For the past year, Fair Wear Foundation (FWF) has been involved in the Social and Labour Convergence Project (SLCP) as a non-signatory advisor. Seeing the importance of reducing duplicative audits, we want to contribute to the process to getting there, but without losing the focus on the shared responsibility of both buyer and supplier in improving conditions for workers.

While audits alone will not improve working conditions, they are an important assessment tool to know where improvement is needed. Given the large number of audits, related costs, and increasing audit fatigue, a valuable first step would be an agreement on a joint assessment framework. Reducing audit costs could help direct more resources towards remediation and training to improve human rights compliance. However, the most important issue to address is what happens after the assessment—hence clarifying the context/framework in which an audit or assessment should take place. Improving working conditions must be the number one goal.

The creation of a joint converged assessment framework should act as a first step; at the same time other areas need to be addressed for long-term improvements in working conditions. In this regard, FWF contributes its expertise and experience to the SLCP by reviewing prototypes and with dialogues on strategic aspects. Topics in our conversations and feedback include verification and worker representation and options to include brands’ purchasing practices into assessments of labour conditions and compliance.

It is crucial to avoid a pass-or-fail situation with this assessment tool, and to not place the focus and burden of compliance solely on the production locations. This would incentivise production facilities to hide critical issues in fear of losing business and not receiving support for improvements and remediation. What is needed is business relations with trust and respect for each others role, with a proper dialogue on what is needed to improve working conditions. For certain findings, factory-level solutions are not possible without a change in the system and conditions set by their customers.

Responsible purchasing practices are increasingly recognised as being key to sustainable business, as highlighted by both the UNGPs and the OECD guidelines (in particular the new due diligence guidance for responsible supply chains in the garment and footwear sector). It would be reasonable—and necessary—for the SLCP to somehow link the assessment results to the business behaviour of the brands. We have seen that, in many production facilities, factory management is more open regarding critical issues like excessive overtime when they know that the purchasing practices of sourcing brands will also be assessed and that their customers are committed to change. This leads to a much more realistic picture of the overall situation.

We appreciate the consultative process from the Social and Labour Convergence Project and the opportunity for us and other advisors to give input based on our real-life experiences. We encourage that the scope of the converged assessment framework and SLCP will go beyond simply reducing audits and would recognise the need for active contribution to change brand behaviour in their purchasing practices, addressing core issues affecting the workers.

FWF is looking forward to seeing how the feedback will be incorporated and how the next version of the converged assessment framework will turn out.

 

Note from the SLCP secretariat, 2 April 2018: We thank FWF for their engagement in the SLCP and their suggestions provided through the public consultation process (http://slconvergence.org/consultation/). We are considering feedback received through the public consultation in the current update of the converged assessment framework (proto3). Some topics in the feedback, such as ‘purchasing practices’ are out of scope for the current SLCP mandate (till end of 2018). Therefore, this feedback will be taken into account in the development of the SLCP 5 year strategic plan (2019-2024), which we are developing in the months of April-September 2018.