OFHPB Newsletter: Responsible Business Conduct Supply Chain Risks


February 2018 • Issue #9

Responsible Business Conduct on SFTool

RBC Module screen

The Responsible Business Conduct module on the SFTool provides a framework for how best practices and resources for addressing human trafficking, child labor, and other applicable supply chain risks can be incorporated within procurements.

View this short video for a quick overview.

The first part of this module covers pre-award best practices and the second part covers post-award best practices. Both the pre-award and post-award sections provide step by step guidance for identifying and addressing risks related to responsible business conduct.

In the module you will find links to relevant resources and tools and guidance for determining and addressing procurement-specific risks. The module also includes case studies illustrating how specific procurements have been successful in addressing these risks.

GSA Federal Supplier Energy and Risk Management (ERM) Tool


GSA recently released the GSA Federal Supplier Energy and Risk Management (ERM) Tool that encourages Federal suppliers to publicly report on cost-saving supply chain practices related to energy use and climate-related risks. The ERM Tool combines federal contract data with data about federal suppliers' and contractors' corporate-level sustainability practices to provide information on energy use and climate-related supply chain risks.

With the Supplier ERM Tool, buyers can see each company’s practices and how much they’re saving. And with a rich visualization of Federal spending, the public can see how government is spending money, and how suppliers are cutting waste and pollution.

Responsible Business Conduct Supply Chain Risks

RPC v 3

20 million. More than twenty million men, women and children around the world are currently believed to be victims of human trafficking, a global criminal industry estimated to be worth approximately $150 billion annually.

Responsible business conduct includes promoting workers’ rights and safe working conditions, preventing human trafficking and forced labor, and addressing other human rights-related risks. Due to the complexity and amount of materials involved, building projects face a variety of supply chain risks that vary both by sector and materials’ country of origin. Informing contractors about these risks and encouraging transparent reporting helps minimize risks from such practices.

U.S. government policy prohibits human trafficking and forced labor within federal contracts. In addition, Section 307 of the Tariff Act of 1930 prohibits importing merchandise mined, produced, or manufactured in any foreign country by forced or indentured child labor. Purchasers importing such merchandise risk seizure of property and potential criminal investigation.

Information on these risks can be found within the Department of State’s U.S. National Action Plan on Responsible Business Conduct (NAP). The NAP addresses global business practices and U.S. Government efforts to focus, improve, and expand its promotion of responsible business conduct.

A new Responsible Business Conduct section on the SFTool provides additional information about how these risks relate to the supply chain. This module provides a framework for incorporating best practices and resources for addressing applicable risks into procurements.


Kevin Funk is Acquisition Lead for Sustainability and Information Technology in GSA’s Acquisition Policy Division