“FWF realises good labour conditions by verifying the efforts made and results achieved by affiliates and ambassadors towards the step-by-step implementation of the Code of Labour Practices, in the company’s internal management system as well as in the factories where their products are manufactured.” (from FWF’s mission/vision)

While company commitments to ethical practices are important, such claims usually only gain credibility when verified by a third party. This is where FWF comes in. FWF’s multi-stakeholder make-up means that it is independent and credible. People have a right to know under what circumstances their clothes are made.

FWF verifies whether companies comply with the Code of Labour Practices, through factory audits and a complaints procedure, through management system audits at the affiliates and through extensive stakeholder consultation in production countries. FWF shares its knowledge and (local) contacts with the member companies, providing them with access to information on local legislation, labour standards and culture.

In order to gain real insight into company performance, FWF’s verification system exists at three levels: FWF verifies at factory level and implements a complaints procedure in all countries where it is active to serve as a safety net. Finally, FWF also verifies at the company level to check whether companies implement the FWF Code of Labour Practices in their management systems effectively.

Verification at factory level

FWF is perhaps best known for its unique and groundbreaking approach to factory-level verification. This is due largely to FWF’s multi-specialist approach to auditing. The rigor of FWF’s auditing process is evident in the higher quality of its outcomes.

FWF finds that managers are generally more open to collaboration and workplace improvements if audits are announced. Pre-planning audits also ensures that appropriate managers and documents are accessible on the days of the audit.

What’s more, FWF’s practice of interviewing workers offsite prior to visiting factories generally addresses the common pitfalls others encounter when they announce visits, namely coached workers and falsified books.

“The offsite interview itself is a fantastic procedure. When you join workers in their homes or community, you pick up issues you may not be able to pick up on the day of the factory audit.” – Bobby Joseph, Lead Auditor and Health and Safety Inspector, Bangalore, India

FWF’s factory auditing serves two main purposes: For factories, it is a step in a process leading to workplace improvements – rather than a policing exercise. For companies, factory verification visits also serve as an indication of their performance in upholding its FWF commitments.

An audit’s main goal is not to find the problems. Audits are part of a broader process aimed at fixing the problems, and collaboration is the best way to achieve solutions.

It is for this reason that FWF’s audit guidelines require auditors to interview trade union (on occasions when there is a factory union) and/or worker representatives. Trade union representatives should also participate in the audit exit meeting, where audit outcomes and improvements to workplace conditions are discussed. Likewise, by seeking to involve member companies in the audit process, company representatives gain a deeper understanding of the problems in the sector and their underlying root causes.

“FWF’s audits are not about long checklists and fixating on minute details. Local specialists are the key to FWF’s approach. They work to find the underlying problems – the root causes… Ultimately, if we want to solve these issues, we need to create an environment of trust and collaboration between buyer and supplier. FWF auditors have the expertise to find and explain problems as the audit unfolds – and to participate in discussions about possible solutions.” – Ivo Spauwen, International Verification Coordinator at FWF

FWF Complaints procedure

FWF believes that the best grievance procedure is one that is fair and effective – and local.

While it would be ideal that companies’ efforts would ensure good conditions, the reality is not there yet. What’s more, workers often lack access to fair and effective complaints channels locally.

FWF’s complaints procedure serves as a safety net. It is designed to ensure workers in member companies’ supply chains always have recourse in instances of noncompliance – but only in instances where workers are not able to access local grievance systems. FWF’s system only applies when other options, such as factory grievance systems or local labour courts, are not fair, effective, and accessible.

In every country where it is active, FWF has a local complaints handler. This ensures that workers making products for FWF affiliates can safely and fairly seek redress for violations of the Code.

For a complaints system to be effective, workers need access to it. FWF complaints handlers therefore need to possess key skills and competencies.

All FWF complaints handlers…

…are accessible: Because they are based locally, they can be reached in the time zone and on a local number. In most cases, complaints handlers are also the worker interviewer during audits, which means workers have seen them and can put a face to the name on the information sheet.

…can understand: They speak the local language(s) and English, allowing them to follow up on details with workers, FWF staff, and FWF affiliates. This means better and faster follow up.

…are trustworthy: Handlers are usually female representatives from labour or women’s NGOs. They are able to communicate with workers in a way that enhances trust.

Management system audits

When a company joins FWF, it commits to implement the FWF Code of Labour Practices in its supply chain. While this includes efforts to work directly with factories to improve conditions there, it also means developing internal management systems to better support good workplace conditions. After one year of membership, FWF annually visits its affiliates to verify these systems and their effectiveness.

Since 2008, FWF staff started visiting the headquarters of each company’s CSR programme to audit its progress in upholding its FWF obligations. During these management system audits (MSAs), FWF staff reviews company documentation and databases, interviews staff, and, where possible, tests company systems. Using this information, FWF staff assesses the extent of meaningful improvements to internal systems and the results and achievements of these systems. Recommendations and requirements for improvement are also provided and can assist companies in shaping their compliance plans for the coming year.

FWF publishes the outcomes of these MSAs, so stakeholders and the public can keep track of how companies are doing.

FWF approaches the implementation of the Code of Labour Practices as a step-by-step process. The management system audit focuses on a limited number of aspects of the management system, so companies can improve these first.

Management system requirements

Affiliates of FWF are required to adjust their management systems in order to allow effective implementation of the Code of Labour practices.

The management system requirements that shall be met are:

1. Sourcing policy
   • Sourcing policy supports effective implementation of the Code of Labour Practices
   • Working conditions and the willingness of suppliers to cooperate on improvements are important criteria in the selection of new suppliers and the continuation of business relationships
   • Delivery times and the pricing policy do not lead to excessive overtime and contribute to a systematic approach towards a living wage for workers
2. Coherent system for monitoring and remediation
   • The percentage of the affiliate’s turnover that has been audited corresponds to the required percentage based on the duration of FWF affiliation
   • The corrective action plans resulting from conducted audits are systematically agreed upon, followed up and reported on
   • The affiliate cooperates with other customers of manufacturers regarding monitoring and the execution of Corrective Action Plans
3. Complaints procedure
   • The affiliate has a designated person to handle complaints of workers
   • The affiliate responds  adequately to complaints submitted by workers
4. Improvement of labour conditions
   • Corrective Action Plans are executed and have lead to verifiable improvements
5. Training and capacity building
   • Staff of the affiliate is sufficiently informed about FWF affiliation and the implementation of the Code of Labour Practices
   • Agents are systematically informed about FWF affiliation and the implementation of the Code of Labour Practices
   • Manufacturers and their workers are systematically informed about FWF affiliation and the implementation of the Code of Labour Practices
6. Information management
   • There is a clear procedure to keep the supplier register updated
   • There is a system in place to effectively integrate information regarding sourcing and the implementation of the Code of Labour practices
7. Transparency
   • The affiliate informs the public about its FWF affiliation.
   • The annual social report of the previous year has been received in time, approved by FWF and placed on the website of the affiliate
   • Information about FWF affiliation is posted the website of the affiliate in correct wording
8. Management system evaluation and improvement
   • The affiliate annually evaluates in a systematic manner to what extent goals related to its FWF affiliation are achieved
   • The affiliate uses feedback from agents and manufacturers to evaluate the implementation of the Code of Labour practices
9. Basic requirements of FWF affiliation
   • Work plan for the current year has been received in time and approved by FWF
   • Affiliation fee for the previous year has been paid