- Step 1: Engage Stakeholders and Partners
- Step 2: Assess risks and impacts
- Step 3: Develop code of conduct
- Step 4: Communicate and Train across your supply chain
- Step 5: Monitor compliance
- Step 6: Remediate violations
- Step 7: Independent review
- Step 8: Report performance
Engaging Your Stakeholders
Some typical roles that stakeholders can play are highlighted below:
- Company employees
- Be involved in code of conduct development.
- Suggest ways that your team’s risk assessment and auditing data and analysis could assist in making decisions on sourcing, product development, strategy and other issues.
- Provide expertise on strategic communication of the social compliance system.
- Act as extra “eyes and ears” on social compliance issues to supplement worksite monitoring programs.
- Contribute material for public reports (such as statements about why employees value social responsibility in their company).
- Contribute ideas for strategic charitable initiatives that can address root causes of labor abuse while achieving other company objectives.
- Be trained to ensure that the work they do in other units of the company does not conflict with social compliance.
- Workers in production facilities and worker representative organizations
- Engage in collective bargaining with management on issues in workplaces.
- Be involved in code of conduct development and help to educate all workers on their rights under the code.
- Help identify risks of child labor and forced labor and other code violations at their worksites.
- Participate fully in worker training and provide feedback so it can be improved.
- Communicate with worksite management or through designated grievance channels to report labor rights violations.
- Monitor workplaces and bring issues to management attention.
- Be involved in remediation planning where appropriate.
- Suggest opportunities for the company to address root causes of labor violations.
- Suppliers throughout your supply chain
- Be involved in code of conduct development.
- Help ensure that their employees are educated on the code and work continuously to ensure that code standards are upheld in the workplace.
- Provide information for your company’s risk assessment, as appropriate.
- Participate fully in all needed training activities and communicate on an ongoing basis, including with affected communities, about issues that arise in workplaces.
- Cooperate fully with auditors and independent verifiers.
- Take an active role in remediation and help to develop appropriate Corrective Action Plans.
- Contribute as needed to the company’s public reporting.
- Suggest opportunities for the company to address root causes of labor violations, whether in supplier workplaces or broader communities.
- Communities and community-based organizations throughout your supply chain
- Provide valuable input into your code of conduct, bringing experience, contacts and local credibility.
- Provide valuable input into your risk assessment, for example, advice on gender, culture and other dynamics in the community.
- Provide training and/or raise awareness among workers and communities about child labor, forced labor and other labor issues.
- Provide information to auditors and independent verifiers as appropriate.
- Help carry out audits and/or independent verification (if qualified), and/or engage in community-based monitoring systems.
- Play a role in remediation by providing the direct services needed for children or adult victims of labor abuse and/or advising companies on remediation approaches.
- Provide comment on public reporting to enhance accuracy and credibility.
- Suggest opportunities to address root causes of labor violations, and/or partner with your company on initiatives to tackle them.
- National or international civil society organizations
- Provide valuable input into your code of conduct, bringing experience, contacts and credibility.
- Supply information, via research, reports or personnel in-country, to inform your risk assessment.
- Provide training on child labor, forced labor and other labor issues.
- Carry out audits and/or independent verification, as appropriate.
- Offer expertise on remediation approaches, such as the rights of children, situations of abuse and other issues.
- Contribute to or provide comment on public reporting to enhance accuracy and credibility.
- Suggest opportunities to address root causes of labor violations, and/or partner on initiatives to tackle them.
- Shareholders and shareholder groups
- Advocate with other shareholders to support the code of conduct and the social compliance program in general.
- Communicate with companies on specific risks and labor rights violations in their supply chains (vocal groups of shareholders can also increase the risk of reputational damage if they believe your social compliance system is not effective and that they are not being heard).
- Encourage the company to dedicate resources to public reporting.
- Engage with the company to help identify root causes of labor abuse that may be linked to its operations.
- Other companies in your industry
- Share example codes of conduct or develop a joint code through an industry group and/or by working with other stakeholders.
- Share risk assessment information about particular sourcing locations or suppliers.
- Join together to train or communicate with shared suppliers and other stakeholders in those locations.
- Arrange joint audits and/or independent verification processes.
- Share lessons learned on remediation approaches and/or develop collaborative remediation strategies for shared suppliers.
- Explore ways to collaborate to address root causes of labor abuses.
Engagement with Workers and Worker Representative Organizations: The Mexican Context
The Maquila Solidarity Network’s 2010 publication, Freedom of Association in Mexico Tool Kit, provides a useful example both of how civil society organizations can advise companies on stakeholder engagement, and of how companies can engage with workers and worker representative organizations in the specific context of Mexico.
For more information, see the Maquila Solidarity Network’s Freedom of Association in Mexico Tool Kit.
The Role of Government Entities in Social Compliance Systems
Governments are obligated to respect, protect and fulfill the human rights of individuals within their territory and/or jurisdiction. This includes the duty to protect against human rights/labor rights abuses by third parties, including business enterprises. It is incumbent upon governments to clearly set out the expectation that all business enterprises domiciled in their territory/jurisdiction respect human rights throughout their operations.
In meeting these obligations, governments should, among other things, enact and enforce laws requiring businesses to respect human rights and ensure that laws and policies governing the creation and ongoing operation of businesses do not constrain business respect for human rights.
Your company can take a proactive approach to engaging with government entities to enhance your social compliance system. Such engagements can include measures such as:
- Encouraging governments to gather and publish data on child labor, forced labor and other issues that are useful for risk assessment.
- Building communication channels to allow your company to report labor abuses to authorities that will result in effective remedy for victims.
- Linking your company’s auditing and/or independent verification functions with government law enforcement personnel, where applicable.
- Collaborating with governments to identify ways to address root causes of child and forced labor.
Engagement with Government: Brazil’s Dirty List and National Pact for the Eradication of Slave Labor
Since 2004, the Government of Brazil has published a Dirty List (Lista Suja) naming companies and property owners who have been found to employ workers under forced labor conditions. Listed companies are banned from acquiring credit from state-owned banks and may be refused credit from some private banks. The government updates the Dirty List every six months. Violators are kept on the list for two years and removed only if they have discontinued use of forced labor and paid all wages due to workers. All government labor inspection data is available to the public.
The Dirty List is complemented by the National Pact for the Eradication of Slave Labor, a multi-stakeholder initiative launched in 2005. Members of the initiative include the non-governmental organizations (NGOs) Ethos Institute, Instituto Observatorio Social, Repórter Brasil, the International Labour Organization (ILO) and over 200 Brazilian companies. Companies that sign the Pact commit to cutting commercial ties with businesses on the Dirty List; formalizing labor relationships with their own employees; providing training to employees and suppliers on forced labor; and supporting social reintegration programs for workers freed from forced labor, among other actions.
For more information, visit the Pacto Nacional website.
Once you have identified your stakeholders and understand the potential roles they can play in your social compliance system, you can begin to target certain groups for engagement. For some companies, identifying key stakeholder groups and getting them involved in specific areas of the social compliance system is the most helpful way to make targeted improvements. This is particularly true for companies that already have some elements of a social compliance system in place, but understand that there are specific areas that should be improved.
For other companies, the best “first step” in engaging with stakeholders may be linking with existing initiatives, such as multi-stakeholder groups, industry associations or initiatives or certification programs if they are available and a good fit given the company’s needs and objectives.
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