1 The ISO process
2 Committee Draft CD1
2.1 CD1 Strengths
2.2 CD1 Concerns
2.2.1 ISO 26000, a set of options to select from
2.2.2 User survey, acceptance/suitability
2.2.3 Boundary between ISO 26000 and applicable law and regulation
2.2.4 Role of governments, regulatory practices
3. Comments on CD1 in detail
4. Voting options
1. The ISO process has the following stages:
New Work Item Proposal
ISO Member Bodies (some 150), also called National Committees (NC)
Working Group (WG) experts
WG asks NC for comments; NC comments (or comments and votes); WG experts address comments
Draft International Standard
NC votes and may comment; WG experts address comments
Final Draft International Standard
NC votes (only YES, NO or abstains; no further comments)
ISO publishes the standard
According to the rules: every 5 years
*There may be more than one WD; the WG SR dealt productively with WD1, WD2, WD3, WD4.1 and WD4.2
**There may be more than one CD
***There may be more than one DIS
****There is only one FDIS because comments would have been addressed in one or more of the earlier DIS periods.
2. Committee Draft1 CD1:
This website deals with CD1, as of December 2008. The CD1 document itself is protected by ISO Copyright and can be downloaded from the ISO server at
Once on this site, please click on ISO/CD 26000, Guidance on Social Responsibility to download CD1 (2 megabytes), which should be read prior to considering the following comments.
Its basic content is:
1 Scope (what the standard covers and what it does not address)
2 Terms and definitions; 3 pages
3 Understanding social responsibility (dealing among others with trends and characteristics,
and the role states can play (the latter one rather unsatisfactory)); 3 pages
4 Principles (like accountability, transparency, ethical behavior, respect for the rule of law
and international norms of behaviour, and human rights); 4 pages
5 Recognizing social responsibility and engaging stakeholders; 3 pages
6 Guidance on core subjects (like organizational governance, human rights, labour practices,
the environment, fair operating practices, consumer issues, and involvement in and development of
the community); 40 pages
7 Guidance on integrating social responsibility into an organization, 14 pages
2.1 CD1 Strengths: the strengths of CD1 are essentially
- the transparency of the ISO process, as a good pre-requisite for later global acceptance
- a wide involvement of more than 400 experts and observers, from more than 80 countries, and from all stakeholder groups
- a Working Group internal process management that has lead to international consensus (consensus being the absence of sustained opposition, not necessarily unanimity)
- a highly effective IDTF (Integrated Drafting Task Force) under the brilliant leadership of Jonathon Hanks from South Africa
- public promotion leading to very wide-spread knowledge about this project and its high expectations.
This work environment for this ISO project is unique, and no other organization could have achieved more progress or a better committee draft, under the given conditions (i.e. complexity of subject, size of WG, multiple stakeholders, and time limits).
2.2 CD1 Concerns: there remain some serious points of general concern; hopefully these will be taken into account when further developing the draft, so that the “market success” of the ISO 26000 is more assured.
2.2.1 ISO 26000, a set of options to select from
Clause 6 of CD1 describes a wide range of social responsibility core subjects and related issues. The introduction to this clause states that, ‘. . . an organization should address the following core subjects . . .’ (“should” is used as directed in the New Work Item Proposal).
However, in the section on SR Dynamics on this website, it is clearly shown the degree to which each organization differs from others, and at any point in time. With this in mind, it does not seem to be logical that all core subjects and issues as set out in the standard would be applicable to all organizations: in practice this simply will not work. See also the section on this site: “Tools around ISO 26000”.
Not surprisingly, some parties in the WG SR wanted to see all guidance binding for all organizations, but this met serious objections. The outcome is that parts of CD1 state that all core subjects are relevant to all organizations but
not all issues given under a core subject whilst in other clauses, an organization is to identify the relevant core subjects and issues. This inconsistency, particularly between clauses 6 and 7 must be rectified, and all references to the applicability of core subjects should clearly indicate that organizations should identify and address the core subjects that are relevant to them. It should also be stated that an organization should be able to demonstrate why the guidance on a core subject in the standard is not relevant to them.
In addition to this, it seems appropriate to add a statement on this aspect of relevance into the scope, which is normative. (An introduction of an ISO standard is only of explanatory nature.)
Proposal: Add a clear statement to clause 2 “Scope” which reads:
“This International Standard offers guidance on a comprehensive set of core subjects and related issues from which an organization, having regard to its individual situation, may determine those that are relevant.”
2.2.2 User survey, acceptance/suitability
CD1, as it stands, is the work of some 400 experts, each equipped with personal viewpoints, experiences and goals. Experts are delegated by their national ISO member body and are sovereign in their contributions to the work. It is supposed that, in addition, they provide the views of their home organizations, e.g. a car manufacturing enterprise in Sweden or a consumer organization in Brazil.
With this approach, the wider public could not be consulted, nor could an analysis of the potential users and their expectations be taken into account (see also the estimation of potential users.
Proposal 1: to undertake a comprehensive, professional survey of potential users, evaluate, evaluate the feedback and include it in the further development of the standard. A good basis for such a user survey could be the next draft when all comments on CD1 have been addressed (leading to, say, a “CD1+”), and before a CD2 or DIS is offered to ISO national member bodies for the next round of comments and votes.
Proposal 2: a quick survey on the possible use of ISO 26000, supposed no major changes are made on the current draft CD1, is actually performed; please see the link Quick user survey. Your participation is most valuabel and takes only 5 minutes of your precious time.
As mentioned in section “Tools around ISO 26000” , ISO 26000 will be only one of hundreds (or perhaps even
thousands?) of other codes and initiatives, many with equal credibility, and needs to be better and more attractive in order to achieve and retain a primary role. This is essentially a matter of volume, contents, language and tone.
Most other codes are far more concise, in some cases having as few as 8 pages, whilst CD1 has some 100+ pages. Other codes show a motivating and encouraging language. CD1 has this too but tends too much to lecture and has too many ‘should’s’. Also, any insinuating tone should be avoided: e.g. Box 1 on “ISO 26000 and small/medium organizations (SMOs)” includes the sentence
“Of course it may not be possible for an organization immediately
to remedy fully all of the negative consequences of its decisions and activities….”
This sentence implies that decisions taken by small/medium organizations invariably have negative consequences. One can easily see that small and medium organizations will react strongly against this aspersion. Such a statement is likely to bring the whole of ISO 26000 into disfavour with SMOs.
a) to shorten the document to some 40 pages (which is possible, without losing substance);
b) to reword the many “you-should-sentences” by using the variety and flexibility of the English language;
c) to scrutinize the document for any insinuating, negative sentences, and re-word them.
2.2.3 Boundary between ISO 26000 and applicable law and regulation
TThis boundary is not adequately addressed in the standard. For instance, Clause 2 Scope says:
“This International Standard encourages an organization to undertake activities that go beyond legal compliance, recognizing that compliance with law is a fundamental part of any organization’s social responsibility.“
In clause 4.7 Respect for international norms of behavior this problem is tackled in some way. However,
potential conflicts between ISO 26000 guidance and applicable law are not addressed. In many countries and regions parts of ISO 26000 are already covered by law and regulation, albeit at different levels, and therefore users will expect an explanation of the relations between these regulations and the ISO guidance standard.
The basic principle should be that the standard by its use or intent should not extend the scope of legislation and regulation, or lead to conflict between the standard and prevailing legislation and regulation.
Proposal: to include at the end of clause 2 Scope a sentence that reads
“Wherever the guidance offered in this standard may conflict with applicable law or regulation, the applicable law or regulation prevails.”
2.2. 4 Role of Governments, regulatory practices
The project scope (see New Work Item Proposal) requires that ISO 26000 is applicable to all organizations regardless of their type, size or location. This includes governments as one type of organization.
GGuidance on establishing the necessary legal frameworks and enforcement mechanisms as prerequisites for an effective approach to SR throughout the community is not included in CD1.
This is despite the fact that it is known that, in many countries, the absence of law, regulation and enforcement mechanisms are a main cause for the existence of inappropriate SR behavior, because organizations may abuse the regulatory vacuum.
Quote from CD1, Introduction, lines 118/119: “Governmental organizations may wish to use this International
Standard. However, it is not intended to replace, alter or in any way change the obligations of the State.”
Similarly it is stated in clause, 3.4:
quote 3.4 The state and social responsibility
This International Standard cannot replace, alter or in any way change the duty of the state to express and act on the public interest. Because the state has the unique power to create and enforce laws, it is different from organizations. For instance, the duty of the state to protect human rights is different from those responsibilities of organizations with respect to human rights that are addressed in this International Standard.
Social responsibility of organizations is not and cannot be a substitute for the effective expression of state duties and responsibilities. This International Standard does not provide guidance on what should be subject to legally binding regulation. Neither is it intended to address questions that can only properly be resolved through political institutions.
Governmental organizations, like any other organizations, may, however, wish to use this International Standard to inform their policies and actions related to aspects of social responsibility.
At first glance, this seems understandable - but on further reflection, it misses the opportunity, as a voluntary standard, to give guidance to governments on how a legal framework could be shaped that embodied socially relevant aspects in law and regulation, including the need for effective enforcement, particularly in view of the above mentioned vacuum and resultant abuse.
In this context the “Failed State Index 2008” is helpful to look at
This index lists countries along these criteria (“indicators of instability”):
- demographic pressures
- refugees and displaced persons
- group grievance
- human flight
- uneven development
- de-legitimization of state
- public services
- human rights
- security services
- factionalized elites
- external intervention.
The matrix lists some 60, mostly developing countries and, without surprise, SOMALIA is the worst in 2008. This overwiew allows this itnerpretation:
- the lesser a state fulfills its regulatory obligations, the worse is the social and welfare status of the population;
- the weaker a state’s regulatory framework on SR, the less effective are SR related actions;
- if there is no appropriate general regulatory framework, SR actions of others than government won’t start.
Therefore, it can be stated:
SR actions are most needed where governments are
reluctant on issuing an appropriate general regulatory framework
(constitution and basic rights).
A few other examples should be shown here because they serve well in this context:
- Cutting down the rainforest continues year by year in Brazil, by 12.000 square kilometers from July 2007 till August 2008, so that the ecosystem may collapse in a few decades; government allows this
- Cutting down the rainforest in Indonesia continues to a degree that by 2022 some 98% of the rainforest will be destroyed; the area is used for palm oil to be exported for producing biofuel; government allows this
- Some governments still don’t have subscribed to the Kyoto Protocol
- While 932 million people are hungry, corn and wheat are used for the production of biofuel;
many governments allow this
- The Zimbabwe government ruins the country’s economy and no-one seems to be able to remedy the population’s sufferings. Other governments allow this happen.
It is school knowledge that forests are an important and effective climate regulator but their protection by government action is widely missing: This can be considered more than socially irresponsible.
And: there is a significant difference in the duration of SR actions:
“ SR by government is continuous”: Governments’ foremost duty is the issuance of laws and regulations on citizens’ safety – including an SR framework - and to provide for their continuous respect and application, and to establish an infrastructure to punish violators (enforcement).
” SR by others is temporary”: if, for instance, a company actively contributes to a country’s SR measures, but it has to leave that country (e.g. for economic or political reasons), all its SR actions and SR related investments are lost to the community.
In fact organizations other than government (such as industry, services, NGOs) cannot replace government or government action. No SR standard can remedy state failure.
Proposal: Set a broader and more realistic basis for a globally successful promotion of SR by including guidance in the standard for governments on establishing effective regulatory systems and enforcement mechanisms.
3. Comments on CD1 in Detail
It is normal ISO practice to ask for comments on a template, so that all the comments can be easily compiled. This way all comments on a particular line or clause in the draft can be grouped together for review.
The author’s proposal for comments is offered in this downloadable document in WORD form, 18 pages; the download takes a few seconds.
It may also be helpful to look at the related Key Issue Paper of the ISG (Industry Stakeholder Group) of WG SR.
4. Voting options
ISO member bodies have the privilege and duty to vote. The vote is formally sent to ISO Central Secretariat by the member body: e.g. in Germany by DIN, in France by AFNOR, in Colombia by ICONTEC, etc.; see also
Each ISO member body normally runs a so-called “mirror committee”, which is supposed to be composed in accordance with the stakeholder balance in the WG SR. The primary functions of each mirror committee include nomination of experts and observers to the ISO Working Group for Social Responsibility (WG SR), gathering and considering the national viewpoints of all parties concerned (stakeholders) and finally agreeing by consensus (not necessarily unanimity) on the national vote.
The general voting options are:
- In favour: this means to be content with CD1 and to support progression to the next stage, the Draft International Standard (DIS). It indicates that the mirror committee reached consensus.
A vote in favour may or not be accompanied by comments.
- Abstain: this means that the mirror committee did not reach consensus on a YES or NO and agreed, or its chairperson decided, to abstain. Such votes will not be counted.
An abstention may also be accompanied by comments.
- this means that the mirror committee reached consensus that it is not content with CD1; comments are obligatory in this case and need to describe the reasons for this opposition and give concrete proposals for change/amendment/improvement to/of CD1
The WG SR Operating Procedures encourage national mirror committees to provide comments regardless - a good request.
National mirror committees often issue their own internal working procedures, including, for example, the voting process.
One of the key tasks of the ISO Member body, through its mirror committee, is to compare the CD1 against the task described in the New Work Item Proposal. In regard to its Annex A, the committee is to judge – among other things - whether CD1:
- assists organizations in addressing their social responsibilities while respecting cultural, societal, environmental and legal differences and economic development conditions;
- provides practical guidance related to a) operationalizing social responsibility, b) identifying and engaging with stakeholders, and c) enhancing credibility of reports and claims made about social responsibility;
- emphasizes performance results and improvement;
- increases confidence and satisfaction in organizations among their customers and other stakeholders;
- is consistent with, and not in conflict with, existing documents, international treaties and conventions and existing ISO standards;
- is not intended to reduce government's authority to address the social responsibility of organizations;
- promotes common terminology in the social responsibility field; and
- broadens awareness of social responsibility.
(These bullet points are copied from the NWIP Annex A point 1, “Scope of the standard”)
Further, the committee must judge the ‘applicability’ as given in point 3 of Annex A:
- The standard should be applicable by all types of organizations. (e.g. regardless of their size, location, the nature of their activities and products, and the culture, society and environment in which they carry out their activities.)
And, referring to Annex B, pointc), it must judge the ‘feasibility’ of the standard:
- limiting the proliferation of SR sector standards;
Finally, with regard to Annex B, point f), ‘benefits’, it must decide whether the standard will:
- facilitate trade liberalization and remove trade barriers (implement open and fair trade); and
- complement [remark: the original text says “compliment”] and avoid conflicts with other existing SR standards and requirements.
Such detailed judgements should form the basis of national comments and votes. Hard and conscientious work of the mirror committees will further enhance substance and quality of the guidance standard, so that the next draft may well be issued as a DIS.
Drafting comments is hard work,
and the 3 months given till 12 March 2009 is a relatively short period.
This website may help this process.