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.
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 remediate 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.
Co-signed by:
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
