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1. “b) in Verification requirements Part A”

Due to the change from the ”Corporate level” to the “Product category level”, which requires evidence of all applicable facilities, and the increase of the conventions and provisions in Annex B, we have concerns that the burden of submitting and verifying all relevant internal regulations and manuals at all relevant facilities will become heavy (including English translations from local languages for CAB audits).

 

The phrase “language to meet or exceed the labor and occupational health and safety (OHS) provisions listed in Annex B.” can be interpretated as language requiring compliance to each provision of the Conventions or Recommendations listed in Annex B, not the Conventions or Recommendations themselves. In this case, it will be required to submit all relevant sections of all relevant internal documents as evidence, which increases the burden of verification and is impractical.

 

2. “c) and d) in Verification requirements Part A”

c) and d) in Part A Verification requirements should be consistent with the requirements and languages in “Annex C Enterprise-specific risk, where applicable.”

 

”issues” should be changed to “assertions or allegations.”

 

The “social audit” in d) should be interpreted as social audits that were conducted to manufacturers prior to the allegation, and the requirement of d) should be interpreted as imposed only if social audits had been conducted prior to the allegation.

 

Regarding “Where issues have been raised,” it should be interpreted that the requirement to prove c) and d) is imposed only if there is a clear allegation to the best of the manufacturer's knowledge.

 

1. Evidence from a representative facility or head office should be acceptable.

 

For RBA members, explaining how the members adopt and comply with the RBA Code of Conduct internally should be acceptable for evidence to Part A, and “b) of verification requirement” should be changed as follows:

 

b) Description of the mechanism how manufactures comply with the conventions, recommendations and domestic law listed in Annex B or the RBA Code of Conduct in the manufacturer’s operations. [DELETE: Evidence (e.g., procedures, HR manual) of how the provisions listed in Annex B are included in the manufacturer’s operations and that there is language to meet or exceed the labor and occupational health and safety (OHS) provisions listed in Annex B.]

 

 

2. “c) and d) in Verification requirements of Part A” should be deleted.

Or the “requirements of c) and d)” should be changed as follows:

 

c) Where [Delete: issues have been raised] [ADD: any assertions/allegations with well-documented evidences pertaining to manufacturer facilities’ failure to meet compliance of the provisions in Annex B from internationally well-known industry-independent civil society organizations are actually delivered to the manufacturer’s facilities within one year before the date of the product’s application,] document the process to identify relevant assessments [DELETE: carried out by industry-independent civil society organizations and other experts] [ADD: related to the assertions/allegations.]

 

d) Where [DELETE: issues have been raised] [ADD: any assertions/allegations  with well-documented evidences pertaining to manufacturer facilities’ failure to meet compliance of the provisions in Annex B from internationally well-known industry-independent civil society organizations are actually delivered to the manufacturer’s facilities within one year before the date of the product’s application,] document the process for evaluating and addressing relevant inconsistencies between [DELETE: social audit findings and findings produced by industry-independent civil society organizations and other experts] [ADD: the prior social audit findings and the assertions/allegations].

 

The condition for the verification requirement should be added as follows:

 

[ADD: If no assertion/allegation with well-documented evidences pertaining to manufacturer facilities’ failure from internationally well-known industry-independent civil society organizations is actually delivered to the manufacturer facilities within one year before the date of the product’s application, c) and d) are not applicable. If manufacturers had no social audit before the allegation, d) is not applicable.]