Joint Initiative on Corporate Accountability and Workers Rights
Turkey Pilot Project ~ Questions & Answers
I. Overview of the Joint Initiative on Corporate Accountability and Workers’ Rights
Q: What is the Joint Initiative on Corporate Accountability?
A: Codes of conduct for labour practices have become a significant part of doing business over the last 10 years. There are now a number of different approaches to their implementation and verification. Brands and retailers are faced with different models of “best practice” for implementing their codes in global supply chains. Suppliers are confused by the numerous codes, each with different standards and methods to assess their compliance. There is clearly a need to develop common approaches and to reduce the duplication and confusion.
The Joint Initiative (Jo-In) is the first collaborative effort between six leading organizations in this field. These are:
Clean Clothes Campaign www.cleanclothes.org;
Ethical Trade Initiative www.ethicaltrading.org;
Fair Wear Foundation www.fairwear.nl;
Fair Labor Association www.fairlabor.org;
Social Accountability International www.sa-intl.org; and
Workers Rights Consortium www.workersrights.org
- These organizations have agreed to explore opportunities for collaboration and common approaches that will improve their overall effectiveness in facilitating improvements in working conditions in global supply chains; and to develop a better understanding of how codes and their implementation systems contribute to improvements in working conditions.
The aims of the initiative are:
- To maximize the effectiveness and impact of the organizations involved in the initiative by ensuring resources directed as efficiently as possible at improving lives of workers and families.
- To explore possibilities for closer cooperation between the organizations involved and common approaches so as to reduce duplication and reinforce each others’ efforts.
- To share learning on the manner in which voluntary codes of labour practice contribute to better workplace conditions in global supply chains.
Q: What is the expected outcome of the initiative?
A: We are seeking the following concrete outcomes:
- Improved working conditions and respect for worker rights in participating production facilities in Turkey.
- Common interpretation of workplace standards provisions in the codes of the participating organizations and common approaches to some aspects of code implementation. Publication of guidance notes on workplace standards and different aspects of code implementation.
- A report on learning generated from the pilot project in Turkey, including process, content, outcomes and good practice in code implementation. The aim of this report will be to enhance understanding of how codes and their implementation systems contribute to improvements in working conditions
- A report on the similarities and differences in the approaches of the organizations including:
- suggestions of how companies and other stakeholders might take advantage of these compatibilities and complementarities; and
- proposals for future collaboration between the participating organizations.
Q: What is the governance structure of the initiative?
A: The steering group is made up of representatives from the six organizations participating in this project. The steering group meets three times a year to make decisions on policy and guide the overall direction of the project. In making its decisions, the steering group consults with trade unions and labor and human rights groups both internationally and in Turkey, with participating brands and factories, and with governmental and intergovernmental agencies.
II. The pilot project in Turkey
The pilot project is the first collaborative effort between the organizations to make concrete advances toward cooperation and shared learning.
Q: Why Turkey?
A: Turkey was chosen as the site for the pilot because of:
- its strategic position as an exporter of textiles and apparel in global markets and likely stability of this position in a post-MFA world;
- its proximity to the European market;
- incentives for change that exist by virtue of the negotiations on accession to the EU;
- positive trends toward the full implementation of international labour standards in labor law;
Q: What is the pilot project about and how will it be carried out?
A: A number of brands have agreed to sign up to the initiative and to work with the initiative in a pilot project in Turkey. These brands will be implementing a draft Jo-In Code of Labour Practice with some of their production facilities in Turkey. The initiative is interested in learning about how they work with these factories to ensure compliance with the draft Jo-In Code. It is also interested in learning about the different ways in which participating organizations involved support and / or assess their implementation of the code.
The project in Turkey will involve the following steps:
- Brands sourcing in Turkey join the initiative
- Supplier sites are identified and asked to participate
- Brands introduce draft Jo-In Code to their suppliers
- Baseline study at suppliers by Jo-In
- Brands implement the draft Jo-In Code with their suppliers (activities may include social audits, monitoring, corrective action plans, training etc.)
- Implementation of Jo-In code may be verified by organizations involved
- Follow-up study by Jo-In at the supplier to assess change
- Discussion of findings and project report with local Stakeholders
- Final project report
- International conference
Q: What will the pilot project focus on?
A: The Steering Committee held extensive consultations with stakeholders and has decided to focus on the following code elements:
The project will seek to gain specific insight on the implementation of three workplace standards provisions in the draft Code of Labour Practice:
- Freedom of Association and collective bargaining
- Wages
- Hours of Work
The trials will focus on three aspects of code implementation:
- assessment of compliance with code provisions and verification of code implementation through different social auditing methods (including worker interviews);
- the use and effectiveness of, complaints mechanisms; and
- remediation and corrective action arising from a social audit or complaint.
III. Factory roles and responsibilities
Q: How were factories selected to participate in the project?
A: Brands were asked to provide the Steering Group with a list of their production facilities in Turkey under the terms of a confidentiality agreement. The Steering Group also consulted with local stakeholders in Turkey. A subcommittee of the Steering Group made the selection against a number of agreed criteria. Among this was an understanding that these were factories with which brands and their suppliers or agents have ongoing relationships with.
Q: What is expected of factories? Is it a different program from what they are already implementing?
A: Suppliers are required to continue to abide by the contracts they have with brands participating in this project, and in that context to implement and work toward complying with the draft Jo-In code. Certain of aspects of code implementation may receive more attention and particular activities may be more intense during the trials.
While we understand that the production facilities may not meet the workplace standards in the draft Jo-In code at the beginning of the project, we do expect suppliers to make real efforts during the course of the project to comply with these code provisions.
Communication with suppliers will be handled through the brands, the International Project Manager and local coordinator in Turkey. The project will provide a memorandum of understanding to suppliers who participate in the project to further clarify their roles and responsibilities.
Q: How can factories have a voice in the project?
A: Suppliers were one of the groups that were consulted about the Turkey pilot in November 2004, along with workers, unions, and NGOs. As with other stakeholders in Turkey, we will continue to consult with suppliers during the course of the project to ensure their maximum commitment and to generate learning.
Q: What is expected of factories?
A: Participating suppliers are asked to work with the brand and Jo-In on the priorities that have been identified above, specifically: in pilot audits assessing levels of compliance with the draft Jo-In code (as noted above, factories are not expected to be in full compliance); in ongoing monitoring efforts by the brands; in implementation of corrective action plans, remediation of non-compliance and development of the systems needed to make the improvements; where appropriate in follow-up audits to reassess levels of compliance; and in the resolution of complaints according to existing complaints mechanisms.
Factory management and workers will also be asked to participate in some of the orientation and evaluation meetings related to the project and in research to establish the baseline and a follow-up assessment at the end of the project. Information from this “baseline enterprise survey” will be kept confidential and not shared with the brands or organizations involved. It will only be used for the purposes of learning from the pilot.
Jo-In members estimate the total time required of factory managers to prepare and attend to pilot audits, attend orientation and evaluation meetings, read reports and recommendations, participate in the research (baseline and follow-up assessment) will be between 3 and 5 days, not including the time they dedicate to improve workplace conditions on their own.
We are seeking commitment from factories to remediate and to work toward compliance with the workplace standards set out in the draft Jo-In code, together with the brands and Jo-In.
Q: What are the benefits for factories?
A: Participation in the pilot will serve as a learning process for participating factories. Apart from the ability to meet price, quality and delivery times, compliance with codes of conduct is increasingly becoming part of doing business with brands. By participating in the pilot, factories will be able to explore the different ways in which they can improve their compliance with these codes, while at the same time increasing their competitiveness and profile in global markets. They will no doubt benefit in the medium to longer term as a result of reduced accident rates, quality rejection rates and employee turnover; and improved worker-manager relations, business stability, and buyer relations.
By participating in the pilot, factories will be part of an attempt to reduce the unnecessary and time consuming duplication of social audits by different buyers and confusion around what standards to apply in the workplace. Brands view such factory participation in the pilot in a positive light as a good faith effort on the part of factories to develop their capacity to comply with codes of conduct. This will no doubt have a positive influence on sourcing decisions.
Q: What kinds of risks do I take by becoming involved in the pilot?
A: The only risk involved is if the factory attempts to misrepresent working conditions in the factory and/or does not make a good faith effort to improve conditions. As mentioned above, brands will also make a good faith effort to support factory efforts to improve code compliance and continue sourcing from participating factories. And as a result of constructive participation, factories will not only be building their relationships with the brands currently sourcing from them, and possibly also exposed to potential clients.
Q: How will my employees and trade union representatives (if there is one) be involved?
A: Social audits will involve interviews with workers and their representatives, in some cases both on and off site. Workers may also be involved in actual remediation efforts and/or complaints. A sample of workers will be involved in initial research to establish a baseline.
Q: Why has a new draft Code of Labour Practice been devised for this project? Doesn’t it duplicate other codes?
A: We needed a consolidated Code for the purposes of the project so that there is a common starting point for testing approaches to implementation. Rather than writing a new Code entirely from scratch, the steering group agreed to take the highest standard for each code element across the six participating initiatives. The key differences between the codes of the six initiatives concern provisions on freedom of association, hours of work, and wages. As a result, these will form the focus of trials.
The aim is not to develop yet another code. Through the trails, we hope to facilitate common interpretation and application between the participating organizations of certain code provisions. In time, this may lead to convergence on a common Code and opportunities to combine compliance resources among the organizations and among brands.
Q: How will the draft Code be implemented in factories?
A: For the purposes of this project, the draft Jo-In Code will be implemented by the brands in the production facilities which agree to participate in the project.
There may be instances where the workplace standards set out in the draft Jo-In Code are higher than those in their code that currently appliers. Brands and factories are asked to commit during the course of the project, to work toward improving upon their levels of compliance with provisions in the draft Jo-In Code and to demonstrate the steps they have taken to work toward this.
Q: What are the public reporting procedures for this project?
A: While we encourage full public reporting, we understand that concerns have been raised and have developed a model that allows brands to participate in the project at differing levels of disclosure, and possibly to move from one level to another level in the course of the project.
- Full reporting: Brand, factory name, location and issue reported together.
- Partial reporting: Brands and a nominal codes for factory on which issues are reported (i.e. factory 11; factory 12; factory 13). The factory name will remain confidential.
- Incremental reporting: Brands and factories may choose to move from partial to full public reporting during the course of the project.
The initiative will also be reporting on what is learnt on a periodic basis and release a comprehensive project report at the end of the trial. These reports will be public. Participating companies and other stakeholders in the project will have the opportunity to see the project reports and should they wish to do so, include a comment from their own ‘perspective’ within the project reports.
Q: What does confidentiality mean in the context of the pilot?
A: This project does not seek to “name and shame” any of its participants; rather it seeks to develop good practice with regard to public reporting and to ensure that the lessons from this project are broadly disseminated and shared.
As required by all initiatives involved in this project, the identity of workers who issue complaints or other communications will be kept confidential, unless the worker communicates that she/he wants this information to be made public.
Q: How will complaints be dealt with that occur in the factory during the course of the pilot?
A: Any complaints arising in the factory in the context of the code should be dealt with by the complaints mechanisms which factories and brands already have in place.
In the event that a serious issue arises during the course of the trial (such as the dismissal of workers), the Local Coordinator and International Project Manager will be asked to assess whether or not it should be dealt with according to an agreed Jo-In dispute resolution process. This ensures that the project can take immediate and effective action to protect workers if necessary. Parties to the dispute will be asked to show that they have made every attempt to use the available complaints systems and to justify why the issue is considered sufficiently serious for the project to intervene.
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