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Assess a supplier management system

An practical review of whether supplier systems are repeatable, auditable, and preventative.

When to use this playbook

Use this when internal escalation has become repetitive and remediation quality is uneven.

Use it when a supplier appears compliant on paper but weak in day-to-day evidence and control.

How this source informs this section

Nike Code Leadership Standards 2025 · p. 5

Nike is the right operating source here because it requires the code to be integrated into effective management systems with verification and monitoring.

The supplier facility must implement and integrate the Code... including implementing effective management systems and undergoing verification and monitoring.

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Step-by-step guide

1. Check whether ownership for standards, monitoring, corrective action plan (CAP), and training is explicit and stable.

2. Review documentation pathways: how records move from collection to review to action.

3. Verify evidence quality signals: timekeeping, payroll, training, incident logs, and corrective actions.

4. Test for repeat findings across different audit rounds to spot systemic rather than one-off issues.

5. Assess whether improvement planning includes prevention, not only closure.

6. Set a short-term action plan with ownership and proof requirements for the weakest control area.

How this source informs this section

The Home Depot Responsible Sourcing Supplier Manual · p. 27

Home Depot is useful because it expects a management system that addresses all standards and can pass assessment before reinstatement.

Supplier must demonstrate they have implemented a management system which addresses all of the Standards.

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Quality checks

Responsibilities are documented and not concentrated in one function only.

Evidence systems support both audit response and root-cause analysis.

System failures trigger preventive actions, not only symptom repair.

Improvement actions are measured after completion, not just assigned.

How this source informs this section

OECD Due Diligence Guidance for Responsible Business Conduct · p. 32

OECD is the best cross-check because a system is only credible if implementation and effectiveness are tracked over time.

Track the implementation and effectiveness of the enterprise's due diligence activities... and use the lessons learned to improve these processes.

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Failure modes

Accepting formal policies without checking execution controls.

Creating corrective action plans (CAPs) without owner-level accountability.

Confusing supplier enthusiasm with documented performance.

How this source informs this section

The Home Depot Responsible Sourcing Supplier Manual · p. 16

Home Depot's repeated-violation escalation is a good signal that the system is still policy-first, not control-first.

The Emerging Issues Council... may be requested to determine the appropriate sanctions for any critical or repeated violations.

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Sources

Nike Code Leadership Standards 2025

Nike · standards PDF

Nike's leadership standards are useful here because they turn code requirements into explicit management-system, grievance, and recruitment controls.

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The Home Depot Responsible Sourcing Supplier Manual

The Home Depot · supplier manual PDF

The Home Depot manual makes the operating details concrete: audit access, CAPA requirements, repeated-violation escalation, and subcontracting rules.

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OECD Due Diligence Guidance for Responsible Business Conduct

OECD · guidance PDF

OECD's due-diligence guidance is the main cross-cutting source here for prioritization, corrective action planning, leverage, and follow-up.

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