11 February 2022 Reports of companies in the Textile Alliance on "Gender-Specific Violence" An initial assessment by Dr. Gisela Burckhardt, FEMNET By 22 December 2021, 43 member companies of the Textile Alliance have published their reports on the exercise of their supply chain due diligence obligations. On the one hand, they report on the implementation of their self-imposed targets for the last two years and, on the other hand, set targets for the next two years. These objectives are based on a mandatory risk analysis: Companies are required to identify the risk of 11 sectoral risks, including gender-based violence (GBV) in the workplace, for their entire supply chain. In doing so, they can describe the preventive measures they are already taking. Following the identification of remaining risks, they must set new targets and measures to prevent serious risks. In the case of this so-called ‘Review process’ the companies are supported by a qualitative evaluation interview, which is carried out by external experts together with the Alliance Secretariat. This review process is, to a certain extent, the basis for the legal requirements of the newly adopted Supply Chain Act. In fact, companies can already prepare on a voluntary basis for what is required by law from 2023. The reports of the companies are publicly available on the website of the Textile Alliance. Civil society in the Textile Alliance has worked intensively on the elaboration of the criteria of the review process. Through this process, she hopes to strengthen corporate responsibility in order to improve working conditions and reduce environmental damage in the supply chain. We know that in many countries, especially Bangladesh and India, women's rights are violated and even violence is frequent (GBV). As a result, companies producing in these countries must take effective action against GBV. A first rough review of the reports shows: Almost all companies generally consider the risk for GBV to be high if they have production in Asia. However, the goals and measures they set themselves to mitigate the risk are very different: Many large companies remain disappointingly general about goals at the policy level. But there are also a few companies, both large and small, that set themselves more ambitious goals. This will be discussed in more detail below. Risk analysis Most companies are aware that social audits usually cannot reveal sensitive issues such as GBV. Aldi Süd also sees this difficulty, but still believes that it can identify GBV by adapting the interview questions (revision of the Aldi Social Assessments). This is not convincing. Some companies mention the difficulties in recognizing GBV: Women did not comment on this in audits or in direct conversation out of shame or fear of stigmatization in the factory and in their own family. Many believe the blame for sexual harassment lies with themselves. They do not know their rights sufficiently and male superiors intimidated them. Complaints are often not brought forward for fear of job loss, making it difficult to record GBV. After all, NKD, for example, describes the advantage of ‘off-site interviews’ as an audit methodology that leads to better insights. This procedure is not new and is regularly used in audits of the Fair Wear Foundation. Some companies, which mainly have production in Europe, assume that there is no discrimination against women here, which is of course far from being the case. Some also assume that female management staff prevent GBV, which unfortunately also does not apply in principle. Very often, companies do not look into the deeper supply chain, probably also because they are not aware of it. However, the lack of supply chain transparency also serves companies as a justification for a low level of ambition. Seidensticker writes that its mitigation processes such as audits, certificates, etc., only focus on directly commissioned suppliers (tier 1), while information about suppliers in the deeper supply chain is not available. But it is precisely there that we know of numerous injuries, such as the publications from FEMNET to spinning mills in India. KiK also writes: “The lack of supply chain transparency and reliable data availability beyond tier 1 heightens the potential of the risk existing in the lower tiers.” However, KiK does not publish its list of suppliers, although it is known to the company, but only feeds it into the list of the Textile Alliance, which is published in aggregate on the Open Apparel Registry (OAR). This list only shows that the producer produces for one of the member companies of the textile alliance, not for which. Even this small step of a Participation in the aggregated list Seidensticker and Otto do not do so despite their prominent position as members of the Alliance's steering committee. So far, only 25 out of the current 70 member companies have done so. Increased work pressure is known to have an impact on GBV due to poor corporate purchasing practices. Overseers put women under massive pressure, insult the women, in some cases they are even beaten if the clothes can not be delivered in time. However, the reason for a delay is often the buyer himself, because he has changed the requirements (different color, buttons elsewhere, etc.) at short notice. However, hardly any company analyzes its own purchasing practices as a risk and a change in purchasing behaviour is accordingly not formulated as a risk-mitigating measure. Objectives and measures If you get a first overview of the goals and measures that companies set themselves for the risk of GBV, a mixed picture emerges. Large companies and discounters are more likely to formulate general measures at the policy level. Some small and medium-sized enterprises (SMEs) are already on their way and are setting precise targets and measures against GBV at the factory level. What they all have in common is that they start at the last stage of the supply chain, but only a few formulate measures for the deeper supply chain. Here are a few examples of goals and actions of randomly selected companies: Inclusion of GBV in the policy and notification to suppliers Eagle: Action: Include a zero-tolerance clause against discrimination in terms and conditions. Aldi Nord: Objective: Gender equality policy, action: Guidance Paper for Business Partners. NKD: Action and objective: ‘By the end of 2022, an explicit directive on gender-based violence will be adopted and communicated to all business partners, suppliers and factories’. The directive becomes part of the CSR statutes and thus contractually part of the supplier manual, the recognition of which is the basis of all business relationships. KiK: Objective and action: KiK aims to ensure that its own internal complaints system includes discrimination and complies with the UN Guiding Principles on Business and Human Rights. The question arises as to why the objectives and measures mentioned here have not already been formulated and implemented in previous roadmaps. They express an intention at policy level, which is a precondition for any action to be taken at a later stage. However, they also show how little these companies are still fulfilling their precautionary obligations. Linking GBV to complaint mechanisms Some companies make it easy by not formulating specific targets for GBV risk in their supply chain, but by saying that it is enough to improve complaint systems. It is certainly necessary to improve the complaint systems. However, all companies are obliged to do so in a separate step within the review process anyway. s.Oliver wants to address GBV through a better complaint system: Objective: “Strengthening the accessibility and awareness to a strong grievance mechanism until 2023”. As explained above, it is particularly difficult to report harassment, especially on sensitive issues. Not even s.Oliver formulates a measure for this. Improving gender-specific data also in the deeper supply chain Somewhat more demanding are the goals of Otto and VAUDE, who want to collect gender-specific data. Otto also wants to take into account the deeper supply chain. Otto: Objective: “Expanding & improving data collection and analysis as a basis for evaluating needs for action also in the deeper supply chain in 2022 and 2023 with a focus on our top 5 producing countries China, Turkey, India, Bangladesh and Pakistan”. C&A measure: With the help of external consultants, the local employees in three production countries are trained for one year so that they can disclose sensitive topics such as GBV in interviews with workers. Objective: “Improve local teams ability to detect sensitive topics (with focus on sexual harassment/ gender based violence, forced labor) during worker interviews Scope: Bangladesh, Pakistan, India Timeline: Dec 2022’. VAUDE also wants to “complement wage increases and raise wages for women and men”. The collection of gender-specific data, especially in the deeper supply chain, is particularly necessary because there is still far too little data available so far.Not only are there different wage payments between men and women, but there is too little data on whether social security contributions are paid for female employees in the same way as for male employees, whether overtime or absenteeism are the same, whether absenteeism is similarly high, etc. Examples of concrete measures to alleviate or remedy GBV Measures against GBV in the workplace are specific and measurable and often apply to training measures taken by either the company's own employees or those of the manufacturer. Brands Fashion states as a goal: “Awareness raising of factory management and workers on discrimination in all active Tier 1 factories in Bangladesh by mid-2023. The measures taken to achieve this objective are as follows: "Together develop a questionnaire with local partners; Carrying out self-developed trainings with workers and factory management; participation in the pilot of the Textile Alliance; Training at two Tier 1 factories in Bangladesh. Tchibo has been providing WE (World Enhancement) training to producers for many years. It is formulated as a goal to GBV: “80% of WE factories in Bangladesh, India and Turkey and 50% of WE factories in China, Cambodia and Vietnam will implement improvements in the prevention of and management of discrimination, sexual harassment and gender-based violence by 2023.” Even if these measures are targeted, the question arises as to why GBV continues to exist so virulently in many factories in Asia. The measures are aimed at initiating a dialogue between management and workers; they all rely on dialogue to bring about improvement. The mediation of a dialogue between management and workers is useful, but not sufficient. Tchibo mentions his cooperation with the umbrella association of trade unions IndustriALL. However, it is unclear what link exists between WE Training and the Global Framework Agreement with IndustriALL Global Union. External pressure and a real mobilisation of workers for their rights is essential. This is only possible through the local trade unions, which often cannot set up and operate freely and without intimidation. Reference to seal Seals and standards are very often referred to in other sectoral risks. If a company has the GOTS (Global Organic Textile Standard) seal, complies with the SA8000 standard or the BSCI Code of Conduct, is audited by the Fair Wear Foundation or the wool is PETA-Approved Vegan, then companies weigh themselves in safety. However, this is not the case. Seals and standards do not exempt a company from reviewing its supply chain itself and complying with its supply chain precautions. Responsibility cannot be deported to the seals. Because seals and standards are based on social audits. However, they do not reflect the whole reality in the factory. With regard to GBV, the OECD also says Due Diligence Guidance on Responsible Supply Chains in the Garment and Footwear Sector, on which the members of the Textile Alliance are also guided, that classical audits are not an appropriate tool for the determination of GBV. Most companies also admit this weakness of audits and point out explicitly in their reports, especially at GBV, that the problem is hardly detected in audits. The Review Process Needs Targets As shown here in the example of GBV, the level of ambition of companies varies, regardless of their size. It can already be seen that the big companies, especially discounters, are still very much at the beginning or do not want to go further. After all, there are some large companies that are continuing with their activities and, above all, starting with training. Even smaller companies have set themselves ambitious goals, as the example of Brands Fashion shows. There may be improvements for individual companies, but overall GBV remains problematic in the factories. This shows that many companies are still very much at the beginning when it comes to gender-based violence. Seven years of the Textile Alliance have not yet led to widespread measures that would effectively remedy the risk. The objectives and measures of the roadmaps cast doubt on the fact that this will change for the majority of companies by 2023. The review process also lacks sufficiently clear guidelines on how companies must monitor and report on the impact of their measures. The different levels of ambition of the companies are not accessible to consumers or the interested public because the textile alliance lacks an evaluation scheme. One cannot at first glance recognize pioneers and laggards. But this would be worthwhile for committed companies and at the same time an incentive for the others. This is why civil society in the Textile Alliance is calling for guardrails and targets to highlight the level of ambition and progress made by companies on each of the 11 sectoral risks. Download Download this analysis (PDF file)
