Compliance due diligence has a reputation for being a paperwork exercise, and too often that is exactly what it is: a supplier emails a folder of certificates, someone files them, and everyone moves on. That process catches almost nothing.
Here is a more useful sequence.
1. Ask which factory, by name and address
Start here, because everything else depends on it. You are entitled to know the legal name and street address of the unit making your goods. If a supplier will not tell you, that is your answer, and the most common reason is that the order is being subcontracted somewhere they would rather you did not see.
Unauthorised subcontracting is the single largest compliance risk in the industry. Every serious incident of the last decade has involved production in a building the buyer did not know about.
2. Check the certificate is current, and matches
Three things to verify on any audit report or certificate:
- Expiry date. BSCI and SMETA reports have validity windows. An expired report is not evidence of anything.
- The address matches. A certificate for a group’s head office does not cover the unit sewing your order.
- The scope matches. A certificate covering cutting and sewing does not cover the laundry your denim is going to.
3. Read the findings, not the score
A compliance report is more useful than a certificate because it lists what was actually wrong. Ask for the full report, then look at the corrective action plan: what was found, what was promised, and whether follow-up verification happened.
A factory with open findings that it is visibly working through is often a better partner than one with a spotless report and no detail. Perfect reports sometimes mean a thorough audit; sometimes they mean a shallow one.
The useful question is not “did they pass?” It is “what did they find, and what happened next?”
4. Confirm building safety separately
In Bangladesh, structural, fire and electrical safety sits under the RMG Sustainability Council, which took over the Accord’s inspection programme. This is separate from social compliance and must be checked separately. Ask for the inspection status and the remediation progress, not just a membership claim.
5. The questions that reveal the most
Certificates tell you about a day. These questions tell you about a culture, and none of them are hard to ask:
- How are wages paid? Digital payment to individual worker accounts creates a record. Cash does not.
- What is peak-season overtime? A specific, unflattering number is a better sign than a confident “always within limits”.
- Where does the wash and print get done? Sub-processes are where undeclared subcontracting hides.
- Can I speak to workers without management present? The answer matters more than anything they say afterwards.
- What was your last major finding? A supplier who can answer this straightforwardly is usually telling you the truth about other things too.
6. Go, or send someone
Nothing replaces a visit. Look at the exits: are they clear and unlocked? Look at the floor: is it congested? Is there a functioning grievance box, and does anyone appear to use it? Is there a crèche if the law requires one, and are there children in it or is it a storeroom?
If you cannot travel, appoint a third party such as SGS, Intertek or Bureau Veritas, or ask your buying house to walk the floor on a live video call. Any partner who resists this is telling you something.
7. Write down what happens when something goes wrong
Agree the escalation path before you need it. What counts as a critical finding? What happens to production if one is raised? Who pays for remediation? Our own position is that critical findings stop production immediately, major findings carry a 30-day window and minor findings 90 days, all with documented verification.
And a point worth making: exiting a factory the moment a problem appears usually harms the workers more than it helps them. Where a finding is fixable and the factory is willing, staying and fixing it is the better outcome. Where a factory conceals or repeats, leaving is the only option.