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Appendix H Submissions following the Workshop
Pages 121-131

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From page 121...
... Dr. Chung's comments are included verbatim in this appendix.
From page 123...
... Workshop, a diverse group of stakeholders provided comments on the framework under development for identifying and organizing business practices to eliminate forced or child labor in the production of goods. The "Draft Criteria," intended to contribute toward the development of the framework, reflected a small portion of the Ad Hoc Committee's1 earlier reflections on the topic.
From page 124...
... Here, my argument is that a set of criteria should point to practices that are holistic and integrated – practices that demonstrate that the objective of eliminating child/ forced labor is integrated into the decision-making processes of every stage of the business' value chain, from product design and engineering, to raw material selection, manufacturing, to sales, marketing, and product decomposition.
From page 125...
... should demonstrate that the objectives of eliminating child/forced labor are integrated into the whole of the business' operational principles and practices. This includes the integration of the objective of eliminating child and/or forced labor into the decision-making processes of every stage of the business' value chain, from product design and engineering, to raw material selection, in-bound logistics (e.g., procurement, sourcing, pricing, etc.)
From page 126...
... For example, even if sound codes and manuals are developed and distributed to suppliers, if such practice is not matched by appropriate purchasing rules that prohibit repetitive rush orders and pricing wars, there may be built-in incentives for non-compliance. Moreover, even with model codes and monitoring systems in the manufacturing/processing sites, if the company's product design calls for use of raw material produced/mined exclusively in high risk parts of the world, no amount of "good" practice in the manufacturing stage could ensure the integrity of the business' efforts to eliminate child/forced labor.
From page 127...
... Given that forced labor and child labor occur in particular contexts with unique mix of historical, socio-economic, political, and cultural factors that enable such exploitation, the design and implementation of the practice should make evident how the particular business intervention contributes to tackling these systemic factors, addressing the root causes of the problem.
From page 128...
... Where the root causes have been adequately analyzed and prioritized by the business, the particular practice or intervention should aim to tackle the root causes, and where appropriate, coordinate efforts with local entities, including: o local authorities, where appropriate o other businesses, where appropriate and possible o community leaders and members of civil society Where possible, the practice should include from its design the input of the intended beneficiaries, such as the local business entities, community leaders, child/forced laborers, and families of the workers. Where the "practice" is intended to change the behavior of other business entities along the supply chain, it should build the capacity of the local entities (e.g., small-scale farmers, local producers, etc.)
From page 129...
... o Utilize sampling techniques that are designed to produce high level of certainty. Evaluations should demonstrate capacity for effective data management: o Establish baseline information.
From page 130...
... o Is the practice reducing forced labor? o Is the practice benefiting child laborers?
From page 131...
... , which is largely perceived as flawed and ineffective in preventing or eliminating exploitative labor conditions in major supply chains. While companies have invested considerable energy and resources to shoring up their CSR efforts, criticisms and frustrations continue, as demonstrable results are difficult to come by.


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