Compliance is
essential given the onslaught of environmental and social legislation on the
horizon, but could upcoming regulations finally reduce the countless audits
apparel manufacturers are expected to carry out?
The
apparel sector is dealing with a raft of new regulation, explains the American
Apparel & Footwear Association (AAFA)’s senior vice president of policy,
Nate Herman.
Social & Labor Convergence Program
(SLCP) CEO Janet Mensink puts it more bluntly by calling it an “avalanche” of
emerging legislative frameworks.
Irrespective of how you word it, the
ultimate goal of all this legislation and regulation is to achieve transparency
and visibility as well as ensure compliance goes all the way back to the raw
material.
Herman admits to attendees of a live
discussion with Mensink on audit fatigue at the recent IAF and ITMF joint
conference that audits continue to play a “critical role” in due diligence and
compliance.
Sustainability has become a growing
priority, but he argues, “we can’t do all the audits in the new sustainability
space.”
Of course, fashion buyers depend on
suppliers to meet regulations as well as their own rules, but he continues:
“The relationship can’t be a one-way street – it must be a partnership”.
Director of operations and supply chain at
global full-service apparel and accessory design and manufacturing
company Décor Apparel, Michael Cai, agrees and shares: “As a manufacturer
we want to provide a safe environment for all workers in our global supply
chain.”
But, he adds the money spent on audits can
be counter-productive. He gives the example of workers being on a factory line
in the middle of their task and getting pulled from their work to conduct an
audit-style interview.
Cai is keen to collaborate with all
stakeholders in the industry to find a solution and he reveals that for his
company SLCP has provided that middle-ground for his team and workers. He
explains that SLCP is a single verified assessment that eliminates the need for
each fashion buyer he works with, which includes the likes of Target and Inditex to NIKE and Converse, to conduct their own audits.
For Herman, its crucial for all audits
moving forward to be both “independent and credible”.
The benefit he says is that if a
manufacturer “has one audit being done that can be shared with all buyers” it
“can ensure due diligence all the way through the supply chain”.
He recommends suppliers use independent
audit organisations like SLCP, Worldwide Responsible Accredited Production
(WRAP), Business Social Compliance Initiatives (BSCI) and Supplier Ethical
Data Exchange (Sedex) to reduce audit fatigue.
Herman acknowledges there are a few to
choose from and many are similar, which is why the AAFA encourages its members
to work with a couple to get “some standardisation and reduce the expense and
resources required to fix any problems that might arise”.
Herman also explains independent audit
associations “make sure their audits and certifications match the laws and
regulations that are coming out,” which will be key over the next few years.
But, he is also keen to remind the sector
that some regulations are already here. He uses the example of the Uighur
Forced Labor Prevention Act (UFLPA) in the US, which was signed by President
Biden in December 2021.
The ULFPA means his US-based fashion brand
and retailer members have to prove forced labour hasn’t been used anywhere in
their supply chain otherwise their goods will be stopped at the US border and
they will lose sales.
“It’s a big deal” and a “huge focus of our
members right now along with the due diligence and compliance that comes with
it,” he explains.
SLCP’s Mensink shares her organisation is
seeing expansion not just from Tier 1 but also from Tier 2 and 3, which she
regards as “promising” given all of the upcoming regulation coming out of the
EU.
“Brands and companies are driving it and
we’re diversifying to adjacent sectors,” she continues.
Mensink also highlights SLCP wants to ensure
that there is a proper single measurement that other stakeholders can use to
mediate and improve working conditions as well as support upcoming legislative
frameworks.
She clarifies that SLCP is not a standard: ”
We provide the data and we would like stakeholders to translate it and use it
for improving programmes.”
At the end of the discussion the CEO and
president of fellow audit organisation WRAP,
Avedis Seferian tells Mensink from the audience that he’d like to
work more closely with organisations such as hers.
Sensink agrees, stating: “We all want to
create collaboration between our different schemes. We started some
conversations a few years ago and now is the time to pick those conversations
up again.”
As a manufacturer, Cai says audit fatigue is
just one of a number of daily challenges. Manufacturers are expected to
navigate all of the complexities of legislation, regulation, auditing, consumer
behaviour changes to industry trends, new fabrics and raw materials as well as
the usual complexities of the supply chain – ranging from tier 1 to tier 4. If
that wasn’t enough, manufacturers have to ensure they stick to their own
sustainability goals.
For us, he says, the best solution to all of
these challenges, including audit fatigue, is also that buzzword –
collaboration: “We build a partnership on both sides – we’re a buyer to our
supplier partners and a supplier to our brands”.
Cai adds that since working with SLCP he has
seen one of his factories reduce its audits from 34 to 14 and on average he
used to see between eight to ten audits across his supply chain, which has also
reduced.
Herman is thrilled to hear Cai’s positive
real-world experience and concludes that if we “can agree on three, four or
five instead of the 100s of approaches that currently stands,” it’s got to be
beneficial for the entire apparel sector.