EICC is working to improve transparency across the electronics value chain as a step in enhancing implementation of the EICC Code of Conduct. EICC is promoting common and comparable KPIs, and intends to help companies mature their approaches to disclosure. EICC is in the early stages of creating a framework for members and their suppliers to report key performance indicators (KPIs) and other information concerning their operations and governance. In this context , EICC is reaching out to key stakeholders to obtain input on various aspects of this effort, the first being identification of the material issues that stakeholders deem most significant for the EICC and the electronics industry. In its submission GoodElectronics stresses the need for EICC to progress, and report on freedom of association, collective bargaining, occupational health and safety, the usage of temporary agency work, and enhanced recycling techniques to efficiently recover and reuse already processed metals and plastics.

GoodElectronics expects EICC and EICC members to be fully transparent and accountable to the public, in particular to workers, communities, governments and consumers. Information regarding each company’s production locations, contractors, suppliers, production processes and products and by-products should be made freely and publicly accessible.

Regular and detailed reporting about policies and practices is expected, including audit results and corrective actions plans on an aggregated country-level. Reporting should provide enough information to assess the adequacy of the steps taken by the enterprise. Reporting should offer a sufficient level of detail to enable comparisons between companies and over time.

External communications should appear in a form and with a frequency that is in tune with the social impact of the business activities.

When an enterprise has a relatively high risk of creating negative social effects, the formal report must include subjects and indicators that show how the enterprise has identified and addressed its social effects.

Independent verification of CSR reports will improve the content and credibility of these reports.

It is important to GoodElectronics that a company uses a specific framework or participates in a specific rating scheme for sustainability reporting. Reporting should offer a sufficient level of detail to enable comparisons between companies and over time. GoodElectronics recommends the UN Guiding Principles for Business and Human Rights as framework that reporting shpuld be based on.

It is important that a sustainability report has been verified by a third party as independent verification of CSR reports will improve the content and credibility of these reports.

Independent verification should enable all stakeholders, the employees and the local community to test the CSR policy against reality. Independent verification should be carried out by an organisation that can form an independent judgement and has the confidence of all relevant stakeholders.

GoodElectronics is recommending ISO-26000 and the UN Guiding Principles on Business and Human Rights as the appropriate assurance standards.

GoodElectronics calls for regular sustainability reporting on an annual basis. Additionally, external communication may be expected on an ad hoc basis when serious labour and/or environmental issues occur.

Asked for the top-12 of key material issues for the electronic industry, GoodElectronics pointed out the following issues from a given list:

  1. Child labor
  2. Freedom of association
  3. Freely chosen employment
  4. Non-discrimination
  5. Wages and benefits [including wages meeting legal requirements]
  6. Working hours
  7. Health & Safety: Occupational health and safety
  8. Waste management [including Hazardous Waste Management]
  9. Conflict minerals
  10. Management of labor agencies
  11. Supply chain code dissemination
  12. Worker feedback and participation  [including freedom of expression and opinion, grievance mechanism]

Asked for the top material issues for the electronic industry that are NOT currently included in the EICC Code of Conduct, GoodElectronics listed the following topics:
1.    Freedom of association and collective bargaining – using standard ILO language. Carry out and report on risk assessment of the potential human rights violations relating to freedom of association. Companies to apply effective methods to detect violations of freedom of association and collective bargaining and to report on non-compliance.

2.    The widespread and increasing usage of temporary agency workers that are not considered employees of a factory is an issue of major concern to GoodElectronics. The avoidance of direct, formal employment relationships is a cause of precarious working and employment conditions. ‘Non-employee' workers generally do not have the right to join trade unions. In the limited cases they can join trade unions they are not covered by collective bargaining agreements, and do not benefit from social security or other benefits. GoodElectronics considers discrimination amongst workers at the workplace and the weakening of trade unions as highly problematic. GoodElectronics calls for the elimination all forms of precarious employment such as casual, temporary, irregular and/or agency work that leave workers in a vulnerable position, including abuse of and excessive use of fixed term contracts, dispatched workers, workers on probation, interns and students, migrant workers, etc. GoodElectronics is of the opinion that workers should be employed directly and on a regular basis. http://goodelectronics.org/news-en/goodelectronics-common-demands-on-the-electronics-industry-update/at_download/attachment.

For what concerns reporting and transparency, EICC and EICC members should:

  • Complement codes of conduct with detailed sections on temporary labour/employment relationships
  • Develop and apply effective methods to detect and address the use of excessive, improper and/or illegal temporary labour (including the abusive use of student labour and migrant workers; undermining of organising and collective bargaining). Adapt audit and reporting systems accordingly.
  • Carry out country-specific pre-investment/pre-sourcing risk assessment of the potential human rights violations relating to temporary (agency) labour, and report on this.
  • Report on numbers and percentages of temporary workers, and the incidence of temporary agency work, also at the level of suppliers.
  • Carry out a gap analysis regarding numbers and rights of temporary workers and permanent workers on factory and country level, and report on this.

Further steps that EICC and EICC members should take include:

  • Ensure regular workers and temporary agency workers receive the same rights and benefits on the basis of equal pay for equal work. Provide recruitment agencies with information on basic pay and employment conditions of regular workers.
  • Bring down the extent of precarious work by reducing the incidence of temporary work to genuine operational requirements.
  • Set an acceptable maximum per temporary workforce in dialogue with designated trade unions, and/or labour NGOs.
  • Look into auditing and certification of recruitment agencies.
  • For more details see the Report of the May 2012 makeITfair and GoodElectronics Round Table ‘Workers’ rights in the global electronics sector’.

3.    Occupational health and safety: Monitor and report on industrial hygiene and worker health consistent with the recommendations from SAICM –(http://www.saicm.org/index.php?option=com_content&view=article&id=96&Itemid=485). Report on the substitution of safer substances and processes (following the “The Guide to Safer Chemicals), and on occupational health surveillance. Track and report on toxic emissions throughout the supply chain to publicly report emissions of all hazardous chemicals into the environment.

4. EICC and its members to prioritise work on reducing reliance on natural resources, including conflict minerals,  by more effectively mining the mountains of e-waste that are dumped in landfills or collected but still not efficiently recycled.  EICC and its members should focus on the potential of enhanced recycling techniques to efficiently recover and reuse already processed metals and plastics from existing waste streams.

Last but not least, GoodElectronics has indicated to be willing to share our views in more detail with EICC, its members, and with other stakeholders. GoodElectronics is willing to consider participating in a small group of stakeholders that will engage more closely with EICC on transparency and reporting over a period of several months in early 2013.