Interview with Francisco Esteve

Francisco Esteve
Francisco Esteve
Strategic Advisor
FSSC 24000

Rethinking Social Compliance in Textiles Through FSSC 24000
The global textile and apparel industry is facing mounting pressure to demonstrate responsible labour practices, ethical sourcing, and transparent supply chains. As social compliance expectations move away from checklist-based audits towards risk-driven, system-based accountability, ISO-aligned management approaches are gaining importance. In this context, FSSC 24000 is emerging as a robust framework for managing social performance across complex and multi-tier value chains.

In this interview, Francisco Esteve, Strategic Advisor for FSSC 24000 and co-author of PAS 24000:2022, explains to Fibre2Fashion how the certification builds on proven ISO management system principles to help textile and apparel businesses strengthen human rights due diligence, reduce social risks, and embed fair working conditions into everyday operations through a structured and continuously improving social management system.

The textile and apparel industry is often under scrutiny for labour practices. How does FSSC 24000 go beyond traditional social audits?

FSSC 24000 includes a comprehensive baseline of controls covering key labour practices such as human rights, forced and child labour, freedom of association, non-discrimination and fair treatment, occupational health and safety, building safety, employment and contractual relations, working hours, grievance mechanisms, and business ethics. Beyond this, its robust ISO-aligned management system requires each company to analyse the risks associated with its specific activities. This risk assessment adds a further layer of company-specific controls, complementing the baseline requirements. When conducted effectively, the process ensures that all significant labour and social risks relevant to the organisation are identified and controlled.

How does FSSC 24000 help textile and apparel manufacturers move from episodic factory audits to a structured, ongoing social management system?

FSSC 24000 is a unique Certification Scheme in that it is currently the only social sustainability standard incorporating ISO’s Harmonised Structure, a well-established framework for the effective deployment and execution of a continuous management system focused on social sustainability. Achieving certification demonstrates that a company is systematically identifying, embedding, and managing social risks within its operational activities. This shifts the approach away from audit-driven preparation and episodic compliance towards an ongoing commitment, similar to how organisations manage quality or food safety. To protect and enhance reputation, social sustainability cannot be treated as a once-a-year exercise. With FSSC 24000, it becomes a continuous, embedded process.

How does the ISO-aligned Plan-Do- Check-Act approach of FSSC 24000 benefit textile mills and garment factories with diverse production models?

The ISO Plan–Do–Check–Act approach establishes a structured management system for achieving defined objectives, in this case social sustainability and responsibility. By integrating social sustainability into everyday operations, it ensures the topic is regularly reviewed, measured, and acted upon, ultimately becoming part of the organisation’s culture. Because the system requires companies to analyse their own activities to identify social risks, each organisation can develop a tailored set of controls suited to its specific production models, products, and processes. This built-in flexibility, allowing different approaches for different risk profiles, is a key reason for the long-standing success of ISO-based management systems.

How does FSSC 24000 align with brand-led ESG requirements and emerging human rights due diligence regulations impacting apparel trade?

It is notable that most modern legislation on environmental and social sustainability reporting and due diligence, such as the EU’s Corporate Sustainability Reporting Directive (CSRD) and CSDDD, emphasises the same core principles. These include proactively managing the inherent risks of a company’s activities through a risk-centric approach and establishing a continuous improvement management system. This closely mirrors the ISO framework, and this alignment is no coincidence. With more than 1.2 million ISO 9001 certifications globally, regulators are clearly drawing on a proven and widely adopted methodology. 
As a result, certification to FSSC 24000 positions companies well to meet emerging social sustainability requirements. In contrast, reliance solely on checklist-based audits, without structured risk assessment and a continuous improvement cycle, is unlikely to satisfy forthcoming regulatory expectations.

How can FSSC 24000 support apparel exporters in meeting growing buyer expectations on human rights, ethical sourcing, and transparency?

FSSC 24000 supports apparel exporters not only in meeting buyer expectations but also in complying with a growing body of sustainability legislation covering both environmental and social aspects. Many countries, including India, China, Thailand, and the European Union, are introducing stricter requirements around reporting and due diligence. Alongside social pressure and commercial considerations, these regulations are driving a stronger focus on risk avoidance. From a buyer’s perspective, the choice becomes clearer when comparing two otherwise similar suppliers: one certified and one not. Certification effectively signals that the supplier has structured systems in place to manage social risks, making them a lower-risk and more credible partner.

Given the complexity of multi-tier textile supply chains, how does FSSC 24000 strengthen due diligence beyond tier 1 suppliers, including processors, mills, and service providers?

Risk management techniques should be used to evaluate risks across the entire supply chain, extending beyond tier 1 to all levels. This approach is also a requirement under emerging sustainability legislation, such as the Corporate Sustainability Due Diligence Directive (CSDDD), which is expected to take effect in Europe in the near future. Given the complexity of textile supply chains, it is neither realistic nor expected to control every supplier fully. Instead, companies should prioritise reducing their initial certification scope to those that pose significant risks for their supply chain. These laws do not demand perfection but require organisations to proactively manage risks and demonstrate continuous, year on year improvement.

In regions where informal labour is common, how can apparel manufacturers realistically implement FSSC 24000 requirements without disrupting operations?

As mentioned earlier, this can be achieved by progressively implementing controls year on year across the supply chain. The focus should first be on the most significant risks and those most likely to occur. Then, through a continuous improvement approach, manufacturers can expand these efforts over successive years to address additional material risks, until all key issues are effectively managed without disrupting operations.

Textile supply chains are cost-sensitive. How do you respond to concerns that implementing FSSC 24000 may increase operational costs?

Implementing a certification such as FSSC 24000 does require resources, including dedicated personnel to manage the system, and this inevitably involves some cost. However, like any strategic business decision, these costs need to be weighed against the potential benefits. These include stronger strategic positioning, new business opportunities through differentiation from non-certified competitors, and cost avoidance by reducing the risk of fines or regulatory penalties. Importantly, it also helps mitigate the risk of social scandals, which can lead to boycotts, negative media coverage, and lasting reputational damage that may ultimately threaten a company’s long-term viability.

In your view, how can textile and apparel companies avoid ‘audit fatigue’ while still demonstrating credible social compliance?

Audit fatigue can be reduced by adopting an ISO-based management system through certification. Without such a system, companies often find themselves responding to multiple buyer requirements and undergoing frequent, checklist-based audits that simply confirm whether certain controls are present or absent, often in a retrospective manner. In many cases, corrective actions are not systematically followed up, allowing the same issues to recur. 
Once certified, companies move ahead of this cycle by actively managing social risks within their operations. Risks are identified, avoided where possible, reduced in likelihood, or mitigated through structured action plans and continuous oversight. Certification provides a credible way to demonstrate control over social performance, reducing the need for repeated audits beyond those required to maintain certification. If additional or unannounced audits do occur, organisations are better prepared, as social compliance is already embedded in everyday operations rather than treated as a periodic exercise.

How important is training, especially for factory management and supervisors, in ensuring effective adoption of FSSC 24000?

Training is essential to the effective adoption of FSSC 24000, particularly for factory management and supervisors. As with all ISO-based management systems, training and communication are fundamental in driving cultural change and embedding social sustainability into everyday business practices. The success of ISO 9001 for quality offers a clear parallel: rather than relying on annual checklist inspections, it integrates quality into how people think, decide, and operate on a daily basis. In the same way, FSSC 24000 works by making social responsibility an integral part of the organisation’s mindset and routine operations, which is why ISO-based certifications have proven to be both effective and enduring.

What roles do worker engagement and grievance mechanisms play in strengthening social performance under FSSC 24000 in garment factories?

Both are critical elements of effective social performance under FSSC 24000. Worker engagement ensures that social responsibility is embedded in daily operations across functions such as sourcing, supply chain management, and human resources. Employees should be aware of issues including harassment, abuse of power, equality, fair treatment, building safety, and working and employment conditions, creating a safer, more equitable workplace over time. 
Grievance mechanisms play a vital role in supporting workers by providing safe channels to raise concerns and ensuring that misconduct is addressed at all levels, with no immunity for abuses. Social performance improves when unacceptable behaviour is clearly not tolerated and carries consequences. Beyond compliance, this also delivers wider benefits, including higher employee satisfaction, stronger customer confidence, enhanced reputation, and greater trust among stakeholders and the wider public.

How can digital tools, automation, and data tracking improve social risk management across textile and apparel supply chains?

In large and complex supply chains, digital tools can play a valuable supporting role, particularly for pre-screening suppliers, assessing risks, and monitoring changes in service providers or sourcing partners. Simple and cost-effective tools, such as dashboard solutions like MS Power BI and data management platforms such as MS SharePoint, can be sufficient for visualising risks and tracking performance. These tools are relatively easy to implement and do not require significant investment in highly complex systems. 
That said, the core success factor under emerging regulatory requirements is not data alone, but robust processes. While data is necessary for reporting, setting KPIs, and monitoring controls, effective social risk management depends primarily on having well-defined, consistently applied processes. Establishing a strong ISO-based management system is therefore critical to managing social risks effectively across the supply chain.

Drawing from your experience of managing large-scale audit programmes, what are the most frequent social compliance blind spots in textile and apparel supply chains?

Based on experience with large-scale audit programmes, social compliance risks are often greater in extended supply chains than within a company’s own operations, particularly for large, global brands. A recent example from July 2025 highlighted this challenge, when several high-end fashion subsidiaries were subject to regulatory action in Italy, underscoring how vulnerabilities can emerge beyond direct control. Even well-resourced organisations can face difficulties if supply chain oversight is insufficient or if short-term commercial pressures override robust governance. Notably, the involvement of the Italian Association of Luxury Manufactures (Altagamma) as a civil party reflects growing industry concern that such issues can affect the reputation of the wider sector. Across Europe, greater scrutiny of subcontracting practices signals that public and regulatory tolerance for social compliance lapses is steadily diminishing.

What key social risks in the textile and apparel industry do you expect to intensify over the next five years?

Over the next five years, continued price pressure is likely to intensify social risks across the textile and apparel industry, particularly by placing strain on wages and working conditions. This may result in a growing number of workers earning below living wage levels, often referred to as the ‘working poor’. As financial pressures increase, there is also a risk of deterioration in working conditions, including excessive working hours, compromised health and safety practices, and weaknesses in building safety, as highlighted by past incidents in the sector. A key underlying challenge remains limited oversight of co-manufacturers and subcontractors, an issue that new due diligence legislation explicitly seeks to address through stronger supply chain controls.

Finally, what practical advice would you give to textile and apparel manufacturers preparing for FSSC 24000 certification for the first time?

For manufacturers preparing for FSSC 24000 certification for the first time, prior experience with ISO standards, such as ISO 9001 for quality, can make the process significantly easier. If such experience is limited, it is advisable to involve people with strong process knowledge and familiarity with ISO-based systems, as this can greatly accelerate implementation. Seeking expert support for conducting the risk assessment is also highly beneficial, as this step remains more of an art than a strict technique, and an inadequate assessment may leave critical risks unaddressed. 
In addition, drawing on experienced internal or external specialists in social sustainability, often found within compliance, legal, or human resources teams, can strengthen implementation, particularly when establishing effective grievance mechanisms. Setting up these channels correctly is essential for managing issues and building genuine trust among employees.
Published on: 06/01/2026

DISCLAIMER: All views and opinions expressed in this column are solely of the interviewee, and they do not reflect in any way the opinion of Fibre2Fashion.com.

This interview was first published in the Jan 2026 edition of the print magazine

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