Reporting against the CTF: ONE+All

In 2021 ETI published the Corporate Transparency Framework (CTF) which requires full ETI company members to publicly report against six minimum requirements relating to their human rights due diligence. This case study captures the impact CTF reporting has had for ETI Company member ONE+All.

What challenges did you face in meeting the Corporate Transparency Framework (CTF) minimum requirements?

We faced several challenges, including the need for a formal process to identify and prioritise human rights risks, difficulties in establishing internal governance structures due to our business size, and difficulties around capacity building for worker participation committees.

How did you overcome the challenges?

We addressed these challenges in different ways.  By developing structured risk assessment processes informed by ETI’s guidelines we were able to implement a formal approach for continuous monitoring and mitigation, this has resulted in our Salient Human Rights Issues report, which we review annually. Clarifying roles and delegating tasks within ONE+All’s team helped us to better manage our human rights governance and accountability. By leveraging ETI’s social dialogue programme in Bangladesh we were able to establish elected worker participation committees where trade unions were not present in our factories in Bangladesh and Egypt. We also enhanced our supply chain transparency by publishing more detailed information alongside social audit reports on tier 1 suppliers on our website and recently publishing this data on Open Supply Hub.

How did ETI support/influence/impact you along this journey?

ETI provided significant support through its Corporate Transparency Framework (CTF) guidelines and supporting materials (in particular 'How to Identify Human Rights Risks: A Practical Guide in Due Diligence'), which helped us develop a structured approach to identifying human rights risks. The social dialogue programme in Bangladesh was particularly impactful, enabling us to support the election of effective worker participation committees in our supply chains in factories in Bangladesh and Egypt where trade unions were not present. ETI’s resources and guidance were instrumental in shaping our governance structures and risk management processes and provided several valuable resources with additional insights.

What were you hoping to achieve, and did you manage to?

To meet the CTF requirements we needed to achieve a few different goals. Our main goals were to establish a formal risk assessment methodology, ensure transparency in our supply chain, and promote worker participation through elected committees where trade unions were not present. We have made progress in achieving these objectives by developing a comprehensive governance structure, improving our risk management processes, enhancing our supply chain transparency, and taking gradual steps towards establishing elected workers' participation committees in all our tier 1 suppliers.

What lessons did you learn from the experience?

We learned the importance of having clear governance structures, continuous risk assessment, and proactive risk management. Collaboration with local stakeholders and leveraging external support, such as ETI’s guidance, proved essential in achieving our goals; particularly in efforts to uphold freedom to association where contexts prove challenging. We also recognised the value of transparency and the need for ongoing monitoring and adaptation to evolving challenges in our supply chain.

Do you have any other reflections?

Before CTF, we felt that our annual assessments were divorced from the real work we do in our supply chain, and that they were merely a separate entity to comply with, rather than complement that work.

Through CTF's guidance, resources, and networks, we have seen an approach that not only captures and assesses the actual work we do with our suppliers, but also enhances and strengthens that work.

Consequently, we have already observed improvements in our relationships with suppliers, as well as an overall sense of improving and strengthening our human rights work.