With 20,000 employees, TechnipFMC has long looked after its people. It is now taking a risk-based approach to ensure high standards of human rights are upheld further along its supply chain and in the communities in which it works.
Davis Stewart, the company’s Legal Counsel for Anti-Bribery & Corruption and Supplier Integrity, explains how membership of Building Responsibly is helping the organisation stay competitive while doing the right thing.
Davis Stewart, Legal Counsel for Anti-Bribery & Corruption and Supplier Integrity, TechnipFMC
What’s your role and responsibility within your organisation?
I’m compliance counsel for TechnipFMC, and I cover a broad swathe of different areas, including human rights, environmental, social and governance issues, anti-bribery and supply chain integrity.
Part of my job is to keep pace with the market in terms of human rights requirements, to ensure that TechnipFMC is up to par with the requirements of legislation. For example, we need to be prepared to comply with the Uyghur Forced Labor Prevention Act in the US.
What sort of business is TechnipFMC?
We’re a leading technology provider to the traditional and new energy industries, with around 20,000 employees. We deliver fully integrated products, projects, and services using our proprietary technologies and solutions to transform our clients’ project economics. This helps them to unlock new possibilities to develop energy resources, while reducing carbon intensity and supporting their energy transition ambitions.
You’ve been a member of Building Responsibly for a few years. How has your participation evolved in that time?
Our Legal Director of Trade Compliance and Human Rights, Melanie Frank, leaned on Building Responsibly a lot as she developed our supplier human rights audit programme, using the tools and principles of BR to build it out. Now, I’ve joined the BR Steering Committee, and we plan to increase our engagement and share our experiences and perspectives as an organisation.
What are the key challenges you face as a business when it comes to protecting and enhancing workers’ rights?
There’s several. Obviously, certain suppliers are inherently higher risk than others by virtue of the nature of their work. And there are certain countries where there’s a higher inherent risk. Certain products have a deep supply chain, so when there’s multiple layers of suppliers, it obfuscates the lower tiers – so, it’s harder to get down to the bottom of things, and that requires a higher level of scrutiny.
This is compounded by some of the new regulations that are requiring due diligence of the entire supply chain. So we’re not only responsible for our direct suppliers, but their suppliers, and their suppliers’ suppliers. That would traditionally be managed business-to-business, so you engage with your supplier and set your expectations. But that’s not always good enough anymore.
Is that why being a member of BR is increasingly important?
Yes. We want to convey to our stakeholders that we are committed to human rights and ethical behaviour. We want to be a part of a group that shares the same values we have.
Our ESG programme is a key driver too. We established our ESG programme in 2020, and one of our metrics is to audit our 100 highest risk suppliers by the end of 2023. In setting that metric, we had to figure out how we would go about that. Building Responsibly gave us the tools and guidance needed to execute a successful supply chain human rights audit programme.
In the last two years, we’ve delivered self-assessment questionnaires and completed due diligence reviews of all 100 suppliers. We’re now in the process of conducting two levels of audits based on those self-assessment questionnaires. One is a desktop audit, to clarify answers or obtain additional information. And then the level above is, where appropriate, to carry out actual onsite audits.
We’re well on schedule to meet our objective of auditing all 100 suppliers by the end of 2023.
And how many suppliers do you have in total?
We have around 7,000 in total. When it comes to auditing – which is extremely time and resource intensive – we have to take a risk-based approach. So we look at which of our suppliers are operating in the most high-risk countries, conducting the highest risk scopes of work, and which ones we have the highest spend with. We conduct an annual review to see if there’s anyone that needs to be added to our top 100.
What do you most value about being a member of BR?
It’s the fellowship, teaming up with peers that have the same ethical culture, and a drive to solve an issue as consequential as worker welfare. And it’s important we do so in a way that allows our business to still be competitive and profitable. Because it’s a balancing act. You have to have resources to execute these programmes. We have to find the right balance for allocating resources to look after human rights, while still doing our jobs.
Having an organization like BR to lean on, and provide tools, is really, really helpful and important.
We take care of our workers, but we should also – to the extent we can – help improve the welfare of the workers that are indirectly working for TechnipFMC. By virtue of being a member of BR, we are doing that, which is something I’m proud to do.
Beyond the principles and guidance, what else would you like BR to focus on next?
TechnipFMC is looking to expand its human rights programme with community engagement, and we’d love to leverage examples and models used by other BR members to allow us to enhance our community engagement strategy.
Training is also important. After we’ve conducted our supplier audits, we need to address what happens next. Using training modules is a large part of that. It’s about educating suppliers on what human rights are, why they’re important, and how to improve them.
Standardisation is another key area that needs to be addressed by the group. There’s a lot of bureaucracy involved in the process of sending out and completing supplier questionnaires. It’s a big paper shuffle. In areas such as finance or quality and safety, there has been plenty of standardisation in the questionnaire process so that you’re not recirculating the same questions over and over. That’s something I’d like us to look at as a group.
So, what’s going to be keeping you busy in the coming months?
Completing the audits of our 100 highest risk suppliers by the end of next year is a huge priority for us. We’re also working on an internally developed dashboard that centralises all the data. Putting all of our data in one place will allow us to track things more efficiently, and to report more effectively. It will benefit our clients because we can easily report to them what we’re seeing. And it will benefit our investors and regulators too.