Förvalta avtalet
Preparing suppliers
After the contract award standstill period has ended, it is good to hold a kick-off meeting with the suppliers. This meeting provides an opportunity to:
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Explain the contract clause by running through this guidance.
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Establish contact with the individuals responsible for due diligence.
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Inform about the monitoring process.
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Answer any questions.
Establishing early contact with the supplier’s due diligence representatives is crucial for smooth collaboration and effective monitoring.
Planning monitoring
Monitoring is crucial for several reasons:
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Ensuring that the supplier complies with the contract clause.
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Guaranteeing that the Swedish Regions get what has been requested.
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Preventing unfair advantages for non-compliant companies.
You should have planned the monitoring during the preparation phase, even if the details are finalized now. Specifically, this involves determining:
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When monitoring shall take place.
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How it will be conducted.
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Who is responsible for it.
Procurement categories with particularly high risks are jointly monitored by the National Secretariat for Sustainable Procurement. The results are published here on the website. You can also contact the secretariat for information on which suppliers will be monitored during the year.
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How to carry out a risk analysisStep 1: Mapping the supply chain The first step in a risk analysis consists of mapping the supply chain to find out its structure. This includes identifying in which countries the work is carried out, and if possible also in which regions. This is particularly relevant if the work is carried out in any region known to have high risks. Within certain industries such as food, textiles and IT there is a lot of information. For other industries such as pharmaceuticals, however, transparency is low. To obtain this information, you can ask the category manager, the category councils, ask questions of suppliers, find out import data, read audit reports and market analyzes for specific industries. It is also important to identify what type of work is carried out and what type of actors in the supply chain that performs it. Is it, for example, an industry characterized by low wages and health-hazardous processes? Does the workforce consist of migrant workers or seasonal workers? Is the supply chain complex with many subcontractors and a lack of transparency? This type of information is important as both geographical risks, industry risks and product risks need to be taken into account. Step 2: Gather information from credible and independent sources Once you have mapped the origin and the supply chain, the next step is to gather information about the situation of human rights, workers' rights, the environment and business ethics in the relevant countries where the work is carried out, that is, both for final manufacturing, component manufacturing and raw materials. For this you need to turn to credible and independent sources such as international organizations, authorities, voluntary and civil society organizations and global trade unions. Sources Step 3: Identify and assess negative impacts The last step involves assessing the actual and potential negative impact the supply chain is associated with, based on the information that has been compiled in steps 1 and 2. This is to be able to determine which concrete measures need to be taken to manage the risks. Often several risks have been identified and to prioritize them you need to make a seriousness assessment. The most significant risks are prioritized based on probability and seriousness ( read more under point d in process requirement 2 )
Conducting monitoring
Excerpt from contract clause
Supplier shall participate in and cooperate with [the contracting organisation] in the monitoring of the commitments in the Code of Conduct for Suppliers (clause 1) and the due diligence process (clause 2). Monitoring may be carried out through various methods such as dialogue, self-assessment, supply chain transparency and audits.
Suppliers are required to participate in monitoring.
The contract clause allows for the use of various methods for monitoring.
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How to carry out a risk analysisStep 1: Mapping the supply chain The first step in a risk analysis consists of mapping the supply chain to find out its structure. This includes identifying in which countries the work is carried out, and if possible also in which regions. This is particularly relevant if the work is carried out in any region known to have high risks. Within certain industries such as food, textiles and IT there is a lot of information. For other industries such as pharmaceuticals, however, transparency is low. To obtain this information, you can ask the category manager, the category councils, ask questions of suppliers, find out import data, read audit reports and market analyzes for specific industries. It is also important to identify what type of work is carried out and what type of actors in the supply chain that performs it. Is it, for example, an industry characterized by low wages and health-hazardous processes? Does the workforce consist of migrant workers or seasonal workers? Is the supply chain complex with many subcontractors and a lack of transparency? This type of information is important as both geographical risks, industry risks and product risks need to be taken into account. Step 2: Gather information from credible and independent sources Once you have mapped the origin and the supply chain, the next step is to gather information about the situation of human rights, workers' rights, the environment and business ethics in the relevant countries where the work is carried out, that is, both for final manufacturing, component manufacturing and raw materials. For this you need to turn to credible and independent sources such as international organizations, authorities, voluntary and civil society organizations and global trade unions. Sources Step 3: Identify and assess negative impacts The last step involves assessing the actual and potential negative impact the supply chain is associated with, based on the information that has been compiled in steps 1 and 2. This is to be able to determine which concrete measures need to be taken to manage the risks. Often several risks have been identified and to prioritize them you need to make a seriousness assessment. The most significant risks are prioritized based on probability and seriousness ( read more under point d in process requirement 2 )
Managing deviations
Excerpt from contract clause
Supplier shall address deviations from the commitments in the Code of Conduct for suppliers (clause 1) and the due diligence process (clause 2). Focus shall be on improvements in Supplier’s operations and in its supply chains.
When managing deviations, the focus should be on improvements. This is best achieved through collaboration with suppliers, whether the issue concerns the Code of Conduct or the due diligence process. Deviations are common, even among suppliers actively working with sustainability. Some issues may be easy to resolve, and not all are equally severe.
Whenever deviations are identified, an action plan shall be established, including a timeline clearly outlining how and when the supplier shall address the deviations. If the supplier fails to follow the agreed plan, the contract clause includes various sanction options.
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How to carry out a risk analysisStep 1: Mapping the supply chain The first step in a risk analysis consists of mapping the supply chain to find out its structure. This includes identifying in which countries the work is carried out, and if possible also in which regions. This is particularly relevant if the work is carried out in any region known to have high risks. Within certain industries such as food, textiles and IT there is a lot of information. For other industries such as pharmaceuticals, however, transparency is low. To obtain this information, you can ask the category manager, the category councils, ask questions of suppliers, find out import data, read audit reports and market analyzes for specific industries. It is also important to identify what type of work is carried out and what type of actors in the supply chain that performs it. Is it, for example, an industry characterized by low wages and health-hazardous processes? Does the workforce consist of migrant workers or seasonal workers? Is the supply chain complex with many subcontractors and a lack of transparency? This type of information is important as both geographical risks, industry risks and product risks need to be taken into account. Step 2: Gather information from credible and independent sources Once you have mapped the origin and the supply chain, the next step is to gather information about the situation of human rights, workers' rights, the environment and business ethics in the relevant countries where the work is carried out, that is, both for final manufacturing, component manufacturing and raw materials. For this you need to turn to credible and independent sources such as international organizations, authorities, voluntary and civil society organizations and global trade unions. Sources Step 3: Identify and assess negative impacts The last step involves assessing the actual and potential negative impact the supply chain is associated with, based on the information that has been compiled in steps 1 and 2. This is to be able to determine which concrete measures need to be taken to manage the risks. Often several risks have been identified and to prioritize them you need to make a seriousness assessment. The most significant risks are prioritized based on probability and seriousness ( read more under point d in process requirement 2 )
The Swedish Regions also have a national escalation procedure that specifies the actions to be taken if the deviations are not resolved. When using the procedure, it is important to:
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Document each step.
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Ensure that the prescribed actions are followed.
Terminating a contract should be a last resort after repeated attempts to address deviations. Even in cases of severe deviations, an immediate termination can sometimes worsen the situation, making it crucial to exit responsibly.
For example, the Code of Conduct states that employers should participate in programs ensuring that children found in labour receive education. This process takes time and requires long-term collaboration with both the supplier and sub-supplier. Simply dismissing the child or terminating the contract could push them into more dangerous work, such as prostitution.
However, the contract clause does allow for immediate termination if a severe deviation is proven. This applies only if the responsible party fails to immediately take action to prevent and mitigate the deviation.
Evaluating results
Before extending or terminating a contract, you should evaluate the contract performance:
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In which contracts has the contract clause been applied?
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Which of these contracts have been monitored?
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How many audits have been conducted per contract/supplier?
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What were the costs of the audits?
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How have you influenced suppliers’ due diligence and supply chain working conditions?
This evaluation provides valuable insights for future procurements of similar goods or services.
The evaluation of the previous contract period is important information in the preparatory phase for future procurement of similar goods or services.
Communicating results
It is important to communicate your due diligence efforts to highlight how procurement contributes to improved supply chain conditions. Your communication can focus on:
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Have you achieved your goals?
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What goals will you set for the next period?
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What lessons have you learned?
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How have you invested in training and skills development?
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How to carry out a risk analysisStep 1: Mapping the supply chain The first step in a risk analysis consists of mapping the supply chain to find out its structure. This includes identifying in which countries the work is carried out, and if possible also in which regions. This is particularly relevant if the work is carried out in any region known to have high risks. Within certain industries such as food, textiles and IT there is a lot of information. For other industries such as pharmaceuticals, however, transparency is low. To obtain this information, you can ask the category manager, the category councils, ask questions of suppliers, find out import data, read audit reports and market analyzes for specific industries. It is also important to identify what type of work is carried out and what type of actors in the supply chain that performs it. Is it, for example, an industry characterized by low wages and health-hazardous processes? Does the workforce consist of migrant workers or seasonal workers? Is the supply chain complex with many subcontractors and a lack of transparency? This type of information is important as both geographical risks, industry risks and product risks need to be taken into account. Step 2: Gather information from credible and independent sources Once you have mapped the origin and the supply chain, the next step is to gather information about the situation of human rights, workers' rights, the environment and business ethics in the relevant countries where the work is carried out, that is, both for final manufacturing, component manufacturing and raw materials. For this you need to turn to credible and independent sources such as international organizations, authorities, voluntary and civil society organizations and global trade unions. Sources Step 3: Identify and assess negative impacts The last step involves assessing the actual and potential negative impact the supply chain is associated with, based on the information that has been compiled in steps 1 and 2. This is to be able to determine which concrete measures need to be taken to manage the risks. Often several risks have been identified and to prioritize them you need to make a seriousness assessment. The most significant risks are prioritized based on probability and seriousness ( read more under point d in process requirement 2 )