For questions relating to SLCP & human rights due diligence, please contact Tom Mason, Senior Policy and Stakeholder Engagement Manager, at tom@slconvergence.org.
Is the CAF a useful tool for undertaking human rights due diligence?
The Converged Assessment Framework provides a comprehensive set of high-quality, credible social and labor data and is a strong foundation for brands and other stakeholders to take a data-driven approach to identifying non-compliances and risks at facilities within their supply chain.
While developing the CAF, SLCP closely coordinated with the OECD, who were part of the initial SLCP Steering Committee. By aligning with the OECD Due Diligence Guidance for Responsible Supply Chains in the Garments & Footwear sector, SLCP designed the CAF so that it could be used as a solution for companies looking to fulfil their due diligence obligations. This is also the intention for emerging due diligence efforts including the EU, France, Japan, Germany and elsewhere. The CAF also enables users to make a compliance determination against International Labor Standards and National Labor Laws.
In the 6-step OECD due diligence framework, the CAF tool is particularly useful for Step 2 (identifying risks) and Step 4 (monitoring and tracking progress on risk prevention and mitigation).
The CAF should be used as one of a number of accompanying measures or industry tools for supporting due diligence compliance. The CAF is a broad social assessment, which provides comprehensive and credible data to provide a robust risk assessment on social & labor conditions across supply chains. It is not an investigative tool, so companies should use additional tools for deeper analysis into topics that require specific expertise.
Is the CAF aligned with the EU Corporate Sustainability Due Diligence Directive (CSDDD)?
The proposed EU Corporate Sustainability Due Diligence Directive is in draft phase, meaning it is currently being revised. The final text is yet to be released, though this will likely occur at some stage in the first half of 2023.
The CAF includes a broad range of social and labor topics in Step 1 of the tool. These topics will need to be addressed when undertaking human rights due diligence for the purposes of compliance with the EU legislation. As outlined in the Annex of the draft EU CSDDD text, there are a number of human rights that companies will need to identify, prevent, mitigate and monitor.
The CAF framework was developed using the risks outlined in the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment & Footwear sector. The EU are yet to provide (sectorial) guidance for the textile industry, so it is not certain what this will entail, but SLCP has advocated for practical guidance to accompany the final text.
SLCP has started developing a Human Rights Due Diligence Toolkit for users to understand the specific applicability of the CAF for due diligence compliance. This will build on the existing SLCP positioning against human rights due diligence. This will be released by May 2023. For more information, contact SLCP’s policy coordinator (Tom Mason, tom@slconvergence.org).