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

Some people think that the idea of common compliance code for textile and clothing industry was initiated in 2005 i.e. after export quotas were dismantled; but, to my mind, perhaps No. If it were so, then perhaps 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 times that the labour laws were enacted and enforced, which were revised from time to time. A slew of labour laws including Factories Act, 1948, Payment of Gratuity Act, Minimum Wages Act, Payment of Wages Act and the State Factories Act were all part of what has now been designed and designated as Compliance Code. It is fashionable to talk in terms of Compliance Code or Common Compliance Code (CCC), which were, in fact, nothing more and beyond what had already been enacted and enforced. It is, however, a different story that we, as a nation ops as a crowd as someone had rightly called us, have a strong tendency not to comply with the law and specialize in finding loopholes and then feel proud of our this achievement.

It is, however, true that the issue of compliances did not come up earlier in as big a way, as it did come up later on, when quotas were replaced by what is known as Free Trade which supposedly came into force with effect from past midnight of 31 December, 2004.

However, all our labour related legislation did not include a new requirement i.e. environmental laws and that too was for the simple reason that environment had not caught the fancy of the international retailers, most Western retailers, but that addition, too, I trust, has been made and added in the list of requirements that our industry needs to meet with.

Why Compliance Code?

As if to confirm what has been stated by me in preceding paragraphs, AEPC says, With many garment exporting countries in Asia and elsewhere facing problems related to increased requirements for multiple compliance accreditations the chief concerns among buyers are environmental laws and regulation, labour reforms, wage differentiation and discrimination, overtime, flexible working hours, health and safety issues and working conditions.

According to AEPC, the Compliance issues are generally classified under social, environmental and technical categories and that Compliance code is required for increasing national competitiveness in terms of social compliance, reducing burden on manufactures and increasing competitiveness of small scale manufacturers. The whole process starts with analysis of facility, requirement analysis of buyers, analysis of national and international laws and regulations, designing and creation of hierarchical structure of common code, mapping of structure with specific laws and regulations and development stage which includes detailed write-up of the common code, review and approval by independent panel made up of legal ad industry experts.

Perhaps, if the Compliance issues, which have been classified by AEPC, under social, environmental and technical categories, had been clearly spelled out, it would have been quite enlightening. Since the Compliance issues have been classified, these must have listed and then classified. Perhaps, only one of the classified categories i.e. environment has been discussed, at much later stage, when the Note says, The code will ensure compliance 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 practices The details of issues of other classifications have not been mentioned for the benefit of reader.

Endorsement of and consultation on CCC

Nonetheless, it is heartening to see AEPCs initiative on the latest avatar of Compliance-Common Compliance Code-which is being endorsed by the International Labour Organisation (ILO) and the Ministry of Textiles. Other organisations being consulted are Fair Labor association, Worldwide Responsible Accredited Production (WRAP), Business Social Compliance Initiative (BSCI) and Ethical Trading Initiative (ETI), besides global brands like GAP, Next, H&M and Adidas besides Indian suppliers and accreditation consultants. As the AEPCs note says, other organizations are being consulted, it is not clear whether the 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 new formulation. Be it as it may. We will presume, but not assume, that every organization might concur with the AEPC proposal without suggesting any amendments.

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