Fair Labor Association Response to the OECD Alignment Assessment 

The Fair Labor Association (FLA) welcomes the publication of the OECD’s Alignment Assessment of the written policies and standards related to Fair Labor Accreditation for manufacturing. We appreciate the OECD Secretariat’s rigorous assessment process and the constructive engagement that took place throughout the review, and we value such opportunities to benchmark our standards against internationally recognized frameworks. 

For more than 25 years, FLA has supported the advancement of effective human rights due diligence through the implementation of our standards in our member companies’ supply chains and our Fair Labor Accreditation program.  

Fair Labor Accreditation is a rigorous, multi-year process that evaluates companies’ systems to protect workers throughout global supply chains. Accreditation looks beyond simply a company’s adherence to written standards and encompasses a broad range of implementation activities—including grievance mechanisms, responsible purchasing practices, and stakeholder engagement—that drive continuous improvements at both the headquarters and factory levels. These implementation elements remain central to FLA’s approach to prevent abuses, ensure sustainable compliance, and remediate violations of FLA’s internationally respected standards. 

The OECD’s assessment found that the standards for Fair Labor Accreditation for manufacturing address all six steps of the OECD due diligence framework and identified significant strengths in our approach to strengthening labor rights in global supply chains.  

In particular, the assessment recognized the comprehensiveness of our requirements related to the following: 

• Management systems: Fair Labor Accreditation has comprehensive requirements for its member companies’ due diligence management systems, with clear assignment of responsibilities.  
• Senior-level accountability: FLA member companies’ senior leadership is expected to formally commit to workplace standards and assign responsibility, supported by defined organizational roles and accountability mechanisms.  
• Responsible purchasing practices: Fair Labor Accreditation has comprehensive requirements for its member companies to consider the impacts of purchasing and production practices. 
• Worker engagement: Fair Labor Accreditation requires engagement with workers and their representatives during the in-depth accreditation assessments.  
• Root cause analysis: Fair Labor Accreditation places a strong emphasis on root cause analysis and continuous improvement to support longer-term prevention and mitigation of risks and impacts. 
• Corrective action processes: Fair Labor Accreditation requires its member companies to verify corrective actions of manufacturers through audits and corrective action follow-up processes.  
• Continuous improvement: The Fair Labor Accreditation model emphasizes continuous improvement, with an expectation that FLA’s member companies seek to understand why certain impacts have not yet been prevented and to respond appropriately.  

The assessment also noted that the Fair Labor Accreditation pathway promotes the progressive strengthening of company systems and that our model supports due diligence uptake among both brands and manufacturers. 

At the same time, we recognize the opportunities for closer alignment identified by the OECD. These include strengthening requirements related to risk-based prioritization, stakeholder engagement, public communication, remediation, collaboration, and the documentation of due diligence processes. We also note the OECD’s recommendation to further clarify terminology and strengthen consistency across standards and supporting guidance.  

We will carefully review the findings and recommendations and consider them as part of our ongoing efforts to strengthen our standards, guidance, and accreditation framework. We are currently engaged in the regular, periodic process of updating our Principles, and the feedback from OECD’s assessment will be taken into account as the updates are developed. 

As responsible business conduct expectations continue to evolve, we remain committed to ensuring that our system reflects emerging good practice and supports companies in identifying, preventing, mitigating, and addressing adverse impacts on workers.  

We thank the OECD for its leadership in promoting convergence around responsible business conduct standards and for providing initiatives with a valuable framework for continuous improvement.