The FLA 3.0 process is best described in comparison with the traditional, audit-based process. In the audit-based process of traditional monitoring, predetermined labor standards and compliance benchmarks define ideal labor standards for workplace conditions and monitoring is based on the assumption that these conditions currently exist in the factory. The audit is then performed to prove or disprove the existence of these conditions in a factory. Non-compliances identified through the audit are handled through remediation, which may be verified through a verification audit. This is a simplified explanation of the process, but points to the problem, namely the assumption that the preset labor conditions reflect the actual working conditions in the factory. This is very rarely the case, which leads to the audit being perceived as a negative experience, one of highlighting a laundry list of problems in workplace conditions as they currently exist. The audit-based process is customer (brand) driven; the factory submits to having the audits performed but does not have any active involvement in the process.
FLA 3.0: A Fundamental Shift in Perspective
A cornerstone of FLA 3.0 is a change in the traditional mindset described above to one of recognition that compliance with labor standards is not yet the reality in most factories – the factory needs to become involved in a process of which compliance will be the end result. The traditional audit involves checking for compliance against each element of a code of conduct and often leads to a long list of issues that the factory will be required to resolve in a short period of time. This inevitably leads to factories looking for quick-fix solutions that are rarely sustainable.
FLA 3.0 is grounded in the belief that requiring compliance simultaneously with an entire code of conduct is not a realistic approach. The FLA contends that in order for compliance to be effective, we must identify the root causes of that non-compliance and address them individually. The FLA 3.0 approach addresses problems one at a time in the form of priority issues. The FLA also believes that in order for labor compliance to be sustainable, the factory needs to take ownership of the process instead of having the process externally imposed on them from the buyer. In the FLA 3.0 model, the factory is an active participant in the process, and only factories that demonstrate a desire to improve conditions for their workers and a readiness to be transparent are invited to participate in the program.
Once a priority issue is agreed upon, assessments are performed to determine the baseline level for compliance as it relates to the priority issue. Both the management and worker perspectives are measured to arrive at the baseline level; the factory management completes a web-based self-assessment on where they think the factory lies with respect to compliance in the priority issue, and in parallel, a representative sample of the factory’s workforce is surveyed on the same questions. This dual assessment provides a 360º view of the situation – what the management believes or knows to be true and what the workers’ perceptions are on the same issue. The baseline results are generated on a scale of 1-5 instead of the traditional yes/no black and white results where partial compliance cannot be captured and results in a ‘not in compliance’ finding.
When FLA 3.0 factories receive results from the management and worker assessments and the baseline has been established, they collaborate with their buyers (FLA-affiliated companies) to undertake a root cause analysis of the areas of weakness highlighted through the assessments and to develop a capacity building plan that addresses the issues identified. It is likely that training will be needed on certain issues and the FLA not only develops training materials and courses on those issues but also trains regional organizations to serve as trainers in the local language. The arduous work of capacity building occurs over an extended period of time (usually up to one year) during which period factories record their progress using key performance indicators developed by the FLA.
The impact of capacity building efforts is assessed through an independent external assessment which evaluates the current situation against the one determined in the baseline assessment. In this way, improvement over time in measured. This feature of the FLA 3.0 process is truly a revolutionary one – we are not only able to determine baseline findings on a scale, but also measure improvement in those results over an extended period of time. FLA 3.0 provides factories with a tool to show effort and improvement in the form of easily understandable, concrete, and tangible results. This creates an incentive for factories to be honest at the outset, since they know that progress will be measured incrementally and reported on over time. This creates a positive experience for both the factory and the company as opposed to the negative experience in the traditional model. The final step for the FLA in the FLA 3.0 process is public reporting of these results on an aggregate level.
