...The challenge of the draft guidance is that it assumes that individual companies can and will make visible their sub-tier suppliers. This is a faulty premise because of the tension between visibility and responsibility. Companies alone are not prepared to identify the full scope of production in sub-tier suppliers because they fear that they will be held responsible for every problem they discover in this high-risk part of the chain. If you think you’ll be responsible for fixing whatever you find, you don’t try to find very much...