how do I answer questions about accommodation for migrant workers

Migrant worker housing falls under working conditions

Questions about migrant worker housing usually do not appear as a standalone question, but as part of a broader section on working conditions and human rights in the supply chain. Clients ask this because housing in the Netherlands often runs through temporary employment agencies or subcontractors, and that is precisely where supply chain responsibility is at stake. The answer that is requested usually does not concern the quality of the housing itself, but the question of whether there is a policy that brings third-party housing under your own duty of care, and whether that policy also applies to subcontractors and temporary employment agencies working for you.

If you do not have your own housing policy but work with certified temporary employment agencies (for example with SNF registration for housing), that certificate is often the supporting document that answers the question — not as a quality mark on your part, but as a demonstrable condition you impose on your supplier. If you do not have that, then do not fill in "yes" for a question about your own policy; in that case, preferably answer the question of whether there is policy for health and safety at work, if that does exist and housing falls under it. If that is also absent, then "no, not yet" is the honest answer — possibly with an explanation that it is arranged with the temporary employment agency.

Where this comes from: EFRAG VSME module on own employees

The EFRAG VSME standard asks in the basic module about employment terms and conditions of own staff, and clients further down the chain often translate that to migrant workers who work through temporary employment agencies for their suppliers. This aligns with the broader supply chain obligation from Directive (EU) 2022/2464 (CSRD), which requires reporting companies to also identify risks with their suppliers. If housing is not in your own file, then this is a good time to also look at the question whether the staff is covered by a collective labour agreement, because those two questions are often asked in the same section and sometimes share the same supporting document.