Press Release: Ten Co-signatories Recommend the Responsible Business Alliance (RBA)

In response to a series of incidents and media reports exposing labor abuses within global supply chains, a coalition of ten civil society organizations calls upon the Responsible Business Alliance (RBA) to instigate meaningful reform in an open letter. Incidents include the death of workers, significant protests, media reports detailing forced Uyghur labor, migrant workers in debt bondage, and students working 12 hour days, the signatories of the letter emphasize the urgent need for action by the RBA and its members to address systemic labor issues.

 

This letter outlines a structured analysis of recurring violations observed within industries that include RBA members. Despite formal standards and an accreditation process, ongoing investigations and interviews with workers confirm the use of excessive overtime, low wages, a culture of intimidation and bullying, sexual harassment, illegal use of student and dispatch workers or temporary workers, and unethical, irresponsible and unlawful migrant worker recruitment processes that leave workers in debt bondage and forced labor conditions amongst other violations. 

 

As a result of these identified issues, the signatories recommend the following actions:

 

  1. Increase transparency in RBA’s internal operations.This includes publicly disclosing the results of its supply chain assessment process, audit results, and corresponding methodologies. 

  2. Introduce consequences for member companies that violate the RBA code. This way, accountability is placed on RBA members as buyers, providing a clear foundation for where the consequences or punitive measures can be directed to.

  3. Prioritize responding to and addressing civil society’s concerns over labor and other practices directly and publicly, with actionable next steps. RBA should set out a public and transparent timeline or process for managing external complaints.

  4. Mandate the creation of independently operated grievance mechanisms. Includes fair, publicly available, accessible, predictable and transparent hotlines for all workers, trade unions and other work worker representatives. 

  5. Add to the RBA’s Board of Directors two or more representatives of worker advocates and/or civil society organizations that have proven experience with surfacing and addressing worker grievances and a longstanding commitment to improving human rights in supply chains.

  6. Move beyond inputs and introduce outcome-based reporting for member companies. Include indicators if the human rights policies and actions introduced into supply chains result in any impact to labor conditions.

 

The recommendations above seek to strengthen the voice of workers who are asking only for what the RBA has already committed to: ensuring that working conditions in supply chains are safe, that business is conducted responsibly and ethically, and that all workers are treated with dignity.

 

 

See the open letter below:

 

 

 

 

Ten Co-signatories Recommend the Responsible Business Alliance (RBA) to Enhance Transparency, Effective Communication and Accountability  

Executive Summary 

In response to a series of distressing incidents and media reports exposing labor abuses within global supply  chains, a coalition of concerned organizations and individuals has today called upon the Responsible Business Alliance (RBA) to instigate meaningful reform. Incidents include the tragic death of  workers, significant protests, media reports detailing forced Uyghur labor, migrant workers in debt bondage  and students working 12 hour days all underscore the urgent need for action by the RBA and its members  to address systemic labor issues. 

This letter outlines a structured analysis of recurring violations observed within industries that include RBA  members. These violations range from excessive overtime and low wages to unethical recruitment practices  and forced labor. Concluding the letter is a series of recommendations aimed at reshaping corporate  accountability within the global supply chain and amongst RBA and its members’ companies. These  recommendations advocate for increased transparency, more consequences for non-compliant member  companies and the establishment of independent grievance mechanisms. Moreover, calls are made for  enhanced representation of worker advocates within the RBA’s governance structure and the  implementation of outcome-based reporting to assess the real impact of corporate initiatives. There is a  need for reform to stop persistent violations within the industry. 

Introduction 

In 2013, a 15-year-old Chinese boy, Shi Zhaokun, passed away in his dorm room in Pegatron Shanghai, a  giant factory manufacturing the iPhone 5C. In his first and only month at Pegatron, he worked nearly 280  hours, often 12 hours a day, and for six days a week. The boy’s death, which is not the first of its kind,  caused a stir over China’s factory conditions. But when the chatter died down, it was business as usual. The  world quickly moved on to embrace the much-anticipated annual new iPhones releases. 

Close to a decade later, in 2022, a massive protest erupted in iPhone manufacturer Foxconn Zhengzhou, a  rare public display of dissent in China’s repressive social climate. “Foxconn never treats humans as  humans,” a worker reportedly said. The protest was triggered by weeks of pent up frustration, the COVID 19 pandemic and delayed pay. This occurred despite Foxconn’s promises of annual social responsibility  audits among its subsidiaries. Past cases have demonstrated that the thousands of workers protesting at  Foxconn Zhengzhou in 2022 will, like Shi Zhaokun, likely be forgotten until such labor abuses reoccur. 

Some would say “corporate social responsibility”, a form of business self-regulation working towards  advancing societal goals through philanthropy, volunteerism, pro-bono services or grants is a positive  paradigm shift. The emergence of the Responsible Business Alliance (RBA) in 2004 was part of this  progress. Founded at a time when ethical production standards were only a discussion, the RBA industry  group announced its efforts towards ensuring responsible business conduct in global supply chains. 

Despite RBA’s efforts over the years, investigations into RBA-member companies suggest a tale of unmet  promises. Media outlets have consistently reported on excessive overtime, low wages, a culture of  intimidation and bullying, sexual harassment, illegal use of student and dispatch workers or temporary  workers, and unethical, irresponsible and unlawful migrant worker recruitment processes that leave workers  in debt bondage and forced labour conditions in RBA-member companies. Ongoing investigations and  interviews with workers in RBA member companies confirm these ongoing challenges.

 

The signatories to this letter join a chorus of voices raising questions about the efficacy of the RBA in  addressing systemic issues in sourcing in the global supply chain, with a focus on labor exploitation. As we  delve into the details of this complex landscape, we provide recommendations for RBA to consider to  reimagine the path to ensure corporate accountability in a rapidly evolving world. We urge the RBA to make substantive changes to ensure its member companies adhere to the RBA Code of Conduct. 

The Responsible Business Alliance (RBA) 

The RBA was founded in 2004 under the name “Electronic Industry Citizen Coalition” (EICC). It was  initiated by a small group of electronics brands and large suppliers seeking to create an industry-wide  standard on social, environmental and ethical issues in electronics industry supply chains. RBA sets  industry corporate social responsibility standards for its members and suppliers to these members, and  functions to connect its members and streamline the corporate compliance process. 

RBA established an industry Code of Conduct (“the Code”) that consists of standards for labor, health and  safety, the environment, and business ethics. In the area of labor, the Code establishes standards against  forced labor, underaged workers, excessive overtime, discrimination, illegally low wages and benefits, and  supports freedom of association, a healthy, safe, and hygienic work environment free of unsafe  environmental hazards. 

While the RBA sets standards, it does not conduct supplier assessments. Rather, it relies on third-party  firms to conduct on-site assessments under the Validated Assessment Program (VAP). The RBA also offers  specialized VAP in the area of forced labor, which is an assessment specifically designed to help identify  the risk of forced labor at employment sites. To become an official RBA “Regular” or “Full” member,  companies must go through the VAP assessment to receive accreditation

Realities On The Ground 

As such, despite formal standards and an accreditation process, suppliers of RBA member companies, or  member companies themselves, demonstrate a sustained pattern of labor abuses ranging from (a) illegal  practices in the use of student and dispatch workers; (b) forced or compulsory overtime and long working  hours; (c) poor workplace health and safety measures; and (c) forced labor and related debt bondage risks  resulting from unethical and irresponsible recruitment of migrant workers. The aforementioned violations  contravene RBA’s Code of Conduct, specifically, Sections A1, A3, and A4, as described below:  

a. Section A1: Forced Labor. Global investigations and reports have demonstrated how RBA  member companies have been complicit in China’s state-sanctioned re-education and labor transfer  programs against the Uyghur ethnic minority in recent years. A 2020 report by the Australian  Strategic Policy Institute (ASPI), a think-tank founded by Australia’s government, states that 82  transnational brands including Apple and Sony were implicated. Lenovo (an RBA member) laptops  produced by Uyghur forced labor have reportedly entered U.S. classrooms. Later that year, the  Washington Post and the Wall Street Journal reported that Lens Technology, an Apple supplier in  China that produces glass iPhone screens, relies on forced labor from thousands of Uyghurs who  were transferred to their place of work under a government labor transfer program. Later in 2021,  the Information also uncovered that seven Apple suppliers participated in Uyghur forced labor  programs. Alleged prison labor is involved in the production of Foxconn’s work uniforms. 

b. Section A1: Unethical Recruitment. Although the RBA’s standard prohibits the payment of  recruitment fees and related costs by all workers, such unethical and often unlawful practices of charging workers for a job have been systemic in RBA member suppliers. This particularly targets  migrant workers from South and SouthEast Asia recruited from impoverished, conflict ridden  countries like Myanmar and also Bangladesh, Cambodia, India, Indonesia and Nepal. In 2020  Electronics Watch and MWRN released a report, also covered by Reuters, revealing that migrant  workers from Myanmar working at Cal-Comp Thailand (Kinpo Group) were subjected to excessive  and unlawful recruitment fees which were equivalent to 30-90 days of their wages. At Cal-Comp,  migrant workers were coerced into lying to social auditors in order to cover up the unethical fees.  In the same year, Electronics Watch also published a report on irresponsible recruitment into the  Possehl plant in Malaysia. In 2023, the Diplomat published a story highlighting how RBA members  Flex, Wistron, Pegatron, General Motors, Ford, Toyota and Nokia were all sourcing from  companies that withheld the passports of Vietnamese workers in Taiwan and demanded $6,000 of  illegal recruitment fees on top of never-ending monthly fees. Later in the same year, the Diplomat  published another article linking Continental, Bosch, Dupont and Walmart to illegal recruitment  and high recruitment related costs reaching up to three to four years of the migrant workers’ wages  back home in Vietnam also. Unlike organizations like Impactt, The Consumer Goods Forum, and  Aim-Progress, the RBA has not published a public methodology or approach to reimbursement of  these recruitment related fees or costs, and it remains unclear what standard RBA members should  be held when remediating these fees. Often workers are not repaid for years after initial complaints  are made, with repayment frequently coming once workers have already suffered and paid off their  debts.  

c. Section A3: Working Hours. Other areas of abuse involving RBA member companies that global  investigations have uncovered include forced or compulsory overtime, long working hours, poor  workplace health and safety measures and more – one violation is often accompanied by others. A  2014 investigation by BBC found that workers were so overworked at Pegatron (an Apple supplier)  that they were falling asleep whilst working at production lines. In 2017, Reuters reported that  workers were made to sign an unfair agreement which said they agreed to “voluntary” overtime  work, and were forced to work up to 140 hours of overtime each month in Huizhou Biel Crystal  factory, another Apple supplier. 

d. Section A4: Wages and Benefits. The illegal employment of students and dispatch workers has  been an ongoing issue for RBA member companies. In China, manufacturers during peak seasons  often rely on the recruitment of temporary workers that are student interns, dispatch, agency or  contract workers. Students generally receive lower pay compared to full-time factory employees,  and teachers and their schools are often economically incentivized to push students to work more  hours. Dispatch workers, on the other hand, are temporary workers who are recruited through third party labor brokers or other companies. Student interns and dispatch workers are frequently  subjected to forced or mandatory overtime, sometimes to an excessive degree of over 100 hours  per month. This is a violation of China’s national labor laws. In addition, RBA’s Code explicitly  states the need for members to ensure legal compliance on the use of student and dispatch workers,  and local laws require student and dispatched workers to be kept under a certain ratio to formally  contracted workers. These requirements are consistently violated, for example: 

i. Through a survey of 362 Apple’s supplier factories, California-based industry journal the  Informant found that “nearly half were over the quota for temporary workers,” periodically  filling their factories with dispatch labor. 

ii. In 2017, a Financial Times investigation found that Foxconn’s Zhengzhou facility (an Apple  supplier) employed students who illegally worked overtime.

iii. In 2018, Students and Scholars Against Corporate Misbehaviour (Sacom), a Hong Kong-based  non-profit, reported students working 12-hour days on factory production lines at Quanta  Computer, a Taiwan-owned company whose factories in China supply Apple, Acer, and Sony  computers. In 2019, The Financial Times reported that the same issue persisted

e. Section D6: Protection of Identity and Non-Retaliation. To further exacerbate the above issues,  whistleblowing on labor violations in China can result in heavy personal consequences, and RBA  member companies provide little protection to whistleblowers that report on its members’ illegal  practices. In 2018, a China Labor Watch (CLW) investigation in association with the Guardian found that more than 40% of the staff in Foxconn’s Hengyang factory were dispatch workers.  Shortly after the investigation, the factory decreased the use of dispatch workers to under the  Chinese legal threshold. In 2019, CLW launched another investigation in the same facility  following a whistleblower, Tang Mingfang’s lede. CLW found that Foxconn reverted to its former  illegal practices of over-relying on dispatch workers, confirming Tang’s statements. Unfortunately,  shortly after CLW’s 2019 report was published, Tang was located by Foxconn management and  was soon brought to the local police station where he was beaten and questioned. In 2020, Tang  was found guilty of infringement of commercial secrets on the grounds of the evidence provided  by Foxconn, and was sentenced to two years in prison. Following his release in 2022, he tried for  a retrial in China and was unsuccessful, all this while without an apology from Foxconn or Amazon,  and no action taken by the RBA. Currently, Tang lives with a criminal record and in a social limbo,  solely because he reported on practices that are illegal and should not have been normalized or  condoned by any company, most of all an RBA member. 

In 2020, nearly 2,000 employees at an iPhone manufacturer in India protested over the management’s  withholding of wages. In 2023, Apple was found to have illegally imposed rules on its employees that  prohibited them from discussing their wages and engaging in other protected activity (such as unionization  and discussing terms of employment). The same year, a joint investigation by the Guardian, the  International Consortium of Investigative Journalists (ICIJ), NBC News and Arab Reporters found that  workers in Amazon warehouses in Saudi Arabia faced extreme labor trafficking conditions, prompting  Amazon to pay $1.9 million (USD) to over 700 contracted workers. This demonstrates that RBA member  companies not only violate RBA’s own standards, but also the International Labor Organization’s (ILO)  core conventions and protocols – which are legally binding obligations for State party signatories – as well  as the UN Guiding Principles, which the RBA Code of Conduct refers to itself. 

Media reports and investigations by civil society organizations have repeatedly shown that poor labor  practices and forced labor have infiltrated the supply chain of large electronic brands. CLW’s undercover  investigations in Chinese electronics manufacturers (see Appendix) throughout the years also attest to that.  In 2016, CLW found that 62% of Pegatron Shanghai workers (producing Apple goods) clocked in over one  hundred hours of overtime per month, and that the factory employed a large number of student and  dispatched workers. It was not until 2020 that Apple put Pegatron on a temporary probation, meaning that  the supplier will not receive any new business from Apple until the issues were rectified. CLW’s follow up investigations of these factory facilities found some improvements, though the improvements later  proved to be temporary. CLW’s most recent investigations into the electronics industry in 2023–including  Apple’s suppliers Chengdu Foxconn and Kunshan Pegatron–found the same series of issues including  illegal use of temporary workers, forced overtime, and lack of worker representation. 

While it is not the core purpose of this letter, it is also integral to emphasize that the RBA’s Code of Conduct  (COC) is not a ‘be-all and end-all’ standard for companies to follow. The Code of Conduct in itself is  limited in terms of the right to freedom of association as well as wages and working hours. Despite the code  acknowledging the need for alternate forms to worker representation where laws and regulations restrict  the right to freedom of association – the limitation to “lawful” forms of worker representation as an alternative still poses a major obstacle to exercise this basic human right. Additionally, the code does not  require its members to pay a living wage – another basic human right — nor has it publicly demonstrated  any efforts to work towards it. Finally, the code allows for a 60 hour workweek, violating ILO standards  that limit the maximum working hours to 48 hours per week. A deeper analysis of the limitations with  RBA’s COC is beyond the purpose of the letter – which is to demonstrate the current shortcomings of RBA  member companies, a lack of adherence to the code, and recommendations moving ahead – but it is  important to acknowledge that there is also room for improvement for the COC.  

A Structural Problem 

The above findings point to one matter at heart: the RBA’s social responsibility standards and evaluations  have not promoted long-term, sustained and systematic improvement in labor conditions in member  manufacturers and member brands’ supply chains located in China and across the globe. This begets the  question: why do labor infringements continue to occur in factories producing goods for RBA-member  companies? 

Over time, questions on the social audit process have been brought to the fore. A 2023 report by the  Guardian detailed how factory audits are easy to falsify. In the report, a manufacturer in Saudi Arabia went  to the lengths of falsifying attendance, pay, hiring, and other records and training workers on preordained  scripts to counter direct workers’ interviews from auditors. Same sentiments are reflected by academics and  human rights watchdogs. A 2021 study of more than 40,000 audit reports across multiple countries by  Sarosh Kuruvilla, Cornell University Professor, found that almost a third of audits have been falsified.  Reports by Transparentem (2021) and Clean Clothes Campaign (2019) document similar challenges in  auditing.  

According to RBA, a typical VAP onsite assessment at a single manufacturing facility may last 2-5 days  and includes a thorough document review, interviews with management and employees and a visual site  survey. Compared to longer-term, undercover investigations or interviewing workers organically in or  around factory facilities, industry auditors’ short-term visits following a set assessment template might be  efficient and less labor-intensive. The methodology of the Speciality Validated Assessment Program (SVAP) approach is limited in its ability to truly uncover forced labor. Methodological elements which  hold it back include:  

a) Short worker interviews which cannot get to the heart of forced labor issues which are hard to see,  and harder to count. This is especially true with respect to the hundreds of social compliance checks  which an SVAP requires worker interview verification for. 

b) Large groups of workers in interviews which restricts the likelihood of workers opening up about  sensitive issues involving menace of penalty or involuntariness of work, which are definitive signs  of forced labor. 

c) Over reliance on verification by multiple sources where workers are exploited. There is often  deliberately no track record via documentation or grievance logs which can corroborate what  workers report to be the case. A worker who is being abused on site by a supervisor will commonly  fear retaliation for reporting such an issue via grievance logs; and as such, worker testimony alone  should be a verifiable evidence source for forced labor issues. 

Therefore, many observers have argued that this quick and streamlined process is prone to produce  unreliable results. In a sense, factory audits appear to function better in helping companies to assess risks  to their reputations rather than alerting them to real problems and promoting sustained changes. After  checking the social responsibility box with RBA, companies can prove reasonable effort and investments in supply chain management, while workers still suffer the consequence of sustained and institutionalized  abuses. 

The second issue could be attributed to the RBA’s function and lack of third-party, independent scrutiny.  RBA’s Board of Directors consists of management personnel from member companies, and RBA certified  entities that conduct VAP audits are all for-profit auditing firms, with some of which having been tied with  alleged compromising records. There are no representatives from civil society in the geographies where  RBA members produce their goods nor independent worker representatives from RBA member supply  chains on the RBA board to provide a more balanced perspective. Without this independent and third-party  oversight, the RBA can easily appear to be an extension of a company’s human resource department,  overseeing and guiding corporate responsibility initiatives without any added accountability. 

Next, RBA members pay annual membership fees in the range of $35,000-$45,000. While the fee is needed  to support the organization’s operations, this also creates a potential conflict of interest between RBA and  its member companies: while RBA serves a monitoring role in the industry, its own operations are supported  by the member companies it monitors. It is thus not in RBA’s financial interest to terminate memberships  of errant members. 

Lastly, while the RBA provides guidelines and conducts VAP audits, it is not an enforcement body, and  has no jurisdiction in ensuring compliance with its Code. Companies, ultimately, regulate their own  practices. Such self-regulation has been criticized to be ineffective and makes labor infringements in regions  with weaker labor enforcement practices even more difficult to change. 

This is not to negate the RBA’s preliminary steps in reforming its auditing practices and establishing a  mechanism for workers to voice their grievances. There has been the initiative of RBA Voices, an app that  allows workers to complete surveys without supervisor oversight, provide worker feedback and access  resources on health, safety and career development. According to the RBA, deploying a worker survey  through RBA Voices is now mandatory through their VAP assessments to ensure safe and anonymous  reporting. While perhaps the positive intent is there, the RBA Voices app arguably fails to center workers’  voices in a multilateral space, open to relationship building and ongoing dialogue. While mobile app data  can be effective in scoping macro level issues, it lacks the personable dynamic required to slowly build  trust-based relationships in spaces, times, and contexts that are comfortable for workers. Use of technology  without trust has major limitations.  

Additionally, consistent transparency and communication across various stakeholders must occur in tandem  with any RBA grievance mechanism. Since the RBA Voices rollout in 2020, only one set of survey results have been published on the RBA website in 2023. Additionally, the data provided was produced in  partnership with other international coalitions and did not offer a breakdown of geographies, industries or  RBA members. Therefore, this successfully anonymizes potential perpetrators – removing the capacity for  punitive measures and remediative action. Instead, the report stated it would publish the details of the survey  in a white paper in 2023 in order to address the cross-industry issues of excessive working hours and low  wages. This white paper has yet to be shared on the RBA’s website. Thus, if there is meaningful output  generated from RBA Voices or any future initiatives – stakeholders simply would not know. There is much  we do not know about RBA Voices that requires deeper interrogation such as: what kind of questions are  asked to workers, which workers use it, who has access to the data, and how is this information used?  Without access to these answers, it is unclear whether RBA Voices is being utilized as a tool to monitor  workers, or a genuine attempt at understanding broader patterns to actively address workers’ grievances. 

This same lack of transparency is mirrored in the methodology of the VAP assessments as there is no  published documentation which indicates RBA Voices is in fact mandatorily deployed, or that off site interviews are required and practiced in social audits. Similarly, communications between RBA and their  partners, negotiators, or civil society organizations that work closely with them – are not shared with  relevant stakeholders and the public.  

We recognize that many stakeholders are complicit here. Governments bear responsibility to protect  workers and their citizens’ rights and lives through enforcement of labor laws. Companies too, bear  responsibility to adhere to these laws and not exploit gaps in labor laws or inefficiencies in enforcement.  To this end, the three chapters of the UN’s Guiding Principles – protect, respect, and remedy – define  concrete, actionable steps for governments and companies to prevent human rights abuses in company  operations and provide remedies if such abuses occur. Despite this, the reality today is that companies are  only taken to task when investigated, and until then, exploitation is swept under the rug. 

Recommendations for the RBA 

RBA prides itself to be the world’s largest industry coalition dedicated to responsible business conduct in  global supply chains. It is in a position to require its members to comply with RBA’s standards and the  obligations of ethical corporate citizenship. A plethora of investigations and media reports suggest that  RBA member companies have fallen short of these standards, and when exposed, it is unclear what RBA,  or these companies have done to rectify alleged infringements. While we acknowledge that the RBA cannot  systematically solve the issue of labor malpractices on its own, minimally, it can take its members to task,  highlight gaps that are being exploited, and point out inconsistencies with its code of conduct. Beyond  recommendations, we also invite the RBA to make their internal methodologies transparent. To better  understand the RBA’s efforts we ask for examples where the RBA has timely led and delivered remediative  action with tangible results and examples where the RBA enacted punitive measures against a member  company that failed to deliver on corrective time-bound measures. 

We commend the RBA’s work in taking the step towards educating its members on ethical production. We  believe more can be done, and recommend the following actions: 

1. Increase transparency in RBA’s internal operations: including publicly releasing the results of  its supply chain assessment process, publicly disclosing audit results and corresponding  methodologies. This should include but not be limited to how RBA Voices is implemented in audits;  whether and how off site interviews are conducted; and the methodology for the repayment of  recruitment related fees and costs to workers who have paid these costs during any stage of their  recruitment processes. 

2. Introduce consequences for member companies that violate the RBA code. These can range  from time-bound corrective actions to the exclusion of continuously non-compliant members. This  can also look like policy reform, such as a responsible purchasing clause directed at members rather  than suppliers. This way, accountability is placed on RBA members as buyers, providing a clear  foundation for where the consequences or punitive measures can be directed to. 

3. Prioritize responding to and addressing civil society’s concerns over member companies’  labor and other practices directly and publicly, with actionable next steps. This practice will  also help RBA members to adhere to legislation such as the European Union’s Corporate  Sustainability Due Diligence Directive (CSDDD). RBA should set out a public and transparent  timeline or process for managing external complaints to overcome the current lack of responses  that civil society partners receive when making complaints to RBA and member companies.  

4. Mandate the creation of independently operated grievance mechanisms, such as workers’  hotlines, in all member companies and their suppliers and provide training for workers in  the areas of rights and the use of the hotline. The worker hotline must be fair, publicly available,  accessible, predictable and transparent for all workers, trade unions and other work worker  representatives. These worker hotlines can provide workers with an avenue to voice their  grievances in a climate where independent union representation and negotiation are suppressed in  certain jurisdictions. RBA will need to monitor the process to ensure that it is adequately staffed  and that worker grievances are regularly being addressed. 

5. Add to the RBA’s Board of Directors two or more representatives of worker advocates and/or  civil society organizations that have proven experience with surfacing and addressing worker  grievances and a longstanding commitment to improving human rights in supply chains. 

6. Move beyond inputs and introduce outcome-based reporting for member companies, in line  with new European rules for global supply chains. While input-based reporting is necessary to  understand what policies companies have introduced regarding human rights in their supply chain,  it does not quite indicate whether the policies or actions result in any impact to labor conditions.  Cornell’s Global Labor Institute has published a policy brief on a set of 25 quantitative measures  for firms to track impact over time, which the RBA can take reference from. 

Beyond the RBA, to comprehensively address labor issues within global supply chains, Governments in  the countries which house many of the RBA members cannot be absolved from responsibility. Measures  such as Section 307 of the United States Tariff Act of 1930 is one piece of the pie that the U.S. Government  has introduced to combat forced labor and trafficking. 

The European CSDDD which has recently been passed by the European Parliament will require RBA  members such as Apple and Amazon not only to identify, assess, and prevent human rights and  environmental impacts of their operations and those of their suppliers, but also to remediate the adverse  impacts. RBA members may look to RBA to assist in this process, and this is an opportunity to reshape due  diligence and ensure that worker voices are included in the process. 

If we are truly interested in equity and standards, then it is time to hear from workers directly. Our  recommendations above seek to strengthen the voice of workers who are asking only for what the RBA has  already committed to: ensuring that working conditions in supply chains are safe, that business is conducted  responsibly and ethically, and that all workers are treated with dignity.  

Sincerely, 

China Labor Watch (CLW) 

Solidar Suisse 

Action Aid France 

Andy Hall – independent migrant workers’ rights specialist 

Center for Trade Union and Human Rights (CTUHR) Manila 

Christian Initiative Romero (CIR) 

Good Electronics 

Migrant Worker Rights Network (MWRN) 

Serve the People Association Taiwan 

Taiwan Labor Front

 

Scroll to Top