Options for Code of Conduct IFOAM traders
Once the code is drafted and approved, putting it into practice requires:
While the application process is relatively straightforward, determining an appropriate secretariat and monitoring mechanism requires careful consideration of a number of options. As the choice of overseeing body is dependent upon the monitoring mechanism in place, the latter will be examined next.
Three broad forms of monitoring codes of conduct include the following:
In this form, the signatory to the code of conduct pledges to observe the requirements of the code and is bound morally to implement it both internally and with respect to its suppliers and subcontractors. There is no requirement for an internal system to be set up to monitor observance of the code nor is there any external verification to confirm that the signatory is indeed meeting the terms of the code. While the simplest to implement, there are many problems associated with this form. From the experiences of a vast number of already existing codes of conduct, the failure of companies to adopt the codes based on self-monitoring has led to dissatisfaction with this form and calls for independent monitoring and verification.
The second variant also involves the signatory to the code of conduct pledging to observe the requirements of the code. However, this form is characterised by the implementation of a reporting structure. The organic trader is responsible to report on how it is implementing the code and meeting the requirements on an annual basis in a written report to the secretariat or other body overseeing the IFOAM code of conduct. The written report can be a standardised questionnaire or a free form document that addresses an agreed upon list of issues, among other possibilities. Procedures could be put in place to make the written reports of signatories available for public review and/or to ensure their circulation to suppliers and subcontractors for verification. Furthermore, the responsibility for implementing and monitoring the code should be assigned to key people within the company. These people should receive training on how to work with the code.
Additionally, the secretariat overseeing the implementation of the code could put in place a separate accessible reporting structure whereby any individual (employee or otherwise) or company could confidentially report the failure to observe any requirements of the code of conduct by a signatory or its suppliers/subcontractors. The overseeing body would then investigate the claim and determine whether or not there has been a failure to observe the code.
An arbitration process would be required to address instances of non-compliance and provide a transparent series of steps to be followed to rectify the situation. This could lead to observance of the code or in the worst-case scenario, the removal of the organic trader from the code of conduct process. This process should begin by internal negotiations with the organic trader where possible and move to the secretariat if a mutually satisfactory outcome could not be achieved at that level.
The third option adds another layer to the procedures. As well as implementing a reporting structure through annual reports by the organic trader and a procedure in place to examine claims of non-observance of the code, the third option involves third party verification by an appropriate certification body. The certification could be integrated into the norms and procedures of the International Organic Accreditation Service with inspections and certification carried out by IOAS accredited certification bodies. In this case, verification of compliance with the code of conduct could be integrated into the annual organic inspection and certification.
This option requires IOAS accredited certification bodies to develop new skills and expertise in social auditing. An auditable check-list of practices and conditions that are consistent with the requirements set forth in the code could be developed for use by IOAS accredited certification bodies and training for inspectors could be provided. Another option would be to use the expertise of already existing social auditing systems. Such organisations could be asked to help in developing materials and in training. Alternatively, all or some of the responsibilities for verification could be transferred to an already existing social auditing system. However, while existing systems have developed expertise in verification of basic labour standards, this would not cover the full extent of issues addressed in the IFOAM Organic Trader's Code of Conduct.
Once the code of conduct is drafted and accepted, there will be a need to establish a body responsible to oversee its implementation. Depending on the choice of monitoring mechanisms, the implementation could be overseen by a number of bodies like IOAS, accredited certification bodies etcetera but this has to be decided by IFOAM World Board.
A key issue raised in discussions about the social agenda in organic agriculture is the place of small-scale producers and companies. As the IOAS accreditation criteria include requirements for certifiers to have special provisions for smallholder grower groups, it is suggested that the implementation of the requirements in the Organic Trader's code of conduct should allow for special consideration in the case of small-scale producers and companies. Such special consideration should not remove responsibility on the part of the company to meet the requirements of the code; instead, it could provide a framework of continual improvement to work towards observance of the code.
last updated: 24 october 2000