Seeing double? Why it’s short sighted to focus on quality assurance as the only solution to double books


The role of purchasing practices in ensuring the reliability of supply chain social and labor data


If one single verified data set is to be shared with all buyers – who all have different expectations and react differently to non-compliance – how can we be sure the facility will share their honest data?  This concern is often raised by stakeholders as a barrier to adoption of SLCP’s Converged Assessment Framework (CAF).

According to research into the reliability of sustainability audits, 41.1% of the over 15,000 apparel industry audits between 2011-2017 were considered unreliable.[1] Given these findings, there is a risk of factories keeping more than one record of accounting (typically for hours and wages, also known as “double bookkeeping”) or providing false data to auditors. As such, the need for robust audit oversight and quality assurance mechanisms is clear. However, we must also focus on purchasing practices to address the reasons facilities might hide their data in the first place. Brands who commit to remediation and driving continual improvements, rather than disengaging at the first instance of non-compliance on topics such as working hours, can incentivize facilities to disclose honest data[2].

Honest data is one of the foundational principles of SLCP. All signatories sign up to the Signatory Charter, committing to “respect the principle of true data in SLCP verified assessments by recording and accepting honest data, and by prioritizing remediation over punishment.” The Charter emphasizes the mutual responsibility of both suppliers and buyers: facilities must be transparent in their data disclosure, and brands & retailers must create the conditions that encourage facility honesty, by demonstrating that they will take a remediation-based approach rather than cutting ties when non-compliances are identified. Users of SLCP’s Converged Assessment Framework (CAF) commit to providing honest data when they sign the SLCP Gateway Terms of Use, and the importance of honest data disclosure is explained in SLCP’s e-learning and facility training program. 

For SLCP, verification oversight and quality assurance are also top priorities. By giving up their proprietary audits and adopting SLCP, brands & retailers are relinquishing a degree of control, and it is therefore important that they trust the SLCP verified data. SLCP has developed a robust Verification Oversight & Quality Assurance Strategy and is continually working to improve and enhance data quality. This includes a rigorous feedback and complaints procedure that users can follow if they suspect data honesty issues that have not been identified through the SLCP verification. With the launch of the CAF v1.5 in November 2022, SLCP is also introducing a Worker Engagement Technology Survey to inform and complement the verified data.

But while strong oversight and QA mechanisms can help mitigate the risk of dishonest data, it is only by tackling the root cause of false data disclosure that the industry can achieve systemic change. Today many brands want to understand the real picture of working conditions as it is only by understanding true data that they can take steps to diagnose and improve. However, while there are still brands that want to avert their eyes to the true realities of their supply chain, and others that cut and run at the slightest sign of problems, there will continue to be a reason for facilities to consider falsifying records. Brands and retailers must collectively embrace a new era of responsible purchasing practices, aligned with the Common Framework for Responsible Purchasing Practices (CFRPP). Developed by several multistakeholder initiatives, including Fair Wear Foundation, the CFRPP provides an aligned reference document for the garment industry on what responsible purchasing practices look like. By adopting the guidelines, brands can commit to partner with their suppliers, incentivizing those who continuously improve and avoiding punitive action.

“Responsible purchasing practices can go a long way in reducing negative impacts on workers in supply chains. They have the potential to support and enable improved working conditions, the implementation of living wages and better planning and business sustainability among suppliers. We want to see more brands and suppliers collaborate on driving change as part of their human rights due diligence. Responsible purchasing practices play a crucial role in this process”

Margreet Vrieling, Associate Director at Fair Wear Foundation.

To improve working conditions in global supply chains, we need credible data that reflects reality. Double books and false records distort the truth and are therefore a serious threat to efforts to improve workers’ lives in important areas such as wages and working hours. While effective oversight and quality assurance can go some way to mitigate the risks of dishonest data, eradicating this practice requires a more seismic shift, which relates to power dynamics in the supply chain. By adopting more responsible purchasing practices, brands and retailers can drive trust-based and equal partnerships with facilities. This will create a reality in which honest data is in everyone’s best interest.


[1] Sarosh Kuruvilla, 2021, Private Regulation of Labor Standards in Global Supply Chains, Cornell University Press

[2] Sarosh Kuruvilla, 2021, Private Regulation of Labor Standards in Global Supply Chains, Cornell University Press (Chapter 4)

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