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IR/PS CSR Case #07-15

Social Accountability International
and the SA8000

By: Angelica Hagman
GRADUATE SCHOOL OF INTERNATIONAL RELATIONS AND PACIFIC STUDIESUNIVERSITY OF CALIFORNIA, SAN DIEGO
Prepared for Professor Peter Gourevitch
Edited by Jennifer Cheng, MPIA 2008
Corporate Social Responsibility
Fall 2007

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Table of Contents
I. Introduction...........................................................................................................................3
II. What is the CSR Problem?..................................................................................................3
III. Social Accountability International ...................................................................................3
IV. Social Accountability 8000 .................................................................................................4
V. Why adopt the SA8000?.......................................................................................................6
A. Costs...................................................................................................................................6
B. Benefits ...............................................................................................................................7
VI. Causes for Concern...........................................................................................................12
A. Cause for Concern #1: SA8000 Accreditation ...................................................................13
B. Cause for Concern #2: SAI Corporate Programs ..............................................................15
C. Cause for Concern #3: SAI Board and Advisory Board.....................................................17
VII. An Illustration: Dole Food Company .............................................................................18
VIII. New Development: The Creation of Social Accountability Accreditation Services ....22
X. Case Questions ...................................................................................................................24
XI. Appendix...........................................................................................................................25
APPENDIX I: SA8000 AROUND THE WORLD: CERTIFIED FACILITIES..........................25
APPENDIX II: SAI STATED BENEFITS OF SA8000 CERTIFICATION ...............................26
APPENDIX III: CORPORATE PROGRAM STATED SERVICES AND BENEFITS................27
APPENDIX IV: SA8000 STEPS AND COST OF ACCREDITATION .....................................30
APPENDIX V: BOARD AND ADVISORY BOARD MEMBERS…………………….……………32

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I. Introduction
In this case study, I will discuss the organization Social Accountability International and its
certification standard, the Social Accountability 8000 (SA8000). Rather than giving a complete
informational overview of SAI and the SA8000 certification and accreditation process, I will
delve into a description of the costs and benefits of SA8000 adoption. In addition, I will explore
possible difficulties in the SAI setup that SAI might need to address to ensure it is a credible andtruly independent organization. I will also use Dole Food Company as an illustration of some of
the issues posed in the case study. After concluding, I present several case study questions forfurther contemplation by the reader.
II. What is the CSR Problem?
The basic Corporate Social Responsibility (CSR) problem is how to get companies to treat theirworkers right, and particularly companies that are involved in factory production in developing
countries that do not yet employ strong labor laws. Additional facets of this CSR problem
include what constitutes “right” treatment, and also how we measure and enforce right treatment.
III. Social Accountability International
Social Accountability International (SAI) is a “non-governmental, international, multistakeholder organization dedicated to improving workplaces and communities by developing andimplementing socially responsible standards.” According to the SAI website, SAI wasestablished in 1997 and convened an expert, international, multi-stakeholder Advisory Board topartner in developing standards and systems to address workers’ rights. SAI trains and accredits
auditors that certify workplace compliance with social accountability standards. The primary

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socially responsible standard SAI has established to date is the SA8000 standard, which is
discussed in this case study.
IV. Social Accountability 8000
In 1997, SIA established the Social Accountability 8000 (SA8000), a voluntary standard that
promotes worker’s rights to attempt to solve the CSR issue stated above. The standard is modeled on
the well-established ISO9000 quality standard. It is thus based on the notion of continuous
improvement, with the added prescription of specific performance standards. The SA8000 system isfurther based on International Labor Organization (ILO) standards and U.N. Human Rights
Conventions, and according to SIA the system is “widely accepted as the most viable andcomprehensive international ethical workplace management system available.” Currently, close
to 1400 facilities employing more than 680,000 workers in 64 countries and 66 industries are
SA8000 certified.1 For a map on certified facilities around the world, see Appendix I. Important
to note is that the standard was created as a by a diverse cross-section of stakeholders, including
trade unions, academia, corporations, auditing firms, NGOs, social investment firms.
The SA8000 Standard consists of nine main areas, with a summary as found on SAI’s
website2:Child Labor: No workers under the age of 15; minimum lowered to 14 for countries operating
under the ILO Convention 138 developing-country exception; remediation of any child foundto be working
Forced Labor: No forced labor, including prison or debt bondage labor; no lodging ofdeposits or identity papers by employers or outside recruiters

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http://www.saasaccreditation.org/certfacilitieslist.htm
http://www.sa-intl.org/index.cfm?fuseaction=Page.viewPage&pageId=473

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Health and Safety: Provide a safe and healthy work environment; take steps to prevent
injuries; regular health and safety worker training; system to detect threats to health and safety;
access to bathrooms and potable water
Freedom of Association and Right to Collective Bargaining: Respect the right to form andjoin trade unions and bargain collectively; where law prohibits these freedoms, facilitate
parallel means of association and bargaining
Discrimination: No discrimination based on race, caste, origin, religion, disability, gender,
sexual orientation, union or political affiliation, or age; no sexual harassment
Discipline: No corporal punishment, mental or physical coercion or verbal abuse
Working Hours: Comply with the applicable law but, in any event, no more than 48 hours per
week with at least one day off for every seven day period; voluntary overtime paid at apremium rate and not to exceed 12 hours per week on a regular basis; overtime may be
mandatory if part of a collective bargaining agreement
Compensation: Wages paid for a standard work week must meet the legal and industry
standards and be sufficient to meet the basic need of workers and their families; no disciplinary
deductions
Management Systems: Facilities seeking to gain and maintain certification must go beyond
simple compliance to integrate the standard into their management systems and practices.
In this case study, I will not explore the quality of the SA8000 standard. A copy of the standard
can be found on SAI’s website3 and future research may investigate how the SA8000 comparesto other workplace standards. This is especially relevant since the SA8000 came out of a crosssection of stakeholders with diverse interests, and might thus be fairly conservative in thedefinition of workers rights compared to other standards. A very brief glance of the standard
assures us that that the standard does seem to protect workers, at least at a basic level.
3

http://www.sa-intl.org/index.cfm?fuseaction=Page.viewPage&pageID=710

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The SA8000 Certification is not directly granted by SIA, but is granted through ThirdParty Certification Bodies (CBs), traditionally trained and accredited by SAI. Althoughseparating the standard setter from the standard enforcer is generally preferable to ensure
independence, I will later explore some issues that may derive from this set-up.
V. Why adopt the SA8000?
The reasons companies choose to adopt a global workplace standard such as the SA8000 are
manifold. In this section, I will briefly mention the costs of certification and especially focus on
the accompanying benefits. As a side-note, this discussion will not entail a competitive element;
i.e. it will not focus on why companies would choose SA8000 over other workplace standards,
although this is an interesting topic for further analysis.
A. Costs
The cost of certification is not well-documented on the SAI website, but can be classified as
direct and indirect costs. The direct cost derives from the actual certification process. The SAI
leaves cost of certification process to CBs. According to SAI, the size, scope, and location offacility determine the number of days and auditors needed for certification, and typically range
between $500 and $1,500 per day. I could not find any information on the average final cost of amedian-sized factory. Pre-audit work is separate, and so are the surveillance audits (conducted
every 6 months to one year according to SAI) and the renewal audits (conducted every 3 years).
The indirect costs are the costs of changes made by companies to live up to thecertification. According to Sharon Hayes, former director of social responsibility andenvironmental affairs at Dole Food Company, the process of gaining SA8000 accreditation

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involved a lot of hard work and commitment on the part of the company.4 Dole does probably
not have a problem in paying the direct certification costs, but it may be that it had to pay muchin terms of indirect costs. Indirect costs are harder to anticipate and quantify without additional
research. The following section of benefits will attempt to explain what benefits companies may
derive from SA8000 certification.
In addition, although I will not delve into indirect costs much further, I want to raise aquestion to be explored at a later opportunity: Who Really Pays? The easy answer to who pay”
(both the direct and indirect costs of certification) is the end consumer. Consumers, however,
may not be willing to pay a premium for adherence to a workplace standard. The unwillingnessof consumers to pay effectively pushes back the cost burden to the retailer. But large retailers
such as Dole, Nike, and Adidas, are probably able to push back the cost to their suppliers
because of their considerable customer power. Factories reliant on these large companies will
feel pressured to bear most of the cost, especially if the retailer does not expect it will be able topass on the price of SA8000 compliance to consumers if needed. Paradoxically, small factories
that arguably could benefit the most from SA8000 may then suffer the most if the cost becomes
too great. Although the direct costs seem bearable ($1500 per day is not exorbitant), particularly
smaller factories in developing countries may be hurt by the direct and indirect certification costs.
This may be compounded if the factory is a producer of commodities and only compete on price.
B. Benefits
Most companies need tangible benefits to adopt such a standard to justify the cost of certification
if they wish to stay competitive in the marketplace. Sharon Hayes interestingly states that thecommercial benefits of adopting SA8000 practices are not immediately obvious. She comments:4

http://www.bsdglobal.com/viewcasestudy.asp?id=60

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“At the moment it doesn't seem that consumers are rewarding this kind of socially responsible
behavior in the marketplace.”5 Hayes comment is intriguing to me. Although I did not findexactly when Hayes gave this statement, one has to wonder why Dole chose to not only
implement the SA8000 standard but also be on the SAI Board and a Signatory member in the
SAI Corporate Program if there were no clear benefits. Dole has directly-owned operations inaddition to contracting with suppliers, and therefore cannot push back all the costs of SA8000
certification to suppliers. Why would a company like Dole implement a costly program if it did
not think it would be beneficial in terms of increased revenues and better reputation? Of course,managers’ values matter—even though cynics may deny this—but consumers and vigilantes
have sadly found watch-dog groups exist for a reason.
I would like to propose a few different benefits I believe Dole and other companies
consider in adopting such a standard. Although SAI claims the benefits are more extensive than I
propose here (See Appendix II), I believe SA8000 certification is a way for companies to (1)respond to vigilante and consumer criticism, (2) hedge against future brand and reputation
damage, (3) reap PR benefit, and (4) gain credibility by implementing an external standard withexternal auditing. Another point that warrants more attention but that I will not discuss further inthis case study is the possibility that there are tangible productivity benefits from implementing
the SA8000. It in unclear whether the SA8000 does increase productivity or not, but if it does,
the added productivity may warrant the costs of certification by itself—positive research in thisarea could help SAI market the SA8000 better.

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First of all, large retailers can respond to vigilante and consumer criticism byimplementing the SA8000. Dara O’Rourke6 in his article on NGO market campaigns points outthat although most consumers are not willing to search out improved products, they are inclined
to avoid “bad” or untrustworthy brands. Although the effect is probably not consistent acrossindustries, consumers tend to punish non-virtuous behavior in the market place. Exposes of poor
working conditions in Adidas and Nike factories in the late 1990s did harm brand image andreputation for the two companies and caused them to more seriously consider working conditionsin their extended supply chains. Implementation of the SA8000 may calm the vigilantes andallow companies to regain lost consumers confidence. Additional research may look at if
watchdog NGOs indeed consider the SA8000 standard to be credible and sufficient.
Secondly, adopting a workplace standard such as the SA8000 may also hedge against
future brand and reputation damage. O’Rourke states that corporations have a motivation to act
to protect their brands and reputations to avoid lost sales. Companies may implement a systemsuch as the SA8000 as a step to avoid future vigilante and consumer criticism that may turn out
to be very costly. Dole Food Company, for example, as one of the largest producers andmarketers of fresh fruit, vegetables, and fresh-cut flowers are susceptible to a variety of
consumer concerns and pressures. Although they may not be as vulnerable to the “sweat-shop”
image as other conglomerates, NGO vigilantes increasingly target industry leaders in various
industries to ensure good working conditions. As O’Rourke’s article shows, Dell, Nike, andStaples—all leaders in their respective fields—have been targeted for CSR reasons.
Implementing the SA8000 may therefore serve as insurance to avoid workplace scandals in the
future.
6

Dara O’Rourke. Market movements: Nongovernmental organization strategies to influence global production andconsumption. Journal of Industrial Ecology. 2005 - mitpress.mit.edu

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In addition to remedying and avoiding brand and reputation loss, many retailers may reap
PR benefits of complying with the SA8000. Although this is partially related to the two above
points, it warrants separate attention. Most large retailers have a Corporate Social Responsibility
website in which they can signal its virtuous behavior, and some companies use their CSR
behavior more aggressively in marketing campaigns. Although PR benefits may help in
regaining consumer confidence or in hedging against scandals, consumers may not reward
virtuous companies in their purchasing decisions except under specific conditions thatO’Rourke’s article also discusses. PR benefits may therefore not always outweigh the costs ofSA8000 certification and compliance by themselves, and a specific case study or further research
may be needed to examine the relationship between PR costs and benefits.
Finally, external standards and third-party auditing lends credibility that Internal Code of
Conducts and internal auditing may not. Company internal codes of conduct and accompanying
internal audits awaken several doubts in the mind of vigilantes and skeptic consumers.
Companies often set internal standards to curb customer or vigilante criticism. If this standard is
not rigorous enough, consumers and vigilantes may ultimately demand a more comprehensive
standard. Even if internal standards and accompanying audits are rigorous, they may still not be
sufficient to calm criticism. As Locke 7states, “given that brands and their suppliers may have aninterest in hiding labor violations rather than reporting them, how trustworthy are these internal
audits? Wouldn’t the incentives for moral hazard be too great for these interested parties?” In
other words, even companies that do not only want to green wash and that indeed have a greatinternal standard may have incentives (perceived or real) to hide adverse labor practices,7

Locke, R., Kochan, T., Romis, M. Beyond corporate codes of conduct: Work organization and labour standards at
Nike’s suppliers. International Labour Review, Vol. 146 (2007), No. 1–2

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especially if the company in question is sensitive to attacks from watch groups. Thus, even if
internal standards are rigorous, they may not be enough. A solution to the dilemmas of selfauditing internal code of conduct may then be to contract out audits of internal codes of conduct.
But since external stakeholders often deem internal codes of conduct insufficient, implementing
an external standard and conducting external audits may be the only way for companies to pleasestakeholders. The SA8000 can act as that external standard, and the third-party verification
offered by CBs can satisfy the need for external auditing.
Thus far I have discussed benefits for large retailers in adopting the SA8000. What about
the benefits and costs for independent factories? We expect them to neither have the same brandor reputation pressures, nor the strong PR benefits certification may afford. Their incentives for
implementing the SA8000 of their own accord should therefore be fairly low. Despite this, it
might be the case that factory owners see adopting the SA8000 standard as a step towards
gaining competitive advantage and to attract business customers. But, as I mentioned earlier, thecosts of certification may be too heavy to bear, especially for producers of commodities.
Additional study on the subject of costs and benefits might include an attempt to quantify
the costs and the benefits for a specific retailer that has the SA8000 certification, such as Dole
Food Company, Toys R’ Us, or Gap. Perhaps even more telling would be a study on a supplierthat does not get the same PR benefit or run the same PR risk as these large retailers do.
Especially interesting is exploring if there are any independent factories that have adopted theSA8000 out of their own accord, and if this has offered them a competitive advantage (ordisadvantage). In addition, estimating if there are any productivity benefits of SA8000
compliance will aid in understanding the benefits of SA8000 certification further.

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VI. Causes for Concern
I will now launch in to a discussion on potential causes for concern in the SAI set-up. These
causes for concern are not meant to discredit the SAI and the SA8000, but rather to highlightpotential areas of improvement. Most of the concerns are not specific to SAI but may be causes
for concern in the certification and verification industry as a whole.
As I discuss the causes for concern, it is important to keep in mind SAI’s revenue mix.
SAI’s financial information helps us uncover potential problems, and one may even consider theorganization’s revenue mix as a cause for concern in of itself. In Table 1 below, we find that
Program Service Revenue as a percent of total Revenues dramatically increased from the year
2003 to 2005, while Government contributions drastically decreased. Although SAI does not
perform audits as mentioned earlier, it does derive income from accreditation and course fees aswell as the corporate programs mentioned above. With almost 60% of income derived fromrevenue, we might expect SAI to be sensitive to pressure from the stakeholders that contribute tothat 60%. To put these percentages into perspective, the revenues for 2003 were about 1.9
million, and for 2005 about 2.3 million.
Table 1: Percent of Revenues
Direct Public Support
Government Contributions
Program Service Revenue*
Other (Misc. Income, Royalties)

2003
20
38
30
3

2005
25
10
59
5

*Includes Accreditation Fees, Course Fees, Conference Fees,
Corporate Fees, Sale of Publication

With this information in mind, let’s move onto the specific causes for concern. Although
there are more issues that need to be taken into account, I specifically mention issues regarding

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the SA8000 Accreditation Process, the SAI Corporate Program, as well the SAI Board andAdvisory Board.
A. Cause for Concern #1: SA8000 Accreditation
The first cause of concern focuses on the SA8000 Accreditation process of Third-Party
Certification Bodies (CBs). As mentioned earlier, external audits of an external standard (as is
the case with the SA8000) seems seem like a winning combination, but there are some problems
that persist. In this case study, I have focused on two troubling aspects of the CB accreditation
process, namely the cost of accreditation and the training of CBs.
The first issue within SA8000 accreditation area is the cost of accreditation. It can bequite expensive for CBs to receive and maintain certification, as can be seen in Appendix IV,
where the steps of accreditation are also included. But the cost is not so much an issue because it
is too expensive for the CBs (although this might indeed be true). Rather, accreditation fees
constitute a large part of SAI’s revenue mix (included in the Program Revenue portion in Table
1). SAI therefore has a powerful incentive to accredit CBs, or in other words declare “false
positives,” i.e. over-accredit. SAI concerns with auditor quality may work to correct this problem,
but we should still be aware of this potential issue. Also, the income derived from further
trainings to maintain the accreditation and the charging of a royalty fee might distort SAI’s
motives in the same direction.
Another issue lies in accreditation training. SAI requires auditors to attend a five-day
training course to be able to apply for accreditation. The five-day course is not only marketed to
management system auditors or those with prior audit experience, but to students from a wide
range of backgrounds and interests; SAI states that about half of the participants come from

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sectors such as consulting, compliance, NGOs, labor, government, and academia. But is a fiveday course enough of a kick-start for someone to monitor working conditions effectively? SAI
also offers a three-day Advanced Auditor Training Courses. Again is three days enough tobecome an advanced auditor of the SA8000 standard?
This issue is also discussed by Locke, who states: “if audits are…contracted out to “third
party” organizations, be they NGOs or private auditing companies, how competent are the NGOs
in assessing certain technical issues (e.g. air quality)...” This is confirmed by Dara O’Rourke,
who in his article8 discusses the ignorance of auditors employed by the industry leader in
auditing, PricewaterhouseCoopers (PwC) to illustrate the shortcomings of the third-party
auditing set-up. PwC’s auditors overlooked major violations of local labor laws and codes ofconduct in several audits O’Rourke attended personally, and not only those involving technicalissues. Monitoring may therefore be very uneven in quality and effectiveness, which iscompounded by potentially poor training.
The concern is therefore that the SA8000 auditors may not be competent. However, SAI
as the standard setter and the CB accreditor has incentives to ensure good quality of auditing to
uphold the reputation of the standard (and thus SAI’s source of income). Keeping auditing
quality high is important to the reputation of the standard and its efficacy, but at the same time
there are few incentives for SAI, the CBs, or certified companies to blow the whistle on
infractions. SAI claims to perform semi-annual accreditation audits of CBs training, procedures,
and audit management. I was not able to find information on what these audits contain, or if CBs
have been stripped of their accreditation. I did however notice that some of the CBs are rather8

See http://nature.berkeley.edu/orourke/PDF/pwc.pdf

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well-known bodies, which helps in reputation-building and maintaining (UL, Bureau Veritas,etc). Despite this, the training may not be sufficient to uphold audit quality.
B. Cause for Concern #2: SAI Corporate Programs
SAI offers three progressive levels of corporate participation in its SAI Corporate Program:
Introductory, Explorer and Signatory. According to SAI, its Corporate Programs are designed to“provide companies with the tools and knowledge to develop and implement credible CSR
policies and procedures…and help companies to extend the principles and management systems
approach unique to SA8000 throughout their supply chains. We help companies integrate social
compliance into their supplier development and supply chain management.” Please refer toAppendix III for stated services and benefits pertaining to the different program levels.
Despite this indication that the Corporate Program is designed to help companies
implement the SA8000 to a greater extent, the Corporate Program also serves a membershipprogram with significant revenue-raising potential for SAI. See Table 2 below for the breakdown of levels and costs of membership.

Table 2: SAI Corporate Programs
Level

Organization's Annual Revenue

INTRODUCTORY Flat Fee

EXPLORER

SIGNATORY$0-$100 million;
to $1 billion;
to $10 billion;
greater than $10 billion$0-$100 million;
to $1 billion;
to $10 billion;
greater than $10 billion

Fee$3,000$5,000$9,500$25,000$37,000$12,000$22,000$60,000$77,000

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Although this is a great revenue-generating program for SAI that will help it to become
self-sufficient, some unintended conflicts of interest follow. Companies might pressure SAI toreceive certification more easily, to not disclose potential complaints or violations of the SA8000,
or to change the SA8000 standard itself. The issue is therefore not that the corporate program isexpensive for the companies in question, but rather SAI’s dependence on the funds generated
through the program (which is part of Program Revenue, as explained in Table 1). The threat ofwithdrawn support, either directly stated or implicitly implied, is powerful. As stated earlier, SAI
does not perform certification and audits themselves, and this alleviates the problem somewhat.
But SAI might still put pressure on the CBs to be more lenient on the members that are
financially important to the organization. Since the CBs are already inclined to approvecertification and recertification because they get paid when they do, CBs may be more likely tocave to pressure from SAI.
Corporate pressure may be further exacerbated by the fact that SAI leaves much of the
SA8000 auditing policy setting to the CBs (although SAI does issue some guidelines andadvisories). CBs may therefore set or modify the auditing standards and rigor to suit their larger
corporate customers. Although I will not discuss the issue of CBs setting their own audit policy
further, I encourage additional study on this point because it potentially has very significant
implications on audit quality and credibility.
In short, since there are no clear incentives for anyone to act as a fire-alarm, collusion
between monitor and monitoree—between certified companies and SAI, SAI and CBs, and CBs
and certified companies—is therefore hard to prevent.

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C. Cause for Concern #3: SAI Board and Advisory Board
The issues that surface with the above-mentioned Corporate Program are compounded due to thefact that many of the larger companies that are consumers of the SA8000 certification and part of
the Corporate Program also sit on the SAI Board or Advisory Board. Here again, the companies
may have a lot of leverage over SAI.
In addition, the Advisory Board was not only responsible for setting the SA8000 standard
as mentioned earlier, but is also responsible for reviewing the SA8000 and the agency’s CB
accreditation procedures. Although this seems good in principle, a lot of abuses might arise. I
found 20 complaints that have arisen in the last seven years, whereof some were directed at CBs
and some resulted in SA8000 decertification. Although this is a good sign in general that gives
more credibility to SAI and the SA8000 process, delving a little deeper allowed me to find clear
indications of the potential problem of having certified companies on the Board or Advisory
Board. I found that 6 or 7 cases out of those 20 are still pending (with one going all the way backto 2005). Only two certifications of companies have been withdrawn in seven years, according to
the website; one in 2000, and the other in 2005. The most interesting finding, however, is thatthe two complaints that name Dole and Chiquita (both on the SAI Advisory Board) as the
subjects of complaint, are the only complaint instances without links to the complaint history.9 In
addition, both cases are still pending as of December 2007. This is an interesting finding, andalthough we cannot be sure why the complaint history is not displayed for these two companies,
it might be an indication of a deeper problem. Perhaps there are additional Board or Advisory
Board member companies that really should be on the complaints list but are not because SAI

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http://www.saasaccreditation.org/complaintlist.htm

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has an incentive to succumb to pressures from companies that sit on the Board or Advisory
Board (and which in addition put a lot of money into certification and belong to the Corporate
Program).
Not only are some of the companies on the Board or the Advisory Board, but also someof the CBs, such as Bureau Veritas Certification. Although this may help with some aspect ofimproving the SA8000, it does present problems, especially considering the problems alreadymentioned in the accreditation section. The CBs do pay the accreditation fees upfront, but they
are also required to pay royalties and they need to get further education in the SA8000 system.
SAI would also probably not be willing to lose the funding and the reputation advantages that
respected CBs such as UL and Bureau Veritas bring with them, and therefore SAI has an interest
to comply with pressures from their side. For a list of Board and Advisory Board Members, see
Appendix V.
VII. An Illustration: Dole Food Company
To make some of the issues I have discussed in this case study more tangible, I will discuss thecase of the US-based Dole Food Company. Dole is one of the world's largest producers andmarketers of fresh fruit, vegetables, and fresh-cut flowers and operates in more than 90 countries
and employs around 60,000 people. In June 2000, Pascual Hermanos, Dole's majority-owned
subsidiary in southern Spain, became the first agricultural operation in the world to obtain
SA8000 certification.

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A Human Rights Watch Report uncovers potential issues of Dole in particular and its
relationship with SAI and the SA8000 standard.10 Dole is an SAI Corporate Program Signatory
Member, and based on the previous discussion of the Corporate Program we might expect
certain problems. In addition, the report highlights another cause for concern. The report statesthat when Dole applied for Signatory membership, it was required to submit a statement formally
adopting SA8000 as the code of conduct for all its directly-owned and supplier banana
plantations. But as the Human Rights Watch report emphasizes, under the conditions of
Signatory membership, Dole is only required to bring its directly-owned and supplier facilities
into compliance with SA8000 terms within an unspecified “reasonable time period.”
Although we might expect that Dole needs time to bring especially its supplier facilities
into compliance, the “reasonable time period” standard is an issue as it leaves room for continued
poor working conditions. This is indeed what Human Rights Watch notes as it has discovered“continuing widespread human rights abuses” on Dole’s supplier plantations in Ecuador. But,
according to the report, since Dole has been a Signatory Member of SA8000 since November
1999 those abuses do not amount to violations of Dole’s SA8000 Signatory membership terms.
Dole as a Signatory Member can then reap benefits in that it can publicize affiliation with “aglobal humane workplace standard,” but need only ensure compliance within an unspecified
reasonable time period. These statements point to several weaknesses with the SAI set-up.
In addition, although Dole has been part of the SAI for over eight years, it unclear exactly
what percentage of suppliers and its directly-owned operations are SA8000 certified. I found anarticle from 2005 that states Dole has approximately 18,000 employees in its banana and10

http://www.ausncp.gov.au/content/docs/146_151_20020901_pier.pdf

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pineapple operations covered by SA8000 certifications, or approximately 73% of thatworkforce.11 In 2007, a Dole press release stated that the SA8000 covered 40,000 of its seasonal
and temporary employees in its banana and pineapple operations12. The two numbers don’t
exactly add up, because 100% certification in 2005 would be considerably less (25,000) than the
40,000 reported in the 2007 report. The increase is probably partly due to a growth in the numberof employees, but also that the 2007 figure includes seasonal and temporary workers. From thewording in these articles, it seems like these employees work on directly-owned plantations. But
what about employees that do not work on the pineapple and banana plantations (i.e. those thatwork with other products)? And what about certification for Dole’s supplier employees? We cantherefore conclude that it is difficult to exactly estimate what the percentage of workers
connected to Dole’s worldwide operations is in fact covered by the SA8000 standard. The global
supply chain for Dole, as for other large companies, gets quite complicated.
This brings up another point; that of Dole’s responsibility to get its suppliers to adhere to
the SA8000. Human Rights Watch believes that Dole as an SA8000 signatory member, shouldhave informed its supplier facilities that they were going to adopt the SA8000 code of conduct;
have established a plan and schedule for them to achieve SA8000 certification; and, throughassessments and audits, work directly with them to achieve compliance. However, thecomplexity of large companies and how difficult it is to align the supply chain is evidenced in
the case of Dole’s Ecuadorian subsidiary. It denies any responsibility for labor rights conditions
on Dole’s independent supplier plantations. When Human Rights Watch questioned a
representative of Dole’s Ecuadorian subsidiary about Dole’s labor rights policies on third-party
supplier plantations, he responded:1112

http://findarticles.com/p/articles/mi_m0EIN/is_2005_March_2/ai_n11838504
http://www.dole.com/CompanyInfo/PressRelease/PressReleaseDetail.jsp?ID=1538

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We do not have jurisdiction over that . . . It is their discretion. . . . [W]e do not intervenein that. Absolutely not. It’s their business. . . . We do not have that responsibility.
Nothing to do there. Our contract is limited to quality and technical assistance.
In addition, although Dole states that it “audits its suppliers in a number of areas, including laborrights,” the company told Human Rights Watch that it will “not comment on monitoring or
inspections of a specific producer or plantation.” Similarly, when Human Rights Watch wrote toDole to confirm the company’s contractual relationships with certain plantations on whichchildren labored and adults were often too afraid to organize, Dole responded that that
information is “proprietary business information, which Dole does not publicly disclose.” Wethus see that problems of exactly which workers should be covered by the SA8000 in the global
supply chain are quite complicated.
One additional illustration lies in the PR benefit to Dole of SA8000 certification. Dole
derives PR benefit every time it certifies another plantation or factory, and might thus have an
incentive to spread out certifications to maximize exposure. On November 3, 2006, for example,
Dole gave out a Press Release that its fruit processing factory in Hua Hin, Thailand had been
SA8000 certified, and could claim that it is the first food company to receive SA8000
certification in Thailand.13 Spacing the next certification too close with the public announcement
may then not give the maximum PR benefit possible. To see more press releases and to learn
more about Dole’s social responsibility efforts, please visit their website.14
Another issue for Dole lies in the cost of certification. The cost of SA8000 may besignificant in Dole’s case. Dole has a significant number of directly-owned plantations, as
alluded to above, so Dole cannot use its buyer power to transfer costs to suppliers. Since Dole

13
14

http://www.csrwire.com/News/6739.htm
http://dole.com/CompanyInfo/Responsibility/Responsibility_Index.jsp

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does not only adhere to the SA8000, the cost may be significant if implementation of these andother standards do not result in productivity increases and/or cost savings. Dole, for example,
proclaims that in addition to the SA8000 it adheres to ISO 9001, ISO 14001, EurepGAP, Organic
Certifications, and Fair Trade. As these organizations are fee-based, costs of compliance withseveral different standards may be great. Who ultimately pays for Dole’s CSR efforts? In thiscase, the consumer may have to pay a CSR premium. If they are unwilling to do so, Dole needs
to bear this cost and face the potential consequences.
VIII. New Development: The Creation of Social Accountability Accreditation Services
Earlier this year (2007), Social Accountability Accreditation Services (SAAS) was formed as anindependent organization separate from SAI, with a different Board of Directors. This means
SAI will no longer be responsible for the accreditation of CBs. It appears that SAI will still be incharge CB training. Although it is not clear why SAI decided to separate the accreditation
services from the rest of its services, perhaps it was because SAI itself noted the problems I havediscussed throughout my case study. Removing accreditation one step away from theorganization may be the answer to some of the problems, but more information on therelationship between SAI and SAAS needs to be gathered and observed to determine this. The
relationship between SAI and SAAS (e.g. does SAI get some form of remuneration from
SAAS?) and how this relationship affects SAI’s motivations and incentives may be good topics
for further research.

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IX. Conclusion
Although this case study is by no means comprehensive, it has highlighted several causes forconcern in the SAI and the SA8000 realm. Although SAI seems to be a credible organization in
general, there are several potential conflicts of interest and causes for concern. I specificallymentioned some issues in the SA8000 Accreditation Process, the SAI Corporate Program, as
well the SAI Board and Advisory Board. I also used Dole as an illustration of some of theseissues.

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X. Discussion Questions
1. Do you think the stated benefits of SA8000 publication put forth by SAI (found in Appendix I)
are valid? In addition to the benefits mentioned in the case study, what are the most important
SA8000 benefits? Do you think they outweigh the costs of certification (i.e. the direct and theindirect costs of the certification process)? In what instances might they not? Consider especiallythe benefits and costs of large retailers versus their suppliers.
2. What are the benefits and/or problems with having private interests help set the SA8000
standards? Do the conflict of interest problems outweigh the benefits?
3. In turn, what are the benefits and/or problems with having private interests—and especiallylarge retailers—on the Board or the Advisory Board? Again, do the conflict of interest issues
outweigh the benefits in this case?
4. In Thailand, the SA8000 requirement on working hours is more stringent than the legal
requirement. Consider the argument for and against adopting the SA8000; which side has thestrongest arguments? Should the SA8000 be modified in those countries to follow the legal
requirements?
5. Is it clear that adopting the SA8000 affords competitive advantage? If not, why would afactory choose to assume the extra cost of certification (even if it brings benefits with it as
explained in the case study)? Does the opportunity for competitive advantage depend on theindustry, the competitive power of the factory in question, or some other factors?
6. Do you agree with the representative for Dole’s Ecuadorian subsidiary, that Dole should notinterfere with labor rights conditions in its independent supplier plantations? Why or why not?
7. Do you agree with the Human Rights Watch argument that Dole as an SA8000 signatory
member should have informed its supplier facilities that they are to adopt the SA8000 code of
conduct; have established a plan and schedule for them to achieve SA8000 certification; andwork directly with them to achieve compliance through assessments and audits? If yes, howshould they work with their suppliers throughout this process?
8. In your opinion, does the creation of Social Accountability Accreditation Services (SAAS)
solve some of causes for concern covered in the case study, especially those related to SA8000
accreditation? Why or why not?
9. Compare SA8000 with ISO 9000. Which standard is more credible and why? Which standards
would small factories likely to adopt? What about large ones? What are the benefits of having
multiple certifications?

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XI. Appendix
APPENDIX I
SA8000 AROUND THE WORLD: CERTIFIED FACILITIES

Source: http://ce35.citysoft.com/_data/global/includes/worldmap.htm

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APPENDIX IISAI STATED BENEFITS OF SA8000 CERTIFICATION
Benefits of SA8000
Along with humane workplaces, the implementation of SA8000 offers more benefits to workers,
companies and others:
Benefits for Workers, Trade Unions and NGOs:••••

Enhanced opportunities to organize trade unions and bargain collectively.
A tool to educate workers about core labor rights.
An opportunity to work directly with business on labor rights issues.
A way to generate public awareness of companies committed to assuring humane
working conditions.

Benefits for Business:••••

Drives company values into action.
Enhances company and brand reputation.
Improves employee recruitment, retention and productivity.
Supports better supply chain management and performance.

Benefits for Consumers and Investors:•••

Clear and credible assurance for ethical purchasing decisions.
Identification of ethically made products and companies committed to ethical sourcing.
Broad coverage of product categories and production geography.

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APPENDIX IIICORPORATE PROGRAM STATED SERVICES AND BENEFITSINTRODUCTORY LEVELSAI Handbook “How to Implement a Responsible Supply Chain”
This new Handbook provides practical guidance on the establishment and management ofresponsible supply chains for any industry. True to SAI’s multi-stakeholder approach, theHandbook features the perspective of suppliers, trade unions and non-governmentalorganizations (NGOs). It includes step-by-step advice for compliance officers on:• Building the Business Case – Internally and Externally (with your suppliers and customers),• Managing Your Supply Chain,• Creating Your CSR Plan,• Navigating Industry Codes, Corporate Codes and the Audit Process.
The Handbook features management system examples, case studies, best practices, resource
guides and comparisons of SA8000 to industry and corporate codes. Publication date January
2008.
SA8000 Certified Supplier Database
Designed to make it faster for buyers to find socially-compliant factories, the SAI Supplier
Database features key business information on SA8000 certified suppliers, including:information on products, capacity, plant and equipment, quality control and certifications. It canbe used to quickly find SA8000 certified suppliers to replace existing non-compliant suppliers, to
add capacity or to source new products. SAI companies are given blinded access, allowing
suppliers to respond to inquiries from interested potential buyers or authorize SAI to release thecomplete contact information. Expected launch first quarter 2008.
Online Corporate Self-Assessment Tool
A companion to the Handbook, the SAI Corporate Self-Assessment Tool is a first-step ingauging your corporation’s level of social responsibility in managing your supply chain andidentifying the types of systems, the policies and the key documents in use by CSR leaders. The
SAI Corporate Assessment Tool is an abbreviated version of the full SAI Corporate
Headquarters Review Instrument.

EXPLORER LEVELAll Introductory Level Services, plus;
Executive Overview Training*
One-day training module at the company’s site, with the topic selected from SAI’s Professional
Development Training series on socially responsible supply chain management. The training is28

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ideal for managers and employees from compliance, as well as production, product development,
design, sourcing and marketing departments.
Invitation to participate in SAI Special Projects
SAI frequently partners in research studies, training programs, technical assistance and multistakeholder collaborations funded by governments and foundations. Explorers are notified of
special projects related to their industry and given the opportunity to participate. Examples ofcurrent projects include a study with Harvard University on the impact of social labeling on
consumer preference, and training programs in Asia and Latin America aimed at improving
producer competitiveness through better social performance.
Review & Analysis of Corporate Self-Assessment Tool
SAI management will review the company’s completed SAI Corporate Self-Assessment Tool for
supply chain management and provide valuable insight and comparisons to best practices in thefield. Areas of review include management systems, supplier development, auditing, verification,transparency and multi-stakeholder participation.
Additional Reporting Services
If desired, SAI provides technical assistance to our Explorer members to meet the laborcomponent of their CSR reporting requirements. One option is for SAI to assist United Nations
Global Compact members in generating the required human rights and labor components of theirannual Communication on Progress report.
20% Discount on Training and Publications
Receive a discount on all SAI training including Basic Auditor Training, Supply Chain
Management Training and our Professional Development Training courses.
SIGNATORY LEVELAll Introductory and Explorer Level Services, plus;
Corporate Assessment Program
SAI’s Corporate Assessment Program provides a confidential in-depth review of a company’s
compliance management system throughout their supply chain. Areas of review include
management systems, supplier development, auditing, verification, transparency and multistakeholder participation.
The Program includes the following:• Use of SAI’s complete Corporate Headquarters Review Instrument to help a company’s
compliance staff organize and evaluate its existing CSR practices and documentation.
• Headquarters visit by SAI executive team for 2-3 days to conduct interviews with all relevant
personnel from the CEO to key staff in the compliance, purchasing, and other relevant
departments.
• Field reviews by expert SAI evaluators to witness audits of selected suppliers by company
monitors or second party auditors.
• Confidential review of SAI’s findings and recommendations by a blue-ribbon multi-stakeholder

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panel featuring business, trade unions and NGO representatives.
• Transparency review of a company’s reporting procedures and practices, and external
communications by an independent specialist.
• Final Corporate Assessment report featuring analysis of headquarters assessment, evaluation ofexisting CSR programs and recommendations for improvement. Recommendations are based onbest practices, incorporating multi-stakeholder panel and transparency review recommendations.

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APPENDIX IV
SA8000 STEPS AND COST OF ACCREDITATION

http://www.saintl.org/_data/n_0001/resources/live/SA8000_Steps_for_Accreditation_Brief_Description.pdf

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APPENDIX V
BOARD AND ADVISORY BOARD MEMBERS
BOARD MEMBERS
http://www.saintl.org/index.cfm?fuseaction=Page.viewPage&pageId=593&parentID=490&grandparentID=4&
nodeID=1
Steve Newman (Chair)Vice-President for Finance Chief Operating Officer
Medical & Health Research Association
Riccardo Bagni
Vice Chairman
Coop Italia Societa Cooperativa
Celina Borges
Torrealba Carpi
President and Shareholder
Grupo Libra
Dana Chasin
Senior Advisor, Federal Fiscal Policy
OMB Watch
Tom DeLuca
Vice President, Product Development & Safety Assurance
Toys R Us
Jan Furstenborg
Head of Department - UNI Commerce
Union Network International
Alice Tepper Marlin
President
Social Accountability International
Nicholas Milowski
Manager
KPMG LLP
Jeff Samuels
PartnerPaul, Weiss, Rifkind, Wharton & Garrison

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Responsibilities of the SAI Board of Directors. The SAI Board of Directors shall consist of atleast three persons, with responsibilities and membership as defined in the by-laws of the
Corporation. It will evaluate the performance of SAI and its management and provide feedbackon this to SAI. This evaluation will include activities and operations for the last year and futurework-plans and policies as presented to it by the management of SAI.
There are two committees of the Board of Directors: Finance and Compensation.
ADVISORY BOARD
http://www.saintl.org/index.cfm?fuseaction=Page.viewPage&pageId=494&parentID=490&grandparentID=49
0&nodeID=1
Affiliated with Non-Governmental Organizations, Trade Unions, Socially Responsible Investingand Government*:
Dorianne Beyer/David Zwiebel (alternate)

National Child Labor Committee (USA)

Jeroen Douglas

Solidaridad (Netherlands)

Pietro Foschi/Francis Boigelot (alternate)

Bureau Veritas Certification - formerly BVQI
(UK)

Jan Furstenborg

Union Network International (Switzerland)

Oden Grajew/Helio Mattar (alternate)

Ethos Intstitute of Business & Social
Responsibility (Brazil)

Joseph Iarocci /Linda Cronin

CARE International (USA)

Alice Tepper Marlin

Social Accountability International (USA)Frits Nagel

Dutch Consultant for Corporate Social
Accountability (The Netherlands)

Alan Spaulding

United Food and Commercial Workers
International Union (USA)The Honorable William Thompson/Ken
Sylvester (alternate)

Office of the Comptroller, City of New York(USA)

Morton Winston

The College of New Jersey (USA)
Affiliated with Business*:

Giorgio Bertinelli/Marisa Parmigiani(alternate)

Legacoop Nazionale (Italy)

Celina Borges Torrealba Carpi

Grupo Libra (Brazil)

Kishor Chaukar /Anant G. Nadkarni(alternate)

Tata Industries Limited (India)

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Sylvain Cuperlier
Tom DeLuca (Chair)

Dole Food Company (USA)Toys “R” Us (USA)

Durai Duraiswamy/Robin Cornelius(alternate)

Prem Durai Exports (India) and Switcher SA(Switzerland)

Amy HallEileen Fisher (USA)Dan Henkle/Chuck Goncalves (alternate)

Gap Inc. (USA)

Achim Lohrie

Tchibo (Germany)

Geoffrey Martin-HenryTNT Express (Netherlands)

David McLaughlin/George Jaksch(alternate)

Chiquita Brands International (USA)Dr. Johannes Merck/Gerd Billen (alternate)

OTTO GmbH & Co KG (Germany)

Nicholas Milowski**

KPMG LLP (USA)Steven Newman**

Medical and Health Research Association (USA)

Jeff Samuels**Paul, Weiss, Rifkind, Wharton & Garrison (USA)In 1996, SAI convened an international, multi-stakeholder Advisory Board to develop Social
Accountability 8000 (SA8000), a voluntary standard for workplaces based on ILO (International
Labour Organization) and other human rights conventions. Its independent verification method
uses key elements from the widely accepted quality management system certification in theInternational Organization for Standardization (ISO) programs.
The SAI Advisory Board includes experts from trade unions, businesses and NGOs. Board
members represent abroad range of expertise in human rights, child and labor rights; socially
responsible investing; auditing; and supply chain management.
Reaching consensus among board members is a continuing challenge. However, this diversity
adds to the strength of SA8000, making its requirements comprehensive and its language clear
and auditable.
SA8000 Advisory Board Members. SAI’s policy is to balance its Advisory Board members
equally between business and non-business (non-governmental organizations, trade unions,socially responsible investors and government) members. SAI also seeks to have an international
representation on the Advisory Board.
Advisory Board Roles and Responsibilities. The SA8000 Advisory Board provides direction
and advice regarding the operation of and policy matters relating to the functioning of SAI.
Through the Board, SAI seeks to ensure that its policy is fair to affected parties from all sectorsof society and does not make unreasonable demands on any party. The Board is responsible forreviewing:34

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1. The SAI Social Accountability Standard, SA8000.
2. The Agency’s accreditation procedures.
3. Any challenges to determinations of SAI regarding accreditation of certification bodies. The
SAI Advisory Board advises the President of SAI.
The Advisory Board has no responsibilities for the day-to-day operations of SAI. The board andits members have none of the legal obligations or liabilities that attach to a Board of Directors.
The President of SAI will appoint the Chair of the Advisory Board. A Vice-Chair, nominated by
the Chair and elected by the full Board, will chair meetings in the absence of the Chair. The
remaining members will be proposed by SAI staff or current Advisory Board members andelected by a majority vote of current members—one representative affiliated with eachorganization shall vote—to represent a cross-section of industry, auditors, consultants, humanrights groups, unions, vendors, and NGOs. The Advisory Board shall have up to 25 members.
The board has a number of committees: Accreditation Review Panel (ARP), and Executive,
Nominating, and Guidance Document Review panels. In addition, there are several ad hoc
committees.
The ARP is chaired by the SAI Executive Director.
Advisory Board Member Responsibilities. Members are appointed for their experience andknowledge of particular sectors to ensure that the interests of the sectors are represented.
Members may also be experts in a particular discipline, and provide impartial expert advice. SAI
Advisory Board members are appointed in their own right to maintain the balance of interests on
the Board, but do not represent any particular organization.
The Advisory Board may request supporting outside expertise to assist its decisions when there
is not sufficient expertise available within its membership. The credentials of any such outside
authority, as well as any opinions, advice, recommendations, or observations provided to theBoard by this authority, will be documented.
There may be an occasion when an accreditation applicant wishes to seek advice from the SAI
staff, but feels that an inquiry might adversely influence the outcome of his or her accreditationassessment. In such cases, one member of the SAI Advisory Board may be sought by the ViceChair to act as a confidential intermediary between the advice seeker and SAI.
A three-person Accreditation Review Panel will review accreditation audits, with two members
drawn from the SAI Advisory Board [excluding certification bodies], which will recommend a
decision to the SAI President.
Annual Meeting. The SAI Advisory Board holds an Annual Meeting to conduct a review ofSA8000 and the continuing suitability and effectiveness of SAI policies and procedures inmeeting the requirements of ISO Guideline 61 and the SAI Quality Policy. The Advisory Board
meets three times a year.