What is expected of Buyers and the Market?
Everybody is talking about ‘Due Diligence’ and, more specifically, about the ‘EU Due Diligence Directive or ‘Supply-chain Due Diligence Act’, but what does this mean?
The main piece of regulation stems from the recently published Corporate Sustainability Due Diligence Directive, which was adopted by the European Union’s member states in May 2024. This directive will now require European companies, and in particular, retailers and importers buying and sourcing produce, to meet these environmental and social requirements. This new regulation requires companies to identify and prevent, end, or mitigate the actual and potential impacts of their activities on the environment and on the abuse of human rights.
In basic terms, the regulations will require these European companies to conduct due diligence on their own operations and the activities of their subsidiaries and other entities in their value chains with which they have direct and indirect established business relationships. This means that buyers will focus more and more on the actual practices of producers, evaluating the information and data in audit reports and looking at areas where improvement has not yet taken place or is needed.
Companies affected by these requirements will have to take and implement a risk-based system to:
- Monitor
- Prevent
- Remedy human rights or environmental damages
As each European country is working towards their own internal or national legislative framework, Germany has already promulgated the German Due Diligence Act. This identified grievance mechanisms as one of the main elements and required adequate grievance mechanisms to be available throughout the value chain to ensure transparency within the entire supply chain. This means that any incident reported against a supplier, whether it was done by a worker, trade union, NGO, media etc., will need to be addressed and investigated. The aim is to identify areas of possible remedy and remove potential environmental and human rights abuses within the supply chain. For more information on the Corporate Sustainability Due Diligence Directive, feel free to visit the European Commission’s page here: CSDDD.
Let’s look at how SIZA can help ensure that everyone in the supply chain, including producers, workers, auditors, buyers, civil society, labour providers, and others, has a voice which is in line with the above requirements.
Enhancing Accessibility and Effectiveness of Complaint Lines
We often think that the world of agriculture is rural, far away from busy city life, or even unreachable to those who do not work or live on farms. In today’s interconnected world, those who live and work on farms are much more intertwined with their surroundings than one would think. In a world where there is a network of requirements set by buyers and enforced on suppliers, it is very important to create a safe space where all voices can be heard.
By creating a voice for all, SIZA would like to ensure an environment where we can communicate over disputes and complaints to find common ground. In today’s digital environment, this allows everyone to have access to direct methods of communication and engagement. The same is true for all stakeholders in the value chain, as transparency and the digital age have allowed fast and up-to-date interaction between producers, buyers, and consumers.
Worker Voice
For various reasons, a business will benefit from allowing its employees to speak freely and resolve any issue directly with management. This allows for a faster turnaround time and builds more trusting relationships between employer and employee. It forms part of a business’ everyday responsibility to create an open and trusting relationship.
he SIZA programme provides multiple channels for agri stakeholders to file complaints regarding working conditions, treatment, and ethical violations. By using these channels, workers, producers, and stakeholders can report issues anonymously, ensuring their safety and encouraging more individuals to come forward without fear of retaliation. This helps rectify immediate concerns and fosters a culture of transparency and continuous improvement in working conditions. Workers have access to multiple channels to launch a complaint to SIZA, which includes a toll-free hotline, WhatsApp, email, an online complaints line that feed directly into the MySIZA Platform and by completing a formal complaints form in person at the SIZA office and on our website. The complaints form can be downloaded and completed here: Complaints Form.
Producer Voice
Similarly, a producer member of the SIZA programme can get their voice heard by contacting the SIZA office or its staff through multiple platforms, as mentioned above, especially if they have a complaint against a particular auditor or know of another member who might be implementing illegal practices. If a business, for example, knows of a neighbouring farm or another business that is implementing illegal practices on purpose, they can follow this process to ensure it gets investigated.
Further to this, a producer can also launch a grievance/complaint against an auditor if an auditor acts outside of the audit process and methodology. This can be in cases where the auditor acts outside their mandate or scope or misbehaves against the business or its staff. Producers can also file a dispute in cases where the producer disagrees with a particular finding made during a third-party audit. This process involves an independent process whereby SIZA will anonymise the dispute and share it with independent experts, including lawyers, producers, industry experts, etc., to provide their independent opinions on the case study. Based on the majority opinions, a recommendation is made to the audit firm on whether the finding will remain as it is or might need to change based on the majority opinion. This way, the producer remains anonymous, and the finding allocation remains objective. For more information on the process, feel free to read up on it here: Third-party Audit Dispute Process.
Auditor Voice
Third-party auditors and audit firms are major role players in the value chain. Because compliance is so important, it’s essential to allow auditors to conduct their duties adequately and to ensure auditors have a voice and feel safe during audits. Auditors can launch grievances if they are mistreated or see a practice that is not correct. SIZA will engage with the audit firm to understand whether remedial action can be taken or if further investigation is needed. As auditors remain an integral part of the process, they can view the process regarding complaints here: Third-party Auditors Complaints Mechanism.
Civil Society and NGOs
As civil society plays a significant role in representing agri-workers and their interests, it’s sometimes necessary to understand that grievances are directly launched/disused with trade unions, NGOs or other groupings with which the worker might be affiliated. In these cases, SIZA also allows these interested parties to engage with the complaints process and grievance mechanism of SIZA. By ensuring this, SIZA enables a voice for workers who might need to be more comfortable speaking to the farm directly or prefer working with their representatives.
Further, ensuring that every stakeholder within the value chain’s voice is heard is crucial for maintaining ethical practices and continuous improvement, particularly within the agricultural sector. This is also true for Temporary Employment Services, as they play a significant role in the employment cycle of South African agriculture. If these Temporary Employment Services experience any wrongdoing, they can also file a grievance, which can be followed up on through the appropriate channels.
Expectations of Buyers
Buyers, including retailers and importers, benefit significantly from SIZA’s complaint mechanisms. By allowing complaints to be addressed through a rigorous process, risks within the supply chain are managed. SIZA’s engagement with all stakeholders in the value chain allows everyone to take hands and work together to remove potential risks and address areas where challenges might exist. It is also essential to remember that buyers require data on complaints and grievances, as is evident from recent Due Diligence Directives in the EU. This transparency lets buyers make informed decisions about their supply chains, ensuring they source products from compliant and ethical producers.
SIZA offers a comprehensive model for this through its programme, which includes robust mechanisms for raising and addressing complaints, as seen in the schematic representation. These multiple complaint mechanisms feed directly into the MySIZA Platform and are recorded and captured so that data can be shared at any given time.
How does the SIZA Grievance & Complaints Process work?
To ensure all the parties have adequate avenues to launch complaints, SIZA provides options to raise a grievance through email, toll-free hotline, WhatsApp, MySIZA Platform, in person, or on social media. The complaint will then be centralised to the SIZA complaints committee, which will appoint an investigator to the individual complaint. The investigator will determine whether the complaint is deemed to fall under the SIZA mandate, and if not, the complainant and complainant will be referred to the relevant party or organisation for assistance. If the complaint falls within the SIZA mandate, the investigator will allow the stakeholders to be informed of the complaint and conduct a review/investigation. Once it’s completed, the remedial action will be implemented, and again, the stakeholders, such as buyers and other interested parties, will be engaged to understand the best remedy possible. The complainant will also receive feedback on the outcome once it is finalised.
By ensuring that the voices of all are heard and addressed, SIZA promotes a multi-faceted approach that includes the use of digital platforms for easy access and monitoring. These methods include something that can work for anyone, such as in-person visits to the SIZA office, anonymous toll-free hotline, email, WhatsApp line, social media or via the MySIZA platform.
Visit the official SIZA website (www.siza.co.za) for more information on its complaint mechanisms and other initiatives.