Update to how outsourcers are recorded

Update to how outsourcers are recorded and new FSC ADVICE 40-004-23 – outsources conformity with core labour requirements.

In reference to Interface and Certificate Holders (CHs), we are introducing new processes in relation to Outsourcing.

Firstly, we have developed a new Outsource Register that all CHs are required to complete. This is in effect a risk assessment to enable us to record and maintain information on which outsource contractors are used and whether they should be considered High or Low risk. Low-risk outsourcers require only a signed Outsource Agreement which you should be familiar with. High-risk outsourcers require an audit from Interface as part of your ongoing compliance with the appropriate FSC standards, prior to their initial use. Please return all completed outsourcer registers to [email protected]

Secondly, FSC has issued guidance on how we are to evaluate outsourcers in relation to FSC Core Labour requirements. Please note this relates to uncertified outsourcers only.

Section 1.1 of the Advice Note requires compliance with Core Labour through an up-to-date Outsource Agreement. Section 1.2 also notes that Outsourcing needs to be considered in the Core Labour Self-Assessment. These 2 requirements are unchanged since the introduction of FSC-STD-40-004 V3-1 at the beginning of 2022.

What is new is how outsourced contractors are managed in terms of risk. In the first instance, points 1.1. and 1.2 as above are in place.

For non-FSC contractors, a further step is required. The completed Outsource Register should assist with this. To qualify as a low-risk outsourcer for core labour, as well as 1.1 and 1.2, non-FSC outsourcers will need to have satisfied the following criteria:

1. there are no substantiated complaints regarding the contractor’s conformity to the FSC core labour requirements since the last surveillance audit; AND
2. the previous evaluation has not resulted in any nonconformities regarding the contractor’s conformity with the FSC core labour requirements; AND

And one of the following:

1. The outsource contractor was audited by Interface at the last audit OR
2. The outsource contractor has undergone a first- or second-party audit and the CH has collated information and records that demonstrates compliance OR
3. The outsource contractor is based in a country with a CPI of greater than 50 AND that country has a ITUC rating of 1 or 2. (Link to CPI and ITUC. (Note that the UK does not meet this criteria with an ITUC rating of 3).

 Please note the definitions of first and second-party audits below.

First-party audit: an assessment that is performed within the organization by their own auditing resource (i.e., internal audit).

Second-party audit: an assessment that is performed by a person or organization that has an interest in the object of the assessment (e.g., an organization conducts an audit of their contractor).

  FSC ADVICE 40-004-24 – Approved Verification Scheme for Core Labour compliance

FSC has approved SA8000:2014 as of the 1^st of July 2023. Any certificate holders, or subcontract outsourcers, who have a valid certificate for this scheme are exempt from 1.6 of the 40-004 standard. The CH shall make documentation relating to this available including audit reports, certificates, corrective action requests, and nonconformities when requested.