- 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
Independent Monitoring (Auditing)
As discussed under Step 5, Monitor Compliance, independent monitoring should consist of unannounced site visits to worksites in the company’s supply chain to evaluate compliance with the code of conduct. Announced visits may also be useful when it is necessary to have access to specific personnel or documentation present. In cases where the company’s internal or paid third-party auditors conduct audits on a sampling basis in high-risk supply chain areas, the sites visited by independent monitors can be the same as those already audited, or a different sample of worksites in those areas, or both.
Independent monitors should be impartial, accredited individuals or organizations with expertise on labor standards, appropriate language skills, and detailed knowledge of local workplace conditions and prevailing industry practices.
Independent monitors should provide the company with a report outlining their findings, and may make recommendations for remediation measures a company should take to address any violations found. Your company should make this report public, or include it in your broader public reporting.
In situations where accountability to institutional structures such as the Fair Labor Association does not exist, independent monitoring can provide another option for credible monitoring results. And if you are not able to secure independent monitoring as described here, you can still maintain open channels of communication with stakeholders who have access to worksites and may detect labor abuses. Labor unions are viewed by some as “independent monitors”—if a union is present at the worksite, it should be aware of safe ways to bring issues to your attention. Similarly, individual workers and community groups may be aware of issues that are not detected by auditors. Making available to the public a list of the suppliers from whom your company sources can provide such groups the opportunity to bring issues to your attention.
The Fair Labor Association’s (FLA) Accreditation Program for Independent External Monitors
The FLA Board of Directors accredits both monitoring organizations and individual lead auditors for its Independent External Monitoring program for a period of two years, which is then renewable for successive two-year periods. Prospective monitors may apply for accreditation for one or more countries, and for all or some provisions of the FLA Code of Conduct. Monitors are accredited based upon their fulfillment of criteria outlined in the FLA Charter and for specific regions in which they document and display (through shadow auditing conducted by the FLA prior to accreditation) experience and expertise. Lead auditors are individuals with sufficient experience to direct and manage a monitoring team and submit the required reporting. All monitors must demonstrate independence, impartiality, and a high degree of rigor and thoroughness in assessing compliance for all areas outlined in the FLA’s Workplace Code of Conduct.
For more information, see the FLA website.
The Bonsucro Accreditation Model
In order to become recognized and approved by Bonsucro to audit and certify against the organization’s standards, a monitoring organization, or what Bonsucro calls a Certification Body (CB), must first meet several criteria. First, a CB must be accredited by the International Organization for Standardization (ISO)/International Electrotechnical Commission (IEC) Guide 65/EN 45011 (1998), General requirements for bodies operating product certification systems. Second, a CB must operate at least one accredited program that meets the sustainability criteria of Bonsucro’s own Production Standard and Chain of Custody Standard. Additionally, Bonsucro recommends accreditation against ISO 14065 (2007) IDT, Greenhouse gases—Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition, and experience in carrying out audits according to ISO 14064-3, Greenhouse gases -- Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions. When a CB is approved by Bonsucro and signs a contractual agreement, Bonsucro will issue official approval and list the CB on the Bonsucro Website as an official Bonsucro-approved CB.
For more information, see the Bonsucro website.
Social Accountability International Model
To ensure the independence of audits conducted against its Social Accountability 8000 (SA8000) Standard, Social Accountability International (SAI) founded Social Accountability Accreditation Services (SAAS) in 1997. SAAS later became a separate not-for-profit organization in 2007. SAAS is an agency that accredits and monitors organizations as certifiers of compliance with social standards, including SA8000, for ethical working conditions.
For more information, visit the SAAS website.
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