Communication Advice 20230904: ADVICE 40-004-23 new transition phase
FSC has an Advice Note ADVICE-40-004-23 Evaluation of contractors against the FSC core labour requirements included in the attached FSC-DIR-40-004.
FSC has extended the transition date until 31 December 2024, which means all Global-Mark audits in 2024 will include an assessment of compliance with this Advice Note.
If certificate holders use outsourcing contractors and they are not FSC certified, then this Advice Note is very relevant to you.
Organisations are required to:1. Inclusion of contractors within the organization’s self-assessment
1.1 The organization shall include provisions in the outsourcing agreement with non-FSC-certified contractors which are specifying their commitment to the FSC core labour requirements or shall be able to refer to an internal policy of the contractor that is demonstrating such a commitment.
1.2 The organization shall include non-FSC-certified contractors with an outsourcing agreement within their self-assessment which describes how the organization has confirmed the subcontractor’s conformity to the FSC core labour requirements.
Global-Mark is required to do a risk assessment of the contractor to determine ‘LOW RISK’ or ‘HIGH RISK’.
LOW RISK CRITERIA
2.2 An outsourcing arrangement with a non-FSC-certified contractor can be classified as ‘low risk’ if the following applies:
a) there are no substantiated complaints regarding the contractor’s conformity to the FSC core labour requirements since the last surveillance audit; AND
b) the previous evaluation has not resulted in any non-conformities in regard to the contractor’s conformity with the FSC core labour requirements; AND
c) the previous evaluation was conducted as an on-site audit at the contractor; OR
d) the contractor’s conformity to the FSC core labour requirements described within the organization’s self-assessment is confirmed with evidence of documentation and records from a first-party or second-party audit conducted at least annually; OR
NOTE: “Annually” is to be interpreted as follows: at least once per calendar year, but no later than 15 months after the last first- or second-party audit (determined by the date of the on-site visit).
e) the contractor is in a country with a rating of 1 or 2 under the ITUC Global Rights Index2 and with a CPI3 score >50.
Australia DOES NOT qualify for e) above as the Global Rights Index for Australia is currently 3.
This means that to demonstrate LOW RISK, the certificate holder (second party audit), or the contractor (first party audit) must audit against the self-assessment and have documentation and records available to demonstrate conformity with core labour requirements.
If Global-Mark already conducts on-site audits of the contractor, then there is no requirement for d) above.
If LOW RISK criteria is NOT met, then Global-Mark (or contracted other certification body if located in another country) MUST perform an on-site audit of the contractor.
Please ensure you familiarise yourself with the Advice Note and implement the required changes.
Please reach out to our Program Manager: emily.silberberg@global-mark.com.au if you have any general questions relating to the Advice Note.
