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Comprehensive Module

C6: Human rights policies and processes

Your code of conduct or human rights policy, and how your people can raise a concern.

In brief

C6 asks whether your company has a code of conduct or a human rights policy for its own workforce. If it does, you say whether it covers child labor, forced labor, human trafficking, discrimination, accident prevention or other topics. C6 also asks whether you have a complaints-handling mechanism for your own workforce. All of these are yes or no questions.

At a glance

Requirement
Essential: code of conduct or human rights policy, and complaints mechanism. The topics covered, if you have a code or policy.
10 employees or less
Voluntary.
Value chain cap (from 2027)
Code of conduct or human rights policy, and complaints mechanism, for companies with more than 10 employees.
In Selko Report
Page "Code of Conduct"

What changed from VSME

  • Changed: the code of conduct question and the complaints mechanism question are essential for companies with more than 10 employees. Under VSME, they were "if applicable".
  • New: voluntary for companies with 10 employees or less.
  • Unchanged: the list of topics.

VS Standard Reference

The official text of the Voluntary Standard, Annex I to Commission Delegated Regulation (EU) 2026/1560.

Selko Insights

How Selko applies it

Scope
Selko Report

Your own workforce, not the supply chain

C6 is about how you treat your own workforce: your employees, and self-employed people and agency workers who work for you. It does not cover your suppliers' workers. A supplier code of conduct belongs in B2 and C2.

Interpretation
Selko Report

What counts as a code of conduct

A written, approved document that sets out how your company expects people to behave and how it respects human rights. It can be one page. A policy that exists only as unwritten practice does not count here. EFRAG's guidance adds that a company with a human rights due diligence process can also answer Yes.

Paragraph 61(c)
Selko Report

What counts as a complaints-handling mechanism

Any established way for your employees to raise a concern and get a response counts: a named contact person, an HR process, a shop steward, a feedback form or a whistleblowing channel. It does not have to be anonymous or digital, but your employees need to know it exists.

Selko recommendation
Selko Report

Policies we recommend

Discrimination prevention, accident prevention and a general code of conduct are relevant to almost every company. We recommend putting them in place even if you do not have them yet. Child labor, forced labor and human trafficking deserve attention particularly in higher-risk sectors such as agriculture, cleaning, construction and hospitality, in larger companies and in higher-risk regions.

Frequently asked questions

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