Responsible Purchasing Practices
Your sustainability annex sets out what the supplier must do. Purchasing practices are the part that sets out what you do — even where nothing has been written down.
How a purchasing decision becomes a human rights risk
Supply chain human rights risk is usually treated as a property of the supplier: the supplier sits in a risk country, the supplier has gaps, the supplier needs auditing. Part of the risk, however, originates at the buyer’s own end — in ordinary commercial decisions that nobody intended as sustainability questions.
- A price below the cost of production.
The supplier takes the order anyway. The difference comes out of somewhere, and it is usually working hours or wages. - An order changed late.
Volume or specification changes; the delivery date does not. The flexibility is found in overtime. - A shortened lead time with nothing else adjusted.
The same order in less time is a different order, even though the contract makes it look identical. - An unreliable forecast.
The supplier sizes capacity wrongly and closes the gap with temporary labour or unauthorised subcontracting. - An invoice paid after terms.
The working-capital gap travels down the chain, and at the bottom of it the gap shows up in the payroll.
All five are mechanisms that produce excessive overtime and unauthorised subcontracting. They are not the supplier’s choices. They are consequences of the buyer’s.
Why this matters legally
The UN Guiding Principles distinguish three relationships to harm: a company can cause it, contribute to it, or be directly linked to it through a business relationship. The distinction is not semantics, because different obligations follow from each.
A company that is linked to harm is expected to use its leverage. A company that contributes is expected to do more: it must cease its own contribution and participate in remediating the harm. Where the purchasing practice is what produces the overtime, the buyer is not a bystander but a contributor — and an audit aimed only at the supplier does nothing for either obligation.
This is the supply-chain risk you do not need a supplier to fix.
What the regulation says about purchasing practices
The Corporate Sustainability Due Diligence Directive does not treat purchasing practices as a separate topic, but it requires due diligence to be embedded in all relevant policies and management systems — procurement decisions included. On prevention, a company is expected where necessary to make changes to its own practices and business plans, not only to impose requirements on its business partners. The mechanism for contractual assurances is built on reciprocity: a buyer cannot require of a supplier what its own practices make impossible. More on sustainability due diligence
The European Commission’s guidelines on the Forced Labour Regulation name responsible purchasing practices as one way of showing that a product was not made with forced labour. That Regulation has no size threshold, and its obligations start on 14 December 2027. More on the Forced Labour Regulation
The difference matters. The CSDDD binds only very large companies directly; the Forced Labour Regulation applies to every economic operator. Purchasing practices are where the two meet — the same work serves both, and your customers’ supply-chain requirements on top of them.
Where most companies start at the wrong end
- Auditing the supplier for a problem your own buying produced.
The audit finds the overtime. It does not find the cause, because the cause sits in your ordering behaviour and is not visible on the supplier’s premises. - Sustainability clauses that run one way.
The supplier commits to ten things and the buyer to none. A contract that binds the buyer to nothing also protects the buyer from nothing. - Buyer incentives that reward exactly what creates the risk.
Cost savings and delivery reliability are both measured. The quality of a purchasing practice is not, so it steers no one. - Forecasting and order-change practices are not seen as a sustainability matter.
So they are never assessed, even though they are among the most common single sources of risk. - The training goes to the sustainability team.
The people who make the price, forecast and schedule decisions are not in the room.
How we help
- 01 Assessing purchasing practices category by category
Risk arises through a different mechanism in each category. One blanket assessment tells you nothing about any of them. - 02 Two-way sustainability clauses and Supplier Codes of Conduct
Terms that bind the buyer as well — and that provide a mechanism for correcting what is found. - 03 Training for the buying function
For the people who make the decisions, built on real situations rather than principles. See also contracting in value chains
Frequently asked questions
What do responsible purchasing practices actually mean?
Setting price, lead time, forecast, order changes and payment terms so that they do not force a supplier to breach the requirements you have placed on it.
Isn’t it enough that the supplier signs up to our Supplier Code of Conduct?
Not if your own purchasing practices make compliance impossible. Then the document exists and so does the risk.
Does this concern us if the CSDDD does not?
Yes. The Forced Labour Regulation has no size threshold, and your customers pass their own obligations down to you as contract terms.
How do we know whether our purchasing practices are a problem?
By comparing your own order and payment data against what you have required of suppliers. The information is already in your systems — not in a supplier questionnaire.
Who should own this internally?
Procurement, not sustainability reporting. The sustainability function can support, but the buyer makes the decisions.
Let’s look at what your purchasing practices actually produce.
The first conversation is free. We go through your procurement categories, the requirements your customers are already making, and what your own order data shows.