WRAP changing approach to encourage transparency on working hours
Ever since it came to prominence as a routine practice in the apparel supply chain about two decades ago, the social compliance certification model has remained more or less unchanged, with most approaches building on the core ILO conventions as the topics covered, and focusing on local laws to determine the specific requirements to establish compliance. That this model has had significant impact is inarguable, particularly in some areas. Factories all over the world are now far more aware of the importance of responsible practices and safeguards for workers in manufacturing plants. Great progress has been made on issues like child labor, and even while recognizing that plenty of work remains to be done, it is unquestionably the case that, overall, factories today are generally safer places for workers. Much of these successes can be attributed to the social compliance audit model that has existed for the past two decades.
However, while this model did make great initial progress, it has simply not moved things past a certain point because it has failed to recognize inherent ground realities. Since certification depends in part on factories meeting some numeric requirements (mostly, those embodied in local laws), there is a resulting misalignment of incentives that has made social auditing a real cat‐and‐mouse game, with factories striving to “pass” audits by showing auditors the kinds of numbers they think the schemes/brands/programs want to see, fearing that telling the truth would actually harm their chances of certification. Experience has shown that this serious problem remains a chronic one, particularly when it comes to the issue of working hours. Currently, all social compliance programs place a maximum (usually, whatever limit is prescribed by local law) on the number of hours workers can work in a given week. This has proven to be an exceptionally difficult component to audit, with many factories doctoring their working hour records to reflect whatever figure they are being assessed against. The resulting set of multiple books is a standing joke in the industry and has the further deleterious effect of casting doubt on any assessment of whether workers are being paid properly, since wage calculations are almost always going to be based on the number of hours worked.
The challenge has always been to avoid the mistake of treating symptoms rather than the disease, by getting factories to focus on improving working conditions, rather than simply passing audits. But progress isn’t possible without first acknowledging the problem and establishing its true extent and that, in turn, isn’t possible when the audit model is not set up to reward honesty.
In light of all this, WRAP is reevaluating its approach to social compliance certification, placing transparency at its core. As part of a revision to its 12 Production Principles, WRAP will, beginning on January 1, 2016, change its certification criteria to allow factories that meet certain conditions to qualify, even if they are not yet in full compliance with limits on working hours set in local laws. Those conditions are:
- Being fully transparent about their working hours;
- Ensuring those hours are all being worked voluntarily, in conditions that protect worker safety and health;
- Compensating all employees fully in accordance with WRAP’s Principle on Compensation and Benefits; and
- Showing progress, from one audit to the next, toward meeting the working hour requirements in local law.
That final element will involve putting into place a Working Hours Action Plan, wherein factory management will establish reduction targets to be achieved over the course of their certification cycle. The goal is to facilitate actual progress by identifying root causes of excessive working hours and addressing them, instead of merely masking the problem through double books. WRAP envisions this being a very factory‐specific process, and intends to work with each of them on a case‐by‐case basis.
WRAP looks forward to joining hands with all the factories in its Certification Program, its monitoring partners, the brands and retailers that utilize WRAP, and all other stakeholders to usher in this new era in social compliance certification, based on transparency and driven by a desire to foster real and lasting improvements.