customer wants to know if we monitor working conditions with our subcontractors

Subcontractor monitoring is supply chain policy, not a standalone answer

This question is not about your own workplace, but about what you do with the next link in the chain: the subcontractors you engage. This means it does not fall under the health and safety policy you conduct for your own staff, but under the broader question how do I answer questions about working conditions further in my supply chain. If you receive this question, you often also receive the question about whether there is a supplier code of conduct — these are two sides of the same coin: the code is the policy on paper, this question is about monitoring in practice.

If you do not have a fixed monitoring mechanism — no checklist at tendering, no periodic audit, no contractual clause that obliges your subcontractor to have a safety policy — then the honest answer is "no" or "no, informally". This is not a problem in itself; many SMEs work with trust and short lines of communication rather than formal audits. What is not possible is to fill in "yes" because you assume your subcontractor will do the right thing. If you do have a code of conduct that subcontractors must sign, then that is the evidence: record when that code was introduced and whether compliance is checked anywhere, even if only on a spot-check basis. If that check is missing, state that too — a code without monitoring is a different answer than a code with monitoring, and clients who ask this question often follow up on precisely that difference.

Basis in the VSME module on the supply chain

The EFRAG VSME standard addresses supply chain issues in the module on human rights and working conditions in the supply chain, asking whether and how an undertaking monitors conditions at suppliers and subcontractors. This aligns with the broader scope that Directive (EU) 2022/2464 (CSRD) pursues: reporting that does not stop at your own door, but includes the chain where relevant. For the underlying basic question on human rights policy in the supply chain, see does the undertaking have a policy on human rights in its supply chain.