We in the social compliance world draw from a lengthy lexicon of specialized terms every day as we go about our business, and if you have been connected with WRAP for any length of time, you have no doubt come across these terms as well. Some of these are pretty self-explanatory, like “corrective action”, “objective evidence”, “risk management”, and “non-compliance.” Others, however, command a little more consideration in order to fully grasp their meaning, especially if you’re new to the world of social compliance. For me, that term was “management system.” I am quite confident that I am not the only person who dismissed this term as obscure office lingo upon first hearing it, but as my tenure with WRAP has grown, I have come to learn two things. First, the term is not as scary as it may seem (in fact, management systems can be found just about everywhere in life if you know what to look for), and second, management systems are without a doubt the essential elements that make social compliance programs like WRAP so successful and effective. So, in the words of Julie Andrews in The Sound of Music, let’s start at the very beginning where any blog examining a specific term would begin, by defining it (that is a very good place to start if I don’t say so myself). I think that ISO, the International Organization for Standardization, provides a very good definition for our purposes. According to them, “a management system defines the set of procedures an organization needs to follow in order to meet its objectives.” Let’s dissect that a little bit further. From the aforementioned definition, we can extrapolate that an effective management system needs two things: a set of procedures and a desired objective. We can break it down even further and define a “procedure” as “a series of actions that are done in a certain way.” With that in mind, we can now say that a management system is an established series of actions that can achieve a given objective. What does all of this have to do with social compliance in production facilities, and more importantly, with WRAP? For the answer, we are going to enter the world of horse racing. Last year, I was watching the Kentucky Derby with a group of my friends (for those of you who don’t know, the Kentucky Derby is one-third of the U.S. Triple Crown and, by many accounts, the largest and most prestigious horse race in the country). As we were watching the pre-race coverage at Churchill Downs, the Kentucky track where the race is held each year, I overheard one of my friends say that all of the jockeys must be from Lilliput because they were all so tiny. After turning my head and saying “did I just hear that?” to myself, I took another look and noticed indeed that most of the jockeys were a lot smaller than the rest of the spectators, breeders, and others milling about the track. Being the curious person that I am, I looked a little deeper into it when I got home that night and learned that not only were my eyes not tricking me, but that their smaller than average stature was not by accident. In fact, many prominent horse races have weight limits for the jockeys who compete in them; that of the Kentucky Derby is a mere 126 pounds, which is reportedly more lenient than in other races. It makes perfect sense as well because the less weight a horse is carrying, the more energy it can expend on speed and endurance during a race. What does this mean for the jockeys? It means that their objective is to remain physically fit in order to maintain compliance with the body weight standards of their trade, otherwise, they don’t race (and yes, I used the words “compliance” and “standards” quite deliberately here). So how do jockeys remain in compliance with these standards? Most medical experts agree that maintaining a proper weight is best achieved systematically through a daily procedure of good habits. With this knowledge in mind, the first step for the jockey should be to ensure he knows exactly what weight requirement he needs to remain in compliance with. After that, the jockey should set out to establish and document his routine for achieving his goal of maintaining compliance. Maybe this includes eating a bowl of oatmeal every morning for breakfast, or running for one hour each evening, or committing to drinking 64 ounces of water each day. Whatever the steps in the process may be, the key for this to be successful is that the process be documented and executed in a consistent manner each and every day. Voila! we have just created a management system for horse jockeys! So now that we have our jockey management system, what do we do with it? Or more specifically, how can we independently verify that it is working? Do we hire secret agents to follow our jockeys around town during their off time? Do we commission SWAT teams to go inspect their cupboards while they’re not home? Do we monitor surveillance footage from every restaurant in town to see if our jockeys were there? We could definitely do any of these, but they would be expensive and onerous at best, and severely invasive at worst. When it comes right down to it, verifying the effectiveness of our weight management system is actually very easy and highly efficient, yet very effective. Put yourself in the shoes of a world-renowned thoroughbred trainer looking for a jockey to ride his horse to a Triple Crown victory. The first step here is to find out which candidates meet the weight requirements and which ones don’t by simply having them stand on a scale, meaning that accurately assessing which jockeys have an effective weight management system is as easy as reading numbers, while the system itself remains robust (because after all, it is nearly impossible to fake weight loss). Let’s take this one step further and say that three of the jockey’s colleagues do not meet the weight requirements, so they ask their healthy friend what his secret his. He shares his system with them, and in just six short weeks, everyone has met the requirements. Voila! Our jockey management system is documented, managed, verifiable, and repeatable with the same results. Now let’s return to WRAP and social compliance auditing. Let’s switch some roles here and say that the jockey is now a production facility and that WRAP is now the renowned trainer conducting the proverbial “weigh-in” via an audit. One of the cornerstones of WRAP is for us to assure ourselves through our monitoring partners that a facility has a documented management system consisting of policies, procedures, processes and work instructions that will support their compliance with WRAP program requirements. The next thing the monitor will do is assure themselves and WRAP, through objective evidence (evidence that is verifiable by a third party) that this system is working and supporting the facility every day of the week and every week of the year, thus making it a true working management system. The first items that a facility needs to have in place are a set of policies that support each of WRAP’s 12 Principles. These are simple statements of intent from Top Management such as “ABC textiles will not employ any worker under the age stated by country law 123 and all other related laws. In doing this we have formulated a set of procedures and processes to support this policy” or “Please see our related support procedures and processes for further information.” Then our auditors will look for documentation on these systems, such as hard copy or electronic system manuals, posted flow charts for procedures and work instructions, or pictorial or video training resources. These policies and manuals should also be easily understandable to both managers and workers. Auditors will also often use non-document based evidence to support their findings. For example, if a facility claims that it has a system to train all of its workers to operate fire extinguishers, then as part of the audit, the auditor may pick a worker at random from the production floor and ask them to demonstrate how to operate a fire extinguisher. That worker either knows how to do it or they don’t; it’s that simple. If they successfully demonstrate for the auditor, then the objective evidence is noted. If not, then it is noted that the management system is not effective. It is important to note that the auditor will also verify that the training procedure itself is properly documented and carried out by the facility’s trainers. The management system approach also helps WRAP to conduct better evaluations inside of the dynamic environments that production facilities are. For example, let’s say an auditor notices that a worker is wearing the wrong kind of protective glove while operating the fabric cutter. This in and of itself is not sufficient evidence that a management system is ineffective, but if the supervisor standing next to the worker doesn’t seem to notice the issue or if several cutters are wearing inappropriate gloves, than the case becomes stronger that the system is not working. Either way, the system is easy to evaluate, yet is only effective because it has become a regular habit. It is worthwhile to note that each facility is free to decide on its own how to implement its management systems based on their own unique characteristics. Some may choose to have their workers read written policy manuals before beginning work. Others may require that employees attend regular training sessions on site to educate them about policies, or have them watch a video of some form. The actual implementation of the system can take many forms, but like the system for our jockey, they must all be managed, documented, objectively verifiable, and able to be repeated over and over again with the same end results. Simply having management systems in place, however, is not enough. WRAP-certified facilities must also objectively demonstrate that they have adequate management systems for their management systems. In other words, are they able to manage their own management systems? The facility must demonstrate that they actively review their own social compliance management systems on a regular basis and make changes as needed to ensure that they remain effective. This includes, but is not limited to, updating employee training procedures to reflect changing laws, revising health and safety practices that may be ineffective or difficult to understand for workers, and even adding completely new ones to meet evolving compliance demands. Quality controls on management systems are a key part of maintaining social compliance, and therefore, a key part of a WRAP audit. Having management systems in place, however, is not the end of the process, but the beginning. WRAP-certified facilities must also demonstrate that they actively review their own social compliance management systems on a regular basis and make changes as needed to ensure that they remain effective. This includes, but is not limited to, updating employee training procedures to reflect changing laws, revising health and safety practices that may be ineffective or difficult to understand for workers, and even adding completely new ones to meet evolving compliance demands. Quality controls on management systems are a key part of maintaining social compliance, and therefore, a key part of a WRAP audit. That is why WRAP requires that all facilities carry out their own internal audits before becoming WRAP certified. Hopefully this blog has helped to make the management system a little less intimidating and given you a glimpse into how they work and why production facilities and we at WRAP rely on them. Management systems allow production facilities to quantify their compliance activities in a sustainable way while also allowing us at WRAP to maintain the values that we have based our work on for so many years. The management system gives us a metric by which to evaluate social compliance in various countries and cultures around the world while simultaneously allowing us to run an efficient organization that remains independent, objective, responsive, and trustworthy.