Statement in response to the SOMO Report from the Rainforest Alliance
The Rainforest Alliance takes the allegations contained within a report, Small Cup, Big Difference by the Netherlands-based Center for Research on Multinational Corporations (known by its Dutch acronym as SOMO) very seriously. In response we wish to place the following on record.
The standards to which the Rainforest Alliance Certified™ farms and estates are certified are set by the Sustainable Agriculture Network (SAN), an independent organization consisting of a range of conservations groups including the Rainforest Alliance. The Certification Body authorized by the SAN, Sustainable Farm Certification (SFC), manages the certification process and is ISO65 compliant.
SAN/Rainforest Alliance are a founder and full member of the ISEAL Alliance, the global association for social and environmental standards.
The auditing process in the certification system consists of annual programmed audits and, where necessary, unscheduled audits between the programmed audits. In order to become certified, a farm needs to fully comply with 15 critical criteria in the standard. Furthermore, an overall score of over 80 percent is required, as well as over 50 percent compliance within each of the ten principles of the standard. Certification promotes continuous improvement as we believe implementing sustainability in agriculture is a journey.
SAN audits are conducted by well-trained inspectors who bring a great deal of experience to the work. Auditors are trained in agronomy, ecology, labor rights and rural development as well as in professional auditing techniques. They follow established procedures defined by the SAN. They are independent, unbiased and mission-driven. The Rainforest Alliance and SAN staff and auditors are constantly on farms and have visited the estates mentioned in the SOMO reports many times. All farms are treated equally in the certification process, no matter to which company they belong or supply their products to.
When complaints are received, a Research Audit is performed when sufficient evidence of non-compliance is found. This is a surprise inspection that corresponds to a complaint about a Rainforest Alliance Certified™ farm. Its objective is to thoroughly investigate the compliance with the respective valid SAN standards and policy documents.
The Rainforest Alliance and the SAN work to conserve biodiversity and ensure sustainable livelihoods by transforming land-use practices, business practices and consumer behaviour. It is not in our interest to keep farms certified that are violating the certification requirements. We act immediately upon substantiated claims made against certified farms. SFC regularly cancels certificates due to violation of certification requirements during annual audits, and even more farms fail to meet the certification requirements during their first certification audit.
During audits, auditors have complete freedom to talk to any workers, anywhere on the farm, and to inspect all relevant documents, such as training and pay records. The auditors also require meetings with workers and other committees to be done outside of management offices. Often surrounding communities are consulted. In this environment, auditors and workers are free to talk to each other. Auditors may stop an audit if this principle is not respected by the farm management. Audit teams are clear to farm management that interviews with workers must be conducted in a safe and neutral environment without management or other staff present.
Workers can make suggestions and complaints at any time, communicating to the estate managers, the company or the SAN in ways that protect their identity. SAN auditors and trainers gather information through these channels to support or challenge the findings of the audit report.
The 2010 SOMO reports and Research Audits
When reports of activities or practices that are not in accord with the SAN standards come from an external source, such as SOMO, SAN auditors need concrete information in order to investigate the specific incidences that form the subject of the complaint. We understand the need to protect the identity of workers; SAN auditors have extensive experience in investigating sensitive issues while ensuring the anonymity of laborers and farm workers. However without specifics, a Research Audit can only look for systemic problems by interviewing workers, reviewing records and the direct observation of practices.
After receiving unpublished reports on India and Kenya in September 2010, we asked SOMO to provide the names of the workers who articulated the allegations in order to perform Research Audits to investigate the complaints. SOMO let us know they could not send us a list of people they interviewed because the research was carried out guaranteeing the workers’ anonymity. Even though we did not have any factual information, we carried out Research Audits at the Kericho tea estate and the seven tea estates in India in October and November 2010 due to the serious nature of the allegations. Violations with the certification requirements were not found on these audits.
In Kenya, we work with SAN-accredited lead auditors from Africert, which also provides services to other certification schemes. The Research Audit carried out in November 2010 was done by two senior lead auditors, experienced in tea production and familiar with the issues raised by the SOMO survey. In relation to the specific allegations mentioned by the SOMO report in September 2010, our Research Audit of the Unilever Tea Kenya estate in Kericho did not find a violation of the SAN’s certification requirements.
It is possible to find complaints and violations of a comprehensive standard on any large farming operation that involves thousands of hectares and workers. The SAN auditors are trained to discern isolated incidences from systemic problems. Any noncompliance is recorded, but auditors look for patterns of noncompliance that may indicate a systemic fault. Meaningful and large-scale improvements can only be made by changing systems and practices through training.
SAN accredited lead auditors performed Research Audits in October and November 2010 on the seven mentioned estates in the report (Dunsandle Estate, Glenmorgan Tea Estate, Coonoor Tea Estate, Glendale Tea Estate, Havukal and Warwick Estates and Kairbetta estate in the Nilgiris and Behora Tea Estate in Assam) to assess the claims referred to in the SOMO report of 2010.
The audits included physical and document verification of the various points of concern, meetings with the respective estate managers, interviews with workers and union representatives in each estate as well as a meeting with the union leaders of five active unions in the Nilgiris. The workers and the Union leaders were interviewed without the presence of the management.
The research audits in the seven estates demonstrate that the claims related to the certification and referred to in the SOMO 2010 report are not verifiable in the field.
2011 SOMO Report
The results of the in depth 2010 Research Audits were shared with SOMO. The Rainforest Alliance met with SOMO on 5 April 2011 to discuss the results. SOMO have continued to decline requests by the Rainforest Alliance for specific evidence that would allow us to further investigate the allegations.
SOMO has also refused to engage in a discussion with the Rainforest Alliance about why the SOMO findings are so different from the SAN audit findings. It is clear that the SOMO researchers and SAN auditors receive different types of evidence in the field and we are very interested to learn from the SOMO researchers about their interview and research techniques in order to improve our social auditing training. We have hitherto requested SOMO to establish a direct dialogue with SOMO’s partners on the ground in India and Kenya but also this request was categorically denied.
The report, Small Cup, Big Difference repeats the allegations made in the previous reports but once more no concrete evidence has been provided. We cannot de-certify the afore mentioned tea estates based on the anonymous claims contained in this report and the lack of substantive evidence. We feel certain that ISEAL and other credible certification schemes would support us in this regard.
We are available to meet with SOMO again at any time to discuss their report findings, receive concrete evidence which will be treated in the strictest confidence, and work with them on finding solution to what we acknowledge is the difficulties encountered in the realm of labor conditions.
In responding to the SOMO report, the Rainforest Alliance followed ISEAL's best practices for handling complaints. This is the same process followed by all certification programs that are full ISEAL members.
It is important to note that as part of the SAN standards there is a requirement for those estates who have achieved Rainforest Alliance Certification to maintain a process of continuous improvement. This is also reflected in the regular reviews and updates of all aspects of the SAN standard. In this spirit the Rainforest Alliance has been working with the Kenyan tea industry on a training program for supervisors and managers designed and developed by the Ethical Trading Initiative entitled Promoting Equal Treatment of Workers. In India a series of local interpretation meetings have been held in 2010 and 2011 involving stakeholders including NGO’s, community groups and industry.
Reports are available confirming positive impact on the ground of Rainforest Alliance Certification. We agree with SOMO that more independent research on the impact of voluntary standard systems should be conducted to get a better grip on what is effective and what is not, and why this is so.
We believe that there is still a long way to go on the journey to sustainability in the tea sector -- still the majority of tea farms in the world are not participating in any certification scheme. Stakeholders interested in a more sustainable tea industry should in our opinion collaborate constructively. Unfortunately we consider the SOMO report to be undermining rather than constructive, and we are disappointed by their approach and publication.