JULY 2020

Assess-and-Address Position Paper
The Assess-and-Address Model in the Rainforest Alliance
Sustainable Agriculture Standard

The Rainforest Alliance is an international non-profit organization working in
more than 70 countries at the intersection of business, agriculture and forests.
We are building an alliance to create a better future for people and nature bymaking responsible business the new normal.

Introduction

This approach is focused on prevention, engagement
and improvement, which is more sustainable for farmers,
processing operations, and workers than immediate disengagement whenever a violation is identified6. It is only
through collaboration and investment in building longterm capacity that systemic transformation on both asector and landscape level will be possible.

The Rainforest Alliance is committed to building an allianceto create a better future for people and nature by making
responsible business the new normal.
There is no place in responsible business practices forgrave human rights abuses such as child labor1, forced labor2, discrimination3, and workplace violence and harassment4. We are committed to working with stakeholders
to protect workers and children from such human rights
abuses.

The “assess-and-address” approach is in line with the growing international consensus around due diligence, capacity-building and continuous improvement laid out in theUnited Nations Guiding Principles on Business and HumanRights, the OECD Guidelines for Multinational Enterprises,
and other international frameworks, which ask companies
to identify, mitigate, account for and remediate adverse
human rights impacts. Many leading companies have adopted such approaches in their own global supply chains.

Our experience over many years has shown that merely
prohibiting labor abuses is insufficient to promote sustainable improvements for workers and their families. Thisap- proach simply drives exploitative and illicit practices
un- derground, making them harder for auditors to detectand for certificate holders to identify and mitigate.

The Rainforest Alliance will implement this system in relation to four of the requirements in its new Sustainable Agriculture Standard that was published for public consultation in June 2019. The standard goes into effect in July 2021.

That’s why our improved certification system will adopt an“assess-and-address” system, which goes much furtherthan a simple prohibition approach in its ability to drivechange on human rights. Building on our experiences andthe find- ings of globally recognized human rights organizations, we will work with certified operations to assess
risks, build capacity, remedy violations and incentivize sustainable progress on human rights5.

Leonie Osso Sona, cocoa farmer in Côte d’Ivoire. Photo by Giuseppe Cipriani
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Women working at FEDECOVERA nursery. Photo by Sergio Izquierdo

Rainforest Alliance Vision

The Problem

Under the new Sustainable Agriculture Standard, the following will be in place:

Human rights abuses are endemic in global agricultural
supply chains. The International Labor Organization estimates that approximately 1.4 million people7 are trappedin forced labor in agriculture worldwide, and 108 million
children in child labor linked to agriculture8. No global data
exist on sexual harassment/violence in commercial agriculture, but case studies indicate high percentages.

• Operations and workers in Rainforest Alliance certified
supply chains understand that discrimination, child labor, forced labor and workplace harassment and violence are prohibited in certified operations, and havethe knowledge, resources and systems in place to identify and mitigate risks, monitor workplaces, and identify
incidents of these abuses.

Agricultural workers are vulnerable to deceptive recruitment practices, withholding or non-payment of wages,
debt bondage, and other indicators of forced labor. Children on farms and in agricultural processing facilities arevulnerable to hazards such as exposure to pesticides, dangerous machinery, equipment and tools, and handling ortransport of heavy loads, among others. Vulnerable workers like young and migrant workers, particularly women,risk discrimination and workplace violence and harassment, including sexual harassment.

• If instances of child labor, forced labor, discrimination
and/or workplace violence and harassment are found,
operations understand their responsibilities related toproviding remedy, and have access to external parties
to support remediation activities as needed.
• Certification Bodies carrying out Rainforest Alliance
audits have the knowledge and resources to evaluate
farms’ and companies’ performance, to verify if their“assess-and-address” system is working, and to identify
and respond appropriately to instances of child labor,
forced labor discrimination and workplace violenceand harassment found during an audit.

.

These human rights abuses have their origins in complex
social, economic and political issues. Root causes of discrimination, child labor, forced labor, and workplace violence/harassment include a lack of social protections andrule of law in many countries, informality in employment,
discrimination against minority groups, low educational
attainment, and poverty.

• Companies purchasing and selling Rainforest Alliance
Certified products know that they were produced in amanner consistent with international best practice onhuman rights due diligence.

No certification program – and no single organization oractor – can change these conditions by itself, but the “assess and address” system recognizes these root causes as
key risk factors, and requires both operations and Certification Bodies to adjust their systems according to specificrisks.
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The Rainforest Alliance Approach
Just as before, the “assess-and-address” system will require certificate holders to commit to comply with all applicable laws and to respect internationally recognized human rights standards.
In addition, each operation will be required to appoint a
person or committee responsible for managing forced labor, child labor, discrimination and workplace violence andharassment, and for raising awareness of managementon these issues. Operations will implement risk assessments using specific Rainforest Alliance guidance, which
will be combined with the Rainforest Alliance’s own dataon risks. If risks are identified, operations will be required toput in place locally-appropriate risk mitigation measures.
Assess-and-address committees will conduct ongoing
monitoring of workplaces and must remediate any cases
found using the new Rainforest Alliance Remediation Protocol. The Rainforest Alliance provides tools, guidance materials and training to certified operations to assist with theimplementation of these measures.
The Rainforest Alliance also has its own child labor andforced labor risk maps, based on data from independent,
external sources as well as internal topic and country expertise. These maps help define what risk mitigation measures operations must take, and help Certification Bodies
focus their audit approaches.
Simon Sigali, nursery worker. Photo by Caroline Irby
External Audits

actions were perpetrated deliberately. In cases found tobe “severe,” CBs have discretion to suspend and/or withdraw certificates, as described in the Certification/Auditing
Rules, including violations of applicable criminal law.

Audits are carried out by third-party Certification Bodies(CBs). During an audit, auditors will verify the effective implementation of the system: communication, risk as- sessment, mitigation, monitoring, and remediation. Did theoperation perform an adequate risk assessment? Has theoperation addressed the identified issues and improvement points in its management plan? Did the operation
implement specific mitigation actions? What monitoring
steps are in place, and are these adequate for the levelof risk identified in this operation? Has the operation beenable to identify and correctly remediate any labor abusecases?

The Rainforest Alliance has published specific rules on how
audits should be planned and conducted, as well as guidance materials and/or training to CBs to assist with auditing/verifying compliance to this approach. The rules coversuch issues as the duration and frequency of audits andthe use of announced versus unannounced audits.
Remediation Protocol

Certified operations that have failed to effectively implement the system will be in breach of our standard, even
if no cases of human rights abuses are actually found by
the auditor during the audit. They will be given a chance
to put such systems in place within 12 weeks before being
decertified.

If any cases of child labor, forced labor, discrimination, orworkplace violence and harassment are identified by theoperation’s monitoring system, or during an audit, themanagement must utilize the Rainforest Alliance Remediation Protocol. The Protocol will specify both immediate
steps that must be taken to ensure the alleged victim’ssafety, as well as longer-term steps to ensure full remedy
and prevent recurrence. It will be critically important formanagement and group members, where applicable, towork together (amongst themselves and/or with externalparties) to address these challenging issues with complex
root causes. We encourage management to engage withexternal stakeholders/experts as part of remediation. The
collective wisdom, experience, and connections of ourpartners and stakeholders will help us deliver the greatest
impact.

In order to verify the effectiveness of the operation’s monitoring system, the auditor will also seek to identify casesof labor abuse that the monitoring system may not havefound. If an auditor identifies a case, the first priority will
be to ensure the safety and provide for the immediateneeds of the actors involved, using guidance provided in
the Rainforest Alliance Remediation Protocol. The CB willthen undertake a further “severity test.” This test examines
the degree to which the case(s) found were prevalent, thelevel and nature of impact on workers, and whether the4Conclusion
As an alliance, we know that certification alone cannot
ad- dress all challenges that farmers and other agricultural operations are facing today. For this reason, we areworking toward an evolved certification system based on
the principle that sustain- ability is a journey of continuous,data-informed improvement rather than a binary pass/
fail model. But certification is just one of our four strategicinterventions, which also include landscape and community projects, advocacy with governments and otherinstitutions, and tailored programs working one-on-one
with companies on their specific challenges. Through all ofthese interventions, we seek to create a better future forpeople and nature.
For further information, please contact info@ra.org.

A primary school in Uganda. Photo by Giuseppe Cipriani

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References
1
Child labor includes the worst forms of child labor as defined by ILO Convention 182, work performed bychildren under age 15 (unless national law sets the minimum age for work at 14, in which case this age applies),and any other work that may harm the physical, mental,
or moral well-being of children.
2Forced labor is defined by ILO Convention 29 as
all work or service which is exacted from any person under the threat of a penalty and for which the person has
not offered himself or herself voluntarily.
3Discrimination is defined by ILO Convention 111
as Any distinction, exclusion or preference made basedon race, color, sex, sexual orientation, religion, politicalopinion, national extraction or social origin, which has theeffect of nullifying or impairing equality of opportunity ortreatment in employment or occupation.
4
Workplace violence/harassment is defined byILO Convention 190 a range of unacceptable behaviors
and practices, or threats thereof, whether a single occurrence or repeated, that aim at, result in, or are likely to result in physical, psychological, sexual or economic harm.
It includes gender-based violence and harassment.
5
Shift Project, Respecting Human Rights ThroughGlobal Supply Chains, https://www.shiftproject.org/media/resources/docs/Shift_ UNGPssupplychain2012.pdf.
6SOMO, Should I stay or should go: exploring therole of disengagement in human rights due diligence,https://www.somo.nl/wp-content/uploads/2016/04/
Should-I-stay-or-should-I-go-4.pdf.
7
Per ILO estimates, approximately 13 million
adults are in forced labor exploitation in the private
economy. Eleven percent of those are in the agriculture
and fishing sector. https://www.ilo.org/wcm-sp5/groups/
public/---dgreports/---dcomm/documents/publication/wcms_575479.pdf.
8ILO, Global Estimates of Child Labour, https://www.ilo.org/wcm-sp5/groups/public/@dgreports/@
dcomm/documents/publication/ wcms_575499.pdf.

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