The ever-enlarging list of compliances has made many aexporter and exporting countries sit up and make a note of what is expected tobe complied with-as desired by the international retailers-by anyone, whowishes to export any products; in our case, textiles and garments.

Some people think that the idea of common compliance codefor textile and clothing industry was initiated in 2005 i.e. after exportquotas were dismantled; but, to my mind, perhaps No. If it were so, thenperhaps all legislations relating to labour should have started from 2005 only,which is not the case. The fact of matter is that it was during British timesthat the labour laws were enacted and enforced, which were revised from time totime. A slew of labour laws including Factories Act, 1948, Payment of GratuityAct, Minimum Wages Act, Payment of Wages Act and the State Factories Act wereall part of what has now been designed and designated as Compliance Code. It isfashionable to talk in terms of Compliance Code or Common Compliance Code(CCC), which were, in fact, nothing more and beyond what had already beenenacted and enforced. It is, however, a different story that we, as a nationops as a crowd as someone had rightly called us, have a strong tendency not tocomply with the law and specialize in finding loopholes and then feel proud ofour this achievement.

It is, however, true that the issue of compliances did notcome up earlier in as big a way, as it did come up later on, when quotas werereplaced by what is known as Free Trade which supposedly came into force witheffect from past midnight of 31 December, 2004.

However, all our labour related legislation did not includea new requirement i.e. environmental laws and that too was for the simplereason that environment had not caught the fancy of the internationalretailers, most Western retailers, but that addition, too, I trust, has beenmade and added in the list of requirements that our industry needs to meetwith.

Why Compliance Code?

As if to confirm what has been stated by me in precedingparagraphs, AEPC says, With many garment exporting countries in Asia andelsewhere facing problems related to increased requirements for multiplecompliance accreditations the chief concerns among buyers are environmentallaws and regulation, labour reforms, wage differentiation and discrimination,overtime, flexible working hours, health and safety issues and workingconditions.

According to AEPC, the Compliance issues are generallyclassified under social, environmental and technical categories and thatCompliance code is required for increasing national competitiveness in terms ofsocial compliance, reducing burden on manufactures and increasingcompetitiveness of small scale manufacturers. The whole process starts withanalysis of facility, requirement analysis of buyers, analysis of national andinternational laws and regulations, designing and creation of hierarchicalstructure of common code, mapping of structure with specific laws andregulations and development stage which includes detailed write-up of thecommon code, review and approval by independent panel made up of legal adindustry experts.

Perhaps, if the Compliance issues, which have beenclassified by AEPC, under social, environmental and technical categories, had beenclearly spelled out, it would have been quite enlightening. Since theCompliance issues have been classified, these must have listed and thenclassified. Perhaps, only one of the classified categories i.e. environment hasbeen discussed, at much later stage, when the Note says, The code will ensurecompliance with environmental requirements like domestic swage, chemicals,hazardous substance and waste handling, storage, material safety data sheets,workers awareness, chemical management for pregnant women and young workers.Personal protective equipment and use, ventilation and recycling practicesThe details of issues of other classifications have not been mentioned for thebenefit of reader.

Endorsement of and consultation on CCC

Nonetheless,it is heartening to see AEPCs initiative on the latest avatar of Compliance-CommonCompliance Code-which is being endorsed by the International LabourOrganisation (ILO) and the Ministry of Textiles. Other organisations beingconsulted are Fair Labor association, Worldwide Responsible AccreditedProduction (WRAP), Business Social Compliance Initiative (BSCI) and EthicalTrading Initiative (ETI), besides global brands like GAP, Next, H&M andAdidas besides Indian suppliers and accreditation consultants. As the AEPCsnote says, other organizations are being consulted, it is not clear whetherthe consultation has been completed or the process of consultation is still on.And if completed whether all of these organizations concur with AEPC on its newformulation. Be it as it may. We will presume, but not assume, that everyorganization might concur with the AEPC proposal without suggesting anyamendments.

Steering Committee

AEPC has created a Steering Committee, consisting of experts with a long array of functions and responsibilities like preparation of advisories, creating structure for programme and implementation; help design institutional infrastructure that leads towards sustainable solutions, supervision of programme implementation, developing appropriate communication, strategies for advocacy and out-reach of DISHA; Strengthening the social and environmental compliance mechanism in the supply chain; creation of institutional infrastructure that drives tangible and measurable social change; to outli9ne programmes, road-maps which include strategies, structure, recruitment, programme, design, assessment, evaluation, reporting and funding; to analyze and give recommendations to the issues relating to social standards brought by the industry and international stake-holders;; to facilitate arbitration and conflicts that arise in industry related social compliance programme; to implement the projects sanctioned by the Government and bother bodies in furtherance of best practices.


AEPCs Executive Committee has approved the establishment of DISHA (Driving the Industry towards Sustainable Human capital Advancement), an initiative to be driven by the Steering Committee, which will oversee the conceptualization, strategy and programme direction of DISHA and would, in turn, seek the guidance from the Ministry of Textiles. The Executive Committee has also approved DISHA as an institutional mechanism for labour and compliance issues.

Implementation of DISHA

According to AEPC, Northern India Textiles Research Association (NITRA) has been entrusted the work of field-level research study to find out incidence of forced labour. The note from AEPC further adds, Trade unions and campaigners have developed model codes as a benchmark for acceptable practice. They mainly concentrate on the five key areas within ILO conventions i.e. forced and bonded labour, freedom of association, right to collective bargaining and no discrimination, health and safety in the work place.

The Note from AEPC is not clear as to whether it proposes to adopt the model codes as developed by trade unions and campaigners.

Implementation Agency

It is not clear as to when and in what form, an implementation agency would be formed or who is going to implement the project. Perhaps, it is left to Steering Committee to create such an institutional infrastructure, as laid down in the responsibilities assigned to the Committee. When it will happen is not quite known; hopefully, quite soon. The degree of success of DISHA would depend entirely on the kind of implementation agency that is created and the vision of the person, who heads it.

I do subscribe to the view that it is well intentioned document, but has gaping holes of extremely relevant information on the Implementation Agency and Plan of Action. I would look out for the same, as and when these are made available.


Here 'I' refers to the author of the article