Dawn's Digest (Sep-26) - Your supply chain's people problem
Updated: 4 hours ago
Dawn's Digest | September 2026 Is your supply chain governance ready for the new legislation from October’  Read about: a FREE supply chain solution that allows you to be ahead of the new legislation | Third-party harassment deadline approaches | Mining conduct back under scrutiny | Tribunal pressure grows This month the focus is on supply chains. From 30 October, the question employers face after an incident won't just be "what does your policy say?" It will be "what did you actually do, and can you prove it?" That's a different conversation, and most organisations aren't ready to have it - not because they don't care, but because their assurance still stops at the point where a supplier ticks a box. None of this means avoiding hard conversations or going easy on the suppliers who fall short. It means building something that helps them get better, not just something that catches them out. Read more about it later in our EA Product Feature.
The Board Question: Could we evidence the effectiveness of our people and conduct controls across our supply chain tomorrow?
AROUND THE WORLDWhat leaders should know this monthUK - your supply chain is about to become your people risk. From 30 October, employers face liability for harassment of their staff by third parties - customers, contractors, agency workers, anyone working alongside your people on your contract - where they've failed to take all reasonable steps to prevent it. EA view: A code of conduct sitting unread on a procurement portal isn't evidence of anything. The organisations in the strongest position by October will be the ones who already know whether their suppliers' policies actually work on the ground - not just whether they exist. US - retaliation is its own separate failure, and regulators are treating it that way. The EEOC has sued a car dealership alleging it retaliated against employees, including firing one, after they reported racial harassment. EA view: People watch what happens to colleagues who speak up, and they learn from it fast. Examine the original behaviour and the response to the person who reported it as two separate failures - because that's how a workforce experiences them. India - a grievance mechanism failure, exposed the hard way. Police in Nashik have registered multiple FIRs and made several arrests, including a senior manager, after allegations of sustained harassment at a major BPO campus. Investigators say a complaint was made and never triggered the mandatory reporting protocol that should have followed. EA view: This is the "reception" gap in its starkest form - a process existed on paper, but the person who received the disclosure didn't act on it. No supply-chain assurance model is worth anything if it can't test that link specifically. UK - the tribunal clock is resetting, and the backlog is growing with it. From 1 October, the time limit for bringing most Employment Tribunal claims doubles from three months to six. The Times reports around 64,000 cases now waiting, up from roughly 32,000 in 2020. EA view: Prevention and early resolution have never mattered more. Unresolved workplace conflict doesn't just create legal exposure - it consumes management time and damages trust for months, whether or not it ever reaches a tribunal. Australia - the mining sector's conduct problems are back in the headlines. Fortescue has suspended a senior executive while an external investigation, led by MinterEllison, examines allegations of sexual harassment and bullying. EA view: Seniority can't determine how seriously an allegation is taken. The real test of a culture isn't whether it has a conduct policy - it's whether governance keeps working when the person named is powerful.
CASES & CONSEQUENCESWhat the tribunals are telling usWilliams-St Louis v West Berkshire District Council - In a decision dated 5 August 2026, the Employment Tribunal found the claimant had been subjected to harassment related to race, with several allegations upheld. EA view: Culture is experienced through behaviour, not organisational intent. Managers need to recognise inappropriate conduct early and know how to intervene before it becomes normalised. Jeffery v Givaudan UK Ltd - The Employment Appeal Tribunal has reinforced a claimant's entitlement to written reasons for a tribunal decision, even where the parties later settle through a COT3 agreement. EA view: Process matters. Transparency and procedural integrity aren't administrative extras - they're part of what makes a process trustworthy in the first place. Sex discrimination remains firmly on the tribunal agenda. Recent decisions published by HMCTS include cases involving Birmingham City Council, Lidl Great Britain, Boots Management Services and others across sex-discrimination jurisdictions. Not every published claim succeeds - publication is never a finding of wrongdoing - but the volume keeps reinforcing something we tell clients often: EA view: the cheapest workplace case is usually the one you prevent.
COMING UPUK - three dates for leaders
1 October 2026 Most Employment Tribunal claim time limits increase from three months to six months. 30 October 2026 The sexual-harassment preventative duty strengthens from "reasonable steps" to "all reasonable steps". 30 October 2026 New third-party harassment provisions take effect. This is no longer a 2027 planning issue - it is a now issue.
EA PRODUCT FEATUREIntroducing the EA Supply Chain ModelSo... you've done supplier due diligence. Financial standing, checked. Health and safety, checked. Modern slavery statement, checked. Equal opportunities policy, usually checked too. But here's the uncomfortable question: does anyone actually know whether those policies work? Does a supervisor know what to do when someone discloses harassment? Can a worker raise a concern without going through the person they're complaining about? Has anyone been trained - or just handed a document? This is the gap the model has been built to close. It doesn't ask whether something exists. It asks whether it works.
WHAT WE ASSESS Harassment prevention & responseSpeaking up & disclosure handlingConduct & behavioural standardsLeadership & supervisor capabilityLabour supply & modern slavery controlsFair work & equality practice WHAT IT REVEALS Whether policy has actually reached the people it's meant to protectThe gap between existence, operation and receptionWhere supervisor capability is - or isn't - keeping pace with policy WHAT YOU RECEIVE Proportionate, evidence-based assuranceAccess to the EA Hub - templates, toolbox talks, manager toolkits, e-learningA share of fees ringfenced into a Supply Chain Development Fund, spent on building supplier capability, not on the principal contractor
Two things are worth saying plainly, because they change how this sits with a board. The first is cost. The model is funded through proportionate, banded fees paid by participating suppliers - smaller businesses pay less, larger and more complex ones undergo greater assurance - which means it's typically delivered to the principal contractor at no direct cost at all. The second is where that money goes. None of it comes back to the principal contractor as a rebate or a service. It's ringfenced into the Supply Chain Development Fund, which pays for the leadership development, policy clinics and practical toolkits that many smaller suppliers simply don't have the in-house HR or people function to build themselves. So this isn't a cost line looking for budget, and it isn't an audit looking for someone to catch out. It's assurance that pays for its own improvement - the fee a supplier contributes goes toward helping the supply chain get better, not toward the principal contractor's own accounts. Telling a small supplier their policy isn't good enough rarely helps them. Helping them build something better does.
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THREE QUESTIONS FOR LEADERSWhat should your leadership team discuss?
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