INTERNATIONAL BUSINESS PAGES
sector including child labour, forced
labour, sexual harassment, engage-
ment with trade unions, wages, occu-
pational health and safety, hazardous
chemicals, water, greenhouse gas
emissions, bribery and corruption and
responsible sourcing from homework-
ers. The OECD Garment Guidance like-
wise incorporates a gender lens to ap-
plying due diligence. Throughout the
due diligence process, the OECD Gar-
ment Guidance supports due diligence
that is preventative, integrated into
decision making processes, risk-
based, dynamic, informed by meaning-
ful engagement with stakeholders, is
appropriate to the circumstances of the
company and involves ongoing com-
munication.
Industry-led and multi-stakeholder ini-
tiatives that incorporate due diligence
expectations can represent a strong
inducement for companies to carry out
due diligence and provide valuable
opportunities for shared learning. How-
ever, a proliferation of expectations at
a domestic level or across initiatives
can create challenges for businesses
operating globally who may be subject
to various expectations. The OECD
Garment Guidance is the negotiated
and government-backed benchmark for
due diligence by industry, multi-stake-
holder and government backed initia-
tives. To help support a common un-
derstanding of due diligence while also
enabling cross-recognition between
programmes, the OECD has launched
a pilot process to assess the alignment
of multi-stakeholder and industry initi-
atives with the OECD Garment Guid-
ance. This process, called the OECD
Alignment Assessment process, is
voluntary and was first piloted with the
Sustainable Apparel Coalition (SAC) in
2018.
The SAC’s Higg Brand & Retail Mod-
ule (Higg BRM) is a self-assessment
tool that seeks to assess the environ-
mental and social performance of SAC
brand and retail members. This report
sets out the findings of the OECD’s
evaluation of the Higg BRM (beta ver-
sion) and corresponding guidance. It
is important to note that due diligencePolicy recommendations under the OECD Gar-
ment Guidance
The enterprise’s policy on responsible business conduct:
a. Should include commitments regarding the company’s own activities and
should articulate the company’s expectations of its business partners –
including suppliers, licensees and intermediaries – across the full length
of its supply chain.
b. Should cover matters covered by the OECD Guidelines. The enterprise’s
RBC policy should also commit to upholding international standards on
sector risks and sub-sector risks, relevant to the enterprise and make
explicit reference to relevant international standards.
c. Should include commitments to conduct due diligence on the enterprise’s
most significant risks in its own operations and in its supply chain.
d. Should include a commitment to responsible sourcing practices, mean-
ing that the enterprise commits to seeking to prevent its contribution to
harmful impacts through its sourcing practices. This recommendation is
only relevant for retailers, brands and other buyers.
e. Should stipulate the enterprise’s expectations regarding the use of sub-
contractors by direct suppliers, when relevant, including a definition of
“subcontract” and distinctions in subcontracted work if they exist.
f. Should put forth the enterprise’s expectations regarding the outsourcing
to homeworkers and the use of handwork, where relevant to the enter-
prise’s business models.
g. Should include a commitment to meaningful engagement with affected
stakeholders through the course of due diligence.
h. Is encouraged to include a commitment to hear and address all com-
plaints against the enterprise regarding their own operations regardless
of how they are raised; and include a commitment to hear and address
measured and substantiated complaints that the enterprise has caused
or contributed to harms in its supply chain that are raised through legiti-
mate processes.
The garment and footwear sector has been criticised in the past for having a
strong emphasis on policy or codes of conduct without sufficient action to
implement those policies; however, not explicitly requiring policies overlooks
the foundational role that policies play in setting a company’s priorities and
direction. Evidence in the garment and footwear sector likewise demonstrates
that while there has been great emphasis on policy development, policies
still insufficiently address important issues in the sector, such as subcon-
tracting and purchasing practices. Explicitly stating that a company’s ap-
proach or strategy to manage its key social or environmental risks should
first include the necessary direction from the top in the form of clear policy
commitments is one way to bring the Higg BRM into alignment. The Higg
BRM should likewise focus on the content and development of those poli-
cies including elements a-h from the OECD Garment Guidance included as
described above.
is not a linear process, but rather interactive and reactive.
About the Sustainable Apparel Coalition (SAC) and the Higg Brand & Re-
tail Module
The SAC is a membership-based organisation with the vision “of an apparel,
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