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DIS Opinions

This site reproduces opinions of important other organizations or persons on ISO/DIS 26000, the Draft International Standard, which was due 14 February 2010.

Contents
- Professor John G. Ruggie’s “Note on ISO 26,000 Guidance Draft Document”
- WSBI (World Saving Banks Institute) position on ISO/DIS 26000
- Article by Paul Hohnen, GRI, that the DIS passage is by far not certain
- Swedish Letter to various ISO member bodies, dated 8 Jan 2010
- NORMAPME draft position (NORMAPME speaks for 12 million European organizations) and
- NORMAPME Letter to ISO member bodies
- ICC comments on ISO/DIS 26000
-
IOE Comments on ISO/DIS 26000
- NORMAPME comments in detail
- IFAN comments (International Federation of Standards Users)
- BIAC comments (
“Business and Industry Advisory Committee” of the OECD)

 

BIAC the “Business and Industry Advisory Committee” of the OECD in Paris.

BIAC would like to thank you for giving us the opportunity as a D-Liaison member to submit our comments on the ISO/DIS 26000 document and to express support or opposition to the draft guidance standard.

It is directly mentioned in the Design Specification that the guidance standard should “be relevant to all organizations and to specific kinds of organizations where appropriate” and that “the language must be clear, understandable and objective throughout the guidance standard”.

It is the conclusion of BIAC that these requirements have not been met sufficiently in order to warrant advance of the document to the approval stage. In addition, other issues – the length of the document and the complexity of the issues for instance – imply the immaturity of the draft.

BIAC recognises the serious and well-meant efforts given to reach the present text. However, it would not be recommendable to rush into publication of a document that is unlikely to be helpful or acceptable to the vast majority of organizations (SMOs) and of little value to large organizations that are already well ahead.

BIAC would instead recommend that efforts be invested in condensing the wealth of information assembled in the document and in simplifying its guidance and language as well as addressing the issue of „relevance” of the document. This step can be expected to enhance the value of the standard immeasurably.

The complete document can be downloaded here.

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IFAN cIFAN logoomments (International Federation of Standards Users)

The International Federation of Standards Users (IFAN), which represents both national standards users groups as well as corporate standards users  remains deeply concerned that the current draft continues to potentially be of little use and/or value to its purported target audience – micro to small to medium sized organizations due primarily but not limited to length and complexity.  For the benefit of standards users the world over,
we therefore do not support the advancement of the DIS to the Final Draft International Standard
stage
.
IFAN proposes to incorporate not only these IFAN comments, but the likely hundreds of other comments that speak to these recurrent criticisms throughout the draft guidance standard’s many iterations of development.

IFAN proposes to promulgate a second DIS for comment and resolution.

The full comments can be downloaded here.

 

Professor John G. Ruggie is the United Nations “Special Representative of the Secretary-General for Business and Human Rights”. In November 2009 his “Note on ISO 26,000 Guidance Draft Document” elaborates on the issue of “sphere of influence” and states inconsistencies of the DIS. Important statements are given in this excerpt:

“The reference to the concept of “sphere of influence” in the human rights section corresponds broadly with how it is described in the UN framework document: namely, that it can be a useful metaphor for companies to employ in identifying opportunities to support human rights, but that influence by itself is not an appropriate basis on which to attribute specific social responsibilities to companies.

However, the same alignment on “sphere of influence” does not exist elsewhere in the document. The draft Guidance is internally inconsistent on this issue, and beyond the human rights section it is inconsistent with the UN framework. This will send mixed and confusing messages to companies seeking to understand their social responsibilities, and to stakeholders seeking to hold them to account…

In short, I have serious concerns about these inconsistencies regarding the sphere of influence: within the ISO Guidance document itself, and between it and the UN “protect, respect and remedy” framework.

I very much hope—and indeed would urge—that the Working Group responsible for drafting the ISO 26000 Guidance document review all references to sphere of influence in the document to ensure that they are consistent with the UN framework not only in the human rights section but throughout.”

The full note can be downloaded here.

 

WSBI (World Saving Banks Institute) position on ISO/DIS 26000

About WSBI – The Global Voice of Savings and Retail Banking
WSBI (World Savings Banks Institute) is one of the largest international banking associations and the only global representative of savings and retail banking. Founded in 1924, it represents savings and retail banks and associations thereof in 92 countries of the world.

WSBI is convinced that social responsibility (SR) can be a key driver for social and economic development and contribute to building more balanced and inclusive societies, both in mature markets and in developing countries. In this respect, it welcomes the International Organization for Standardization (ISO)’s general objective to provide tools and guidance to encourage the taking-up of social responsibility by business, civil society and public actors. It supports the ambition to broaden awareness on the social responsibility concept, to enhance the credibility of committed bodies and to increase customers and stakeholders’ confidence.

However, WSBI is concerned by the broad ambition of the ISO initiative, in terms of scope of application and range of topics covered, as well as of the overall coherence of the project with already existing CSR tools. In this
regard, the current version of the Draft International Standard (DIS) 26000 would require substantial adjustments, to ensure that the final Guidance document is understandable and usable, and that it brings the required support to achieve the goal of assisting organizations in addressing their social responsibility.

With this constructive approach in mind, WSBI, as a D-Liaison organization in the ISO Working Group on Social Responsibility, submits comments on and proposals for amendments of the DIS 26000 on Social Responsibility.

The WSBI position addresses the following topics:

General:

  • Extent of the scope of application
  • Relevance of all core subjects
  • Convergence with other CSR tools
  • Usability of the Standard for all organizations

Specific:

  • 6.3.7 Human rights issue 5: Discrimination and vulnerable groups
  • 6.6.5 Fair operating practices issue 3: Fair competition
  • 6.7. Consumer issues and 6.7.3.2 Related actions and/or expectations

The full document can be downloaded here.

 

Article by Paul Hohnen, GRI, that the DIS passage is by far not certain

13 January 2010

Article of 12 January 2010 in  “Ethical Corporation”

Opinion: by Paul Hohnen     
ISO 26000’s long and windy road

The long awaited ISO 26000 international standard on social responsibility is due to be launched this year. Paul Hohnen argues that its clear passage is far from certain …

Remark by Guido Gürtler: Paul Hohnen’s article came to my attention through the LinkedIn group on ISO 26000. He is an appreciated person and active in the ISO 26000 project from its very beginning, i.e. in the former SAG (Special Advisory Group of ISO TMB). His article is, in my view, a very fair description of the current situation that "….its clear passage is far from certain". The full article is available at http://www.ethicalcorp.com/content.asp?ContentID=6736

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Swedish Letter to various ISO national member bodies, dated 8 Jan 2010

The core statement is: Sweden judges the current DIS (N172) sufficiently mature and will vote in favor on 14 February 2010. The content and  timing of this outreach strongly suggests an attempt to influence voting and certainly raises ethical considerations at a minimum.

Because its content is partly emotional and doesn’t mention facts it seems adequate to compare its statements with known facts, sentence by sentence.

The letter (PDF) can be downloaded here, the statements and facts (Word)  here.

 #

Sentence of the Swedish Letter

Facts and Remarks

1

The ISO 26000 standard is intended to support organizations in their aims for a sustainable development.

ISO 26000 intends to support organizations in regard of their socially responsible behavior, not sustainable development as a whole.

2

The process of developing ISO 26000 involves thousands of experts on social responsibility issues from all over the world

  • Some 80 or 90 participating ISO member bodies are active in the project; assuming an average size of their national mirror committees (where delegates to WG SR are regularly part of) at 15 persons sums up at 1.200 resp. 1.350 persons, not thousands.
  • With all due respect and recognition of personal engagements and qualities it has not been disclosed yet in how far the experts nominated to WG SR carry professional experience in social responsibility matters.

3

Designed as a voluntary guidance standard it is likely to have a major impact on the conditions under which humans live and on the environment we exist in.

Correct. That’s why the guidance document must have the highest possible quality to get the highest possible market acceptance, particularly by small, medium and micro organizations.

4

The combined strength of the ISO brand, the development processes and the commitment of the experts in ISOs Working Group on Social Responsibility is the foundation for the product, the standard ISO 26000

  • ISO has a powerful brand in regard of technical standards; ISO 26000 is the first ISO experiment of that size in societal standards
  • The development process with its direct stakeholder participation at WG level is part of the experiment, from the CD stage  onwards the normal ISO Rules apply (with possibly a special role of D-Liaison organizations)
  • Correct: the commitment of experts is enthusiastically high and invaluable, it seems incomparable

5

In fact, businesses and other users in both developing and developed countries are already adapting to the standard in wait for its official release, and the feedback from the end users is truly positive.

  • The first adapters seen were certifiers who mistakenly or willful put the ISO 26000 next to ISO 9000 and ISO 14001 while the ISO 26000 scope explicitly excludes the certification option
  • The IISD Study, the Quick User Survey and many further contacts give a feedback between critical and unacceptable. Truly positive feedback is known from certifiers, consultants and other service providers, and universities

6

Credible process
The distribution of the experts in the international working group displays a balanced participation with regards to stakeholder category, region and gender

This balance has been a high goal but has not sufficiently been achieved: fact is that representation of stakeholder groups at national level is missing at these percentages:

Industry  23,75%

Government  17,50%

Consumer  38,75%

Labor  52,50%

NGO   30,00%

SSRO  25,00%.

 

Only 32,5% of national delegations to WG SR include all stakeholder groups.

For details:  http://www.26k-estimation.com/html/iso_and_societal_standards.html#analysis

It can be questioned whether this selection of stakeholder groups is sufficiently representative of “society”. What about representatives e.g. of cultures, religions, national history, healthcare, or representatives of national societal associations?

7

Credible process
All through the process the organization and decisions of the working group has been formed in an inclusive spirit.

Correct as regards the inclusive spirit, but see one line up

8

Credible process
The high number of experts in the working group and in national mirror committees is a warranty for the quality and worldwide relevance of the standard.

The high number of experts is not relevant for the quality and worldwide relevance of the standard; this is rather emotional than factual

9

Stakeholder consensus
The stakeholder groups in the process were shaped already at the first meeting in Salvador in January 2005 and have been operating actively and independently since.

Correct, but shaping of stakeholder groups is neither relevant for the document’s content nor for finding consensus on a national vote

10

Stakeholder consensus
This new concept has proved to be a key element on reaching consensus on the contents and structure of the standard.

The new concept of direct stakeholder participation at WG level has proven to reach consensus, but it is not a key element for reaching consensus

11

Stakeholder consensus
At this point in the process the stakeholders has an agreement on the major parts of ISO 26000.

Correct, on major parts, but not on all

12

Mature product

The number of comments on the draft standard has declined during the last rounds of enquiry which is an indicator that the content is more mature.

Correct that the number of comments has declined…

2005-09  1200 comments

2006-05 2040 on WD1 (Working Draft 1)

2007-02 5176 on WD2

2007-11 7225 on WD3

2008-08 5231 on WD 4.1/4.2

2009-05 3411 on CD Committee Draft

…so that the document may be seen “more mature” but this huge number of comments lead to their grouping into “key topics” for further work, so that individual comments often were lost and had to be repeated in comments on the subsequent draft (there was indeed no other practicable way)

13

Mature product

The working group and the integrated drafting task force has successfully resolved key topics and reached consensus on a number of difficult issues.

Correct that both groups, WG and IDTF, have, under the given circumstances, accomplished an enormous and admirable task, particularly the leader of the IDTF; but that doesn’t necessarily mean that the resulting document gets the broadest possible success on the market

14

Mature product The feedback from end users who are already using the latest drafts of ISO 26000 is clearly positive while pointing out that the document gives practical guidance and is well structured.

See remarks on #5

15

Mature product

It is a ready-to-use tool which contributes to sustainable development.

 

This is widely seen different: the document is widely judged as not easy to understand and particularly for small, medium and mirco organizations it is not easy to use without external consultancy and advice (which these organizations would have to pay for!)

16

Mature product A positive outcome of the vote on ISO DIS 26000 will keep the project on the current timetable for publication in the fall of 2010.

Correct, but it would be more than detrimental to the globally expected and desirable success of the guidance document if time would prevail over quality; many commenters urge for further improvements.

The FDIS will (according to the normal ISO process) stay for some years before getting the opportunity to be enhanced.

17

Mature product

We have decided to support ISO 26000 because it is ready and the world needs it - now.

 

  • The Swedish vote deserves all respect. Each one of the 106 ISO member bodies is totally sovereign in taking its own decision, based on recognized arguments and convictions
  • The world’s need is only known by the world, not by one country; the world may wish a more mature” document, even if it is published a bit later.

18

Is ISO 26000 a good idea?

Yes, it is; to meet its goal and purpose the current DIS needs further improvements

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NORMAPME draft position on ISO/DIS 26000

20 January 2010

NORMAPME is the European association of SMEs for Standardization and represents over 12 million enterprises in all European countries. In spite of its efforts as D-Liaison organizations to contribute to the development of the guidance standard, NORMAPME is critical of this ISO project and opposes it on the grounds that there needs to be recognition of the specific reality of SMEs as final users of the standard. Obstacles to the application of ISO26000 in SMEs arise in issues such as the volume of the text, its language and tone, and the lack of relevance to small enterprises of all core subjects.

NORMAPME argues that despite its good intentions the WG SR process has failed to represent the reality of stakeholders involved in social responsibility and has been misused by some groups with detriment to the majority of its users.

SMEs will be affected negatively by this standard if approved. They are simply not in a position to adapt the recommendations proposed by the ISO standard. NORMAPME has argued throughout the process that this standard in its current form is too long, complex and its content is neither relevant to nor adaptable by SMEs within their informal SME management structures.

NORMAPME calls for the rejection of the current DIS text on the grounds that it is fails to address the needs of SMEs. Work should be continued on the text of the standard on social responsibility toward the attainment of such which is more utility driven and practicable.

The full document is downloadable from http://www.normapme.com/docs/positions/2010/FOR%20COMMENT%20Draft%20NORMAPME%20Position%20Paper%20on%20ISO%2026000%20_DIS_.pdf

or from hereIt seems hardly imaginable that the situation of SMEs is totally different in other continents.

In addition NORMAPME has raised its voice towards the ISO member bodies with this letter, emphasizing that the current document (DIS) will not be useful for small and medium organizations.

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ICC comments on ISO/DIS 26000
The International Chamber of Commerce speaks for hundreds of thousands of organizations/companies of all sizes, for small and medium as for large ones, all over the world. The ICC
, D-Liaison (Industry) in the ISO Working Group, has submitted its comments on the DIS and registered its lack of support for moving to the FDIS stage. The comments can be downloaded here.

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IOE Comments on ISO/DIS 26000
The International Organization of Employers offers the most thorough and substantial comments. It should be emphasized that a good portion of the comments analyses how official intergovernmental documents are referenced and identifies several mistakes. If the IOE comments would be taken duly into account the document would be significantly better. In fact, the IOE urges (like the ICC) to draft a second DIS.

The IOE does not support to advance the DIS directly to the next phase, the FDIS where ISO member bodies can only YES or NO, without proposing any further comments.

The IOE comments can be downloaded here.

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NORMAPME comments in detail
These comments are very detailed and contain a lot of concrete proposals for the needed improvement of the draft guidance standard. It is worthwhile to study also these ones. They can be downloaded here.

 

 

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