This has been reflected in the approach to social auditing; traditionally a process in which facilities have had little agency. The buyer would demand the audit, dictate which audit firm is used, and own the resulting data. This dynamic has driven supply chain opaqueness as, often, the results of such audits do not reflect the reality on the work floor and are not geared towards remediation of non-compliances.
To create meaningful improvements to working conditions, we need a system that redresses the power imbalance and enables equal partnership between supply chain actors. SLCP envisages a move beyond traditional audits to future-focused tools founded in collaboration and partnership. To support this, SLCP grounded the Converged Assessment Framework (CAF) in a model of facility ownership that puts manufacturers in the driver’s seat. In general, the SLCP assessment process starts with a facility self-assessment so that the facility can review and understand their own social and labor data. This is followed by a mandatory on-site verification from an external qualified party. We call this a verification rather than an audit because it is designed to be a more collaborative and supportive process than the traditional audit approach and does not, for example, result in a pass/ fail outcome or provide a score of any kind. The verification is a stringent process governed by a robust Verification Oversight and Quality Assurance strategy.(1)
Some critics fear that this approach increases the risk of integrity issues with social and labor data. SLCP data itself demonstrates the necessity of external verification: In 2023, 88 percent of facility self-assessment data was marked as accurate by the Verifiers; however, when it comes to issues of legal non-compliance, self-assessment accuracy dropped to 33 percent (2). SLCP acknowledges the limitations of self-assessments, particularly on data points of fundamental labor aspects such as forced labor. In such cases, direct validation by an external party is more appropriate and will yield more accurate data.
SLCP’s experience to-date however has proven that self-assessments can be a beneficial process, particularly for learning and development. Indeed, SLCP signatory manufacturers have consistently reported that understanding their own data has allowed them to be proactive in making sustained improvements that meet their unique context and needs(3). In research conducted on behalf of SLCP in early 2023, facilities reported that they were more willing to remediate issues following an SLCP assessment as they had identified issues themselves. 2023 SLCP data also showed that facilities completing assessments for the second time had less non-compliances than new facilities, indicating the potential of the assessment process to educate facilities and prevent non-compliances.
While promoting facility ownership of the process, SLCP also expects accountability from all parties involved. The concept of transparency and full disclosure by the facility (referred to as “honest data”) is emphasized in all aspects of the assessment process, from the CAF terms of use the facility signs and the training they receive, to the robust verification process. In line with our ambition of equal partnership, accountability also extends to the brands that use SLCP data. There is also an expectation on brands to implement minimum standards in terms of purchasing practices, and to commit to taking a non-punitive approach to non-compliance. These principles are set out in the SLCP Signatory Charter. The SLCP model positions credible and actionable social and labor data as an enabler for all stakeholders to uphold their responsibilities and to hold others to account.
To ensure that the facility ownership model supports, and is compatible with, the delivery of credible and actionable data, SLCP implements a policy of continuous learning and improvement. With the support of our signatories, partners and stakeholders, we have developed a multiyear CAF Roadmap. This includes critical enhancements that we will be working on in the coming years, such as:
Continued priority on data quality and integrity by capacity building of Verifiers and a smart mix of quality assurance (including innovative and data-driven approaches)
Leverage and promote self-assessment as a learning & development tool.
Provide more flexibility on the collection and validation of data points, depending on where it drives credibility e.g. include option of a verified only assessment, without the self-assessment (under conditions/specific data points)
Expanding options to include worker voice and worker engagement in the assessment process.
Drive transparency on social & labor data (‘honest data’) and enable collective action (vs a punitive approach).
By creating a system in which facilities participate in the collection of their social and labor data, own the resulting externally verified data set, and control how it is shared, SLCP aims to help create a new paradigm of equal partnership between facilities and their buyers. In this new dynamic, facilities are better informed and prepared to engage in dialogue with their buyers about necessary remediation and tackling root causes together. While acknowledging the limitations of self-assessments, SLCP believes that when coupled with stringent and independent verification, the overall impact is to improve the credibility and actionability of social and labor data.
Janet Mensink holds more than 25 years’ experience in sustainable supply chains, including sustainability consultancy and leadership roles in international development in the nonprofit sector. She has served on several boards and councils of multistakeholder initiatives. As CEO of the Social & Labor Convergence Program (SLCP), she is responsible for overseeing SLCP’s strategic direction and execution.
