GoodWeave International Assurance Public System Report

Transcription

1 GdWeave Internatinal Assurance Public System Reprt March 2017 Cntents 1. Assurance System Structure Persnnel Cmpetence Assessment Oversight On-ging Scrutiny... 4 Referenced Dcuments... 4 Appendix: Organizatinal Structure f GdWeave... 5

2 1. Assurance System Structure GdWeave is an rganizatin wrking t end child labur in the carpet industry and t replicate its market-based apprach in ther sectrs.gdweave perates as a netwrk f rganizatins based in India, Nepal, Afghanistan, Germany, the UK and USA. The scheme wner f the GdWeave system is GdWeave Internatinal (GWI), which is a legal entity registered in the United States f America. The verarching rganizatinal structure f the GdWeave system is depicted in Appendix 1. Standards The GdWeave prgram currently uses a single certificatin standard, the GdWeave Generic Internatinal Standard fr Rug Prducers (current versin 3.0, dated January 2016), which is available at Certificatin Divisin The GWI Certificatin Divisin (GWI-CD) is the certificatin bdy fr GdWeave glbally. GdWeave currently perates a single certificatin bdy, which cmplies with ISO 65/17065 and is assessed by a third-party accreditatin rganizatin. In 2013 this was cnducted by Scial Accuntability Accreditatin Services (SAAS) and in 2016 it was cnducted by Internatinal Organic Accreditatin Services (IOAS). Oversight f the GWI-CD is prvided by the Certificatin Cmmittee (CC) and Oversight Cmmittee (OC). System Review and Imprvement The assurance system is reviewed as part f the annual GWI-CD Management Review. Because there is a single certificatin bdy in the GdWeave system, the verall system is reviewed alngside the perfrmance f the certificatin bdy fr greater efficiency. The GWI Secretariat mnitrs the perfrmance f GWI-CD and the verall assurance system n an nging basis thrugh regular cmmunicatin, participating in CC/OC meetings and regularly reviewing GWI-CD recrds and dcumentatin. The GdWeave Secretariat identifies risks in the assurance system and ways t mitigate thse risks during the regular and nging reviews f the system. Where areas fr imprvement are identified, these are brught t the attentin f the Executive Leadership Team and Bard fr decisin-making n any necessary changes t the system. 1 Stakehlder Engagement During GdWeave audits/inspectins the key stakehlders are invlved thrugh interviews with the factry r prductin site management, lm wners, wrkers, family members and/r ther cmmunity members as needed and apprpriate t the situatin. In the case f subcntracting and hme-based prductin in particular, infrmatin is gathered frm the weavers and thers in the cmmunity in rder t crss-check recrds prvided by cntractrs t identify whether there culd be any undisclsed subcntracting as well as t identify indicatrs f pssible nn-cmpliances, particularly child labur, frced and bnded labur. There is a cmplaints prcedure in place as well as GWI-CD Cde f Ethics, available nline fr all stakehlders t share feedback, dissatisfactin r t reprt any instances f ptential fraud r prfessinal miscnduct at 1 See Appendix fr an explanatin f the Certificatin Cmmittee, Oversight Cmmittee, Executive Leadership Team, Bard and their respective rles and respnsibilities. Page 1

3 2. Persnnel Cmpetence GWI sets minimum qualificatin and cmpetency requirements fr inspectrs/auditrs in cnsultatin with the GWI-CD Directr and lcal field teams. It als determines the key qualificatin requirements fr the CC/OC members and the GWI-CD Directr. Inspectin/audit persnnel are evaluated thrugh annual perfrmance reviews, as well as thrugh peridic shadw audits in cnjunctin with internal audits f GdWeave s ffices in prducer cuntries t identify strengths and areas fr imprvement. Inspectr/auditr team training Once taken n as a trainee, inspectrs underg an in-huse training prgram cvering inspectr respnsibilities, cntent f the GdWeave standard, plicies and prcedures, etc. This is fllwed by field training under the supervisin f a senir inspectr, which includes: Shadw a senir inspectr audit; Cnduct audits alng with a senir inspectr; Senir inspectrs evaluate the perfrmance and cnduct f the trainee; Once the training has been satisfactrily cmpleted, the GWI-CD Directr apprves new trainees t lead inspectins. GdWeave als prvides nging training t inspectin teams n the basis f needs identified during internal audits, annual management reviews and persnnel evaluatins. GdWeave als cnducts all-cuntry inspectin team training prgrams peridically when needs arise, in rder t calibrate and ensure cnsistency acrss the varius cuntry and reginal inspectin teams. Managing Cnflicts f Interest Identifying and managing ptential cnflicts f interest is an imprtant part f safeguarding impartiality. This is addressed in each f the Terms f Reference (TOR) fr GWI-CD and the CC/OC. Certificatin Divisin persnnel are required t cmplete the Declaratin f Interests frm. The cmpsitin f the Certificatin Cmmittee, which is respnsible fr making certificatin decisins, is designed t minimize ptential cnflict f interest by requiring a majrity f independent experts t serve as vting members, and prhibiting invlvement f industry members and inspectin staff in the decisin-making prcess. 3. Assessment The GWI Licensing and Certificatin Plicy describes the requirements fr a cmpany t becme licensed and fr certificatin labels t be issued, as well as requirements related t cmpliance assessment, decisin-making, handling nn-cmpliances, appeals and cmplaints. There are three types f assessments f prducers fr cmpliance with the GdWeave Standard, which are referred t as inspectins r audits: Initial inspectins/audits Regular (unannunced) inspectins Fllw-up inspectins/audits Page 2

4 Frequency and Intensity f Inspectins/Audits Initial inspectins/audits must be cmpleted prir t licensing. After this, regular (unannunced) inspectins are carried ut at a minimum every 6 mnths fr all prductin units supplying t the exprter, including subcntractrs and hme lms. All units, irrespective f level, where child labur has been identified earlier, are inspected at a higher frequency, at least nce a mnth during the 3 mnths fllwing the date in which child labur was last identified at that unit. Higher inspectin frequencies may be used in particular areas taking int accunt risk factrs identified, such as areas knwn t have high incidence f child labur, bnded labur, trafficking r ther issues. Fllw-up inspectins are carried ut when child labur and ther nn-cmpliances are identified, in rder t verify that remediatin prcedures have been cmpleted. Exprters that are fully cmpliant receive a fllw-up audit annually. Tw inspectrs wrk as a team as standard practice. Hwever, there culd be reginal r cuntry specific reasns (security level, gegraphic spread, manpwer availability) allwing either ne inspectr r a larger inspectin team t be deplyed. GdWeave inspectrs and ther persnnel prvide general infrmatin abut the GdWeave standard and infrm emplyers and wrkers abut child rights and labur rights. This infrmatin may be shared within r utside f the audit/inspectin prcess. Decisin-Making n Nn-Cnfrmities and Sanctins The Certificatin Cmmittee makes decisins relating t licensing and certificatin n the basis f findings frm the inspectin/audits. In rder t ensure a cnsistent decisin-making prcess, the GWI-CD emplys a certificatin methdlgy t determine levels f nn-cnfrmity with the standard. When nn-cmpliances are fund, there are tw types f actins that fllw: (1) In cases where child labur is discvered during an inspectin, the rle f the inspectr is t raise an alert and the inspectin prcess fr purpses related t certificatin effectively stps at this pint. Thereafter prcedures fr rescue and rehabilitatin f child labur are fllwed; hwever, these fall utside the scpe f the certificatin prcess. (2) In any case f child labur r ther nn-cmpliances, GdWeave emplys enfrcement guidelines and a schedule f sanctins t direct the actins t be taken with respect t the prducer if the nn-cmpliance is nt crrected as cnfirmed thrugh a fllw-up inspectin. NOTE: The remediatin f child labur is undertaken by GdWeave with the cperatin f the prducer; the respnsibility f the prducer is t crrect the nn-cmpliance (nn-emplyment f child labur, allwing access t facilities fr unannunced inspectins, etc.) as per the certificatin methdlgy. It is therefre imprtant when using the term remediatin t distinguish between the actins taken by GdWeave in respnse t cases f child labur and the actins f the prducer t cmply with the standard. 4. Oversight An versight mechanism independent f the GWI Certificatin Divisin (GWI-CD) ensures that it cmplies with GdWeave plicies and with the requirements f ISO 17065, and that its cmpetence and cnsistent perfrmance is peridically reviewed. This mechanism cnsists f an assessment by an independent third party individual r rganizatin, which may be an accreditatin bdy member f ISEAL, using an ISO mdel and/r which has experience with ther similar scial r envirnmental certificatin systems. The prcedures and timelines fr versight assessments are Page 3

5 develped by the GWI Secretariat, requiring at a minimum a full assessment f the GWI-CD management system, the inspectin/auditing prcesses, and perfrmance and cmpetency f persnnel t be cnducted at field ffices thrugh dcument review and shadw (witness) audits, at least nce every five years with virtual/desktp review t take place every tw years. Any crrective actins necessary are identified in cnsultatin between the Secretariat and GWI-CD and the results reprted t the Oversight Cmmittee, which determines whether the actins taken are sufficient. The versight prcedure as well as the parties invlved (the independent assessment bdy and Oversight Cmmittee) will be reviewed annually in rder t ensure their cntinued suitability including independence and cmpetence. 5. On-ging Scrutiny GdWeave maintains a trademark plicy, which cntrls the use f intellectual prperty, including the GdWeave lg, certificatin labels and any claims r prmtinal use by members f the carpet industry. Cmpliance with the Trademark Plicy (available nline at is a requirement f the license agreements executed with carpet imprters and exprters. In case any indicatin f pssible fraud r misrepresentatin is fund, license agreements allw GdWeave t audit and inspect the licensee s wrkplace, recrds and persnnel. The license agreement and any right t use GdWeave trademarks are terminated if any vilatins f the plicy are fund. Each GdWeave certificatin label is individually numbered and can be traced back t the licensee t which it was issued. Any use f the GdWeave trademark ther than fr prduct certificatin with GdWeave labels must cnfrm with the Trademark Plicy. In n case may a licensee r its subcntractrs make misleading r false claims regarding the certificatin status f the prducts including any claims regarding certificatin status ther than as evidenced by the applicatin f certificatin labels n finished prducts per the Licensing and Certificatin Plicy. GdWeave tracks label use patterns, as well as media and publicity (e.g. in advertising, retail shwrms, trade shws, etc.) used by prducers, exprters, imprters, and retailers in rder t mnitr fr any pssible fraud, in particular within the cnsumer-facing marketplace. Referenced Dcuments GWI Licensing and Certificatin Plicy GWI-CD Terms f Reference Certificatin Cmmittee Terms f Reference Oversight Cmmittee Terms f Reference Certificatin Methdlgy Page 4

6 Appendix: Organizatinal Structure f GdWeave GdWeave Internatinal is a legal entity registered in the United States f America and perates as a netwrk f rganizatins based in India, Nepal, Afghanistan, Germany, the UK and USA. The verarching structure f the rganizatin is depicted belw, cnsisting f a Bard f Directrs, Secretariat, Executive Leadership Team, several cmmittees and the Certificatin Divisin. The latter is established as a distinct divisin f GWI with the respnsibility f managing and implementing all peratins relating t inspectins, mnitring and certificatin, as well as licensing in prducer cuntries. GWI Bard Oversight Cmmittee GWI Secretariat GWI Certificatin Divisin Directr / Senir Management Standards Cmmittee Executive Leadership Team Child Prtectin Cmmittee Certificatin Cmmittee Natinal Inspectin Units Nrth America Prgram UK Germany Afghanistan Prgram Nepal India Cntracted Inspectrs GWI is gverned by the Articles f Assciatin, which is the highest gverning dcument and establishes the Bard f Directrs, as well as designated decisin-making bdies including the GWI Standards Cmmittee and GWI Certificatin Cmmittee. Plicies and prcedures direct the daily peratins f the rganizatin. The GWI Bard f Directrs is the highest decisin-making bdy n fundamental matters and determines GdWeave s strategic bjectives. It is respnsible fr apprving GWI plicies and versees the Secretariat and the Certificatin Divisin. The Executive Leadership Team (ELT) is respnsible fr the day t day peratins f GdWeave. The Standards Cmmittee, which is respnsible fr develping and deciding n the cntent f GdWeave Standards, reprts t the ELT. The GWI Certificatin Divisin (GWI-CD) is the certificatin bdy fr the GdWeave system. It is separate frm the standard-setting arm f GWI and cnsists f: The Directr and Senir Management f GWI-CD; Page 5

7 The Certificatin Cmmittee, which is respnsible fr making certificatin decisins and prviding guidance fr the implementatin f the inspectin and mnitring prgramme; Natinal inspectin units based in each prducer cuntry where GdWeave perates the inspectin and mnitring prgramme; Cntracted inspectrs may be emplyed fr specific purpses utside f the natinal inspectin units if a need arises; and An Appeals Cmmittee may be frmed n an as-needed basis The Oversight Cmmittee is respnsible fr prviding versight and safeguarding impartiality. The Child Prtectin Cmmittee prvides feedback and advice t the Secretariat n issues related t child prtectin. GdWeave s and Prgrams (als previusly referred t as Natinal Initiatives) carry ut the day t day activities f the GdWeave prgram in prducer and cnsumer cuntries, including prgrams utside the scpe f the certificatin system. Page 6