The Future Of Due Diligence In Textiles: An Interview With SLCP

The EU’s intensified focus on business accountability and its Corporate Sustainability Due Diligence Directive (CS3D) represent crucial steps in making supply chains more sustainable and advancing our green transition. However, the lack of appropriate guidance for implementation and the changes proposed under the new EU Omnibus Simplification Package might pose a challenge to its implementation and overall effectiveness.

To discuss how we can ensure that the CS3D will drive long-lasting, positive impacts in the textile industry, I recently sat down for a chat with Tom Mason, Senior Policy and Stakeholder Engagement Manager at the Social & Labor Convergence Program (SLCP). Another major focus of our discussion was the recently launched Handbook for Due Diligence Implementation in the Textile Sector, a resource designed to support textile businesses in meeting their due diligence obligations and guide the work of EU policymakers.

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Getting To Know Tom and The Social & Labor Convergence Program

With a background in law and public policy, for the past four years Tom has been working at the Social & Labor Convergence Program (SLCP), leading its policy and stakeholder engagement efforts. SLCP is a multi-stakeholder initiative committed to reducing audit duplication in the apparel and textile industry. Their Converged Assessment Framework (CAF) provides a common framework for collecting social audit data, replacing the inefficient practice of manufacturers undergoing multiple, often redundant, audits for different buyers.

“The idea is to use a common framework to collect social audit data, so we can free up resources to put towards actual improvement programs,” he explained, highlighting how some manufacturers were previously undergoing 20 or more audits per year for different buyers, with up to 95% of the questions asked being duplicative. “It was just inefficient.”

The SLCP’s work has evolved significantly in response to legislative developments. Initially focused on voluntary frameworks such as the UN Guiding Principles, OECD Guidelines and brands’ codes of conduct, the organisation has shifted towards supporting compliance with mandatory regulations like the Corporate Sustainability Due Diligence Directive.

Beyond its technical aspect, SLCP has an important advocacy role. With a tool primarily focused on manufacturers – data is collected through and by manufacturers – it also works to give a voice to many who are not often heard during the policymaking process, informing legislators about what the reality looks like on the ground. Tom notes:

“When you’re asking for more sustainability compliance, you’re asking for more data, which is fine, but we need to make more efficient ways to capture this data. Otherwise, you’re going to create this undue burden on manufacturers since they’re the ones who have to figure out how to actually do it in practice.”

“And if we don’t have common frameworks and organisations like SLCP to support data collection, then we’ll be adopting unilateral approaches that are just going to create huge inefficiencies.”

Taking a Collaborative Approach: The Handbook for Due Diligence Implementation in Textiles

One of the most exciting developments in this space has been the recent launch of the Handbook for Due Diligence Implementation in the Textile Sector in January. Developed in collaboration with the Policy Hub, the Fair Wear Foundation, and Amfori, the handbook consolidates existing industry tools, standards, and frameworks to provide a practical guide for due diligence implementation.

Tom shared the motivation behind the initiative:

“A year ago, we hosted a roundtable in Brussels where it became clear that, regarding due diligence, while there is a lot of good work being done, there’s also a great deal of misalignment and confusion. So the idea behind the handbook was to consolidate these efforts into a single document that could serve as a reference point for policymakers and industry alike.”

For EU legislators, the handbook serves as a stock-take of where the industry currently stands and highlights key areas where further attention is needed. Tom further explained:

“The textile industry faces significant challenges in upholding responsible business conduct, and many of these challenges are not on policymakers’ radar. So we as a multi-stakeholder initiative can bring in our expertise and help bridge that gap.”

SLCP’s Perspective On The Omnibus Simplification Package and The Changes to The CS3D

Our conversation naturally turned to the potential impact of the EU Omnibus Simplification Package on the CS3D, and how in the effort to simplify the directive we could be actually diluting its effectiveness.

As Tom pointed out, the core principles of due diligence — based on well-established frameworks like the OECD Guidelines and the UN Guiding Principles — are not new. However, while voluntary frameworks have been promoted for years, what we have seen is that they have not moved the needle as they should have, and simply did not generate the same change that mandatory frameworks would.

In Mason’s perspective, mandatory policies like the CS3D serve to push companies beyond just having a conversation about sustainability, and into actually working towards compliance, ‘“because when we get the attention of boards and C-suites, things start moving further and faster.’”

“While it’s important that CS3D is encouraging collecting data and measuring it against a code of conduct, its key role is to highlight very real and critical issues currently impacting workers in the supply chain. These are not just legal compliance matters, they’re real problems that many people face. So we would hope that something mandatory, such as the CS3D, could employ a risk based approach to focus on these severe issues and create actual change.”

The Need For More Alignment and Clarity

Indeed, I believe that there is no need to fully open and review files to guarantee a successful due diligence implementation, only to focus on better guidance.

“There are many successful initiatives and tools out there, so for implementation you don’t have to reinvent the wheel, but more guidance and alignment with international standards. This is essential because, at the moment, the political discussion is very much focused on EU brands and retailers, but we must not forget that our textile industry works with a very international supply chain, meaning that it has a massive ripple effect on manufacturers on a global scale.” I added.

Tom agreed, and noted that while it is understandable that the CS3D’s requirements could seem challenging for many organisations, watering them down is not the way to go.

“We fully understand that it can be confusing for many stakeholders, especially for more inexperienced companies. But if we had practical guidance that walked us through the steps, detailing what good due diligence looks like, maybe this wouldn’t be happening. So it’s really important that we continue to share that message, and the handbook is a good example of that.”

A Call For Stakeholder Integration and Legal Certainty

Regarding the industry’s reaction to the handbook, Mason told me that it was in fact met with great interest by stakeholders across the board during the OECD forum in Paris. He also mentioned an overwhelming support for the fact that the industry must come together to collaborate and advocate, keeping in mind how many stakeholders who were not present should also have their voices heard.

“We need to make sure that we go down the supply chain to listen to manufacturers, and that not only the tier one manufacturers’ perspectives are reflected in these conversations. The indirect suppliers – primarily those in tier three and tier four supply chain levels, at the raw material stage, often do not get their voices heard. Irrespective of the scope of the legislation, indirect suppliers are important voices in the policy debate.”

Further integration is undeniably a key step to the success of legislation such as the CS3D and the Corporate Sustainability Reporting Directive (CSRD), and it is essential that any accompanying measures, help desks, and other support systems established, take the reality and needs of smaller players into account.

Approaching the end of our conversation, I asked Tom about what SLCP’s key asks to EU policymakers would be.

“Regarding the Omnibus, what we really believe in is the need to preserve the integrity and the ambition of policies like the CS3D and the CSRD. We need to remember that so much effort has already been put into developing the legislation and many businesses have invested significant resources into aligning their practices with the directives’ requirements.”

“Yes, pushing for simplification and efficiency is important. But, actually, the best form of simplification is guidance, and timely guidance.” Tom added.

He then went on to highlight that with so many new policies on the horizon, such as the EU Forced Labour Ban, remaining focused and fostering a stable legislative environment should be a priority.

“We would like to make sure that the legal uncertainty we have at the moment with the Omnibus is resolved sooner rather than later, so we can actually get moving with the work. What we saw at the OECD forum in Paris and have been hearing from a lot of people, is that it’s creating confusion and delaying implementation and enforcement.”

Looking Ahead

SLCP and its partners remain committed to ongoing collaboration on the CSDDD Handbook and the broader CS3D implementation process. Mason emphasised that they consider the handbook to be a first-step document and a reference point to build on as we further the discussions around guidance development and the Omnibus Package.

We both agree that now is the time to take action and ensure that CS3D implementation remains robust, effective, and grounded in the realities of the industry.

If you’re interested in collaborating and learning more about the handbook, be sure to reach out to Tom and his team at SLCP.

“We definitely welcome more perspectives from different stakeholders, and want to keep them front of mind as we move forward. As an industry, we need to do more and better to make sure that all perspectives are heard.”

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch!

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