In April 2013, the Rana Plaza building in Bangladesh collapsed. More than 1,100 garment workers, laboring for low wages, died in the tragedy. Thousands more were injured and traumatized.

Just weeks before the poorly constructed building caved, a factory audit by TÜV Rheinland, under the oversight of Amfori BSCI, reportedly failed to notice significant safety defects, even noting the building was of “good construction quality.” The audit, which was supposed to be ensuring humane working conditions in a properly built facility, also reportedly failed to identify that child labor was being used.

The Rana Plaza collapse.

This, according to a new study, is one of the more damning examples that highlights what is allegedly a systemic issue in the apparel sourcing supply chain – namely, that the so-called social audits brands and companies use to ensure factories are safe have “failed spectacularly.”

Promotional products companies that rely on factory audits to ensure social compliance might do well to review the report – called “Fig Leaf For Fashion: How Social Auditing Protects Brands & Fails Workers.” Produced by labor rights group Clean Clothes Campaign, the study could contain insights and information that will help promo firms navigate the complexities of factory auditing and sourcing ethically. (More on that below.)

In our report launched yesterday we're exploring how social auditing functions as a #FigLeafForFashion and is #FailingWorkersByDesign. Instead of exposing & addressing labour rights violations, social auditing firms function as an opaque buffer between brands & their suppliers. pic.twitter.com/747gfJEo6x

— Clean Clothes (@cleanclothes) September 18, 2019

Nonetheless, some social responsibility and product safety experts that Counselor spoke with said that the study is one-sided and paints an overly negative picture of social responsibility audits.

“I work with hundreds of companies who are the ‘good guys’ in the world of social responsibility, and although not one of their programs is perfect, they have surely made a huge difference in improving worker safety, wages, hours, benefits, human rights and environmental compliance,” said Leeton Lee, founder of ComplyBox, a firm that specializes in product safety and social compliance initiatives for the promotional products industry. The study “fails to look at the progress that has been made in the last 25 years, and how many lives and communities our collective efforts have improved in the countries where our products are made. From a promo industry perspective, we should keep working hard to improve our programs and keep auditing to verify efforts.”

Andy Church expressed similar sentiments to Counselor. “The study doesn’t reflect the good that auditing has brought to manufacturing,” said Church, founder and CEO of Quality Insight Services, which conducts factory audits and offers product inspections and other quality control services. “Audits are a tool in increasing awareness of social issues in the workplace. Social auditing is effective at taking a snapshot of what an auditor observed and should be recognized as such.”

Even so, the CCC study asserts that the multi-billion dollar social auditing industry acts as a mechanism for protecting “brand reputation and profits, while aggravating risks to garment workers.”

The report further asserts that the “corporate-controlled” social auditing industry has served as a roadblock to more effective models for protecting workers and improving working conditions – models that would include mandatory transparency and binding commitments to remediation.

In particular, the study analyzes social compliance initiatives such as Social Accountability International, WRAP, the FLA, and Amfori BSCI, and auditing firms that include Bureau Veritas, TÜV Rheinland, UL, RINA, and ELEVATE.

“Twenty years of CSR has failed to improve labor conditions, and will continue to fail until there is an overhaul of the prevailing social auditing regime,” said Ben Vanpeperstraete, lobby and advocacy coordinator at Clean Clothes Campaign and the author of the report. “Brands cannot be trusted to regulate themselves. Binding regulations with the threat of sanctions and worker empowerment via unions are the only mechanisms that can ensure brand responsibilities are taken seriously, due diligence is performed and workers lives are protected.”

The report goes on to detail various examples of alleged auditing failures. For instance, in 2012, a factory fire at Ali Enterprises in Pakistan killed more than 250 apparel workers. The blaze occurred a few weeks after RINA awarded the factory a SA8000 certification. CCC alleges that auditors never visited the building.

To help prevent such tragedies, the CCC says that brands should do the following. The full list of recommendations can be found on page 91 of the report here.

*Develop a robust due diligence process to assess supply chain and prevent/mitigate human rights risks or violations. In-depth site assessments should be part of the process.

*Conduct root cause analysis of violations, and how pricing, purchasing and sourcing practices contributed to violations.

*Ensure that audits are conducted by independent third parties, and that off-site worker interviews occur.

*Make sure there are no conflicts of interest, such as auditing firms having financial incentive to produce reports that keep companies “happy,” rather than providing honest assessments.

*Regularly review methodologies used by auditing firms, especially when no violations are found.

*Adopt supply chain transparency. This includes publishing audit reports, time-bound corrective action plans, complaints and progress reports shortly after these findings are completed.

*Implement a strategy on freedom of association, which should include assessing factories to see if they put up barriers to workers forming and/or joining a union.

*Require factory partners to allow independent inspectors complete access to the workplace for regular announced and unannounced inspections.

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