Ethical Fashion Africa Project Update - FAIR LABOR ASSOCIATION | INTERNATIONAL TRADE CENTER

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Ethical Fashion Africa Project Update - FAIR LABOR ASSOCIATION | INTERNATIONAL TRADE CENTER
Improving Workers’ Lives Worldwide

FAIR LABOR ASSOCIATION | INTERNATIONAL TRADE CENTER

Ethical Fashion Africa Project Update
Ethical Fashion Africa Project Update - FAIR LABOR ASSOCIATION | INTERNATIONAL TRADE CENTER
FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

    TABLE OF CONTENTS
    EXECUTIVE SUMMARY .................................................................................................................................... 2

    INTRODUCTION ................................................................................................................................................. 3

    OBJECTIVES .......................................................................................................................................................4

    BACKGROUND ...................................................................................................................................................4

          Labor Profile ................................................................................................................................................ 5

          Jua Kali: Informal Sector in Kenya ......................................................................................................... 5

          ITC and the Ethical Fashion Initiative.................................................................................................... 7

    PROJECT ACTIVITIES ..................................................................................................................................... 10

          Awareness Building on Standards ....................................................................................................... 10

          Tool Adaptation and Development...................................................................................................... 10

          Supply Chain Mapping and Task and Risk Mapping ........................................................................ 10

          Training Needs Assessment ................................................................................................................... 11

          Development of EFAL’s Internal Systems ...........................................................................................12

          Field Visits ..................................................................................................................................................12

          Impact Assessment ................................................................................................................................13

                 Information Collection and Definition of Social Indicators ............................................................13
                 Collecting Information from Workers through Photo Elicitation .................................................14
                 Developing, Defining and Using the Impact Assessment Methodology...................................15
                 Review of the Methodology .......................................................................................................................15
                 Assessments and Data Analysis ...............................................................................................................16
          FLA’s Baseline Assessment Methodology and Key Recommendations...................................... 16

    RECOMMENDATIONS AND GUIDELINES FOR FLA INDEPENDENT EXTERNAL ASSESSMENT .. 19

          FLA’s Assessment Approach ................................................................................................................. 19

          Assessment at the Community Level ...................................................................................................21

    CONCLUSION ...................................................................................................................................................22

    ANNEX I: Extended and Outreach Community Groups that EFAL is working with ........................23

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    EXECUTIVE SUMMARY                                    FLA led a number of activities in the sourcing
                                                         communities of ITC’s local subsidiary, Ethical
    In support of its mission to promote and             Fashion Africa Limited (EFAL), based in
    protect workers’ rights, and to improve              Nairobi. Existing FLA tools on risk and supply
    working conditions globally, the Fair Labor          chain mapping were adapted to the informal
    Association (FLA) continuously engages               sector1 while some others, such as photo
    with other organizations in strategic (special)      elicitation and social impact assessments,
    projects. These projects help address specific       were developed specifically around the
    areas of risk for noncompliance with labor           artisan groups. EFAL carried out a number of
    standards, or targeted issues identified by          baseline and follow-up impact assessments
    affiliates. They often allow FLA to pilot new        with extensive trainings conducted in
    tools to assess labor compliance and evaluate        between. Lastly, FLA tested independent
    risks. These special projects often lead to the      external assessments for the informal sector
    development of creative strategies in unique,        and made recommendations for how its
    nontraditional sectors or in underserved             methodology could be adapted for this
    communities.                                         sector.

    In early 2010, FLA launched a pilot project          This has led to the creation of FLA’s FAIR-
    with the International Trade Centre (ITC) and        ART (Artisans for Responsible Trade)
    its Ethical Fashion Initiative, which promotes       project. Additionally, ITC’s Ethical Fashion
    trade within marginalized communities of             Initiative is slated to expand to other parts
    artisans. ITC’s Ethical Fashion Initiative is part   of the world (Haiti, Ghana, Mali and Burkina
    of a larger program – the Poor Communities           Faso), following a similar approach to social
    and Trade Program – which aims to reduce             responsibility based on learnings from this
    global poverty through the generation                project. Ongoing collaboration between ITC
    of trade opportunities for marginalized              and FLA has the potential to improve the
    communities and micro producers in the               lives of thousands more workers, and have an
    developing world.                                    impact in informal sectors at a large scale.

    The first two years of the pilot project aimed
    at assessing the needs of this informal sector
    of artisans; developing the methodology;
    and building the necessary tools to address
    labor issues. Additional tools were created to
    measure the impact of working with the ITC-
    Ethical Fashion Initiative on the livelihoods
    of communities producing goods for them in
    Kenya and Uganda.

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     INTRODUCTION
    In February 2010, FLA welcomed the
    affiliation of Ethical Fashion Africa Limited
    (EFAL) – a subsidiary of the International
    Trade Centre (ITC). 2 As a nonprofit
    Participating Company with nontraditional
    supply chain, the affiliation of EFAL has been
    handled as a special project.

    ITC’s Ethical Fashion Initiative of the Poor
    Communities and Trade Program is based
    on an inclusive business3 model that offers
    job and income opportunities to informal
    producers from marginalized communities
    and works with women groups in Kenya4 and
    Uganda5, mostly groups of micro-producers
    based in poor rural and urban settings. The
    initiative enables disadvantaged communities
    and their groups of informal manufacturers
    to become part of the global supply chain,
    thus developing their export capacities and
    strengthening their position in the domestic,
                                                     A woman working in one of the communities that partners with EFAL.

    2                                                regional and global markets. It is based on a
                                                     joint effort of ITC and Ethical Fashion Africa
                                                     Ltd. (EFAL), a not-for-profit entity based in
                                                     Nairobi, which manages, in collaboration with
                                                     ITC, all the business operations and the social
                                                     agenda of the Ethical Fashion Initiative in East
                                                     Africa.

                                                     EFAL’s supply chain extends to informal
                                                     workshops, artisan communities and home-
                                                     based work in Kenya and Uganda.

                                                     Within the “aid for trade” framework,
                                                     the Ethical Fashion Initiative has strong
                                                     social objectives that aim at improving
                                                     the livelihoods of the communities they
                                                     work with. A part of these objectives is a
                                                     commitment towards fair labor conditions
                                                     and the empowerment of workers. In support
                                                     of this goal, ITC partnered with FLA on a pilot
                                                     project to better assess and control risks in

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    the program’s supply chain and strengthen           FLA affiliates or organizations working with
    its outreach by implementing remedial and           the informal sector. The report concludes
    capacity building measures that help improve        with recommendations and an outline of
    the lives of workers. This pilot project is         the framework for FLA’s future independent
    aimed at adapting and extending FLA’s               external monitoring in informal settings.
    work into the informal sector with tailor-
    made methodology and tools to address the
    specific needs of this sector.
                                                        BACKGROUND
                                                        Kenya has a land area of 580,000 sq. kms and
                                                        a population of nearly 41 million, representing
     OBJECTIVES
                                                        various ethnic groups: Kikuyu, Luhya, Luo,
    The main objectives of this pilot collaboration     Kalenjin, Kamba, Kisii, Meru, Mijikenda,
    are to:                                             Masai and Turkana. About 40 percent of
      đƫ 1,,+.0ƫ ƫ* ƫ ƫ%*ƫ0$!ƫ                   the population reside in urban areas and 60
         understanding and implementation               percent live in rural areas.
         of labor standards in the artisan
                                                        Following a referendum and adoption of
         communities and empowering workers
                                                        a new constitution in August 2010, Kenya
         by being part of the Ethical Fashion
                                                        was divided into 47 counties with semi-
         Initiative;
                                                        autonomous units of governance. These
      đƫ //!//ƫ0$!ƫ*!! /Ďƫ !ü*!ƫ0$!ƫ                   units are expected to be fully operational by
         methodology; and develop tools to              August 2012 – in time for the first general
         monitor and remediate labor issues in          election under the new constitution. The
         informal workplaces;                           counties will be governed by elected officials
                                                        and will operate independently of the central
      đƫ     !*0%"5ƫ0$!ƫ)!*%*#ƫ+"ƫ,%05ƫ1%( %*#ƫ
                                                        government in Nairobi.
           for artisan communities and develop
           tailored training programs;                  The capital, Nairobi, is a regional commercial
      đƫ +ƫ!5+* ƫ0$!ƫ.!()/ƫ+"ƫ/+%(ƫ                hub. Kenya has the largest gross domestic
         compliance to develop a methodology            product (GDP) in East and Central Africa. The
         and tools to measure the social impact         agriculture industry is a major employer, and
         of the program on the livelihood of the        the country traditionally exports tea, coffee,
         workers and communities;                       and – more recently – fresh flowers to Europe.
                                                        However, about half of the population lives
      đƫ !2!(+,ƫƫ)!0$+ +(+#5ƫ"+.ƫ%* !,!* !*0ƫ         below the poverty line.6
         external assessment and monitoring of
         artisan clusters in the informal sector.       Although Kenya is the most industrially
                                                        developed country in East Africa,
    This report describes project activities from       manufacturing accounts for only 14 percent
    2010 - 2012, beginning with background              of GDP. Industrial activity is concentrated
    information on the informal sector in Kenya,        around Nairobi, Mombasa and Kisumu -
    where the project is implemented. The               the three largest urban centers - and is
    report outlines the activities carried out by       dominated by food-processing industries,
    EFAL and FLA and provides a description             such as grain milling, beer production,
    of the methodology and tools developed
    throughout the project, which can be used by

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                                                                                                                                   Number, 000’s

                                                                                        2005      2006      2007      2008      2009     2010*

                                                                     Private
                                                                     agriculture and    272.4     280.3     289.0     289.7     288.0     291.8
                                                                     forestry

                                                                     Rest of private
                                                                                        885.0     927.4     992.7    1,016.2   1,058.5   1,105.2
                                                                     sector

                                                                      Public service   654.2     649.9     628.1     638.0     653.5     663.4

                                                                      Total            1,811.6   1,857.6   1,909.8   1,943.9   2,000.1   2,060.4

                                                                     Table 1: Wage employment by sector of activity, 2005-2010.
                                                                     Source: Kenya National Bureau of Statistics.
                                                                     * Provisional

                                                                     JUA KALI: INFORMAL SECTOR IN KENYA

                                                                     As in most developing countries, the
    sugarcane crushing, and the production of                        organized sector is unable to absorb the
    consumer goods. There is also a fast-growing                     growing number of jobseekers and therefore,
    cement industry, and Kenya hosts an oil                          the informal sector fills the gap9. It is
    refinery which processes imported crude                          estimated that the workforce of the informed
    petroleum into products mainly for domestic                      sector is some 6.4 million workers.
    consumption. In addition, a substantial
    and expanding informal sector commonly                           Typical activities associated with the informal
    referred to as Jua Kali engages in small-scale                   sector in Kenya are10:
    manufacturing of household goods, motor-                           đƫ /!((%*#ƫ".1%0/ƫ* ƫ2!#!0(!/Ď
    vehicle parts and farm instruments.                                đƫ "++ ƫ+,!.0%+*Čƫ/(!ƫ* ƫ,.+!//%*#Ď

    LABOR PROFILE                                                      đƫ /!((%*#ƫ(+0$!/ƫ* ƫ/$+!/ƫĨ+0$ƫ/!+* ġ
                                                                          hand and new);
    In 2010, the composition of Kenya’s GDP was:
    17 percent agriculture; 17 percent industry and                    đƫ '%+/'/ƫ/!((%*#ƫ2.%+1/ƫ%0!)/Ď
    commerce; 59 percent services. Formal sector                       đƫ 30!.ƫ'%+/'/Ď
    wage earners were approximately 2 million,
                                                                       đƫ /)((ƫ.!0%(!./ƫ+.ƫ$3'!./ƫ3$+ƫ/!((ƫ!.!(/Čƫ
    of which 30 percent were in the public sector
                                                                          home supplies, fuels and other goods;
    and 70 percent in the private sector.7
                                                                       đƫ /)((ƫ)*1"01.%*#Čƫ,.+ 10%+*Čƫ
    According to the Kenya National Bureau of
                                                                          construction and repair of goods;
    Statistics8, the most current employment
    statistics are:                                                    đƫ $* %."0ƫ* ƫ#.)!*0/Ď
                                                                       đƫ /$+!ƫ,.+ 10%+*ƫ* ƫ.!,%.ċƫ

    7 U.S. Department of State, Background Note: Kenya, www.state.
    gov/r/pa/ei/bgn/2962.htm
                                                                     9 Source: http://www.nayd.org/PDF/The%20informal%20sector%20
    8   Source: http://www.knbs.or.ke/Labour_Basic_Min_wages.php     in%20Kenya.pdf

                                                                     10 World Bank: Kenya inside Informality: poverty, jobs, housing and
                                                                     services in Nairobi’s slums, May 31, 2006, report no.36347-KE

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    According to the 2006 World Bank report
    on the Kenyan informal sector focusing on
    housing, social services provision and slums,
    there has been an increase in the activities
    and involvement of the population in this
    sector. This is largely due to the privatization
    of the public sector and the rise in the
    unemployment rate, especially among the
    youth.

    Poverty is rising especially in Kenya’s urban
    areas. This has resulted in a growing number
    of slums, which house the vast majority of
    the urban poor. Approximately 73 percent
    of urban slum dwellers are poor11. Rents
    are quite high in the slums, despite the
    poor quality of the buildings. The landlords
    often build these shelters in an unplanned
    manner, using low-quality materials (e.g.,
    mud, timber, iron sheets) and without basic
    necessities such as toilets, water sources, or
    garbage disposal systems. The tenants have          In the last decade, access to finance, services
    no permanent or formal contracts with the           and training has increased - even though it
    landlords and may face eviction at any time.        is not well distributed. This has resulted in
    Slum residents are stuck in what is referred to     a dramatic development of micro and small
    as a “high cost, low quality trap” (World Bank,     enterprises (MSEs). More and more married
    2006, p.43). Engaging in the varied activities      women create MSEs to boost the family’s
    of the informal sector is the only way for slum     income. In most cases, the husbands provide
    dwellers to earn an income.                         the capital for starting the business. However,
                                                        one of the biggest problems facing MSEs
    The informal sector is referred to as “Jua Kali”
                                                        in Kenya is that the husbands often feel
    in Kenya, which literally means “fierce sun”
                                                        threatened by the success of such businesses
    in Swahili. Kenya’s informal sector is large
                                                        and withdraw the financial support or bar
    and dynamic, including 95 percent of the
                                                        their wives from operating the business.
    country’s businesses and entrepreneurs. The
                                                        This has led women to diversify ways to
    Kenyan government has established a Ministry
                                                        empower themselves by forming saving clubs
    of Technical Training and Applied Technology
                                                        to ensure their economic independence and
    (MTTAT), to raise the very low skill-level of the
                                                        development.
    workers, and MTTAT has been charged with
    developing training programs for the informal
    sector12.

    11

    12

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    ITC AND THE ETHICAL FASHION
    INITIATIVE13
                                                         ITC acts as a liaison between the international
    It is in this specific context that ITC and          buyers and EFAL. Working with design
    EFAL got involved in 2009, in working                teams from partner companies in Europe and
    mainly with marginalized communities of              around the world, ITC’s team develops the
    women in Kenya and Uganda to supply                  designs through the EFAL Hub – a design
    income-generating opportunities to assist            centre, administrative office and workshop in
    the groups in reducing poverty. The Ethical          Nairobi. ITC also plays an important role in
    Fashion Initiative enables international             marketing EFAL activities to ensure regularity
    fashion companies and distributors to source         in the flow of orders and to raise awareness
    from African communities without bias in             among consumers on ethical issues.
    price or quality, thus allowing groups of
                                                         EFAL includes a team of full-time
    marginalized artisans to become part of the
                                                         management staff that facilitates business
    larger global value chain. The program thus
                                                         interactions with international companies.
    contributes to reducing poverty by offering
                                                         Most of these people have been selected
    trade opportunities to micro-producers and
                                                         from local community groups, after
    marginalized artisan groups. EFAL’s supply
                                                         demonstrating their management or
    chain model is set out in Figure 1.

    Figure 1: Functioning of EFAL’s supply chain model

    13

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    technical abilities. The Hub (EFAL                The Hub also acts as an incubator to foster
    headquarters) houses a Product Development        small hubs at the community level. The
    Centre where the initial product development      vision is to reproduce smaller independent
    takes place. Also at the Hub is a team of         entities that EFAL can rely on for planning,
    tailors and people with other skills who          production, quality control, etc. The majority
    undertake critical production processes.          of these micro-entrepreneur groups are
    The logistics of placing orders in the            organized into Self-Help Groups14 with a goal
    community, and the supplies are managed           of achieving economic empowerment.
    from the Hub. EFAL currently employs 39
                                                      At the outset of the FLA project, EFAL was
    people, including: managers, accountants,
                                                      working with 30 community groups. Since
    product developers, quality control officers,
                                                      then, EFAL made a strategic decision to
    production supervisors, packing and shipping
                                                      consolidate work with fewer groups and
    managers, tailors, embroiderers, beaders and
                                                      strengthen the collaboration. Reasons for this
    preparation staff. Critical path production
                                                      consolidation include the ability to provide
    processes take place at the Hub along
                                                      more regular work, deliver better training,
    side final quality assurance, packaging and
                                                      and offer more control over product quality
    shipment. The Hub is also responsible for
                                                      and labor standards at the community level.
    carrying out sampling, price setting, training
                                                      The core community groups EFAL is currently
    and preparation before the work is sent out
                                                      working with in Kenya are presented in Table
    to the communities. Orders are usually sent to
                                                      215 on the following page.
    the communities for a particular task (such as
    embroidery, screen printing, embellishments,
    metal working, etc.) when they are large
    enough and incorporate the skills represented
                                                      14
    in the community groups. When placing
    orders with community groups, EFAL sends
    in-house supervisors to each group to impart
    training and to supervise the production
    process. All pieces produced are then sent        15

    back to the Hub for finishing, quality control,
    packing and shipping.

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    Table 2: Core community groups working with EFAL for the Ethical Fashion Initiative, 2012

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     PROJECT ACTIVITIES                             of a certain product. These tools were then
                                                    shared with ITC – EFAL, who then conducted
    Since EFAL joined FLA in 2010, a series of      a task and risk mapping exercise for each
    joint and independent activities have been      community group.
    carried out in relation to the project. The
    following section describes the different       In phase one of the project, FLA and ITC/
    activities that have helped shape the           EFAL also developed a methodology in to
    program.                                        measure the impact of the Ethical Fashion
                                                    Initiative on the livelihoods and well being of
    AWARENESS BUILDING ON STANDARDS                 the workers involved in the program based
                                                    on a study framework inspired by a previous
    EFAL has built an understanding about the       study by Marsha Dickson and Mary Littrell on
    importance of the FLA’s Workplace Code of       artisans working for a fair trade organization16
    Conduct in the communities where it operates    in a Mumbai (India) slum. The work done in
    through continuous local engagement. The        the slums of Mumbai helped FLA to identify a
    Code is shared in a practical way with the      set of preliminary social indicators that were
    groups and the issues are re-iterated with      further refined to fit the specific context of
    the placement of each new order. ITC and        Africa and the involved communities. This
    EFAL have outlined detailed policies and        was achieved through consultation with local
    procedures that follow, amongst others,         experts on the draft social indicators and
    the guidelines of ISO 26000 as well as FLA      the input from the workers using a photo-
    standards. They organize ongoing awareness      elicitation mechanism.
    building activities of these policies and
    standards to all actors in the immediate        FLA and EFAL also developed a Social
    supply chain. EFAL is developing internal       Impact Assessment Tool that became a
    control systems to ensure adherence to these    cornerstone of EFAL’s internal monitoring
    standards.                                      methodology. EFAL conducts Impact
                                                    Assessments (social and economic) for
    TOOL ADAPTATION AND DEVELOPMENT                 each production order. The results are made
                                                    available to the customer on request and
    FLA’s first activity as part of this project    serve as valuable information to track the
    was to adapt its supply chain and task and      social impact of the opportunities provided
    risk mapping tools to the informal sector. A    to the groups against the increased income
    section on home and community workers was       generated.
    added to the tool to track information on the
    tasks performed, characteristics of the work    SUPPLY CHAIN MAPPING AND TASK AND
    force, conditions of employment, and whether    RISK MAPPING
    informal or formal management systems
    were in place. The tools are self-managed, to   EFAL’s field staff has used FLA’s tools to
    help companies and organizations to better      complete the mapping exercise. The data
    understand their supply chains and the          are then reviewed by FLA staff to make a
    processes involved in the manufacturing of a    preliminarily assessment of the supply chain,
    product. The tools are designed to provide an   including the tasks and labor risks involved.
    overview of the supply chain in a particular    For example, they identified the need for
    country and to map all the tasks and
    associated risks involved in the production     16                           Artisans and Fair Trade

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    strengthening internal management systems         Overall, the task and risk mapping exercise
    (creation of policies and procedures and          informed EFAL and helped them to start
    their implementation) at the Hub and the          shaping up their internal processes by
    community level. The lack of information on       identifying priority issues for each community.
    the labor profile of the communities was also
    identified as a risk. Indeed, due to the casual   TRAINING NEEDS ASSESSMENT
    nature of the work place, employee-employer
                                                      In 2011, ITC and EFAL organized an
    relationships were seldom present and labor
                                                      assessment of the various groups to identify
    tracking was nonexistent. Therefore, it was
                                                      their training and capacity building needs.
    difficult to develop an internal monitoring and
                                                      From this needs assessment (conducted by
    remediation program in the absence of any
                                                      EFAL), a training program was developed.
    data about the beneficiaries of the program.
                                                      Training and capacity building took place
    A third example of risk identified was the
                                                      throughout 2011. The training was pertinent
    lack of a grievance procedure, deprivings
                                                      to newly-formed groups and the issues they
    workers at the Hub and communities with
                                                      faced in working together, and included the
    an opportunity or channel to raise their
                                                      following topics:
    complaints and solve them in a systemic and
    timely manner.                                     đƫ +*ý%0ƫ)*#!)!*0ƫ* ƫ+*ý%0ƫ
                                                          resolution;
    FLA advised EFAL staff to implement a basic
                                                       đƫ %**%(ƫ(%0!.5Ď
    labor tracking system through registry books
    in each community to collect information on:       đƫ !*!.(ƫ(%"!ƫ/'%((/ƫ* ƫ3.!*!//ƫ+*ƫ$!(0$ƫ
      đƫ (+.ƫ,.+ü(!ƫĨ3+.'!./Ěƫ#!Čƫ#!* !.Čƫ*)!Čƫ       issues;
         attendance);                                  đƫ  ƫ+ !ƫ+"ƫ+* 10ċ
      đƫ ,.+ 10%+*ƫĨ*1)!.ƫ+"ƫ,%!!/ƫ) !ƫ5ƫ
         each worker);                                Subsequent to the FLA field visit in early
                                                      2012, discussions were held in Kenya on
      đƫ $+1./ƫ+"ƫ3+.'ƫĨ0%)!ġ%*ƫ* ƫ0%)!ġ+10ĩĎƫ       adopting a more practical approach with the
      đƫ ,.!/!*!ƫ+"ƫ+*0.0/ƫĨ2!.(ƫ+.ƫ3.%00!*ĩĎ   groups to inform them about labor standards.
                                                      The plan is for the group to receive continued
      đƫ 3#!/ƫ!.*! ċ                                guidance and revised training in 2012 with
                                                      assistance from FLA.
    The objective of this activity was to better
    know the labor profile in EFAL’s supply chain     In March 2012, ITC conducted another training
    and ultimately advise what kind of internal       needs assessment at both the EFAL Hub
    monitoring and intervention is needed at          and community level. Two trainers from
    the work place. In some of the communities        ITC conducted a general survey in order to
    where some form of employer-employee              develop an appropriate training program
    relationships exists, FLA advised EFAL to be      related to general management, financial
    particularly vigilant about working conditions.   management, trade and exports. The trainers
    In contrast, in a tribal artisan community        conducted a Learning Style Questionnaire
    where the women work together to complete         for each of the groups to assess how each
    a certain order and the money is divided          group/sector prefers to learn. Relevant
    equally amongst them, the application of the      training material and methods (visual, audio
    full Workplace Code of Conduct may be less        or activity based learning) will be developed
    relevent.                                         based on this feedback.

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    A training program is being developed for          đƫ +.'%*#ƫ3%0$ƫ Čƫ ƫ$/ƫ/0* . %6! ƫ
    2012, and a subject matter expert is engaged          its impact assessment methodology
    to conduct training on the following topics:          which now includes the different tools
      đƫ !*!.(ƫ1/%*!//ƫ)*#!)!*0ƫ* ƫ                 used to measure impact (questionnaires,
         operations                                       matrix, etc.) and guidance on the
                                                          methodology.
      đƫ %**%(ƫ)*#!)!*0
      đƫ 4,+.0ƫ)*#!)!*0                            FIELD VISITS

                                                      Since the project launch, FLA staff have been
    DEVELOPMENT OF EFAL’S INTERNAL
                                                      in regular touch with ITC and EFAL and have
    SYSTEMS
                                                      conducted field visits in order to understand
    In the past two years, EFAL has systematically    the peculiarities of the informal sector and
    initiated activities to develop and strengthen    develop meaningful tools. Supported by ITC,
    internal systems to implement fair labor          FLA has conducted three field visits during
    standards and operational procedures at both      the project.
    the Hub and community levels.                      đƫ *ƫ 1*!ƫĂĀāĀČƫ ƫ.!/% !*0ƫ1.!0ƫ2*ƫ
      đƫ $.+1#$ƫ.!#1(.ƫ)+*%0+.%*#ƫ* ƫ0.%*%*#ƫ         Heerden – along with two members from
         by the social department, the community          ITC’s team – made the first field study
         groups of micro-producers working with           to get familiar with the systems at the
         EFAL have adopted a worker registration          EFAL Hub and the community level. A
         and tracking system. This includes               number of rural, urban and slum-based
         information about the identity of workers,       communities were visited. The objective
         hours of work, and remuneration. This            of the visit was to provide ITC and EFAL
         system is continuously being improved            with preliminary considerations on how
         and adapted to the respective contexts           to couple fair labor standards with their
         of the groups. The Hub has improved              social agenda. The need for designing a
         its existing registration system and now         methodology to conduct social impact
         has a digital registry, which effectively        assessment on the community groups
         records relevant information on workers’         was also identified.
         involvement in production as part of
                                                       đƫ *ƫ!,0!)!.ƫĂĀāĀČƫ"0!.ƫ/+)!ƫ3+.'ƫ+*ƫ
         EFAL’s internal monitoring system.
                                                          the risk mapping results and development
      đƫ ƫ,.0%%,0+.5ƫ)*#!)!*0ƫ,,.+$ƫ             of a social impact assessment
         has been adopted in developing the               methodology had been carried out, FLA’s
         structures at EFAL and each department           Projects Officer made a follow-up visit
         has focus group meetings to develop              focusing on the refinement of the Social
         systems and conduct root cause analysis          Impact Assessment (SIA) framework.
         when required.                                   During this visit, FLA tested the photo
                                                          elicitation method with a sample of
      đƫ  ƫ.!!*0(5ƫü*(%6! ƫ0$!ƫĂĀāĂƫ2!./%+*ƫ
                                                          workers who took pictures illustrating
         of its Standard Operating Procedures
                                                          activities they performed during a typical
         (SOP). This manual describes the systems
                                                          day. These photographs served as stimuli
         and processes used by EFAL, ranging
                                                          during interviews to incorporate workers’
         from technical processes of production,
                                                          perspectives in the definition of social
         to management systems for interacting
                                                          indicators. In addition, FLA and ITC
         with the informal sector.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

         co-organized a consultation with local          IMPACT ASSESSMENT
         academics and experts in order to:
                                                         *!ƫ+"ƫ0$!ƫ)%*ƫ+10+)!/ƫ%*ƫ0$!ƫü./0ƫ5!.ƫ
         i.   solicit feedback on design of the social   of the project has been the development
              impact assessment process;                 of the Social Impact Assessment (SIA)
         ii. seek advice on pre-selected social          )!0$+ +(+#5ċƫ$%/ƫ)!0$+ +(+#5ƫ((+3/ƫ
             indicators and get input to complete,       measuring the impact of an intervention
             improve and refine them;                    program on the capabilities, livelihood and
                                                         3!((ƫ!%*#ƫĨ)0!.%(Čƫ,/5$+(+#%(Čƫ,$5/%(ƫ
         iii. seek advice on the workers’                and social) of the workers involved. The
              questionnaire (taking into account         )!0$+ +(+#5ƫ3/ƫ !2!(+,! ƫ"+((+3%*#ƫƫ
              cultural specificities); and               (//%ƫ.!/!.$ƫ,,.+$ƫĨ%#1.!ƫĂĩċ

         iv. establish relationships with credible
             local organizations, experts and
             academics for future collaboration.

         More information on the SIA process is
         available later in this report.
      đƫ *ƫ!.1.5ƫĂĀāĂČƫ Ě/ƫ%.!0+.ƫ"+.ƫ
         Agriculture and Strategic Projects and the
         Projects Officer conducted another visit
         to:
         i.   conduct an in-depth assessment of the
               ƫĢƫ ƫ,.+#.)ƫ0+ƫ+0%*ƫ/!(%*!ƫ
                0ƫ+*ƫ%*0!.*(ƫ)*#!)!*0ƫ/5/0!)/ƫ
              and labor conditions; and

         %%ċƫ 0!/0ƫ0$!ƫ,,(%%(%05ƫ+"ƫ Ě/ƫ
              independent external monitoring
              )!0$+ +(+#5ƫ3%0$%*ƫ0$!ƫ%*"+.)(ƫ
              sector.
                                                         Figure 2:ƫ+%(ƫ ),0ƫ//!//)!*0ƫ !0$+ +(+#5
      ƫ $!ƫ ƫ0!)ƫ/,!*0ƫ03+ƫ 5/ƫ0ƫ0$!ƫ
        1ƫ%*ƫ%.+%ƫ* ƫ03+ƫ 5/ƫ%*ƫ0$!ƫü!( ƫ
        visiting four of the ten communities that        Information Collection and Definition of
         ƫ1..!*0(5ƫ!*##!/ƫ3%0$Čƫ%*(1 %*#ƫ          Social Indicators
        Sanchat Charitable Trust in Gilgil; Baba
        +#+ƫ%*ƫ +.+#+$+Ďƫ0$!ƫ.//ƫ3+.'/$+,ƫ           !ü*%*#ƫ,,.+,.%0!ƫ%* %0+./ƫ3/ƫ'!5ƫ0+ƫ
        %*ƫ %!.Ďƫ* ƫ0$!ƫ /%ƫ! !./ƫ%*ƫ            conducting a relevant impact assessment.
        the Ngong hills. The detailed results of         Previous studies17ƫ$!(,! ƫ0+ƫ% !*0%"5ƫƫ
        this assessment were communicated                /!0ƫ+"ƫ,.!(%)%*.5ƫ/+%(ƫ%* %0+./Čƫ3$%$ƫ
        0+ƫ ƫ* ƫ ƫ(+*#ƫ3%0$ƫƫ/!0ƫ+"ƫ             were subjected to review in order to fit the
        recommendations for improvement.                 specific context. This was achieved with
        $!ƫ//!//)!*0ƫ)!0$+ +(+#5ƫ* ƫ'!5ƫ
                                                         17 Littrell and Dickson, 2010
        recommendations are described later in
        this report.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

    feedback from the workers through photo-
    elicitation and through the consultation
    of local experts, including professors from
    local universities, social workers, labor
    rights experts, nutritionists, doctors, and
    anthropologists. To ensure the highest level
    of accuracy with these assessments, ITC
    organizes bi-annual workshops with this
    group of experts to review and improve the
    existing tool.

    Collecting Information from Workers
    through Photo Elicitation                        Picture taken by a member of the Maasai community (Ngong Hill) as
                                                     part of the photo elicitation exercise.
    The photo elicitation method was employed
    as a valuable field research tool to introduce   They were explained the objective of the
    the informants’ criteria for self-assessing      photo elicitation exercise and were asked
    workers’ lives. Photographs of the workers,      to take pictures throughout the day, from
    produced by the workers themselves, were         the time when they woke up to when they
    used as stimuli in an interview, leading to a    3!*0ƫ0+ƫ/(!!,ċƫƫ"!3ƫ3!!'/ƫ(0!.Čƫ//!//+./ƫ
    deeper understanding of what was valuable        returned with the developed photographs,
    in their lives. This method is particularly      using them as stimuli to interview the same
    helpful when dealing with illiterate workers,    participants. Participants were asked to
    or when the participants’ life-experience        select the pictures depicting their typical
    is dramatically different from that of the       day, identifying the time of day, location,
    researcher. The goal of this exercise was to     people, and activities. This exercise resulted in
    incorporate the workers’ perspective when        measurable data, such as:
    defining the social indicators.                   đƫ 0$!ƫ)+1*0ƫ+"ƫ0%)!ƫ,!.ƫ 5ƫ3+.'!./ƫ
                                                         /,!* ƫ+*ƫ!$ƫ0/'ƫ* ƫ0%2%05Ď
    The photo elicitation method was first
    used amongst a small sample of workers            đƫ 0$!ƫ0$%*#/ƫ0$0ƫ.!ƫ)+/0ƫ %þ1(0ƫ0+ƫ
    (5 women), as an explorative approach to             )*#!ƫ 1.%*#ƫ0$!ƫ 5Ď
    illustrate:                                       đƫ 0$!ƫ)%*ƫ$+1/!$+( ƫ,.+(!)/ƫû!0%*#ƫ
      đƫ ƫ05,%(ƫ 5Ď                                  3+.'!./Ď
      đƫ $+3ƫ3+.'!./Ěƫ2%!3ƫ0$!%.ƫ(%2!/Čƫ3+.'ƫ* ƫ     đƫ 0$!ƫ,+/%0%2!ƫ* ƫ*!#0%2!ƫ%),0Ĩ/ĩƫ+"ƫ
         +))1*%05Ď                                       ƫ3+.'ƫ+*ƫ0$!%.ƫ(%2!/ƫ* ƫ3$0ƫ+1( ƫ
                                                         be improved.
      đƫ 0$!ƫ0$%*#/ƫ0$!5ƫ+*/% !.ƫ0+ƫ!ƫ%),+.0*0ĥ
         2(1(!Ď
                                                     To illustrate, the following table describes the
      đƫ $+3ƫ0$!ƫ3+.'ƫ0$!5ƫ +ƫ"+.ƫ ƫ%/ƫ           )%*ƫ %þ1(0%!/ƫ"! ƫ5ƫ0$!ƫ ƫ3+.'!./ƫ
         embedded in their daily routines.           as well as the indicators that best measure
                                                     livelihood improvement according to their
    Participants were provided with disposable       own judgment:
    cameras and were taught how to use them.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

    Table 3: Initial results of the photo elicitation exercise

    The results gathered during the photo                         đƫ ,/5$+(+#%(ƫ3!((ġ!%*#Ď
    elicitation were used to guide the first
                                                                  đƫ ,$5/%(ƫ3!((ġ!%*#Ď
    brainstorming workshop with the experts
    (September 2010), resulting in detailed                       đƫ /+%(ƫ3!((ġ!%*#ċ
    indicators and a questionnaire to conduct the
    SIA. The workshop recommended testing the                    Review of the Methodology
    methodology in the field.
                                                                 Results of the SIA among micro-producers
    Developing, Defining and Using the Impact                    was evaluated at a workshop in 2011. At
    Assessment Methodology                                       the time of the review workshop, ITC had
                                                                 developed a complementary tool to gather
    The SIA methodology was tested in 2011                       quantitative information on economic
    with a sample of ten community groups                        indicators. This tool, also known as a “Shocks
    varying according to size, gender and                        Matrix”, demonstrates the difference between
    age distribution, and other factors. The                     the participants’ income earned from the
    facilitation and interviews were conducted                   domestic market and income earned through
    by a local social worker with the necessary                  EFAL. In other words, it measures growth
    communication skills who could easily                        in economic well-being as a result of ITC’s
    gain trust within the communities. The                       intervention.
    questionnaire derived from the photo
    elicitation and workshop activities was used                 At the workshop, experts endorsed the,
    to guide interviews with illiterate participants,            Impact Assessment Tools (Questionnaire and
    and self-administered questionnaires                         Matrix), calling them effective and relevant.
    were given to literate participants. The                     They advised that the analysis be cognisant
    questionnaires were designed to measure the                  of the categories involved and of the value
    perceived impact of the ITC/EFAL program                     attached to skills, such as how much each
    on the communities. Key areas of focus                       skill generates in terms of wage, and to what
    included:                                                    extent the registered shock levels in rural
      đƫ   !)+#.,$%ƫ* ƫ+))1*%05ƫ%*"+.)0%+*Ď                 areas differ from urban areas. The experts
                                                                 also recommended that hours of work be
      đƫ !+*+)%ƫ(%2!(%$++ ƫ* ƫ)0!.%(ƫ3!((ġ                  factored into the matrix, and that progress be
         being;                                                  recorded and tabulated over a period of time.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

    Assessments and Data Analysis                            The Impact Assessment methodology allows
                                                             ITC to measure the factual economic and
    ITC/EFAL is currently conducting Impact
                                                             social impact on the beneficiaries of its
    Assessments in the various communities
                                                             program. This allows ITC to identify the areas
    where they place orders. They have
                                                             in which the impact is most significant, to
    developed a methodology for data analysis
                                                             communicate findings to different audiences,
    and use a well-known software (SPSS) to
                                                             and to guide the program’s social agenda. In
    produce statistical results. The first set of
                                                             order to ensure the case-specific needs of
    results helped ITC/EFAL to communicate
                                                             this ever-changing area of work are met, the
    more effectively with the customers about
                                                             Impact Assessment methodology is subject
    the impact of each order on the livelihoods
                                                             to continuous improvement to accommodate
    of the workers. Box 1 presents an overview of
                                                             the various issues uncovered which are
    preliminary data.
                                                             often related to the complexities of inclusive
                                                             business operations in developing countries.
      Box 1: Preliminary Data Analysis from the Impact
      Assessments                                            FLA’S BASELINE ASSESSMENT
      Over a fifth of those who work with the EFAL           METHODOLOGY AND KEY
      earn less than US$1 a day without orders from the      RECOMMENDATIONS
      Ethical Fashion Initiative. With orders from EFAL,
      workers can earn $4 - $7 per day. Casual laborers      In February 2012, FLA conducted an in-depth
      earn less than artisans.                               assessment of the ITC/EFAL program to
                                                             obtain baseline data on internal management
      There is no correlation between the level of
                                                             systems and labor conditions at both the Hub
      education and the income of the artisans; even
                                                             and community levels. The questions included
      with no formal education, an artisan who is highly
      skilled in his/her trade can earn as much as her/his   in the assessment are presented in Box 2.
      production capacity allows.
                                                             The methodology involved a review of 1)
      The women surveyed confirmed they had earned           the supply chain mapping tool; 2) social
      respect from their male counterparts, especially       impact assessment data; and 3) photo
      from their husbands, thanks to their ability to earn   elicitation results. Communities were
      a living and to take care of family needs as well as   selected for visits based on this analysis.
      restocking their animals.

      94% of the people interviewed confirmed that
      being involved with the program had increased
      their self-confidence; 94% of the total respondents
      said they had learned useful skills; 90% reported
      that earnings from the program enabled them
      to make improvements in their homes; 88%
      mentioned their ability to make independent
      financial decisions as the most important change
      in life, and 54% cited the ability to invest; 86%
      claimed that their diets improved, owing to
      workplace meals, and 84% cited access to fresh
      foods; 68% claimed the additional income allowed
      them to eat three times a day as opposed to once
      or twice a day.
                                                             EFAL’s workers and supervisors participating in participatory
                                                             workshops.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

                                                               Tools from the FLA’s Worker Integration
      Box 2: The assessment provided insight into how labor
      standards were integrated into the management systems.   Project (the PREPARE18 Dialogue Project)
      Key questions included:                                  were used to carry out participative
                                                               workshops. These focused on problem
        đƫ .!ƫ*5ƫ+*.!0!ƫ,.+#.)ƫ+&!0%2!/ƫ/!0ĕ
                                                               identification, prioritization, solution finding
        đƫ .!ƫ0$!ƫ,+(%%!/ƫ2%/%(!ƫ0$.+1#$+10ƫ0$!ƫ/1,,(5ƫ     and communication at the Hub. Additional
           $%*ĕƫ                                             focus group discussions, interviews with the
        đƫ .!ƫ%*0!.)! %.%!/Čƫ/1,!.2%/+./ƫ* ƫ)*#!./ƫ       management and workers, visual inspection
           0.%*! ƫ0+ƫ%),(!)!*0ƫ0$!ƫ,.+#.)ĕƫ                  and documentation review were carried
                                                               out to further inform the assessment. More
        đƫ +3ƫ.!ƫ,+(%%!/ƫ%),(!)!*0! Čƫ* ƫ*ƫ0$!5ƫ
                                                               than 20 workers (mostly supervisors) and
           $%!2!ƫ0$!ƫ+&!0%2!/ĕƫ
                                                               seven management staff participated in the
        đƫ $0ƫ'%* ƫ+"ƫ0.%*%*#ƫ* ƫ,.+!//!/ƫ.!ƫ/!0ƫ        assessment workshop at the Hub Level. In
           1,ƫ"+.ƫ%),(!)!*00%+*ĕ                              addition, six individual interviews and two
        đƫ $0ƫ)!*/ƫ* ƫ.!/+1.!/ƫ.!ƫ1/! ƫ"+.ƫ              focus group discussions were carried out
           implementation (training, responsibilities,         at the community level with approximately
           +*0.+(Čƫ!0ċĩĕ                                     15 community members. EFAL and FLA
        đƫ *ƫ+. !.ƫ0+ƫ//!//ƫ+*0.+(ƫ* ƫ.!,+.0%*#Čƫ.!ƫ
                                                               staff conducted a separate workshop for
           any indicators developed and do they align          management staff.
           3%0$ƫ0$!ƫ+&!0%2!/ĕ
                                                               The assessment provided information that
        đƫ $0ƫ$/ƫ!!*ƫ$%!2! ƫĨ.!/1(0/ƫ* ƫ'!5ƫ            was shared with ITC/EFAL in March 2012. FLA
           ,!."+.)*!ƫ%* %0+./ĩĕƫ+.ƫ!4),(!čƫ$!(0$ƫ       made a series of recommendations for ITC,
           and safety improvements, number of people           EFAL and at the community level:
           trained, social impact measurement.
                                                                    đƫ %),.+2!ƫ ƫ%*0!.*(ƫ/5/0!)/ƫ0+ƫ
        đƫ $0ƫ.!ƫ/0'!$+( !./Ěƫ2%!3/ƫ+*ƫ0$!ƫ,+(%5Čƫ                include a better definition of roles and
           %),(!)!*00%+*ƫ* ƫ01(ƫ+10+)!ĕ                          responsibilities; an efficient internal
                                                                       communication and decision-making
    These communities provided a variety of                            process; a grievance mechanism for the
    workplace arrangements, including self-help                        management staff (it is already working
    groups, micro-entrepreneurs, tribal artisans,                      well at the worker and supervisors level);
    and a slum-based community. FLA followed                           and a consultation mechanism to address
    its usual methodology in conducting the                            the communication issues that can occur
    assessment, which included interviews, visual                      between workers and management.
    inspection, and documentation review. In
    addition, the informal nature of the workplace
                                                               18
    and low number of workers provided an
    opportunity to use participatory rural
    appraisal techniques and assessment through
    participative workshops.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

      đƫ "+.)(%6!ƫ,.+)+0%+*ƫ,.+! 1.!/ƫ0ƫ             Based on the recommendations provided
         the Hub level to make the process for          by FLA, EFAL and ITC have developed an
         becoming a supervisor more transparent         internal action plan. Some of the salient
         (an objective process does exist but is not    features of the action plan are:
         well communicated and understood by             đƫ Ě/ƫ.+&!0ƫ *#!.ƫ$/ƫ !2!(+,! ƫƫ
         workers).                                          template that takes a practical approach
      đƫ 1%( ƫƫ/0.+*#ƫ%*0!.*(ƫ)+*%0+.%*#ƫ,(*ƫ           to the FLA Code of Conduct and is
         taking into account the differences and            specific to each group in EFAL’s supply
         particularities of each group involved in          chain. This template outlines each Code
         production and facilitate the prioritization       element for each artisan group, with
         of standards for individual communities.           relevant issues highlighted as they are
         Due to the informal nature and the lack            monitored. This document also serves to
         of employer-employee relationships in              record all steps the group has taken to
         some of the communities, it is obviously           address the FLA Code and also serves
         more fruitful to define the priorities             as a monitoring tool to outline any labor
         (with respect to code of conduct                   related issues that may arise on visits
         implementation) and the outcomes                   by ITC’s Project Manager or the Social
         together with the community. Therefore,            Worker and EFAL supervisors.
         a typical internal monitoring visit rather      đƫ $!ƫ2.%+1/ƫ#,/ƫ%*ƫ ƫ,+(%%!/ƫ$2!ƫ
         than looking like an audit should take             been addressed and there are ongoing
         the form of participatory assessment               participatory-approach workshops
         with issue and solution prioritization and         conducted on the ground in all areas of
         agreement.                                         management and labor-related issues.
      đƫ "+1/ƫ+*ƫ,%05ƫ1%( %*#ƫü./0ƫ"+.ƫ               The participatory approach is much
         most informal communities rather than              appreciated by those stakeholders of
         simply checking for compliance to labor            EFAL and records of each focus session
         standards.                                         are kept onsite at the Hub. This way, the
                                                            internal systems and monitoring of the
      đƫ ,.+2% !ƫ0.%*%*#ƫ0+ƫ%),.+2!ƫ-1(%05ƫ+"ƫ            activities of EFAL are known throughout
         work and productivity in order to enable           the workforce and there is increased
         those communities to move up the value             clarity regarding roles and responsibilities.
         chain.
                                                         đƫ *ƫ%*0!.*(ƫ)+*%0+.%*#ƫ/5/0!)ƫ%/ƫ%*ƫ,(!ƫ
      đƫ %),(!)!*0ƫ/%ƫ)*#!)!*0ƫ/5/0!)/ƫ%*ƫ             for each department and group and the
         the groups where there is an employer-             document template is being continuously
         employee relationship. For example,                improved. Capacity building of the
         teaching groups how to record, manage              groups and training on specific areas is
         and report on hours of work and wages.             also being done in a way that it is relevant
      đƫ +.#*%6!ƫ.!#1(.ƫ3+.'/$+,/ƫ0ƫ+0$ƫ0$!ƫ            to the groups as well as their levels of
         Hub and the community level and closely            understanding. Operations are guided by
         following up on the action plans that are          a Standard Operating Procedure (SOP)
         collectively developed.                            manual, which is also adopted specifically
                                                            for each group.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

    RECOMMENDATIONS AND                                 đƫ $!ƫ1/1(ƫ,,.+$ƫ0+ƫ%* !,!* !*0ƫ
                                                           external assessments need to be adapted
    GUIDELINES FOR FLA                                     to take a participatory approach at the
    INDEPENDENT EXTERNAL                                   community level. Most of the information
    ASSESSMENT                                             should be derived from interviews and
                                                           workers’ testimony, as documentation
    The activities carried out during these                is often lacking or entirely missing at
    first two years of the project have allowed            the community level. The Hub, however
    FLA to reflect on external assessments                 functions as a center for internal
    for the informal sector and to fine-tune its           management systems and can be subject
    new sustainable compliance methodology                 to FLA’s usual monitoring methodology.
    (SCI) and tools for artisan clusters. FLA is
    developing a version of its Independent             đƫ 0ƫ%/ƫ%),+.0*0ƫ0+ƫ%*0!#.0!ƫ!(!)!*0/ƫ+"ƫ
    External Assessment methodology for the                social impact assessment in the FLA’s
    informal sector, based on field visits and             independent external monitoring tools
    other activities conducted during this project.        and assessments. The internal impact
    Required adaptations to independent external           assessments conducted by EFAL should
    assessments for the informal sector are listed         form the baseline data and the FLA’s IEM
    below.                                                 process checks for progress made on the
                                                           social indicators along with the presence
      đƫ $!ƫ ƫ+.',(!ƫ+ !ƫ+"ƫ+* 10ƫ
                                                           of management systems and applicable
         Benchmarks cannot be applied in their
                                                           labor standards.
         entirety to the informal sector (especially
         where there is no employer-employee            đƫ %*((5Čƫ0$!ƫ.!,+.0%*#ƫ+"ƫ0$!ƫ!*0%.!ƫ
         relationship). The benchmarks need to             process has to be balanced with the
         be adapted to fit the particular context          inclusion of activities conducted, status
         of artisan clusters. The FLA COC and              of the program, social impact on the
         benchmarks are applicable to the Hub.             communities, labor issues identify, lessons
                                                           learnt and next steps. The report should
      đƫ %2!*ƫ0$!ƫ2.%! ƫ*01.!ƫ+"ƫ0$!ƫ+))1*%05ƫ
                                                           not be limited to listing noncompliances
         groups present, the FLA Code and
                                                           against the FLA Workplace Code and
         Benchmarks need to be interpreted in
                                                           Benchmarks.
         a way that captures the essence of the
         FLA Code and ensures protection for
         workers and do not necessarily measure        FLA’S ASSESSMENT APPROACH
         the compliance status of the communities      Two levels of assessment have to be
         against the well-defined benchmarks.          differentiated in the case of ITC-EFAL Ethical
      đƫ 0ƫ)5ƫ*+0ƫ(35/ƫ!ƫ,+//%(!ƫ0+ƫ)'!ƫ         Fashion Initiative: 1) the Hub level; and 2) the
         unannounced visits to the communities,        community level.
         especially in the case of tribal groups who
                                                       At the Hub level, the external assessment
         move frequently and often squat in the
                                                       methodology can incorporate some key
         wilderness without any address. In such
                                                       features of the new FLA Sustainable
         cases, visits may have to be announced
                                                       Compliance (SCI) methodology , keeping
         in advance and someone from EFAL must
         accompany the verifiers.

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FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

    in mind the specificities of informal supply     Onsite Assessment
    chains. The sustainable compliance approach
    places emphasis on identifying root causes of    Since most of the policies and procedures
    noncompliance so that sustainable solutions      should have been reviewed prior to
    can be developed and implemented. External       arriving at the workplace, the onsite work
    assessments consist of a number of activities    of the assessment team should focus
    conducted prior to the workplace visit (pre-     on investigating the high-risk areas and
    onsite assessment); during the visit (onsite     testing the implementation of policies and
    assessment); and after the visit (post onsite    procedures. The onsite assessment evaluates
    assessment).                                     different management functions through four
                                                     sources of information (management and
    Pre-Onsite Assessment                            worker interviews, observation, and records
                                                     review). The management areas assessed
    1.   Desktop Research: The external
                                                     include:
         assessment approach begins with desk
                                                      đƫ *0!.*(ƫ)*#!)!*0ƫ/5/0!)/Ď
         research on the national and local labor
         market, the informal sector and the          đƫ +(%%!/ƫ* ƫ,.+! 1.!/ƫĨ0$+/!ƫ3$%$ƫ
         company or supplier (if information is          have not been received in advance);
         available).
                                                      đƫ %/%%(%05ƫ+"ƫ0$+/!ƫ,+(%%!/ƫ* ƫ,.+! 1.!/Ď
    2. Policies and Procedures Review: The            đƫ +))1*%0%+*ƫ0+ƫ0$!ƫ3+.'"+.!Ď
       assessment is better prepared and
       informed when the assessment team can          đƫ .%*%*#Ď
       review the main policies and procedures        đƫ ),(!)!*00%+*Ď
       prior to the onsite visit. This allows the
       team to save time while on site and            đƫ *0!.*(ƫ+*0.+(/Ď
       focus on evaluating implementation             đƫ !,+.0%*#ċ
       and developing an understanding of the
       processes.                                    Post-Onsite Assessment

    3. Task and Risk Mapping: In addition to         After the onsite assessment, the assessment
       the task and risk mapping studies that        team will carry out root cause analysis
       FLA may have conducted for a particular       and reporting. The assessment findings
       workplace, the assessment team should         are not considered as isolated events but
       list all the functions involved in the        rather the results of systemic failure within
       production process and assess the risks       a management function. Findings are
       involved in each activity. The risks should   symptoms of underlying problems, which
       then be prioritized and determine the         can only be corrected, or their recurrence
       assessment’s planning.                        prevented, if root causes are addressed.
                                                     The assessment team will compile the
    4. Impact Assessment Review: The impact
                                                     findings in an assessment report that will
       assessments conducted by EFAL can
                                                     be communicated to the assessed company
       form a strong base to define the external
                                                     or organization for review and action plan
       assessment methodology. Review of the
                                                     building.
       SHOCK and SIA reports are a crucial part
       of the pre-onsite assessment.

www.fairlabor.org                                                                                       20
FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

    ASSESSMENT AT THE COMMUNITY LEVEL                  fully understood and accepted. For
                                                       example, the essence of each code of
    The assessment process cannot be as formal
                                                       conduct element should be taken out
    at the community/artisan clusters level as it
                                                       of the standard format and translated
    is for the management and production center
                                                       in a way that means something for the
    (Hub) level. Some recommendations and
                                                       community. The same approach should
    guidelines have been drawn for the external
                                                       be applied to external assessment where
    assessment of the communities or artisan
                                                       the assessment team will adapt the
    clusters:
                                                       assessment focus and methodology to
      đƫ ƫ %/0%*0%+*ƫ/$+1( ƫ!ƫ) !ƫ!03!!*ƫ         the specific context.
         the community groups in which there
         is an employer-employee relationship        đƫ  Ě/ƫ/+%(ƫ.!/,+*/%%(%05ƫ,.+#.)ƫ"+.ƫ
         and those without such a relationship          the most informal communities will focus
         (self-help groups and very informal            on capacity building as opposed to labor
         communities). In the Maasai community,         standards monitoring. EFAL will regularly
         for example, the female members do             organize participative workshops to help
         beading on products for EFAL. There            them to understand the perceptions of
         are no formal policies and procedures          workers in each community and define
         in place. Work is done outside their huts      capacity building activities to address
         in between doing household chores.             workers’ needs. For this reason, FLA
         Most of the people are illiterate with no      external assessments in these regions will
         documentation within the community. In         focus more on measuring progress made
         such groups, it is therefore recognized        through capacity building activities than
         that having policy documentation or            traditional “compliance auditing.”
         a written workplace code of conduct         đƫ *ƫ!$ƫ+))1*%05Čƫ0$!ƫ//!//)!*0ƫ0!)ƫ
         is irrelevant. For those very informal         should at a minimum check that the
         communities, assessments should instead        fundamental labor standards – such as
         focus on checking the effectiveness            child labor, forced labor or serious health
         of awareness-building programs. In             and safety issues – are being upheld.
         communities where there is an employer-
                                                     đƫ *ƫ %0%+*Čƫ'!5ƫ-1!/0%+*/ƫ* ƫ%* %0+./ƫ
         employer relationship, however,
                                                        from the Social Impact Assessments
         assessments can focus on internal
                                                        should be identified and integrated
         management systems (basic systems for
                                                        into the tools while conducting the
         recording attendance, hours of work and
                                                        assessments at the community level.
         wages), policies, procedures and their
         implementation.                             đƫ .0%%,0+.5ƫ,,.+$ƫ0+ƫ//!//)!*0ƫ3%((ƫ
                                                        form the basis of assessments carried out
      đƫ *!ƫ/%6!ƫ +!/ƫ*+0ƫü0ƫ((ċƫ+.',(!ƫ
                                                        at the community level.
         rules and fair labor principles need to
         be defined in a way that makes them
         applicable to individual situations and
         communicated to community members
         (workers) through means that are

www.fairlabor.org                                                                                     21
FLA - ITC EThICAL FAshIon AFrICA ProjECT UPdATE

     CONCLUSION
    FLA’s collaboration with ITC and EFAL has
    been a valuable learning experience and
    has led to the development of an effective
    methodology and tools for assessments in the
    informal sector. As indicated by the Impact
    Assessment results, the ITC Ethical Fashion
    Initiative is already making improvements in
    the lives of individual workers and is reducing
    poverty in the community by providing
    workers with opportunities to earn higher
    incomes while imparting new competences
    and skills, and building self-esteem. ITC and
    EFAL are committed to making improvements
    for workers and take ownership for reaching
    a higher level of social responsibility by
    implementing FLA labor standards with
    rigor. The expansion of ITC’s Ethical Fashion
    Initiative to other parts of the world is an
    encouraging signal of its intention to continue
    to collaborate with FLA and will allow for
    even greater impact.

    FLA’s experience during this special project
    with ITC’s Ethical Fashion Initiative has led to
    the creation of an umbrella project within FLA
    called FAIR-ART (Artisans for Responsible
    Trade)20. FAIR-ART is dedicated to tackling
    labor issues in the informal sector, and the
    tools developed during this special project
    can be applied to other parts of the world
    and utilized by other FLA affiliates who
    conduct business in informal settings.

    20 To know more about the FLA’s FAIR-ART project, please contact
    FLA staff or visit www.fairlabor.org

www.fairlabor.org                                                      22
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