7.0): Earliest imported version (provision D6). Programs ensuring confidentiality, anonymity and protection of supplier and employee whistleblowers, and a communicated process for personnel to raise concerns without fear of retaliation. Rated on documentary policy/procedure completeness only — Priority was Not Applicable; the worst rating was Major ('No detailed and understandable policy and procedures implemented'), with Minor for partial policy/procedures/implementation. No evidence-based confirmed-retaliation or identity-breach Priority trigger yet existed.