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Ensuring fashion supply chain grievance mechanisms are truly effective

The well-intentioned efforts of fashion brands and retailers to put in place grievance mechanisms in their supply chains are missing the mark. Companies should consider sector wide approaches, writes corporate responsibility consultant, Doug Cahn.

This article was first published on 4th May 2023 by JustStyle and was republished here with permission. You may find the PDF version here.

When John Ruggie, special representative to the UN secretary general for business and human rights, conceptualized the foundational principles for effective grievance mechanisms throughout the supply chain he understood the central role that fashion brands and retailers would play. He called on companies to ensure access to those mechanisms be a part of a company’s commitment to respect rights. When it came to operational-level grievance mechanisms in particular, he understood that a company’s obligations could be administered not only by each company acting alone, but by companies in collaboration with others. This is relevant for global brands today as regulators in Europe and elsewhere require transparent communications that document the impact of brands’ initiatives to protect workers in their supply chains, including their grievance channels.

Do grievance mechanisms for fashion supply chain workers work?

Leading fashion brands and retailers have invested significant time and money into developing and implementing global grievance mechanisms in their own supply chains. These efforts are well known and include reporting channels accessed through links to web forms, mobile apps, toll free numbers staffed by local compliance professionals or call centers. Information when provided by workers is managed in a variety of ways, each according to the customized protocols typically developed by the brand or retailer.

Evidence of these efforts can be easily found by glancing at a factory’s notice board where multiple customer hotlines can be found posted side-by-side, often creating a bewildering and confusing array of numbers to call or text in order to file complaints. Most are placed within sight of a watchful management who are suspicious of the role of third-party complaint channels and who passively or sometimes actively discourage their use. Workers rarely understand what to expect if they file a complaint and even more rarely trust management claims to refrain from retaliatory behavior.

To consider a better design of grievance mechanisms, we must first recognize two important truths:

  1. The unskilled and semi-skilled labourers that constitute the vast majority of the workforce in fashion supply chains are transient and their skill sets are fungible. They may work in one factory today and another factory next month or next year. This is the nature of a workforce that has recently entered the formal sector, is building skills, and is looking to better themselves and their families through higher skilled jobs and increased earnings. A worker who learns about a grievance channel in one factory may not be permitted access to it when they move to a different factory. This lack of continuity leads to a lack of awareness and trust.
  2. Factories and the subcontractors they use are rarely exclusive to one brand or retailer customer. As such, brand and retail-centric initiatives can appear to workers to be duplicative, confusing, or simply irrelevant.

Providing effective grievance mechanisms for garment workers in the long-term

Brands and retailers considering approaches to meet Germany’s new Corporate Due Diligence Obligations for the Prevention of Human Rights Violations in Supply Chains Act, for example, should keep in mind that investments in grievance mechanisms that are focused solely on a particular company’s supply chain may well meet their immediate reporting obligations.

However, effectiveness over time is not likely to be achieved unless grievance mechanisms are designed to reflect the transient nature of the workforce. In the complex web of commercial relationships between brands, retailers, suppliers, factories and subcontractors, workers do not fall neatly into brand-by-brand silos. Collective actions are needed and they are possible.

The Amader Kotha Helpline in Bangladesh serves as an example, supporting a significant portion of that country’s Ready-Made Garment (RMG) sector since 2014. As a partnership between Clear Voice, a project of The Cahn Group, ELEVATE an LRQA Company, and Phulki, a non-profit organization based in Dhaka, the Helpline has been able to provide in-factory training to over a million workers and currently provides a grievance reporting channel to over 400 factories. In so doing, the Helpline has become a one-stop shopping solution for workers who need to report and resolve a concern.

The benefits of this critical mass approach are many including:

  • Reduction of confusion on the part of factory management and workers that comes with elimination of multiple brand and retailer grievance channels
  • Widespread awareness of and access to the Helpline: workers will know or have heard about a friend or family members who have used the grievance channel
  • Facilitating the ability of brand and retailers to collaborate on remediation when that is needed, consistent with anti-trust requirements.

Brands and retailers need not worry that collective or consolidated grievance mechanisms will make it difficult for them to exercise their responsibilities or deny them what they need to meet regulatory requirements. On the contrary, collective efforts will increase effectiveness and efficiency at the same time. Through agreed-upon escalation protocols, brands and retailers can learn of small problems before they become more serious or larger problems that require their timely attention.

Sector-wide initiatives take time to establish since they involve multiple parties aligned to a single set of operational protocols. Still, collaborative approaches that recognize and reflect the needs of a sector-wide labor force, and not the immediate fashion supply chain specific workforce, will be worth the effort.

Rana Plaza Anniversary

[This post is written by ELEVATE on April 30 2021. To view the blog on ELEVATE’s site, please visit https://www.elevatelimited.com/blog/rana-plaza-anniversary/

Eight years ago, on 24 April 2013, the Rana Plaza Building in Dhaka, Bangladesh collapsed. The building contained multiple clothing factories manufacturing items for major fashion outlets. The disaster was one of the worst industrial accidents on record. 1,132 workers lost their lives with more than 2,500 injured. The Ready-Made Garment (RMG) industry was awakened to the issue of factory structural integrity. The fires in 2012 at Tazreen Fashion (Bangladesh) and Ali Enterprises (Pakistan) had made clear to the industry the need to redouble efforts in fire and electrical safety. This combination of events served as a chilling reminder to retailers, brands, and consumers that many of today’s workers around the world face dangerous working conditions and that the risks if not identified and remediated can lead to grave consequences.

In Bangladesh, this was not a case of one unsafe building. This was a systemic issue reflecting a variety of interconnected problems. Across Bangladesh, as the garment industry grew, factories grew, new floors were added to multi-story buildings to support additional equipment and people. The additional equipment also increased power requirements, placing a greater load on electrical grids which were not necessarily sized appropriately. The grid issues increased the risk of fire, and the fire preparedness, prevention, and suppression systems did not keep pace with these increasing risks. Lastly, workers did not have a means of reporting safety and security issues as they were encountered.

Eight years later and so much has changed…and for the better. The Bangladesh RMG sector has taken has put significant effort and investment to significantly improve their safety standards. The Government of Bangladesh has taken the initiative to support worker well-being and safety by updating the BNBC and published new versions of the Code in 2020 to incorporate additional standards and regulations. Thousands of factories have been inspected, safety issues identified, and remediation started and for many, completed. Building, fire, and electrical safety trainings have been rolled out across factories to identify and reduce facility hazards, ensure the facility and workers are well prepared to deal with emergencies, and embed common requirements for safety from international clients. A helpline has been established for workers and new safety management evaluation system is emerging.

Worker safety includes making factories safe for workers not only from a building and fire safety perspective but from a holistic perspective – including the ability of workers to safely raise their voice. Worker voice can play a critical role in ensuring factory safety and can serve as an “early warning” system to flag safety issues before they escalate into major disasters like Rana Plaza. Since July 2014, the Amader Kotha Helpline has been providing garment workers in Bangladesh with a trusted, accessible mechanism to report and resolve safety and other concerns.

The Helpline receives hundreds of calls per month from the 1.5 million+ workers it reaches, across thousands of RMG factories, including worker reports of active fires in the factory, blocked or locked factory exits, structural building issues, and other urgent building and fire safety issues, as well as issues that affect workers and their well-being, including reporting harassment and abuse in the workplace, and other labor issues such as wage and compensation.

“In one case, the Helpline received a call from a worker who noticed that sparks were coming from an electrical circuit on the 3rd floor of the factory. When workers attempted to ring the fire alarm, it failed to work. Later that morning, sparks continued to be noticed from the circuit and after being notified, management allowed workers to leave the building until the cause of the sparks could be resolved and the malfunctioning fire alarm could be fixed. Several days later, the Helpline made follow-up calls to workers in the building confirmed that the problems had been resolved.” (Amader Koth Helpline)

Though the RMG sector in Bangladesh has taken positive steps to improve the safety standards of building structures and ensure factory workers are not at risk of physical danger, there is still much work to be done. Completing all outstanding corrective action plans, ongoing monitoring of safety management systems, continued training, better government enforcement and collaboration with different international organizations are all key to preserving the improvements and creating a new legacy in honor of the workers who lost their lives.

NGO Leadership in Grievance Mechanisms and Access to Remedy in Global Supply Chains, Ethical Trading Initiative, 2017

In a study commissioned by the London-based Ethical Trading Initiative, “NGO Leadership in Grievance Mechanisms and Access to Remedy in Global Supply Chains”, authors Jesse Hudson J.D. and Mark Winters examine the Amader Kotha Helpline as an example for designing, implementing, and monitoring operational-level grievance mechanisms and facilitating access to remedy in global supply chains. Read More