Daily Archives: September 5, 2010

Is a 45,000 fine in your future?

Any UK organization with half-hourly metered electricity that used more than 6,000 MWh in 2008 that does not register for the UK-wide CRC Energy Efficiency Scheme before September 30, 2010 could be fined as much as £45,000!

Previously known simply as the Carbon Reduction Commitment, the CRC Energy Efficiency Scheme is an emissions trading scheme introduced by the UK government to cut greenhouse gases by 1.2 million tonnes of carbon per year by 2020. Organizations are now required to monitor their emissions, and if they exceed this threshold, they need to purchase allowances to emit additional tonnes of CO2 or face a hefty fine.

The government estimates that as many as 5,000 organizations exceed the threshold, but only 1,229 have registered to date. Eligible private and public sector organizations that don’t meet the registration deadline will be immediately fined £5,000 plus an additional £500 penalty for every subsequent working day the company fails to register, to a maximum of 80 days. Is your company one of the roughly 3,800 that hasn’t registered yet? Are you sure?

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Supplier Audits Must Be Surprise To Be Effective

As per this recent article in CPO Agenda by Meryl Bushell on why ethical audits aren’t the final word on supplier standards, in the past few years, audits have been shown to be ineffective for workers and also to be increasingly affected by fraud, double bookkeeping and coaching for workers so that they give “the right answer”.

If a supplier who knowingly violates common standards on child labour, health, safety, and hygiene, working hours, and wages (among other things) knows that they are going to be audited on a given day, they are going to be prepared. They’ll send the child labour home. They’ll reduce the work force on that day to “safe” numbers (which is whatever number they have enough “show” protective equipment for and / or whatever number fits in the factory without overcrowding). They’ll make sure to give the staff that will be present that day some “time off” the previous two days (i.e. they’ll only work them 8 hours instead of 16) so they don’t look dog dead tired. And they’ll fix all the books so that everyone makes a “living wage”.

But if you show up unannounced, you’ll see how things really run. You’ll see whether or not they (regularly) use child labour. (In some situations, child labour is okay. We let our children work part time at McDonalds when they turn 13. If they only employ children part time for light work in safe situations, in struggling economies, that’s a good thing because it boosts the family income, teaches them responsibility, and gives them a better quality of life. But if they work the child labour 80 hours a week in the mines or on the shop floor, that’s a different story. In this situation, they should all get life in work-camp prison doing the same job.) You’ll also see how “safe” working conditions really are and whether or not their people are not overworked simply by counting the number of employees with bags under their eyes and lifeless faces. (And if you get to the office fast enough, you might even catch them with the real books on the table!)

In addition, as Meryl recommends, you should also make sure that the surprise audit includes a detailed forensic assessment and unsupervised off-site interviews with random workers. This type of audit can quickly reveal a range of serious problems including child labour, below-minimum wages, faked records and protective equipment provide only during audits even when the standard on-site audit reveals only minor issues.

Now it’s true that regular surprise audits can pose quite a resource strain on your suppliers, and a financial strain on the suppliers that aren’t committing ethical atrocities in particular, and that your average supplier shouldn’t be subjected to more than a couple of surprise audits each year, but this problem is easily rectified if you cooperate with other major customers of the supplier and hire a reputable third-party that specializes in ethical audits to perform the extended surprise audits (with forensics and off-site interviews) on your behalf. This way, the supplier knows that they won’t be overburdened with too many resource and productivity draining audits, without knowing when the semi-annual audits will actually happen. It’s a win for everyone.

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