How to: Write a Policy Aligned with the Accountability Framework

This guide is designed for companies that produce or source agricultural or forestry commodities. It helps them develop supply chain policies that meet a range of expectations and obligations. This includes frameworks and standards that reference the Accountability Framework, such as the Science Based Targets initiative (SBTi) Forest, Land, and Agriculture (FLAG) Guidance, requirements or requests from buyers and financial institutions, expectations from civil society and other stakeholders, and regulations.

Financial institutions may also use this guide when assessing the policies of their clients or investees as part of environmental and human rights due diligence. Financial institutions should also maintain their own policies covering these topics. Additional guidance for financial institutions is available in the Annex to the Operational Guidance on Commitments and Progress Pathways.

Policies are formal written documents that specify the company’s commitments, as well as guide its implementation and progress towards them. The Accountability Framework uses the following terminology to describe these inter-related elements: 

Commitment (what) 

Definition: Public statements expressing a company’s intention to achieve specific environmental and social outcomes. 

Purpose and key features: Defines what the company aims to achieve. Including: 

• Goals: high-level statements of ambition, describing intended future outcomes, such as no-deforestation, no-conversion, and respect for human rights
• Targets: specific, measurable, and time-bound performance levels that a company intends to achieve 

Policy (how to say it) 

Definition: A formal, written, public document that defines and communicates company commitments. 

Purpose and key features: 

• Primary way to express commitments, including their scope and application
• May also indicate (at a high level) how the company intends to implement commitments
• Intended to provide a relatively stable, long-term statement of company commitments 

Progress pathway (how to achieve it) 

Definition: The sequence of actions, milestones, and improvements through which commitments are achieved over time. 

Purpose and key features: 

• Describes how policies will be implemented in order to fulfil commitments
• May include phased implementation approaches, milestones, and timelines
• Typically articulated through supporting documents outside the policy itself, such as implementation plans, roadmaps, transition plans, and workplans
• Regularly reviewed and updated to reflect progress, lessons learned, changing circumstances, and evolving priorities   

Responsible supply chain policies are now a standard expectation for companies that produce or source agricultural and forestry commodities. They serve multiple purposes, including three core functions: 

1. They help companies identify and manage material risks. Deforestation, conversion, and human rights harms can lead to supply chain disruptions, commodity shortages, legal exposure, reputational damage, and increased financing and insurance costs. A clear policy helps companies anticipate and mitigate these risks proactively, strengthening overall supply chain resilience.
2. They serve as practical management tools to align and mainstream decisions and practices. Policies provide a common reference point that helps to align sustainability commitments, regulatory obligations, and business priorities across the company. They support consistent decision-making, clarify expectations and responsibilities, and help identify where systems or processes need to be strengthened. Policies also provide a basis for setting expectations for suppliers, and for guiding supplier engagement.
3. They strengthen credibility and trust with external stakeholders. Policies act as public statements through which companies communicate their sustainability goals and commitments. They are a reference for customers, investors, lenders, civil society, and assessment and reporting initiatives. These stakeholders can use a company policy to understand how it manages environmental and social risks and opportunities in its supply chains. Policies are also increasingly expected by voluntary initiatives, such as SBTi FLAG, and they underpin disclosure frameworks such as CDP, the EU Corporate Sustainability Reporting Directive (CSRD)

Companies that produce or source multiple commodities may choose to develop ‘umbrella’ policies that covers the full scope of their raw material production and sourcing. This can help improve consistency across commodities, streamline implementation and reporting, and provide greater clarity for suppliers, buyers, investors, and other stakeholders.

Companies may choose to complement an umbrella policy with additional documents that provide more detail on specific commodities or topics. For example, a company may maintain an overarching responsible sourcing or forests policy alongside commodity-specific policies (such as a Palm Oil Sourcing Policy), topic-specific policies (such as a Labour Rights Policy), in addition to supplier codes of conduct, sourcing standards, or implementation procedures.

Regardless of structure, policies and related documents should be aligned and mutually reinforcing. 

Many companies are subject to sustainable supply chain regulations that require them to address risks of deforestation or human rights abuses in their supply chains. Examples include the EU Deforestation Regulation (EUDR) and the EU Corporate Sustainability Due Diligence Directive (CSDDD). 

While these regulations establish mandatory requirements, they do not generally provide a comprehensive framework for responsible supply chains. This is needed for companies to align internally and communicate requirements to suppliers. For instance, EUDR covers only certain commodities and a defined set of deforestation-related risks. A responsible supply chain policy can help companies establish a broader, company-wide approach to environmental and human rights risks across operations and sourcing activities. This provides an umbrella for helping to fulfil regulatory obligations, while also supporting wider expectations related to climate, biodiversity, human rights, and due diligence. It can also help companies prepare for current and emerging requirements beyond the EUDR.

In addition, regulations typically establish what companies are required to achieve, but do not provide detailed direction on how. To comply in practice, companies need governance, management systems, supplier engagement processes, grievance mechanisms, and other internal processes. A responsible supply chain policy provides a roadmap for developing and strengthening these systems so that compliance becomes more feasible and credible. Policies can also help companies align internal teams, communicate expectations to suppliers, and demonstrate leadership to customers, investors, and other stakeholders. 

Companies that set targets through the Science Based Targets initiative’s (SBTi) Forest, Land and Agriculture (FLAG) Guidance are required to maintain public no-deforestation commitments for primary deforestation-linked commodities and document how they intend to implement them. The SBTi recommends that both the company commitment and its implementation be aligned with the Accountability Framework. This guide can therefore help companies develop no-deforestation commitments and related policies that support SBTi FLAG requirements.

Box 1 in the resource on Writing the Policy provides guidance on the elements that should be included in a no-deforestation commitment. Additional information on the relationship between Accountability Framework guidance and SBTi FLAG requirements is provided in the AFi Explainer: Setting and Implementing No-Deforestation Commitments under SBTi FLAG.

Companies can draw on a range of examples and references when writing their responsible supply chain policies. Reviewing these resources can help companies understand how others have translated general expectations and good practice into policies that work for their sectors, supply chains, and business contexts.

Specifically, reviewing the policies of peer companies can help illustrate different approaches to policy structure, scope, and articulation of commitments. The AFi provides examples of companies that have used the Framework to set or strengthen their policies. Companies may also look to assessment platforms such as Global Canopy’s Forest 500 assessment to identify companies with leading policies related to no-deforestation, no-conversion, and respect for human rights.

In addition to peer examples, companies can draw on industry guidelines and frameworks that provide common approaches or model elements for policies. The AFi provides examples of industry and multi-stakeholder initiatives that have aligned with the Framework.

Annex 1 of the Operational Guidance on Commitments and Progress Pathways also provides examples of commitments, targets, and implementation elements that can help inform overall policy design and language.  

If your company would benefit from external technical expertise, the AFi recommends seeking support from a qualified service provider. Organisations participating in the AFi Delivery Partner Programme are trained to support application of the Accountability Framework.

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