How to Communicate on Corporate Responsibility in the … · 2015-06-24 · How to Communicate on Corporate Responsibility in the Supply Chain: ... situation, let alone communicate

How to Communicate on Corporate Responsibility in the Supply Chain

A Step-by-Step Approach

December 2014

BSCI Participant Manual

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TABLE OF CONTENTSINTRODUCTION 4

STep 1. DeCIDING WHeTHeR OR NOT TO COMMUNICATe ON CSR .................................................................................... 5

1.1 Why some companies are reluctant to communicate on CSR ............................................................... 5 - They do not have a CSR programme in place ...................................................................................................5 - They believe CSR communication can increase exposure to reputation issues ..........................................5 - To communicate is to commit: There is no turning back ................................................................................5 - CSR communication will distract customers from your company’s core marketing message .................61.2 More and more countries are making CSR reporting compulsory ......................................................... 61.3 Organisations that do not communicate are the exception today ........................................................ 7 - CSR reporting is becoming the norm worldwide ..............................................................................................7 - Scope and content: SMEs excepted ..................................................................................................................71.4 Lack of communication is now a priority target for NGOs ..................................................................... 8 - Have you got something to hide? .....................................................................................................................8 - A target for campaigners ....................................................................................................................................81.5 Loss of control over what is said about you or in your name ................................................................ 91.6 CSR crisis: Difficult to manage when the organisation has never communicated before .................... 9

STep 2. WHAT yOU NeeD TO kNOW befORe yOU beGIN ............................................................................................... 10

2.1 Accountability is the cornerstone of any CSR programme .................................................................. 10 - Accountability requires transparency ............................................................................................................10 - Expectations are high .......................................................................................................................................10 - Make your CSR programme work for you .......................................................................................................102.2 The main risk is what NGOs call “greenwashing” ................................................................................ 11 - Definition of greenwashing ..............................................................................................................................11 - Greenwashing is one of the business practices most targeted by NGOs ...................................................13 - Greenwashing is increasingly the object of national regulation or legislation ..........................................132.3 benefits of a comprehensive communication strategy ...................................................................... 142.4 To communicate on CSR is to commit: There is no turning back .......................................................... 142.5 One step at a time. Responsibility in the supply chain is not the easiest topic to start with! ........... 15

STep 3. DO yOUR HOMeWORk: MARkeT INTeLLIGeNCe ............................................................................................... 16

3.1 be aware of existing regulations and norms ....................................................................................... 173.2 Understand CSR challenges in your industry ...................................................................................... 183.3 know what your competitors are doing and how they communicate ................................................. 183.4 figure out stakeholders’ expectations and market trends ................................................................. 19 - If you are a B2C company ................................................................................................................................19 - If you are a B2B company ................................................................................................................................20

STep 4. be AWARe Of THe SpeCIfIC CONTexT fOR yOUR COMpANy: bUSINeSS INTeLLIGeNCe ....................................21

4.1 Why assess your company’s specific context? ...................................................................................214.2 How to assess your company ...............................................................................................................21 - Evaluate how visible your organisation is on CSR issues ............................................................................. 21 - Identify your customers’ and partners’ expectations .................................................................................. 22 - Assess your company’s CSR maturity ........................................................................................................... 224.3 Define objectives in line with your company’s maturity and CSR strategy ........................................ 25 - If you are a beginner .........................................................................................................................................25 - If you are already engaged ...............................................................................................................................25 - If your company is committed .........................................................................................................................25 - If your company is a CSR leader.......................................................................................................................26

STep 5. bUILD A COMMUNICATION pLAN fOR A pROGReSSIve AppROACH ................................................................... 27

5.1 Why should you develop a communication plan? ............................................................................... 27 - What is a communication plan? ......................................................................................................................27 - Further reasons for developing a communication plan ................................................................................275.2 What you should define in your communication plan ......................................................................... 28 - Identify your purpose .......................................................................................................................................28

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- Identify your audience. .....................................................................................................................................28 - The message ......................................................................................................................................................29 - Channels of communication ............................................................................................................................295.3 Crisis management: preparation is key ............................................................................................... 30 - What constitutes a crisis? .............................................................................................................................. 30 - Be prepared ........................................................................................................................................................315.4 What to do when a crisis occurs ........................................................................................................... 33

STep 6. GeT STARTeD! .................................................................................................................................................. 35

6.1 “basic” regulatory reporting first ........................................................................................................ 35 - Comply with or anticipate future regulations ................................................................................................35 - Develop your reporting .....................................................................................................................................35 - Engage teams ....................................................................................................................................................366.2 Internal communication as a prerequisite to any CSR external communication ................................ 37 - Targeted audiences ...........................................................................................................................................37 - Aims and objectives ..........................................................................................................................................38 - Tools ....................................................................................................................................................................386.3 external communication: keep it simple and show humility .............................................................. 38 - Top goals to achieve with your first communication ....................................................................................38 - Key content and messages..............................................................................................................................39 - Corporate communication first ....................................................................................................................... 40

STep 7. keep Up THe MOMeNTUM... AND GROW TO MeeT WIDeR INDUSTRy AND ReGIONAL STANDARDS ..................... 41

7.1 Why go beyond basic CSR communication on the supply chain? ....................................................... 417.2 prerequisites ........................................................................................................................................ 417.3 Grow existing practices first and then go further ................................................................................ 42 - Internal communication .................................................................................................................................. 42 - CSR reporting .................................................................................................................................................... 42 - Corporate and marketing communication ......................................................................................................43

STep 8. beCOMe A STAR ................................................................................................................................................51

8.1 What you need to reach for the stars ....................................................................................................518.2 CSR leadership comes with strong benefits..........................................................................................518.3 More than one way to shine: Noteworthy communication campaigns ............................................... 52 - M&S: The accountability leader ........................................................................................................................52 - Patagonia: The alternative consumption champion ......................................................................................53 - H&M and Nike: Full transparency as a licence to operate enabler ..............................................................54 - Marshalls: The CSR Don Quixote .......................................................................................................................55 - Switcher: The ethical company ....................................................................................................................... 56 - Puma: Messages of innovation and operational excellence ........................................................................57

SpOTLIGHT: pRACTICAL CASe STUDIeS

SpOTLIGHT 1: france, a pioneer in effective Mandatory Regulation ............................................................6SpOTLIGHT 2: Major voluntary comprehensive standards on CSR Reporting ..............................................8SpOTLIGHT 3: Transparency and Accountability ......................................................................................... 10SpOTLIGHT 4: The Seven Sins of Greenwashing .........................................................................................11SpOTLIGHT 5: Companies pilloried in europe for Greenwashing ................................................................ 13SpOTLIGHT 6: Latest eU Regulations on extra financial Reporting ........................................................... 17SpOTLIGHT 7: ethical Consumerism, key Trends Across europe ................................................................ 19SpOTLIGHT 8: 10 Tips on being prepared if a Crisis Arises .........................................................................32SpOTLIGHT 9: 6 elements of effective Crisis Management ........................................................................34SpOTLIGHT 10: Should you Report on Audit Results? .................................................................................36SpOTLIGHT 11: Managing the Information flow Throughout the Supply Chain ..........................................37SpOTLIGHT 12: Main benefits Associated with external Communication on bSCI .....................................39SpOTLIGHT 13: Supply Chain Related Standards Disclosures in GRI (G4) .................................................44SpOTLIGHT 14: bSCI participation Should Not be Mentioned on products .................................................46

4 How to Communicate on Corporate Responsibility in the Supply Chain: A Step-by-Step Approach

INTRODUCTION • Should I or should I not communicate about my company’s CSR programme?

• If I do communicate, how much should I say?

• To whom should I be speaking?

Depending on your company’s size, its visibility, the industry it belongs to, the notoriety of its brands and where it stands in the supply chain between producers /manufacturer and consumer, the answers to these questions can be very different.

For many businesses, particularly those which have only recently become engaged in a CSR programme, or whose CSR activities are relatively basic, the issues these questions raise are awkward and sensitive. Unless you are an experienced CSR professional, they may not even be perceived as pertaining to core business, and the concerns and stakes which they deal with might be unfamiliar.

Yet increasingly CSR is becoming embedded in all business activities and stakeholders expect you to state where you stand – and how you are dealing with many other far more complex issues.

One issue that is particularly topical today is the tendency for brands to celebrate shorter supply chains and local or nearby production and sourcing. By implication, companies can be led to believe that purchasing from distant and emerging markets is not something to communicate on. Such an inference is flawed. It is not only possible but actually desirable to demonstrate your company’s involvement in global supply chains, and in the drive to uphold human rights and improve working conditions worldwide.

This manual has been designed to help you address these questions.

In a convenient step-by-step format, you can use the manual to:

• Assess where your company is positioned in terms of CSR maturity

• Understand how to use your company’s positioning to determine your communication policy

• Build an appropriate communication strategy

• Be prepared with the right level and type of response to critical situations

By participating in BSCI, your company has put a stake in the ground. It has taken the position that it is committed to upholding social standards and improving working conditions in the supply chain. This manual will help you communicate this stance internally and externally, and inform your stakeholders with confidence about where your company stands and what its aspirations are.

December 2014

5How to Communicate on Corporate Responsibility in the Supply Chain: A Step-by-Step Approach

STEP 1: Deciding Whether or Not to Communicate on CSR Should you, shouldn’t you? Many companies are reluctant to take the floor on CSR, but the pressure to speak up is growing, and the decision to remain silent is itself a statement.

1.1 WHy SOmE COmPANIES ARE RELUCTANT TO COmmUNICATE ON CSR

Why are some companies reluctant to communicate on CSR? Smaller businesses in particular tend to shy away from being heard, either on the issues or on their own involvement, however straightforward it may be. Many business managers and owners are ignorant of the subject. Others, who neither disparage the concept nor condemn it, simply believe that it is not a core priority for them or their companies. For many, the idea of communicating on CSR simply does not occur to them, considering themselves to be non-specialists and/or not large or involved enough for it to matter. To this may be added the fact that as non-specialists some businesses may simply be reluctant to draw attention to something that they do not feel they master.

The truth is, of course, that all companies, large and small, are to some degree connected to the world’s web of supply chains, more or less directly or indirectly. However, it is not always a simple matter to identify and understand both the expectations of communication from stakeholders (including customers) and the benefits a CSR communication policy can bring, as well as the inevitable risks.

1.1.1 THEy DO NOT HAvE A CSR PROgRAmmE IN PLACE

Even companies without a formally structured CSR programme in operation are implicated to some degree in a value chain of CSR. Their suppliers and/or customers may have an active programme. Their employees have expectations, which the companies are meeting more or less, and outside stakeholders will accordingly have a view on their internal policies.

As such these companies are vulnerable in the sense that they are not organised to understand their own situation, let alone communicate on it. They would be better off, at the very least, identifying where they stand, and understanding what the expectations of their stakeholders are. From there it is but a small step to formalise the current situation and then later to build on it. What gets measured gets managed – and, by extension, what gets communicated gets measured.

1.1.2 THEy BELIEvE CSR COmmUNICATION CAN INCREASE ExPOSURE TO REPUTATION ISSUES

As non-specialists in CSR, many managers and business owners feel uncomfortable about communicating on the subject. They are concerned that they will be drawing attention to themselves, and to an aspect of their business that they do not perceive to be a core priority, and that they are unsure whether they are mastering correctly.

It is possible in such a situation to be excessively cautious. In the worst case scenario this kind of attitude is akin to hiding one’s head in the sand. The rest of the body remains highly and embarrassingly visible to the outside.

1.1.3 TO COmmUNICATE IS TO COmmIT: THERE IS NO TURNINg BACk

Once you have started communicating, you have no choice but to move forward. It is more difficult, perhaps even impossible, to step back. In other words, producing the first item of communication on CSR is effectively drawing a line in the sand and will be the yardstick against which all future actions, revelations and communications will be measured.


1.1.4 CSR COmmUNICATION WILL DISTRACT CUSTOmERS FROm yOUR COmPANy’S CORE mARkETINg mESSAgE

Without in the least making a critical appraisal of CSR, for some companies it remains outside of the company’s real reason for existence. To communicate on it, some managers feel, is to dilute the marketing message with a spotlight on topics that are not germane to the customer’s view of the company.

1.2 mORE AND mORE COUNTRIES ARE mAkINg CSR REPORTINg COmPULSORy

For a business to be fully responsible for its actions, it must be accountable. Accountability depends on reliable information, so reporting is a critical element of any corporate responsibility programme. There is not yet a real consensus on whether reporting should be mandatory or voluntary. Arguments for and against principally revolve around the dangers of adopting a “one-size-fits-all” approach versus the risks in not providing a level playing field for all organisations. Historically, perhaps in the face of a lack of clear mandatory legislation, the emphasis has been on voluntary standards. Clearly, however, the trend today is towards a growing body of laws, from national to global level, with more or less precise expectations.

These national and international laws have emerged partly as a response to the bewildering confusion of available standards, in an attempt to bring clarity and some measure of harmonisation to a complex subject. Some countries have resolved to stay close to laissez-faire, like in the UK, which limits its mandatory requirements to carbon disclosure, human rights and gender equality. Others have built on a long legacy of state centralisation to define in comparatively precise terms what must be reported on and how. France, after a multi-year process of consultation, is one of the leading proponents of the mandatory approach.

SPOTLIgHT 1: France, a Pioneer in Effective mandatory Regulation

In effect since the end of 2013, the French framework for mandatory CSR reporting, known as section 225 of the Grenelle II legal framework, is one of the world’s most perfected, thanks to a combination of characteristics:

• The set of regulations is the fruit of an exhaustive round of consensus-building involving all concerned parties including government, business, civil society (NGOs and unions) and academia.

• The framework has been adapted in a second version including comprehensive adjustments and corrections to the inadequacies of a first set of regulations adopted in 2008.

The law is extensive, listing over 40 subjects that companies must report on in three main areas:

• Social (employment, labour relations, health and safety)

• Environmental (pollution and waste management, energy)

• Sustainable development (social impact, stakeholder relations, human rights)

The subjects chosen reflect the main international guidelines on CSR reporting including the Global Compact, the Guiding Principles on Human Rights and Business, the OECD Guidelines for multinationals and the Global Reporting Initiative.


In general, mandatory reporting concerns only larger companies – those which are publicly quoted, for example, or above a threshold number of employees.

It is not only in developed markets that the body of legislation is developing. In 2013, an update of the “carrot-and-stick” approach of CSR reporting internationally, identified 45 countries with a total of 180 policies of which 72 percent were mandatory. The 45 included the main western economies but also fast-growing emerging markets like Brazil, China and India. The authors note “a notable increase in the number of mandatory reporting measures”. In 2006 the original report had covered 19 countries, and found that just over half the policies identified were mandatory. (See Step 3)

1.3 ORgANISATIONS WHICH DO NOT COmmUNICATE ARE THE ExCEPTION TODAy

1.3.1 CSR REPORTINg IS BECOmINg THE NORm WORLDWIDEAn overview on CSR reporting worldwide by CorporateRegister.com, which covers 52,000 reports from 10,500 companies across 170 countries shows a slight slowdown in the growth of CSR reporting, possibly because of the impact of the financial crisis which has led to ruthless cutting of any expenditure not deemed essential. Nevertheless the report shows a continuing increase in numbers of companies formally reporting on non-financial aspects of their business.

According to a 2013 international study by KPMG, “CSR reporting has evolved into a mainstream business practice”. The overview looks at the largest 100 companies in each of 41 countries as well as the top 250 companies worldwide. Clearly, CSR reporting has become standard practice with 93% of the world’s 250 largest companies disclosing non-financial information as a matter of course. Europe no longer leads the pack, and over 70% of the companies surveyed both in Asia and in the Americas now report on CSR routinely.

1.3.2 SCOPE AND CONTENT: SmES ExCEPTED

Expectations of CSR reporting are now widespread, not only from civil society stakeholders, but also from governments, stock exchanges and investors now factoring in CSR elements into their consideration of companies under their watch. By and large, however, the scope and the content of expectations can still vary widely:

• Size is the single most important criterion for whether or not a company is going to be under scrutiny. A useful (but not watertight) rule of thumb is that SMEs with fewer than 500 employees are still under the radar. Another criterion frequently called upon is a stock market listing, although large privately-held companies inevitably attract attention and, while their reporting requirements generally are less strin-gent, tend to be noticed when they do not communicate.

• A second criterion is sector of operation. Some sectors, particularly those with a direct consumer inter-face e.g. the garment sector, are followed more closely by civil society. For example, less stringent social demands are made on certain industries without mass appeal, although from the lawmaker’s point of view they will be especially attentive to questions of anti-corruption and bribery.


• Last and by no means least comes the complexity of the supply chain. Increasingly a company’s part-

ners, government and/or stakeholders will reach behind it to its network of suppliers and intermediaries, who now find themselves under steadily increasing pressure to unveil their own CSR positioning and policies. The Rana Plaza catastrophe in Bangladesh and the horsemeat scandal in Europe are illustra-tions of how far-reaching these networks are and how difficult it has become for the more unscrupulous links to hide behind the brands and stores they supply.

SPOTLIgHT 2: major voluntary comprehensive standards on CSR Reporting*

• Global Reporting Initiative (GRI), referred to by almost all of the larger reporting companies

• United Nations Global Compact, with over 7,000 participating companies in 145 countries

• OECD Guidelines for multinational enterprises, supported by 44 governments including non-members of the organisation

• ISO 26000, elaborated with governments, companies, unions, NGOs and consumer groups

*E.g. multisectoral, combining social and environmental parameters

1.4 LACk OF COmmUNICATION IS NOW A PRIORITy TARgET FOR NgOS

1.4.1 HAvE yOU gOT SOmETHINg TO HIDE?

Poor communication, or communication that does not genuinely reflect the commitment of a company, has always drawn the ire of NGOs and civil society stakeholders. Too often they have seen in it the failures of greenwashing or of paying lip service to corporate responsibility without actually integrating any meaningful CSR policies or attempting to make any progress in CSR.

In recent years, however, awareness of issues around sustainability, the environment and human rights has become increasingly widespread. Media attention is constant and CSR communication for large companies has effectively become part of the ordinary course of business. As a result, an outright lack of communication has become the exception rather than the rule, and the focus of civil society has shifted. The absence of communication in itself draws attention and is becoming tantamount to lack of transparency.

The upshot is that, at best, a lack of communication is perceived to indicate a lack of commitment or of engagement in CSR. At worst it could even suggest that the company has something to hide.

1.4.2 A TARgET FOR CAmPAIgNERS

To fail not only to communicate, but also to respond to enquiries from NGOs or unions will compound the perception. A likely consequence is that a company in this position will be singled out by civil society campaigners and publicly called upon to report. NGOs will not shrink from encouraging consumer boycotts and other measures of pressure whenever a company shows a reluctance to inform, however justified that policy may appear to be.


1.5 LOSS OF CONTROL OvER WHAT IS SAID ABOUT yOU OR IN yOUR NAmE

Nature abhors a vacuum, and so do the media. If you do not communicate about yourself, you run the risk of leaving the space wide open for others to do so in your place.

But the reasons for communicating are not only defensive, they can be an opportunity too:

• The first objective of a communication plan is to inform, and in so doing to rally stakeholders, including clients and employees, around the company brand and its commitments

• By aligning key messages, a communication plan will deliver an unambiguous stance for the company and thereby ensure greater control by management

• A lack of communication, conversely, leaves room for multiple varying and sometimes conflicting messages to be conveyed on the company’s engagements. Customers will rely on salespeople to answer their question and business partners or other colleagues. The risk of embroidering on any key messages or of distorting them is very high

• A centralised and dedicated platform, typically a website, can provide the framework for a coherent flow of information, centralising and sharing key messages defined in the context of the company’s strategic plan.

1.6 CSR CRISIS: DIFFICULT TO mANAgE WHEN THE ORgANISATION HAS NEvER COmmUNICATED BEFORE

A comprehensive communication strategy identifies all target stakeholders as well as the media through which they are reached. When a crisis has begun, time is of the essence and it is too late to elaborate such a strategy.

• If no response or communication is made, stakeholders can understandably draw the conclusion that nothing has been done

• If a CSR communication plan is first used in a crisis, stakeholders may have doubts about the credibility and honesty of the company’s actions

• These doubts will be compounded if the company only begins to communicate after a crisis.

Sometimes the media and the public are aware of a problem before the company itself is. Immediate responses are expected and if they are not provided audiences are likely to think the worst. To be ready with instant reactivity to a CSR problem, the company must be able to rely on processes and a network of contacts which have already been tried and tested through an existing communication plan (See Step 4).


STEP 2: What you Need to know Before you Begin2.1 ACCOUNTABILITy IS THE CORNERSTONE OF ANy CSR PROgRAmmE

Accountability in business means that all companies must be answerable for their actions and for the impact of their activities. It is not only government but also the company’s stakeholders and civil society which may call a business to account and even demand redress for failures to meet standards.

2.1.1 ACCOUNTABILITy REqUIRES TRANSPARENCy

Companies sometimes need to engage in a learning process to bring transparency to their activities, even when – or especially when – that openness goes against the grain. Transparency requires not only that no aspect of the business may be hidden, but also that companies are able to openly discuss problem areas in CSR and past mistakes.

SPOTLIgHT 3: Transparency and Accountability

Transparency and accountability are two of the central pillars of good governance. Transparency is also a necessary precondition for the exercise of accountability since without access to clear, accurate and up-to-date information, it is impossible to judge whether the standard promised has been met.

International Institute for Sustainable Development 2013

2.1.2 ExPECTATIONS ARE HIgH

Stakeholders expect to be able to gain access to full information on CSR issues involving the company they are interested in. They will also call for redress for any missed objectives or standards that are not met.This means that the CSR programme of a company needs to state its objectives and how it hopes to achieve them, as well as underline the fact when the objectives are aspirational, i.e. not achievable immediately but part of a longer-term vision.

2.1.3 mAkE yOUR CSR PROgRAmmE WORk FOR yOU

Companies are in a position to guide their own accountability towards those standards against which they choose to be judged. For example, the Coca-Cola Company is striving to replenish the water used in its products. At present its performance stands at 52% and it has pledged to become water neutral by 2020.

A CSR communication plan (see Step 5) is a tool for addressing the challenges of accountability. Having first established a CSR programme and secondly brought the expected transparency to business activities, the company’s third step is to articulate a communication plan that can show how the programme and the business’s own supply chain characteristics support its goals and demonstrate the convergence in CSR and business objectives.


2.2 THE mAIN RISk IS WHAT NgOS CALL “gREENWASHINg”

2.2.1 DEFINITION OF gREENWASHINg

The Oxford dictionary define greenwashing as “Disinformation disseminated by an organisation so as to present an environmentally responsible public image”. Originally applied only to environmental issues, the term has come to refer to any CSR-related attempt by an organisation to dress up its activities as responsible, instead of actually engaging in responsible business.

One of the most famous examples of greenwashing was when BP, a UK-based oil major, changed its tagline to state that BP meant “Beyond Petroleum”. It was eventually revealed that renewable energies represented a smaller portion of the business than the company’s communication and advertising budget.

A CSR communication plan (see Step 5) is a tool for addressing the challenges of accountability. Having first established a CSR programme and secondly brought the expected transparency to business activities, the company’s third step is to articulate a communication plan that can show how the programme and the business’s own supply chain characteristics support its goals and demonstrate the convergence in CSR and business objectives.

SPOTLIgHT 4: The Seven Sins of greenwashing

TerraChoice’s 2010 report on the Seven Sins of Greenwashing is still relevant today. It identifies a useful breakdown of what, in self-explanatory terms, constitutes greenwashing, i.e. the sins of:

1. The hidden trade-off: When a product is claimed to be e.g. environmentally friendly thanks to one of its attributes while ignoring or concealing another attribute that is the opposite

2. No proof: When claims are unverifiable, such as giving a percentage content of recycled material in a package or paper

3. vagueness: E.g. a claim so broad or poorly defined that it can be misunderstood

4. Worshipping false labels: Giving the impression of third party endorsement when none exists

5. Irrelevance: When a claim may be true but is unhelpful or not pertinent

6. Lesser of two evils: When the product can have favourable attributes while ignoring the category’s more damaging nature

7. fibbing: Simply, not telling the truth.


Some examples of multiple greenwashing sins:

Communicating your CSR credentials: a step by step approach |BlueQUEST

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Originally applied only to environmental issues, the term has come to refer to any CSR-related attempt by an organisation to dress up its activities as responsible, instead of actually engaging in responsible business.

One of the most famous examples of greenwashing was when BP, a UK-based oil major, changed its tagline to state that BP meant “Beyond Petroleum”. It was eventually revealed that renewable energies represented a smaller portion of the business than the company‟s communication and advertising budget.

SPOTLIGHT: The Seven Sins of Greenwashing TerraChoice‟s 2010 report on the Seven Sins of Greenwashing is still relevant today. It identifies a useful breakdown of what, in self-explanatory terms, constitutes Greenwashing, i.e. the sins of:

1. The hidden trade-off, when a product is claimed to be e.g. environmentally friendly thanks to one of its attributes while ignoring or concealing another attribute that is the opposite;

2. No proof, when claims are unverifiable, such as giving a percentage content of recycled material in a package or paper;

3. Vagueness, e.g. a claim so broad or poorly defined that it can be misunderstood;

4. Worshipping false labels, giving the impression of third party endorsement when none exists;

5. Irrelevance, when a claim may be true but is unhelpful or not pertinent;

6. Lesser of two evils, when the product can have favourable attributes while ignoring the category‟s more damaging nature; and

7. Fibbing – simply, not telling the truth.

Some examples of multiple Greenwashing sins:

Hello Kitty: Two sins in one, of no proof and of worshipping false labels

Hello Kitty: Two sins in one, of no proof and of worshipping false labels


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2.2.2 Greenwashing is one of the business practises most targeted by NGOs. Disinformation or misleading communication is considered by civil society stakeholders to be as iniquitous as not communicating at all. When an instance of greenwashing is noticed it becomes the immediate target of NGO ire and often becomes widely disseminated by the press and media. Most household brand names, even those with good CSR reputations, have been cited more than once for misleading information.

For the larger and more visible companies, like WalMart, accusations of greenwashing are a regular and frequent occurrence. For others less used to the limelight, a well-publicised anti-greenwashing campaign can come as a major shock, since the accusation generally addresses an initiative by the company to show its CSR credentials.

SPOTLIGHT: Companies pilloried in Europe for greenwashing Companies which have been taken to task for misleading advertising or communication on social conditions in the supply chain:

A discount retailer had to climb down on claims they ensured that human rights were respected in their supply chain, although no such guarantee was in place.

Similarly, an Asian technology company was accused of ignoring the real labour conditions prevalent among its suppliers, while claiming to have adopted a strict code of conduct concerning working conditions in its supply chain.

A hypermarket operator was accused of defaulting on its obligations of remediation and of not carrying through its due diligence when it refused to contribute to a compensation scheme for victims of the Rana Plaza catastrophe.

Manteca skateboard : Fibbing. (NB mentioning PRC – People’s Republic of China – is another way of saying “Made in China” while trying not to attract attention)

A case of fibbing. (E.g. mentioning PRC – People’s Republic of China – is another way of saying “Made in China” while trying not to attract attention)


2.2 2 gREENWASHINg IS ONE OF THE BUSINESS PRACTICES mOST TARgETED By NgOS

Disinformation or misleading communication is considered by civil society stakeholders to be as iniquitous as not communicating at all. When an instance of greenwashing is noticed it becomes the immediate target of NGO ire and often becomes widely disseminated by the press and media. Most household brand names, even those with good CSR reputations, have been cited more than once for misleading information.

For the larger and more visible companies, like Walmart, accusations of greenwashing are a regular and frequent occurrence. For others less used to the limelight, a well-publicised anti-greenwashing campaign can come as a major shock, since the accusation generally addresses an initiative by the company to show its CSR credentials.

SPOTLIgHT 5: Companies Pilloried in Europe for greenwashing

Companies which have been taken to task for misleading advertising or communication on social conditions in the supply chain:

• A discount retailer had to climb down on claims they ensured that human rights were respected in their supply chain, although no such guarantee was in place

• Similarly, an Asian technology company was accused of ignoring the real labour conditions prevalent among its suppliers, while claiming to have adopted a strict code of conduct concerning working conditions in its supply chain

• A hypermarket operator was accused of defaulting on its obligations of remediation and of not carrying through its due diligence when it refused to contribute to a compensation scheme for victims of the Rana Plaza catastrophe

2.2.3 gREENWASHINg IS INCREASINgLy THE OBjECT OF NATIONAL REgULATION OR LEgISLATION

In France the stringent body of regulations adopted by the government around CSR and CSR reporting includes a precisely defined ban on false environmental allegations. Green and environmental claims feature prominently in the Canadian Competition Bureau’s environmental guidelines and in the US Federal Trade Commission’s Green Guides.

Of course, in many countries, ordinary advertising rules can be brought to bear on false CSR claims by companies.


2.3 BENEFITS OF A COmPREHENSIvE COmmUNICATION STRATEgy

A well-articulated communication strategy will confer a whole series of benefits on the company beyond the basic objective of transparency with stakeholders. This is the case regardless of whether the CSR programme and the communication plan are basic and limited or highly sophisticated and ambitious.

• Staff cohesion and prideArguably one of the first benefits is internal and related to employee engagement. Employees must be part of any communication plan and indeed will constitute one of its primary targets. Although it is not an objective of the plan, a frequent corollary of CSR commitments is increased pride and support by staff in company activities and goals.

• CredibilitySimilarly, clients and other business partners will both benefit from the company’s CSR commitments and communication on CSR, and are consequently more likely to approve of and reinforce the company’s CSR goals.

• Licence to operateIf it is extended to the wider community, the support and approval conferred by employees, clients and business partners will constitute what is known as a licence to operate. Far from being an official or formal seal of approval, a licence to operate refers to the overall approval of society at large of a company’s activities and objectives.

Without a licence to operate, the best a business can hope for is public indifference, but it is more likely to court disapproval and attract questions and increasing scrutiny. The object of an effective communication plan will include demonstrating the company’s good corporate citizenship which in turn will enhance the company’s licence to operate.

• Brand differentiationGuiding a communication plan towards supporting brand or company differentiation is not reserved for leading businesses in their sector. Even a modest positioning by a company on CSR goals and benefits will contribute to brand development. Such a benefit will be conferred automatically by an effective communication plan provided the plan sticks to factual CSR claims without overstretch.

2.4 TO COmmUNICATE ON CSR IS TO COmmIT: THERE IS NO TURNINg BACk

It may appear obvious, but it is important to emphasise that once taken, the decision for a company to communicate on CSR and on any CSR initiatives is irreversible.

During the recent global financial crisis and subsequent economic downturn, most companies the world over have had to implement cost-cutting measures of some description, to offset stagnant or declining markets. Nevertheless, while the rate of growth of CSR reporting worldwide also slowed in proportion, it never came close to shrinking.

It is no longer possible to consider CSR initiatives and their accompanying communication strategies as optional extras, to be slowed or abandoned when times are tough. Once a company has become engaged in a CSR programme and has begun to make it known, there is no room to backtrack. A previously vocal company which becomes silent will only attract more attention.


This context is all the more unconditional with trends worldwide towards increased reporting, growing stakeholder and consumer expectations and ever more regulation making more and more precise demands on reporting and CSR communication.

As such it is only a matter of time before the decision to begin communicating becomes an obligation in most markets and jurisdictions. For companies which have not yet launched a communication plan, therefore, it may be advisable to anticipate and start doing so now on their own terms, before they have to submit and comply to those which are imposed on them.

2.5 ONE STEP AT A TImE - RESPONSIBILITy IN THE SUPPLy CHAIN IS NOT THE EASIEST TOPIC TO START WITH!

Particularly in the early stages of CSR programmes and communication plans, the subject of responsibility in the supply chain is awkward and difficult to master.

For one, the issues at hand concern fundamental human rights enshrined in hard law, and notably in the ILO Conventions. These topics are highly sensitive and attract enormous consumer, media and stakeholder interest.

Secondly, the world’s supply chains are notoriously opaque and absolute visibility throughout the chain is virtually impossible to achieve.

Thirdly, while the Universal Human Rights under consideration are non-negotiable, they are accompanied by a wide array of cultural norms and bodies of soft law, of uncertain and varied levels of implementation. This can lead to multiple interpretations and sometimes contradictory aspirations.

Finally, the benchmarks and measures, which can provide a framework for evaluating and implementing social compliance, are often a matter of judgment and case-by-case assessment. They are more awkward to pin down in hard and fast terms than scientific and data-driven issues such as those covered by environmental compliance.

For companies beginning to get involved in CSR and beginning to communicate about their CSR initiatives, it is critical to stay factual and transparent, and not to overstretch.

Prepare the groundwork with great care, and take small steps, one at a time, in communicating on the subject.


Before defining your CSR communication strategy and designing your communication plan, you will need to gather and analyse information and data on the markets in which your company operates, and to share this information with key colleagues (incl. CSR, communication and marketing practitioners etc.).

Such research will include:

• Existing regulations and norms related to CSR communication in the countries where you operate

• Main CSR challenges and risks in the industry and main markets where your company operates

• The CSR positioning and communication practices of your competitors

• New expectations from customers, clients and other stakeholders (incl. partners, NGOs, media etc.)

Regulations and Norms• Existing national / regional

regulations

• Common international market practices and norms

Competitive practices• Main actions

implemented by your competitors

• Competitors' CSR positioning and lines of communication

CSR Challenges in your Industry• Main CSR impacts and risks

associated with your company's activities, geographical

location, areas of sourcing

Stakeholders' expectations

• Market trends and clients/customers' expectations

• Key influencers and other local stakeholders

exTeRNAL CONTexTMAppING

Why is market intelligence important?

• If your company hasn’t started to communicate yet

You need to be aware of the main drivers in the market where you operate. And for you, the main drivers may be existing or future regulations on CSR reporting, for example. You will need to anticipate these if you do not want to put your business at risk.

• If you are a B2B company (e.g. importer, agent, trader or manufacturer)

You are of course much less visible than the well-known retailers and brands among your customers, but their reputation can be at risk if they don’t implement a sound approach on responsible supply chain management. It is consequently strategic for your company to understand your clients’ expectations in this field and to develop or align your CSR communication accordingly.

• If you are a B2C company with a CSR communication plan in place

Market intelligence is something you should do on a regular basis, either to ensure that your communication is aligned with market trends, or that you are still ahead (if that is your strategy).

STEP 3: Do your Homework: market Intelligence


3.1 BE AWARE OF ExISTINg REgULATIONS AND NORmS

Most European countries have developed regulations over several years on social and environmental reporting that relate to:

• Employment: Several countries require medium and large companies to publish a "social balance sheet" that refers to a statistical statement of social data, more particularly on employment (workforce struc-ture, KPIs on human resources management, etc.)

• Self-declaration on critical environmental issues such as compulsory financial reporting of environ-mental liabilities and risks.

Since the 2000’s, CSR regulations started to appear across Europe, mainly to make CSR reporting compulsory for listed and large companies. These regulations exist today in most European countries but cover various CSR topics (disclosure on carbon footprint, diversity, health & safety, human rights, relations with subcontractors, responsible supply chain management, etc.). Some countries have also developed or revised their regulatory framework on consumer protection and misleading advertising in order to cover self-declared environmental claims and other claims related to sustainable development. They can now more easily prevent and rule green-washing cases from companies in their advertising and product labelling.

These regulations are still progressing across Europe:

• In many countries, existing CSR regulations on reporting are evolving to cover smaller companies and larger CSR topics

• EU regulations on CSR reporting were adopted in 2014 (see Spotlight 6, below)

• Several experiments have been organised on products’ social and environmental labeling

SPOTLIgHT 6: Latest EU Regulations on Extra Financial Reporting

Companies which have been taken to task for misleading advertising or communication on social conditions in the supply chain:

• After a long gestation period a directive on non-financial reporting was adopted by the European Parliament on 15 April 2014, and will come into effect once approved by the Council and published in the Official Journal. The directive applies to companies with over 500 employees. This concerns some 6,000 larger businesses, including unlisted, compared to the 2,500 (less than 10% of the total number of large companies in the EU) which currently provide some form of CR reporting

• The requirement is for these companies to provide information on their CR approach, its results, verification and risks, with measures of non-financial social and environmental performance including human rights, anti-corruption, bribery and diversity issues

• To a certain extent the companies will choose which information to disclose and which code or standards they benchmark performance against, depending on their individual situation or business context


3.2 UNDERSTAND CSR CHALLENgES IN yOUR INDUSTRy

Even if your plan is to develop specific communication on how you manage risks in the supply chain through the BSCI process, understanding the wider CSR challenges faced by your company is a must.

First, you need to understand what the social and environmental issues are in your company’s supply chain. For example, what are the specific human rights most at risk in the business activities or countries you source from? This understanding is essential to explain the rationale behind your engagements (if you have or want to).

Secondly, a broader understanding of what CSR (or sustainability) is, and how it can apply to your company, will strengthen your communication and bring credibility.

Where will I find this information?

• Look at the main issues addressed by leading companies in your industry in their communication (website, annual report etc.) (See Section 3.3: “Know what your competitors are doing and how they communicate”)

• Read national or regional media specialised on CSR that may have covered your industry. Ex: Ethical Corporation (for CSR across Europe); Business & Human Rights Resources Centre (for human rights issues internationally); Novethic (in France), etc.

• Visit key NGO websites. BSCI can provide you with a list of active NGOs in your country and industry

• Contact BSCI which may also be aware of recent reports or of leading companies in your industry.

3.3 kNOW WHAT yOUR COmPETITORS ARE DOINg AND HOW THEy COmmUNICATE

Are your competitors already communicating on their CSR credentials? Do they have a specific message on how they manage their supply chain responsibly? What are their main lines of communication?

As you can imagine, this information is highly strategic for your organisation. It will allow you both to measure the CSR maturity of your peers and to find the right positioning for your company in terms of CSR communication.

Where will I find this information?

• Focus first on your main peers and competitors (same products, same markets, same size): review their website (both commercial and corporate websites) and make additional desk research

• Identify industry leaders (because of their size or their visibility) and assess how they communicate on CSR

• Look for companies offering a “responsible alternative” to your products (e.g. certified organic or fair trade products): How many are they? What is their positioning? How do they translate their commit-ments into messages?

• Look at BSCI participants: Other BSCI participants are probably similar to your company. Contact the team for help in identifying them


3.4 FIgURE OUT STAkEHOLDERS’ ExPECTATIONS AND mARkET TRENDS

In the context of CSR communication - and more specifically if CSR communication is new for you - understanding expectations from both clients and key NGOs active in your markets is a prerequisite (see Step 3: Market Intelligence).

3.4.1 IF yOU ARE A B2C COmPANy

• Understanding the position of NGOs and the media towards your industry is all the more important if you are a large or visible company. You need to review the most topical CSR issues including those in the supply chain to be able to align your communication if needed, and prepare potential answers in case an alert or a crisis arises. To help you in this task, BSCI can provide you with a list of the most influential NGOs operating in your markets

• Understanding market trends and consumer expectations is also an essential move. Various organi-sations regularly poll consumers to understand how they prioritise CSR issues and behave when they make purchases. These organisations include worldwide specialized agencies and media such as FutureBrand, ConeComm, GlobeScan, Sustainable Brands along with other organisations and agencies at the national or regional levels (Eurobarometer across Europe, Ethical Consumer in the UK, etc.)

SPOTLIgHT 7: Ethical Consumerism, key Trends Across Europe

Differences may exist across European countries and sectors, but the following trends are notable developments in the way European consumers view CSR, view companies, and shop:

• A vast majority of European consumers knows about “sustainable development” (more than 90% in some European countries)

• An increasing number of European believe that the onus is on business to act in favour of sustainable development: In various European countries, consumers now place business at the same level as states, and before NGOs

• 79% of European customers are interested in which companies behave responsibly

• However, 62% of them do not feel informed

• “Made In”, traceability and manufacturing conditions are key topics for consumers. They expect more information on these topics, which have become top priorities since the high profile crises in 2012 - 2013 (e.g. horse meat in the food and beverage industry; Rana Plaza in the apparel industry, etc.)

• A significant segment of customers boycott products because of a company’s behavior (55% of consumers in the UK in 2014). Child labour is generally seen as one of the most important reasons for such a boycott


3.4.2 IF yOU ARE A B2B COmPANy

• Understanding the position of NGOs and of the media is perhaps less a priority as your company is much less visible. Nonetheless, note that in various countries across Europe some NGOs have begun questioning the role of intermediary companies and do not hesitate to start campaigning against medium-sized enterprises if they are considered to form part of a controversial supply chain. In addi-tion, seeking to identify the expectations of significant NGOs on responsible supply chains will always be a good way to understand better your customers’ expectations towards your products, processes or additional services, and to be prepared if a potential crisis arises in your supply chain

• Understanding market trends can be done through research on leading companies’ corporate websites and sustainability reports (e.g. retailers, apparel or food and beverage brands). BSCI can help you iden-tify both leading companies and key trends in your industry.


STEP 4: Be Aware of the Specific Context for your Company: Business IntelligenceImplementing a methodical self-analysis of your business is a necessary step before defining any communication plan. You will find below some useful tips and tools to process this self-assessment smoothly, but note this step usually requires carrying out a full “as-is” analysis, based, for example, on an internal CSR audit. If you have never performed such an exercise, defining or rethinking your communication on responsible supply chain management is a good opportunity to implement such an approach.

4.1 WHy ASSESS yOUR COmPANy’S SPECIFIC CONTExT?

To prepare future communications on your responsible supply chain approach and your participation in BSCI, you need to assess not only initiatives implemented in the supply chain but also how your company deals more broadly with CSR.

Responsible supply chain management is not an easy topic to communicate on. It is generally considered as one of the most sensitive areas in the CSR sphere.

For that reason, your communication should not only be aligned with your actual program in the supply chain, it should also be:

• Adapted to the CSR abilities of your communication team, to ease the communication process and avoid any gaps between the walk and the talk (which is considered to be greenwashing; e.g. section 2)

• Consistent with your overall CSR maturity level to ensure that your company has developed an embedded CSR culture and that additional enquiries into your programme will not lead to awkward situations

• In line with your main stakeholders’ expectations

• Backed up by a clear CSR strategy, or, at least, a shared vision on why and what you should communi-cate on your supply chain

4.2 HOW TO ASSESS yOUR COmPANy

4.2.1 EvALUATE HOW vISIBLE yOUR ORgANISATION IS ON CSR ISSUES

This is an important question to ask because whether or not your company is at risk of attack from NGOs or other associations, campaigning on CSR will probably impact your communication process.

Usually B2B and small companies are below the radar. In such a case your communication plan will primarily target clients and partners.

For B2C and bigger companies, you need to acknowledge that if you are already on NGO radars or sufficiently visible these stakeholders should keep you on your toes before, during and after the communication process.


Your company is visible or under risk of attack if:

• It has already been mentioned in an NGO campaign related to the protection of human rights in the supply chain or other CSR issues

• Local or national media have already requested an interview with your company regarding social or CSR matters

• Some of your competitors or similar companies (same size, same business) are already targeted by NGOs and media

4.2.2 IDENTIFy yOUR CUSTOmERS’ AND PARTNERS’ ExPECTATIONS

Step 3 was about understanding the main CSR trends in the markets where your company operates. This gave you a hint of what your clients and partners may expect from your company regarding CSR.

Nonetheless your company and brands are unique, and so are its clients. Consequently, it is worth investi-gating whether your clients and partners have specific expectations.

How do I obtain this information?

• Classic market research tools, but these can be expensive

• Set up a client survey – however, for some companies this means opening a direct dialogue with customers on CSR, which is not always easy when you are at the beginning of the process

• Survey your sales force on questions frequently asked by your clients

• Interviews and exchanges with key sales forces colleagues and customer relationship management services to establish whether questions, demands or comments associated directly or indirectly with CSR and responsible supply chain management have already been coming in

4.2.3 ASSESS yOUR COmPANy’S CSR mATURITy

Assessing your company’s maturity on CSR and responsible supply chain management will help you define consistent targets in your communication plan. If your company wishes to push the boundaries in terms of communication, it can be a good thing only if you are sure you have a good story to report on how you are improving working conditions in the supply chain.


You should evaluate your maturity with the following measures:

• Responsible supply chain management

1. How long have you been working in the supply chain/ have you been a BSCI participant? 2. What is the range of social issues covered? Does your approach go beyond monitoring compliance with basic standards?

• Other CSR issues covered

3. Does your programme cover wider CSR issues (e.g. social responsibility in your company, environmental stewardship, responsible marketing, community engagement etc.)? 4. Are all material CSR issues under control?

• Strategy and management

5. Has your company defined a comprehensive CSR strategy? 6. Are your company’s CSR ambitions clear and shared throughout the organisation?

• Teams & resources

7. What is the CSR maturity level of your colleagues? 8. Are the resources allocated to your CSR programme sufficient to achieve your company’s CSR goal?

• Follow-up and reporting

9. Has your company set up a CSR reporting process? 10. Can your company easily measure the scope and impact of its CSR initiatives?

On the following page is a simple assessment tool to help you define where your company stands with regard to CSR.


A qUICk TEST TO kNOW WHERE yOU STAND AND HOW yOU SHOULD USE THIS gUIDE:

(FOR EACH BELOW CSR TOPIC CHOOSE THE SITUATION – A, B, C, D – THAT BEST DESCRIBES YOUR COMPANY)

CSR TOPICS A B C D

CSR know-how CSR is a new concept which is not fully mastered by the company

The company is familiar with CSR but it is a concept mastered only by a few executives

Key executives understand what is at stake for the company in terms of CSR

Top management has a good grasp of CSR and communicates publicly on the subject

CSR programme characteristics

Company involvement is broadly limited to community activities (e.g. sponsoring, green initiatives)

Major risks are known and the company CSR programme is endorsed by top management

The company has excellent visibility over all CSR stakes and the company’s comprehensive CSR programme is endorsed and monitored by top management

The company leads an innovative CSR programme and is recognised as a leader in the subject among its peers and stakeholders

Means allocated to CSR Minimum support provided to the programme with no formal organisation or lines of responsibility

One person or team (dedicated or not) is accountable for the programme and has an operating budget for it

The CSR programme is run by a dedicated executive or team and uses a network of relays in the company’s operations

The whole workforce receives training on the CSR programme, which permeates all functions and operations

Initiatives in the supply chain

The company uses a code of conduct and has led a few audits. It has been a BSCI participant for less than three years

The company has been a BSCI participant for more than three years or has audited the majority of its suppliers. Buying teams have received CSR training

The company has excellent visibility over the performance of its suppliers. It has put in place a robust process of risk prevention and management

The company has placed responsibility at the heart of its buying policies. It anticipates and deals with emerging issues and drives sophisticated capacity-building projects

Communication level No communication or communication limited to the regulatory acceptable minimum, in uncontroversial areas (e.g. sponsoring)

The company has been reporting on CSR for some years, and communicates sporadically on the subject, but without clear visibility on its ROI

The company has made CSR a major pillar of its institutional communication. CSR product marketing covers a limited number of products

CSR constitutes an integral element of the company’s or the brand’s positioning. CSR permeates all forms of communication. The company is engaged in a process of transparency

MATURITy LeveL You have a majority of A: beGINNeR

You have a majority of B: eNGAGeD

You have a majority of C: COMMITTeD

You have a majority of D:LeADeR

HOW TO USe THIS GUIDe fOCUS ON STepS 1 TO 6

fOCUS ON STepS 2 TO 7




4.3 DEFINE OBjECTIvES IN LINE WITH yOUR COmPANy’S mATURITy AND CSR STRATEgy

Your communication objectives will vary depending where your company stands and where top management wants to go with its CSR ambitions.

You will find below typical objectives per maturity level as per the maturity table developed above.

4.3.1 IF yOU ARE A BEgINNER

Communication on the social challenges in your supply chain is new to your company.

A mid-term objective could be to address the most critical risks in the supply chain with a simple, factual and targeted communication plan (mainly intended for internal audiences). For example:

• Inform colleagues about your participation in BSCI with an internal communication plan

• Raise awareness of key colleagues in the sales force team in order to equip them to answer potential questions from clients and customers

• Long-term objectives might be to reposition the company at the heart of its sector’s level of CSR stand-ards and therefore to close the gaps with your most engaged competitors

4.3.2 IF yOU ARE ALREADy ENgAgED

CSR communication is not new for you and your company already has solid social achievements in its supply chain. First, you should ensure that your company has already developed a crisis communication plan. If not, it should be added to your short-term to-do list.

Mid-term objectives could be to improve your communication in order to:

• Close the gap with industry standards

• Build on your company’s CSR ambitions

• Reduce reputational risks and seize new business opportunities

4.3.3 IF yOUR COmPANy IS COmmITTED

You already have a quite mature CSR communication approach that includes some efforts towards transparency on aspects of a responsible supply chain. A mid-term objective may be to confirm the foundation and legitimacy of the company’s approach. That objective should also be on going one for you. As regulations and industry standards usually progress over the years, you should ensure that your company maintains its advanced position.

If, (and only if!) your company’s strategy is to become a CSR leader in its market / industry, you should push the boundaries and identify:

• Areas needing improvement to close the gap with CSR leaders in your industry

• Means of differentiation to gain visibility


4.3.4 IF yOUR COmPANy IS A CSR LEADER

Your company is recognised as a CSR leader by its stakeholders and its peers. Congratulations! Your main objectives should be to reinforce your position while creating brand preference. To do so you need to:

• Identify more precisely current communication trends and practices involving the supply chain across leading industries

• Identify and understand innovative communication initiatives to feed your own strategy


Once you have shared your market intelligence and business intelligence reports (see sections three and four) with key colleagues (including, at the least, those colleagues you will be working with to define your communication approach), you are ready to work on your communication strategy.

The strategy should mainly address your company’s objectives, target groups and messages, and can be summarised in what we call a communication plan.

5.1 WHy SHOULD yOU DEvELOP A COmmUNICATION PLAN?

To communicate effectively on CSR, it is helpful to plan your different goals and what you need to do to achieve them.

5.1.1 WHAT IS A COmmUNICATION PLAN?

Planning is a way to organise communication actions that will lead to the fulfilment of your CSR goals. In the context of your participation in BSCI and your broader engagement in the supply chain, your overall objective is to raise awareness about your efforts to raise the social compliance bar in the supply chain and long-term benefits to your company and its wider community.

A communication plan always covers mid- or long-term objectives (i.e. how to raise your profile and refine your image over time) but it can also be rolled over as a yearly roadmap to define a more short-term approach.

To develop a plan for communication of any sort, you have to consider some basic questions such as:

• What is your purpose?

• Who is your audience?

• What is your message?

• Which communication channels will you use?

Communication is an ongoing activity and CSR is a continuous improvement process. Therefore – above all if you are in the early stages of CSR communication – your chosen purpose, audience, message, and channels may change. As a result, an important part of any communication plan is to continue implementing and revising the plan, based on your experience, for the duration of your organisation’s existence. Moreover, using the communication plan to track the evolution of your strategy will help you ensure more consistency in your messages, and will therefore help maintain positive relationships with your stakeholders and the media.

5.1.2 FURTHER REASONS FOR DEvELOPINg A COmmUNICATION PLAN

Developing a communication plan on your responsible approach in the supply chain should not be seen as a chore.

First, building a communication plan is a great opportunity to collaborate with the communication and marketing teams, and therefore to ensure that respective objectives are fully aligned.

STEP 5: Build a Communication Plan for a Progressive Approach


In addition, a plan will make your CSR communication efforts more efficient and effective:

• It provides the best view of the big picture and you can share it with your colleagues

• A plan will make it easier to target your communication accurately by giving you a structure to determine whom you need to reach and how.

Finally, if you can spend some time planning at the beginning, you will save time later on, because you know exactly what you should be doing at any point in the process.

As soon as your organisation begins planning its CSR objectives and actions in the supply chain, you and your communication colleagues should also begin planning ways to communicate them (even internally!).

5.2 WHAT yOU SHOULD DEFINE IN yOUR COmmUNICATION PLAN

5.2.1 IDENTIFy yOUR PURPOSE.

Why do you want to communicate on your approach towards a responsible supply chain?

What you may communicate depends closely on what you are trying to accomplish with your communication strategy. Keep in mind, too, that your objectives in terms of communication should be consistent with your organisation’s CSR maturity and must be fully aligned with overall company fundamentals ((i.e. culture, brand content and essence) and strategy (i.e. global communication strategy, CSR ambitions, etc.).

Your purpose might be one or several of the following, for example:

• Achieving compliance with regulatory CSR reporting

• Informing colleagues on your programme and engaging them

• Becoming known, or better known, for your work in the supply chain through BSCI

• Raising awareness amongst your client base on the social issues your organisation addresses

• Differentiating your company from its competitors

• Being ready in case a crisis arises

5.2.2. IDENTIFy yOUR AUDIENCE.

Who are you trying to reach?

Knowing your audience will help you plan your communication more logically. You may need different messages for different groups, and different channels and methods to reach each of these groups too.

First, there is the question of which group(s) you will focus on:

• Colleagues (i.e. internal communication to executives operating in selected functions of your company only, or all of your organisation)

• Suppliers and agents (i.e. supply chain communication for the purpose of BSCI implementation)

• Shareholders, investors or SRI analysts (i.e. financial communication to showcase management’s approach to social risks)

• Corporate partners or other stakeholders (i.e. corporate communications aimed at students, job appli-cants, other stakeholders, etc.)

• Customers, clients or purchasing advisors (e.g. brand communication to address your clients’ new expectations)


• Mass market (e.g. marketing communication to add value to your product)

It can then be useful to group your targets in each category according to a number of different characteristics, such as demographics, geography, how long the relationship has been in existence, etc.

Another aspect to consider is whether you should address your communication directly to your final audience or whether your communication needs to be indirect. Sometimes, in order to influence a population, you have to aim your message at those to whom they listen – salespeople (instead of targeting clients directly), professional associations (to address partners), NGOs, specialised media, etc.

5.2.3 THE mESSAgE

What do you want to communicate?

In defining your message, you should first consider its content but also other criteria such as mood, language and design. This is a rule that any communication practitioner should follow, but it is especially true when you start communicating on CSR: whatever your message is, its mood, language or design are “details” that can push some campaigners to react against your company, or make stakeholders feel that your communication is just greenwashing.

• Content: You should keep your audience in mind while defining your message to make it more effective. If, say, your objective is to inform stakeholders about your participation in BSCI, you will define a radi-cally different message from the one you will address to investors, employees or students, for example

• Mood: This is an important factor in your CSR communication. You should both consider how your company usually communicates and what specific emotions you want to appeal to with your CSR communication

• Language: You need to define the kind of language you use – formal or informal, simple or complex, refer-ring to popular figures and ideas or to more expert ones depending who are your targets

5.2.4 CHANNELS OF COmmUNICATION

How do you want to communicate?

You have to reach your audience by placing your message where they will see it. A good choice for CSR is not always the media that will give you the greater audience but instead the one that will help you to be heard by the specific audience you want to target.

• BASIC NON-MEDIA CHANNELS:

• Website: It is the first source of information about you for many people, so it needs to contain the right information. Depending on your target you can communicate on your institutional / corporate website or your commercial website.

• Publications: Create CSR publications for your company that are easy to read and understand (briefs, flyers, CSR brochures or reports).

• Newsletters: Newsletters are a good medium to let people know about your actions, inform readers regularly about recent changes, new initiatives, events in which you have participated, or even interesting case studies. You can also check newsletters compiled by other organisations as they can be interested in CSR activities. This is a great opportunity to reach out to a new segment of your target audience


• Promotional materials: Promotional materials are items carrying the visual identity of your project, e.g.

bags, pens, USB stick, cups, calendars, t-shirts, etc. Always make sure the materials have practical value and keep ecological and social compliance aspects in mind when producing them

• Participating in external events: Take part in external events such as exhibitions, conferences, trade shows and round-table discussions. This could be either as an exhibitor, speaker or even a delegate. External events give you an opportunity to come face-to-face with your target audiences and tell them about your engagement

• Events: Organise events that are interesting for your target audiences and for media to attend (conference, exhibition, a round table discussion, field trip, etc.). Events can be organised for colleagues or partners (e.g.: suppliers convention)

• OTHER NON-MEDIA CHANNELS:

• Social media: Internet offers various opportunities to promote your CSR initiatives in the supply chain. Social networking tools (Twitter, Facebook, etc.) can be difficult to deal with and they should be reserved for specialists

• Participation in award schemes: You will need a great story to tell, and therefore a mature approach that goes – for example - beyond strict compliance with basic human rights in the supply chain

• Sponsoring and funding: They can be ideal communication channels as long as you have a comprehensive programme in place and do not use philanthropy as a way to “offset” your own responsibilities

• MEDIA:

• Only big companies, CSR leaders in their categories, or companies with very specific corporate positioning or innovative projects go to the media to communicate on their CSR work

• There are an enormous number and a wide range of news media, each with a different target audience and its own values (TV, newspapers and magazines, radio, internet news, general, specialised etc.)

• You should consider two factors to choose the most adapted media for your CSR communication:

1) Which media do our own target audiences pay most attention to?

2) Which media will consider our messages newsworthy?

5.3 CRISIS mANAgEmENT: PREPARATION IS kEy

This section will look at how BSCI participants can prepare for and respond to crises concerning social issues in the supply chain. It is intended as an overview and is not a substitute for your company’s own policies or obligations.

5.3.1 WHAT CONSTITUTES A CRISIS?

The kind of crisis this section addresses is a situation in the supply chain, which arises abruptly and presents immediate risk to a company and to its reputation. Crises generally involve wide coverage in the media.

Every crisis is different. Consequently, it is the principle rather than the detail that can be prepared for.


With the close scrutiny of supply chains by NGOs and trades unions, a crisis situation may develop from various origins, such as:

• A previously unknown violation of social standards in the supply chain is discovered and engages media attention – e.g. an instance of child labour

• An accident causing death or injury occurs due to non-compliance with security or other standards, in a factory or farm that supplies the BSCI participant

• The professionalism of an auditor that has previously been used by BSCI participants is called into ques-tion

Frequently the origin of a crisis will be found at the lower-tier subcontractor level, unbeknownst to the buyer.

In a worst case scenario (for the buying company) the media and the public become aware of an issue before the company itself.

5.3.2 BE PREPARED

The most important and even essential element of any crisis management process is to have established (and tested) both a process and the infrastructure it will be based on, before any crisis occurs. Lack of readiness will turn a difficult situation into a disaster for the buying company.

• THE INFRASTRUCTURE: AN ExISTING AND WORKING COMMUNICATION PRACTICE

Infrastructure refers to an established communication strategy with its network of target audiences.

This communication infrastructure must be internal as well as external. In a well-publicised crisis all employees become ambassadors for the company, since they will be asked about it. The same holds for investors and board members.

Externally, not only the media but also customers, business partners and of course civil society stakeholders will be relays for information. If the company already has an established network of communication with all these agents, they are more likely to be able to repeat whatever message the company wants to be heard.

The size and visibility of the buying company is likely to be reflected in the scale and intensity of media and stakeholder attention once an issue has been identified and publicised.


SPOTLIgHT 8: 10 Tips on Being Prepared if a Crisis Arises

A crisis can arise at any moment and without warning. Consequently the safest procedure is to assume that one will occur and to be ready for it.

1. Keep up a regular dialogue with a network of stakeholders and media Lines of communication which are already in use are easier and faster to open when an emergency arises

2. Keep yourself and your colleagues up to date Know your supply chain and regularly update any data on it, on labour partnerships, on who you are working with, on where the flashpoints and vulnerabilities are. Admit to weaknesses and show how they are being dealt with, i.e. they must be areas pinpointed for improvement and acted upon as such.

3. Share responsibility Ensure both the supply chain and the communications people are aware of each other’s roles and activities. This will provide a safety net and will support engagement.

4. Use all channels in your regular communication In a crisis, all methods of communication can and should be used as appropriate to be able to give wide coverage quickly: These will include mobile phones, webinars, open meetings and conference calls. If these technologies have already been used in the normal course of business they will be much easier to bring to bear in a crisis.

5. Be reliable and transparent in your regular communication If your audiences know they can rely on you in your regular communication they will be open to your message in an emergency.

6. Build goodwill with your stakeholders The stakeholders in your network are more likely to listen to you and relay your messages in an emergency if they already have an ongoing dialogue with you

7. Construct an early warning system Know your supply chain, identify and monitor weak points, follow up relentlessly on non-compliances, understand the idiosyncrasies of sourcing countries. Your network of stakeholders (NGOs and civil society, unions), if engaged, will be helpful in alerting you to potential crises

8. Keep your policies public and jargon-free Communicate clearly where you stand on social issues in the supply chain so that your policies are understandable by non-specialists and outsiders

9. Stay realistic and down-to-earth in your communication Do not hide behind PR or dress up your policies; be open about the challenges and weak points in your supply chain, and engage in dialogue with constructive partners about how to address them

10. Involve and engage top management regularly In an emergency the most senior executives need to be able to speak out immediately


5.4 WHAT TO DO WHEN A CRISIS OCCURS

An established communication plan with involved stakeholders, based on reliability and transparency, is a source of goodwill that can be tapped into when a crisis emerges. It also gives company spokespersons confidence and authority, two essential attributes which are quick to be threatened in a crisis situation. This will reassure an audience and provide the company with the means to communicate facts quickly and effectively. The nature of a crisis is such that it demands immediate responsiveness. Any delay will only dig a deeper hole for the buying company. Companies should also be prepared for open hostility and adversity from all sides.

Effective crisis management includes the ability to strike a fine balance between opposing risks:

• Show confidence and authority BUT do not be proud or oversell your case

• Stick to the facts BUT understand that they may be ignored. Expect rumours to swirl

• Be open and transparent BUT avoid the temptation to confess to false weaknesses in order to curry favour

• Tap into your goodwill bank BUT understand that your network may not stand by you

It is crucial to understand that in a crisis, emotion tends to take over and rational thought and discourse hold no sway. This state of affairs, depending on the level of media attention, may last only a few days, but in that short time expectations need to be managed and met in this context. The impact of major crises will be felt for much longer and will not be discarded.


SPOTLIgHT 9: 6 Elements of Effective Crisis management

1. Check the nature and scope of the issue If you react to rumour that turns out to be unsubstantiated a crisis may occur which should never have happened.

2. Engage the company at the highest possible level Top management needs to be seen to be in charge and to know and understand what is at stake. Low level responses will be taken to reflect the company’s attitude, so if the crisis is serious they should be avoided. There should be no improvisation.

3. Show the company to be open and transparent Provide a comprehensive overview of the facts, including any bad news, but stick to the facts: do not engage in any guesswork or speculation. If you do not know something say so and explain you are in the process of finding out (if that is the case). Do not oversell the company but equally do not underline or overplay any gaps or weaknesses. Stay factual.

4. Say what you are doing and do what you say Explain how the company is dealing with the issue and follow through with your announcements. Point to where you are going and then go there. Show reliability by doing so and equally, competence and understanding of the issues. By doing what you say, you are also demonstrating your capability to act.

5. Avoid a defensive attitude Don’t complain, criticise or find excuses. Show humility but equally, firmness of intention and purpose.

6. Keep the information flowing Provide regular and frequent updates; however, do not fill gaps with unsubstantiated suggestions or rumour if there is no hard news

BSCI will be a potential resource in the event of a crisis. Contact the secretariat as soon as possible and keep the lines of communication open for frequent monitoring and updating. If the issue concerns the BSCI Code or activities, a concerted response will also be required.


6.1 “BASIC” REgULATORy REPORTINg FIRST

If your company has not yet started any form of CSR communication, whatever your CSR ambitions are, compliance with existing regulations is a must.

6.1.1 COmPLy OR ANTICIPATE FUTURE REgULATIONS

If your company is not yet affected by national or regional regulations on CSR reporting, you should nonetheless assess whether your company is exposed to future regulations in the different markets where it operates.

In all cases, if your company will be or may become concerned by regulatory CSR reporting you should mobilise teams to be ready in due course or anticipate future regulations, if that is your strategy.

When defining your strategy, keep in mind that:

• While anticipating regulation may be valued as a proactive action, strict compliance with regulation will not help you shine.

• The bigger your company is, the more time you will need to develop your reporting in the supply chain. On average, one year is necessary to develop a basic CSR reporting process from scratch

• CSR reporting is an on going process. When your first annual review is finished, you will then need to update your reporting based on new actions implemented in the supply chain and progress made

6.1.2 DEvELOP yOUR REPORTINg

You will need to develop both qualitative and quantitative reporting on actions taken to improve working conditions in the supply chain.

Qualitative reporting includes a description of your engagement and a rationale for your approach. It can include the following topics:

• Your ambition and goals

• Standards covered (e.g. the BSCI code)

• Internal team training and coaching on social responsibility and human rights

• Your monitoring approach

Quantitative reporting must, as a minimum, be in line with regulatory requirements when these specify precisely the key performance indicators (KPIs) to report against. If no particular KPIs are specified, you should start to develop basic KPIs anyway: this will facilitate the management of social compliance and will be useful in case you are further questioned on your approach. To define these KPIs, get inspiration from your direct competitors, CSR leaders in your industry or other BSCI participants (see Step 7).

STEP 6: get Started!


For a long-term approach, you can also have a look to the GRI guidelines (see Step 7), but that is not an easy task if you are not yet totally comfortable with CSR jargon. As a minimum you can build your approach on existing KPIs with your company and the BSCI database:

• procurement basics: Main sourcing zones and countries, number of suppliers

• bSCI kpIs: Number of audits and re-audits implemented during the year; % of suppliers covered

• Other: % of buyers and merchandisers trained

SPOTLIgHT 10: Should you Report on Audit Results?

Reporting on BSCI audit results is considered best practice as it constitutes a major initiative for transparency. Nonetheless, reporting quantitative data on BSCI audit outcomes is not an easy decision to take when you are not required by regulations to do so.

For example, if you are at a starting point of BSCI implementation, your stakeholders may not understand why a significant share of your factories are “non compliant”, or what that means. As a result, you will need to get into much more detail to describe typical non-compliances along with your continuous improvement approach.

A lot of experienced BSCI participants recommend enriching external reporting only when you feel ready to. Therefore we would recommend that BSCI participants with less than three years of experience in social compliance adopt a step-by-step approach, by reporting first qualitative information and KPIs related to implementation measures in their first years of reporting, before disclosing additional information on detailed results achieved.

6.1.3 ENgAgE TEAmS

Reporting on your social approach in the supply chain presupposes that you have developed beforehand effective internal communication to ensure that the information is provided in good time (see Step 6.2). You should therefore develop an internal communication plan dedicated to the fulfilment of your regulatory reporting, targeting the following audiences:

• CSR department (or other CSR practitioners)

• Sourcing, procurement and quality departments, buying offices

• Financial reporting and corporate communication teams


6.2 INTERNAL COmmUNICATION AS A PREREqUISITE TO ANy CSR ExTERNAL COmmUNICATION

Internal communication is just as important as external communication. Internal communication might even be seen as a prerequisite for any CSR external communication. Internal communication helps to ensure that all your colleagues speak with one voice and provide the same consistent information on your CSR programme. This is highly important when communicating on responsible supply chain management as some areas of communication can be considered sensitive.

Some tips to define and develop your internal communication strategy:

6.2.1 TARgETED AUDIENCES

There are three different kinds of audiences:

1. One group consists of people working directly with you or within the CSR organisation. They include CSR or procurement colleagues, people you are reporting to, or other key executives contributing to the development of your CSR approach (communication, marketing, supply chain, sales force etc.) These are key partners!

2. The second target group is made up of all executives who work more broadly within your organisation. Too often, responsible supply chain executives are too busy to tell people within their organisation what they are working on and why it benefits both the company, partners and suppliers and sourcing countries ultimately. If you do not tell them what your project is about and its benefits, they will not know about it. Informing people might also help you develop a “network” of backers or endorsers

3. finally, a third target can be your company at large. Even if employees at large might not have a direct role in the implementation of your CSR programme, because they are also citizens and consumers they are probably very interested in what your company is doing in the field of CSR and sustainable development. When you start revealing targets and achievements, you might be surprised to see how communication can boost cohesion, identity, pride, and a feeling of belonging in your company

SPOTLIgHT 11: managing the Information Flow Throughout the Supply Chain

This guide is about communicating and valuing your engagements and your initiatives to improve working conditions in high-risk countries, including through your participation in BSCI.

It does not explicitly cover information management towards your supply chain (i.e. informing suppliers and partners of your participation in BSCI, of their roles and your expectations etc.). You will find more information on this topic in the BSCI Terms of Implementation (TOI).


6.2.2 AImS AND OBjECTIvES

An internal communication strategy should be planned using the same framework as that for an external communication strategy (see section 5). The importance of aligning internal and external CSR communication is often underestimated by companies although it is a strategic matter to avoid confusion and ensure the commitment of your colleagues to your CSR programme.

The following objectives could be included in your mid-term strategy:

1. for key internal partners:• Ensure colleagues commit to / feel part of the project or know their responsibilities and tasks

• Prepare the development of internal reporting

2. for broader company executives:• Share what results are produced, how the organisation benefits from the results

• Inform colleagues on the organisation and main contact persons (key executives, line of responsibilities etc.)

3. for the company at large:• Raise awareness on your programme internally (what is done, why and when, deadlines etc.)

6.2.3 TOOLS

There are a number of different ways that you can communicate internally. You can use tools dedicated to CSR or include your CSR messages within existing communication channels.

Below are a few suggestions that you could consider:

• One-way communication: Newsletters, corporate intranet, leaflet and flyers

• Two-way communication: Meetings and conference calls, internal conferences, team-building events, blogs and other corporate social networks tools, etc.

6.3 ExTERNAL COmmUNICATION: kEEP IT SImPLE AND SHOW HUmILITy

If your company is classified amongst the “beginners” in our CSR maturity table (see section 4), external communication should be a mid -term objective, after you have developed internal communication. If your company is already “engaged” in CSR communication, communicating on your supply chain should be your next challenge.


6.3.1 TOP gOALS TO ACHIEvE WITH yOUR FIRST COmmUNICATION

The most common goals defined by companies when they communicate on responsibility in the supply chain for the first time are the following:

• To overcome blank page syndrome: This is a fact, it does not seem like a valid goal. For anyone who has struggled to convince executives that being accountable on CSR was the right thing to do, getting started is highly symbolic

• To provide centralised information for those interested in CSR (partners, clients and customers, students and job applicants etc.) and more specifically on what your company is doing in the supply chain

• To show that your company‘s approach to sustainable development goes up to the supply chain and working conditions in the factories producing your products

• To reassure clients and customers after a crisis in your industry

6.3.2 kEy CONTENT AND mESSAgES

Your communication should be:

• factual and straightforward: Focus on the key aspects of a responsible supply chain programme (ambi-tion and goals, standards covered and monitoring approach through your participation in BSCI) and progressively give visibility on your objectives and key actions implemented.

• Simple: Your first communication does not have to be long. It has to be clear, in order for your audience to understand easily what you try to achieve, without any possible confusion.

• Humble: Keep focused on your engagements and your efforts without crying victory (even worldwide leaders do not cry victory when it comes to responsible supply chain management!) Improving working conditions in the supply chain is a long journey and humility is a necessity. That is also the best way to avoid any form of greenwashing (see Step 2).

SPOTLIgHT 12: main Benefits Associated with External Communication on BSCI

• Demonstrate a positive commitment in the following areas:

• Social responsibility, social compliance or communities

• Human rights protection

• Ethical sourcing, sustainable procurement, responsible supply chains

• Support your commitment with:

• A reference to solid standards

• Participation in an initiative that promotes continuous improvement

• Fruitful cooperation with other companies

• An appropriate answer to

• Growing expectations on the company’s role and responsibilities in worldwide supply chains

• New expectations from major brands and retailers in terms of risk prevention and social traceability


6.3.3 CORPORATE COmmUNICATION FIRST

Generally, first communication campaigns on responsible supply chain management sit within corporate websites in order to target different kinds of stakeholders. It is often inaccessible from the homepage but easily identifiable within sections dedicated to either CSR, product quality, ethics or other commitments. This voluntary lack of visibility aims at targeting a limited audience looking precisely for CSR information.

Nonetheless, to facilitate access to CSR information from interested customers, the following options are often implemented:

• Place a link on your commercial website that brings visitors to your corporate website or directly to the corporate section dedicated to your CSR approach. Do not forget that a majority of consumers visit company websites to prepare their purchases

• Inform your commercial colleagues (sales force, customer relations) that the company communicates on its approach on its corporate website so that they can redirect customers who want to know more

Smaller B2C companies have generally one website only that includes both corporate and commercial information. Because they are less scrutinised than well-known brands and major retailers, a majority of them start to communicate externally through their commercial website. See, for example, the Mistral Home website, below: Participation in BSCI is clearly presented as part of the value offered by the company to its clients.


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other commitments. This voluntary lack of visibility aims at targeting a limited audience looking precisely for CSR information.

Nonetheless, to facilitate access to CSR information from interested customers, the following options are often implemented:

Place a link on your commercial website that brings visitors to your corporate website or directly to the corporate section dedicated to your CSR approach. Do not forget that a majority of consumers visit company websites to prepare their purchases.

Inform your commercial colleagues (sales force, customer relations) that the company communicates on its approach on its corporate website so that they can redirect customers who want to know more.

Smaller B2C companies have generally one website only that includes both corporate and commercial information. Because they are less scrutinized than well-known brands and major retailers, a majority of them start to communicate externally through their commercial website. cf. the Mistral Home website below: participation in BSCI is clearly presented as part of the value offered by the company to its clients.

Mistral Home sells high-quality home textiles for bed, table and interiors to European supermarkets

Mistral Home sells home textiles to European supermarkets


STEP 7: keep up the momentum...7.1 WHy gO BEyOND BASIC CSR COmmUNICATION ON THE SUPPLy CHAIN?

Having developed a comprehensive internal communication plan and started to report externally on actions taken to improve working conditions in the supply chain, you are probably ready to take it a step further and increase the breadth of your communication.

The goal is not to make you a CSR leader at this stage, but rather to:

• Align your communication with the minimum expectations of your stakeholders

• Reposition your company within industry standards

• Fully value your work in the supply rather than just give a taste of your commitments

• Increase the benefits of responsible supply chain communication

7.2 PREREqUISITES

To make your communication plan more robust you will need:

1. Full endorsement from top management – a clear CSR strategy would obviously be a plus

2. Secondly, a quite solid CSR programme in place, meaning that all key CSR issues are on your radar (even if you have not started working on all of them). Particularly as far as responsible supply chain management is concerned, it is not necessary to have had a programme in place for ten years, but you do need to master the main social issues in your sourcing countries and have a good understanding of international standards, topical issues and best practices in your industry

3. Next, to be fully aware of both strengths and weaknesses of your supply chain approach, in order to clearly identify what your areas of improvement are

4. Finally, you will need a crisis communication plan to be effective if a crisis arises. If not, all your efforts to value your company might be undermined by poor communication

All this will mean that the communication ground work is sufficiently solid and that you are ready for a higher level of accountability in the supply chain.


7.3 gROW ExISTINg PRACTICES FIRST AND THEN gO FURTHER

The first thing would be to improve existing communication initiatives by increasing accountability on topics you already report on (e.g. communicate your objectives and main results reached) and by extending the scope of your communication (e.g. by adding new topics in which your company has taken significant steps). Then you will need to push the boundaries of your communication plan.

7.3.1 INTERNAL COmmUNICATION

You have various options for building on your actions.

You can first strengthen your communication to targeted audiences in order to maximise your CSR impact and increase benefits for the company. This can range from comprehensive awareness raising programmes for all procurement staff (in order to ensure there is a real alignment between CSR engagements and procurement practices) to sophisticated campaigns aimed at your sales force:• Provision of a sales brief on your social programme in the supply chain in order for colleagues to easily

answer customer and client questions, or to develop sales pitches

• Ongoing communication on your initiatives including position papers with corporate explanations each time issues become topical for NGOs and the media

You can also improve your communication as a whole by making it more comprehensive, engaging, and interactive. Some companies choose, for example, to develop internal blogs and other social networks to keep colleagues updated; others organise internal awards or implement sophisticated idea management tools to receive colleagues’ inputs on their responsible approach.

7.3.2 CSR REPORTINg

CSR reporting is clearly a field where communication can be continuously improved. The objective is to address mostly professional audiences (shareholders, partners, media, students, CSR experts etc.). For B2B companies CSR reporting can be communicated to clients to support the description of your approach and demonstrate progresses.

Several BSCI members (incl. Metro, Rewe, Otto Group, etc.) have developed advanced practices in this area, and it is worth getting inspiration from what they have been developing for years. You will find on the following page, an example where both corporate and BSCI information have been used to build a comprehensive reporting on social compliance in the supply chain.



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On-going communication on your initiatives including position papers with corporate explanations each time issues become topical for NGOs and the media

You can also improve your communication as a whole by making it more comprehensive, engaging, and interactive. Some companies choose, for example, to develop internal blogs and other social networks to keep colleagues updated; others organize internal awards or implement sophisticated idea management tools to receive colleagues‟ inputs on their responsible approach.

7.3.2 CSR reporting CSR reporting is clearly a field where communication can be continuously improved. The objective is to address mostly professional audiences (shareholders, partners, media, students, CSR experts etc.). For B2B companies CSR reporting can be communicated to clients to support the description of your approach and demonstrate progresses.

Several BSCI members (incl. Metro, Rewe, Otto etc.) have developed advanced practices in this area, and it is worth get inspiration from what they have been developing for years. You will find below an example where both corporate and BSCI information have used to build a comprehensive reporting on social compliance in the supply chain.

For those companies whose strategy is to invest in CSR reporting, the Global Reporting Initiative (GRI) should be an additional source of inspiration. GRI is today considered as the CSR reporting norm worldwide. It provides a list of detailed KPIs across all CSR fields and these are often referred to in regulations on reporting. Reporting on your actions in the supply chain against the GRI framework (the latest version is the GRI G4) is quite an ambitious project, and should be prepared over two or three years.


SPOTLIgHT 13: Supply Chain Related Standards Disclosures in gRI (g4)

The standard disclosures related to supply chain are placed in different sections of the GRI guidelines. Here is an overview of where the supply chain related standard disclosures can be found:

• GENERAL STANDARD DISCLOSURES

- Organisational Profile: G4-12 (p. 27), G4-13 (p. 27)

- Governance: G4-41 (p. 38)

• SPECIFIC STANDARD DISCLOSURES

- Category: Economic

- Procurement Practices: G4-EC9 (p. 51)

- Category: Environmental

- Energy: G4-EN4 (p. 53)

- Emissions: G4-EN17 (p. 58)

- Supplier Environmental Assessment: G4-EN32 (p. 63), G4-EN33 (p. 63),

- Category: Social

- Sub-Category: Labour Practices and Decent Work

- Occupational Health and Safety: G4-LA6 (p. 66)

- Supplier Assessment for Labour Practices: G4-LA14 (p. 69), G4-LA15 (p. 69)

- Sub-Category: Human Rights

- Freedom of Association and Collective Bargaining: G4-HR4 (p. 72)

- Child Labour: G4-HR5 (p. 72)

- Forced and Compulsory Labour: G4-HR6 (p. 73)

- Supplier Human Rights Assessment: G4-HR10 (p. 74), G4-HR11 (p. 74)

- Sub-Category: Society

- Supplier Assessment for Impacts on Society: G4-SO9 (p. 78), G4-SO10 (p. 79)


CSR MATURITY LEVEL KPI TO REPORT* SOURCES LINKS WITH G4

beGINNeR

Ambitions and goals on responsible supply chain management

Company’s internal records BSCI vision and missions

G4-15

Standards covered BSCI Code of Conduct G4-15

eNGAGeD

Description of the monitoring approach BSCI Terms of Implementation (TOI) G4-DMA

Description of capacity building activities undertaken towards colleagues and suppliers

Company’s internal recordsBSCI CB activities description

G4-DMA

Main sourcing zones and countries, incl. risk countries

Company’s internal recordsBSCI platform

G4-12EC9

COMMITTeD

Number of suppliers, incl. in risk countries Company’s internal recordsBSCI platform

G4-12EC9

Company’s organisation and line of responsibilities on responsible supply chain management

Company’s internal records G4-12G4-13

Detailed description of the company’s policy (e.g. zero tolerance policy) and core processes

Company’s internal recordsBSCI terms of Implementation

LA15 LA16HR11 G4-DMA

Number / % of buyers and merchandisers trained Company’s internal recordsBSCI secretariat

G4-DMA

Number of audits implemented; % of suppliers covered in risk countries


LA14 LA15 HR10

Number of re-audits implemented; % of suppliers covered


HR10

Number / % of suppliers participating in capacity building activities

Company’s internal recordsBSCI platform (if registered with the participant’s name)

HR4 HR5 HR6

Procurement value by sourcing zones and countries, incl. risk countries

Company’s internal recordsBSCI platform (depending on data uploaded by participants)

EC9

Number of suppliers by sourcing zones and countries, e.g. risk countries


HR4 HR5 HR6

LeADeR

Description of the company’s position on topical / emerging issues

Company’s internal recordsBSCI Code of ConductBSCI position papers

LA15SO9

SO10

Overall/ year-on-year audit results (global and by sourcing country)

BSCI platform HR11

Description of company’s due diligence processes Company’s internal recordsBSCI TOI

G4-DMA

Overall/ year-on-year non-compliances areas (global and by sourcing country)

BSCI platform LA6 HR4 HR5 HR6 HR11

Main capacity building programme results Company’s internal records HR4 HR5 HR6

*All GRI 4 KPIs should be covered and / or the company have assessed the opportunity to develop an “Integrated Reporting”

CSR reporting should be externally assured

kPIs to Report by maturity Level


7.3.3 CORPORATE AND mARkETINg COmmUNICATION

At this stage, many companies have developed their CSR engagement into some product ranges, above all by providing clients and consumers with ecological alternatives. Solid social claims on products are pretty rare(except for certified products) as marketing products on human rights platforms requires prudence. If this is still in your plans, you should get in touch with BSCI but also question legal and CSR experts.

SPOTLIgHT 14: BSCI Participation Should Not be mentioned on Products

Except when labels such as “fair trade” certification are used, social claims for products are extremely challenging to develop and manage. Opportunities to integrate social claims into product marketing should be assessed very comprehensively and with great caution, as this is one of the primary causes of attack from NGOs. In addition, please note that none of the BSCI communication signage or mention should be stamped on products as BSCI is not a certification body.

Corporate and brand communication are two areas where valuing your social actions in the supply chain will be easier. But once again the more you except visibility from your communication campaign, the better you should be prepared to avoid a boomerang effect.

To limit risks and to target audiences better, B2C companies usually totally dissociate their communication to customers from that to other audiences:

• Content can be very different with communication to consumers focusing on less sensitive issues (envi-ronment, community issues for example)or topics closely related to consumption channels (product safety, green products, packaging etc.)

• Content can be similar but with greater detail on the approach provided for specialist audiences

• The channel used can vary from very simple web pages on commercial websites to dedicated mini-web-sites for shareholders and other CSR specialist (ex: SRI analysts, media). Usually, interested consumers can access companies’ most advanced information thanks to a system of web links from the commer-cial websites



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extremely challenging to develop and manage. Opportunities to integrate social claims into product marketing should be assessed very comprehensively and with great caution, as this is one of the primary causes of attack from NGOs. In addition, please note that none of the BSCI communication signage or mention should be stamped on products as BSCI is not a certification body.

Corporate and brand communication are two areas where valuing your social actions in the supply chain will be easier. But once again the more you except visibility from your communication campaign, the better you should be prepared to avoid a boomerang effect.

To limit risks and to target audiences better, B2C companies usually totally dissociate their communication to customers from that to other audiences:

Content can be very different with communication to consumers focusing on less sensitive issues (environment, community issues for example)or topics closely related to consumption channels (product safety, green products, packaging etc.).

Content can be similar but with greater detail on the approach provided for specialist audiences

The channel used can vary from very simple web pages on commercial websites to dedicated mini-websites for shareholders and other CSR specialist (ex: SRI analysts, media). Usually, interested consumers can access companies‟ most advanced information thanks to a system of web links from the commercial websites.

REWE Commercial website homepage

REWE commercial website homepage


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BSCI presentation in CSR section on REWE GROUP website (institutional website)

Section dedicated to sustainability on REWE Commercial website

Section dedicated to sustainability on REWE commercial website



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BSCI presentation in CSR section on REWE GROUP website (institutional website)

Section dedicated to sustainability on REWE Commercial website

BSCI presentation in CSR section on REWE GROUP website


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Discrete access to Sustainability section at the bottom of Colruyt’s commercial website:

The REWE Sustainability report describes extensively the Group‟s responsible actions (incl. details about objectives, measures and progress). In this section, the Group also communicates its Guidelines for Sustainable Business Practices.

The REWE sustainability report describes the Group’s responsible actions (e.g. details about objectives, measures and progress). In this section, the Group also communicates its Guidelines for Sustainable Business Practices.



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Discrete access to Sustainability section at the bottom of Colruyt’s commercial website:

The REWE Sustainability report describes extensively the Group‟s responsible actions (incl. details about objectives, measures and progress). In this section, the Group also communicates its Guidelines for Sustainable Business Practices.

Discrete access to sustainability section at the bottom of Colruyt’s commercial website


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CSR communication on Coruyt Group institutional website is limited…

Coruyt’s communication toward consumers covers environmental initiatives taken by shops

Colruyt’s communication toward consumers covers environmental initiatives taken by shops



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CSR communication on Coruyt Group institutional website is limited…

Coruyt’s communication toward consumers covers environmental initiatives taken by shops

CSR communication on Colruyt Group institutional website is limited...


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... but the Group has developed a mini website on CSR

... but the Group has developed a mini website on CSR


8.1 WHAT yOU NEED TO REACH FOR THE STARS

To become a CSR leader in your industry (and even more, an internationally recognised CSR leader) you need careful planning and a long-term investment in CSR.

Some leaders have developed a wide-ranging comprehensive corporate approach, covering all their CSR challenges, while others have adopted a strong selective position (whereby brand communication on CSR focuses mainly on one powerful topic that becomes iconic). Such a stance can bring them CSR fame (e.g.: the Body Shop on the ban of animal testing; some specialised retailers on organic or locally produced products, etc.).

Whatever your strategy or the industry in which you operate, you will need the following attributes to go further and aspire to leadership status:

• A clear (and detailed) CSR strategy, approved and endorsed by the Board and visibly aligned with corpo-rate positioning and brand platforms

• Committed and knowledgeable top management, able to communicate publicly on CSR

• A very robust and global CSR programme covering all material and latent issues for your company

• Some leading practices in the CSR field. In the supply chain area, these could consist of, for example: innovative projects on living wage, a high level of traceability (well beyond tier-2 suppliers), a ground-breaking partnership with NGOs to improve factory working conditions, etc.

• Strong capabilities and experience in stakeholder dialogue and existing partnerships with key NGOs and influencers.

8.2 CSR LEADERSHIP COmES WITH BENEFITS

What leaders have said about the main benefits they receive from their CSR positioning:

• Worldwide visibility well beyond your industry and countries of operation (including awards, media coverage etc.)

• Increased brand value translated into loyal customers and strong client confidence, sympathy and robust credibility (well beyond the CSR field)

• A sharp decrease in attacks against the company and its brands from stakeholders

• Easier management of CSR alerts or crises due to the company’s credibility and experience

• The development of a “brand preference” and, depending on the CSR strategy and positioning, a possible increase in sales (e.g. green or fair trade product lines)

STEP 8: Become a Star...


8.3 THERE IS mORE THAN ONE WAy TO SHINE: NOTEWORTHy COmmUNICATION CAmPAIgNS

8.3.1 m&S: THE ACCOUNTABILITy LEADER


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8.3 THERE IS NOT ONLY ONE WAY TO SHINE: NOTEWORTHY COMMUNICATION CAMPAIGNS

8.3.1 M&S: the accountability leader

The M&S “Plan A” initiative was launched on 15 January 2007, to increase dramatically the sustainability of the business within 5 years. The plan covered "100 commitments over 5 years” to address the key social and environmental challenges faced by M&S with the tag-line "Because there is no Plan B". The commitments span five themes: climate change, waste, sustainable raw materials, 'fair partnership' and health.

Plan A was one of the most noticeable initiatives in the 2000s as it placed CSR accountability at the heart of M&S communication. For some experts, M&S is today the most responsible company worldwide.

The M&S “Plan A” initiative was launched on 15 January 2007, to increase the sustainability of the business within 5 years. The plan covered “100 commitments over 5 years” to address the key social and environ-mental challenges faced by M&S with the tag-line “Because there is no Plan B”. The commitments span five themes: climate change, waste, sustainable raw materials, ‘fair partnership’ and health.

Plan A was one of the most noticeable initiatives in the 2000s as it placed CSR accountability at the heart of M&S communication. For some experts, M&S is today the most responsible company worldwide.


8.3.2 PATAgONIA: THE ALTERNATIvE CONSUmPTION CHAmPION

“Don’t buy this jacket”, Patagonia’s campaign has been extensively discussed in the media, as it was launched when a lot of apparel retailers were facing sluggish consumer demand. Behind this iconic campaign, Patagonia adopted innovative approaches regarding product longevity and recycling, along with a comprehensive project on product traceability (The Footprint Chronicles).


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8.3.2 Patagonia: the alternative consumption champion "Don‟t buy this jacket", Patagonia‟s campaign has been extensively discussed in the media, as it was launched when a lot of apparel retailers were facing sluggish consumer demand. Behind this iconic campaign, Patagonia adopted innovative approaches regarding product longevity and recycling, along with a comprehensive project on product traceability (The Footprint Chronicles).


8.3.3 H&m AND NIkE: FULL TRANSPARENCy AS A LICENCE TO OPERATE ENABLER

More than 15 years ago, H&M was already amongst CSR leaders in the fashion industry. But at the time CSR communication was mainly targeted at CSR experts.

The group has progressively extended its communication coverage. Worldwide consumers can access detailed information on H&M’s programme, including the most sensitive topics such as remediation programmes in the supply chain for cases when a factory is found to have employed children.


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8.3.3 H&M and Nike: full transparency as a licence to operate enabler More than 15 years ago, H&M was already amongst CSR leaders in the fashion industry. But at the time CSR communication was mainly targeted at CSR experts.

The Group has progressively extended its communication coverage. Worldwide consumers can access detailed information on H&M‟s programme, including the most sensitive topics such as remediation programmes in the supply chain for cases when a factory is found to have employed children.

In the same vein, Nike was the first consumer good company to publish a list of its global supplier factories in 2005. Such a move was inconceivable for many brands and retailers as supplier details were generally considered to be valuable competitive information for the business. Nike claimed its initiative was a push for greater transparency and collaboration to improve labour conditions. Some experts saw in this initiative a way to avoid bad coverage associated with illegal subcontracting in sweatshops.

In the same vein, Nike was the first consumer goods company to publish a list of its global supplier factories in 2005. Such a move was inconceivable for many brands and retailers as supplier details were generally considered to be valuable competitive information for the business. Nike claimed its initiative was a push for greater transparency and collaboration to improve labour conditions. Some experts saw in this initiative a way to avoid bad coverage associated with illegal subcontracting in sweatshops.


8.3.4 mARSHALLS: THE CSR DON qUIxOTE

In 2007 Marshalls, a 3,000-employee construction company operating in the UK, denounced working conditions in the Indian industry by organising a dedicated communication campaign. Marshalls targeted both its clients (retailers and construction companies) and mass media with a dedicated leaflet.


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8.3.4 Marshalls: the CSR Don Quixote In 2007 Marshalls, a 3000-employees construction company operating in the UK, denounced working conditions in the Indian industry by organising a dedicated communication campaign. Marshalls targeted both its clients (retailers and construction companies) and mass media with a dedicated leaflet.

The company was at the source of a national debate on the sandstone industry and received several awards for its engagement in the supply chain. Moreover, without any help of social certification or similar schemes, Marshalls sandstone became a brand sought-after by British DIYers and construction companies.

The company was at the source of a national debate on the sandstone industry and received several awards for its engagement in the supply chain. Moreover, without any help of social certification or similar schemes, Marshalls sandstone became a brand sought-after by British DIYers and construction compa-nies.


8.3.5 SWITCHER: THE ETHICAL COmPANy

Switcher can be called an ethical company as its business model was developed to serve a social purpose: “Minimalist garments declined in a wide choice of colours [...] our commercial activity must be compatible with ethical production”.

Beyond this statement, Switchers developed a 100% traceable supply chain that supports Switcher’s base-line “made with respect”.

The company recently received wide media coverage for its initiatitive, allowing customers to examine detailed aspects of the supply chain of their preferred product by scanning its bar code with their smart-phone (incl. eco-certificates, socal compliance etc.)


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8.3.5 Switcher: the ethical company Switcher can be called an ethical company as its business model was developed to serve a social purpose: “Minimalist garments declined in a wide choice of colours [...] our commercial activity must be compatible with ethical production”.

Beyond this statement, Switchers developed a 100% traceable supply chain that supports Switcher‟s baseline “made with respect”.

The company recently received wide media coverage for its initiatitiveallowing customers to examine detailed aspects of thesupply chain of their preferred product by scanning its bar code with their smartphone (incl. eco-certificates, socal compliance etc.).


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8.3.5 Switcher: the ethical company Switcher can be called an ethical company as its business model was developed to serve a social purpose: “Minimalist garments declined in a wide choice of colours [...] our commercial activity must be compatible with ethical production”.

Beyond this statement, Switchers developed a 100% traceable supply chain that supports Switcher‟s baseline “made with respect”.

The company recently received wide media coverage for its initiatitiveallowing customers to examine detailed aspects of thesupply chain of their preferred product by scanning its bar code with their smartphone (incl. eco-certificates, socal compliance etc.).


8.3.6 PUmA: mESSAgES OF INNOvATION AND OPERATIONAL ExCELLENCE

Puma is an interesting case if we compare two initiatives launched by the brand within a short period of time.

First the “clever little bag”, a new generation of shopping bag for Puma shoes.

On the customer side:

• A reusable (and fashionable) bag

• Including a sustainable matrix to enable product labelling

• Note the use of the red colour (instead of green) that makes the product highly visible in multi-brand shops with its smart merchandising

For CSR specialists, Puma delivers:

• Deep R&D in the product involving several experts

• An eco-friendly solution that reduces cardboard (compared to a standard shoe box) and transport related impact (lighter packaging)

• Additional cost savings

More than just a little bag, Puma’s “clever little bag” has become iconic and a symbol of Puma’s commit-ment to environmental stewardship.

Later, Puma completed the first-ever environmental P&L with Trucost. A communication campaign was launched to target CSR experts and specialised media, including a very ambitious project to rally other brands on environmental accounting.

Two different campaigns, same values. Puma is building the robust image of a committed brand thanks to selective positioning based on environmental performance and operational excellence. Two topics totally in line with sportswear industry values.


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8.3.6 Puma: messages of innovation and operational excellence Puma is an interesting case if we compare two initiatives launched by the brand within a short period of time.



A reusable (and fashionable) bag

Including a sustainable matrix to enable product labelling

Note the use of the red color (instead of green) that makes the product highly visible in multi-brand shops with its smart merchandising


Deep R&D in the product involving several experts

An eco-friendly solution that reduces cardboard (compared to a standard shoe box) and transport related impact (lighter packaging)

Additional cost savings

More than just a little bag, Puma‟s "clever little bag" has become iconic and a symbol of Puma‟s commitment to environmental stewardship.




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8.3.6 Puma: messages of innovation and operational excellence Puma is an interesting case if we compare two initiatives launched by the brand within a short period of time.



A reusable (and fashionable) bag

Including a sustainable matrix to enable product labelling

Note the use of the red color (instead of green) that makes the product highly visible in multi-brand shops with its smart merchandising


Deep R&D in the product involving several experts

An eco-friendly solution that reduces cardboard (compared to a standard shoe box) and transport related impact (lighter packaging)

Additional cost savings

More than just a little bag, Puma‟s "clever little bag" has become iconic and a symbol of Puma‟s commitment to environmental stewardship.



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How to Communicate on Corporate Responsibility in the … · 2015-06-24 · How to Communicate on Corporate Responsibility in the Supply Chain: ... situation, let alone communicate