NORMAPME Draft Comment on ISO/FDIS 26000 July 2010

8/9/2019 NORMAPME Draft Comment on ISO/FDIS 26000 July 2010

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Template for comments and secretariat observations Date: July 2010 Document: ISO/FDIS 26000:2010(E)NORMAPME Comment

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Comment (justification for change) by the MB Proposed change by the MB Secretariat observationson each comment submitted

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ge NORMAPME is dedicated to looking after theinterests of European small and mediumenterprises in standardization. We appreciatethe intensive work of ISO/TMB/WG SR over thelast five years but have to recognize that

- NORMAPME is the only truerepresentation of SMO interests in thisISO 26000 project

- SMO stand for more than 95% of allpossible ISO 26000 users, and that

- their main concerns and proposals havenot been sufficiently taken into account

when drafting the FDIS.More details offered the following comments.

We remain convinced that the entire wisdom onSR guidance contained in the FDIS could easilybe expressed in half the number of words andthat such a shorter document would be mucheasier to use.NORMAPME is ready to contribute to the furtherimprovement of the guidance standard, on thebasis of our comments. We recommend for anyfurther work that SMO interests are properlyrepresented, on a global scale. In particular, we

believe that, in order to establish balancedrepresentation of stakeholders, SMOs should berepresented by an additional category ofstakeholders; hence, SMOs should constitute anindependent stakeholder group in the process.Within the FDIS vote (deadline 12 September

1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by**)

2 Type of comment: ge= general te = technical ed = editorial

NOTE Columns 1, 2, 4, 5 are compulsory.

page 1 of 23ISO electronic balloting commenting template/version 2001-10


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2010) ISO is seeking full and formal backingfrom the D-Liaison organizations.

NORMAPME is not in a position to express thisfull and formal backing.

NORMAPME

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ge The NWIP requirement: applicable to all typesof organizations is not met.According to N049 Design Specification and itsannex New Work Item Proposal, see NWIPsAnnex A, item 3, this requirement should be met:

the standard should be applicable by all types oforganizations (e.g. regardless of their size, location,the nature of their activities and products, and theculture, society and environment in which they carryout their activities.)

Volume, language, lacking comprehensibility(easy to understand), and a high level ofdetail make the document not applicableunless an organization has specialists forsocial responsibility matters; thus thedocument is not applicable to all

organizations and particularly not to SMOs.Proposal:

- shorten the document and focus onsocial responsibility issues ofgreatest effect and global acceptance

- Clarify the statement in lines437/438 saying that there is anexplicit exclusion of micro-organizations in the scope of thisstandard.

- Lines 437/438 should also clarify that

for all other types of smallorganisations the applicability of thestandard should be assessed in linewith the principle of proportionalityrespective of their size, and theadaptability of the standard






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recommendations to their activities.

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ge NWIP requirement: limiting proliferation of SRsector standards is not met.According to N049 Design Specification and itsannex New Work Item Proposal, see NWIPsAnnex B, little c), this requirement should be met:

limiting the proliferation of SR sector standards;

We have not seen WGSR addressing thisrequirement.

Although criteria for better social behavior oforganizations is increasingly discussed, andwe see more sectororbranch standardsare published, often in the form of a sectorscode of conduct; the FDIS does not offeroptions to stop this trend. To the contrary: bylines 164 and 165 (This InternationalStandard is not intended to prevent thedevelopment of national standards that aremore specific, more demanding, or of adifferent type.) the FDIS explicitly denies this

requirement!Proposal: start work on this NWIPrequirement by e.g. identifying the criteria foremerging SR sector standards, analyzing thesubstance of SR sector standards and thedeltas to the FDIS, and amend the FDISaccordingly.

NORMAPME

Wholedocument

ge NWIP requirement: easy to understand isnot fulfilled.

In N049 Design Specification, lines 63 and 64, thisrequirement reads:

The language must be clear, understandable andobjective throughout the guidance standard.

The purpose and intent of this NWIP requirement,as agreed by the ISO/TMB/SAG Special AdvisoryGroup was to make an involvement of external

At many instances the document is notconsidered as easy to understand: The levelof detail has lead to far too manyrecommendations, making it impossible forthe user to distinguish between what isimportant and what is not.This will provoke a considerably expensiveconsulting business. This is contradictory tothe goal of promotion of a more socialresponsibility behavior.Proposal:






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advisors, consultants etc. unnecessary. 1) prioritize the different recommendations orsuggest a system of criteria for anorganization to prioritize them2) conduct a user survey to identify allinstances of lacking comprehensibility andrevise the document accordingly.

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Wholedocument

ge Volume; self-containing document vs.referencing other sources; non-applicability,particularly to SMOs

Particularly SMOs will not study some 80 pages inorder to find guidance eventually valuable for them.

The immense volume was articulated in CDcomments by various ISO member bodies and D-Liaison organizations. We dont understand the WGSR Secretariats observation (reply in column 7 ofthe comment template), in preparing for the Quebecmeeting: This issue has been considered in somedetail during earlier WG SR meetings where apreviousdecision was taken, often on the basis of acareful compromise. It is thus strongly advisedthat we do not reopen discussion on this issue.

In this context please note that the statement

sentence in line 437/438 in the SMO box isproposed to be rephrased. For the purpose ofthis International Standard, SMOs include thosevery small organizations referred to as microorganizations..

The document should not extend beyond 40pages.

An 80 pages volume could only be justified if50% of it offers practical guidance in form ofgood practical examples.

Proposal: a 40 page volume can beachieved without loss of substance by

- Deleting redundancies and broaderexplanations in the document itself

- Referencing other valuable sourcesinstead of developing own guidanceproposals;

e.g. the core subject Human Rightscan be dealt with by referencing theUnited Nations declaration UNDHR

and briefly describing how best toapply it.

E.g. guidance on the Environmentcan be dealt with by referencing theISO 14000 series and briefly






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describing how to apply thesestandards.

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Introduction,scope andother sub-clauses

Lines49/50;454/456;714; 2957;

ge Relevance of all core subjects to everyorganization; inconsistency of statements

The term relevant calls for action. The documentneeds consistency in this regard to be applicable:

1 relevance of all ... to everyWhile not all parts of this International Standard willbe of equal use to all types of organizations,all coresubjects are relevant to every organization. It is the

individual organization's responsibility to identifywhat isrelevant and significant for the organizationto address, through its own considerations andthrough dialogue with stakeholders.

Comment: this statement can be read in manyways; firstly, that all core subjects are relevant (i.e.have to be taken into account), and then that theorganization has to decide itselfwhat is relevant toaddress. This is a contradiction in itself.

2 relevance of all to every.be aware that when reviewing all seven coresubjects and identifying the relevant issues, theorganizations own context, conditions, resourcesand stakeholder interests should be taken intoaccount, recognizing that all core subjects, but notall issues [will be relevant] for everyorganization;

Proposal: Change lines 49onwards byreplacing are relevant with may berelevant so that it reads:

While not all parts of this InternationalStandard will be of equal use to all types oforganizations, all core subjects are may berelevant to every organization.

Additionally: include a sentence likeIt is at the organizations discretion todecide, according to the concerns expressedby its stakeholders, whether a core subject isrelevant to it or not or to what degree.

Further: delete the repetitive statements onthis relevance from the other indicated lines.






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Comment: depending on the kind of activity of anSMO, it will not be considered acceptable that allcore subjects should always be relevant.

3 relevance of all ... to everyresponsibility. Every core subject, but notnecessarily each issue, has somerelevance forevery organization.

and in clause7.3.2.1 Determining relevance

All the core subjects, but not all issues, haverelevance for every organization. The degree ofrelevance of the

Comment: if all core subjects are supposed to berelevant to an organization and the organizationdecides about the degree of relevance, this degreecan be zero, in other words: it can be decidedthat a core subject is not relevant.

NORMAP

ME

2 Terms andDefinitions

Variousdefinitions

ge Various definitions don't meet the requirementof the ISO/IEC Directives

Definitions are not in line with the ISO/IECDirectives Part 2 which says on page 48:

C.1.5 Drafting of definitions

C.1.5.1 Rules for the drafting of definitionsare given in ISO 10241.

C.1.5.2 A definition shall not take the form

Proposal: rework the definitions so that theyall meet the requirements of the ISO/IECDirectives






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of, or contain, a requirement.

C.1.5.3 The form of a definition shall besuch that it can replace the term incontext.

Additional information shall be given only inthe form of examples or notes (see C.3.9).

C.1.5.4 A definition given without anindication of its applicability may be taken as

representing the general meaning of theterm. Special meanings in particularcontexts shall be indicated by designatingthe subject field (see C.3.6).

The requirements of C.1.5.2 and C.1.5.3 are notmet by a number of definitions, in particular thoseon social responsibility itself and on sphere ofinfluence.During the commenting phases this deficiency wasrepeatedly mentioned and one can only wonderthat i t had been ignored in spite of ISOrepresentatives taking part in the process.

NORM

APME


Line 180 te Definition due diligence

This definition assumes that an organization has a

formal process in place to identify risks.

Micro and small organizations generally operate thisway without having a formal process in place.

Proposal: Add a note that reads

NOTE To act accordingly does not require a

formal process.

NORM


Line 212 Definition international norms of behaviorthis definition reads 2.11international norms of behaviour

Proposal:Reword this definition to:






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expectations of socially responsible organizationalbehaviour derived from customary international law,generally accepted principles of international law, orintergovernmental agreements that are universallyor nearly universally recognized.

This definition is not a definition because it containsundefined terms like

- expectations- customary international law- generally accepted principles of

international law

- universally recognized, and- nearly universally recognized.

The notes don't remedy this deficiency

2.1.10 international norms of behaviourCustomary international law, generallyaccepted principles of international law, orintergovernmental agreements (such astreaties and conventions) that are universallyor nearly universally recognized.NOTE 1 (as it stands)

add NOTE 2 In any case of doubt about, orpotential conflict with, international normsof behaviour, national law prevails.

add NOTE 3: give 5 examples for customaryinternational law and expectations expressedtherein

add NOTE 4: give 5 examples for generallyaccepted principles of international law andexpectations expressed therein

add NOTE 5: give 5 examples forintergovernmental agreements that areuniversallyrecognized and expectationsexpressed therein

add NOTE 6: give 5 examples forintergovernmental agreements that arenearly universallyrecognized andexpectations expressed therein






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To make this part easy to understand, makesure that selected expectations dont overlapand are not in conflict with each other.

NORMAPME


Line 248to 256

ge Definition social responsibility

The current definition is not in line with therequirements of the ISO/IEC Directives because

a. it contains requirements and the bulletpoints and

b. it cannot replace the term socialresponsibility where it occurs in the text

The explanations and requirements currentlycontained in the definition itself should go intonotes.

Proposal: Change text into a shorter andeasier to understand definition that reads:

2.1.18social responsibility

responsibility of an organization for theimpacts of its decisions and activities onsociety and the environment

NOTE 1 Such a behaviour

- contributes to sustainable

development;

- takes into account the expectationsof stakeholders;

- is in compliance with applicable law;

- is an integral part of the organization;and

- is practiced in its relationships.

NOTE 2 Activities include products, servicesand processes.

NOTE 3 Relationships refer to anorganizations activities within its sphere ofinfluence.






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Line 222onwards

ge Definition organizationThe current definition reads2.12 organizationentity or group of people and facilities with anarrangement of responsibilities, authorities andrelationships and identifiable objectives

-

This wording contradicts the scope and seemsparticularly unrealistic when reading the sentencefrom line 437: For the purpose of this

International Standard, SMOs include those verysmall organizations referred to as microorganizations.Please note that this statement is proposed to bedeleted.

The definition 2.1 on accountability explains that anorganization has its governing bodies. This readsas if every organization has one or more levels andgoverning bodies. This is not realistic for SMO.

Key words like governing bodies, managementstructure, functions, positions, authority for and

delegation of responsibility are missing in thecurrent definition.

Proposal: Use this practice-proven definition:Social unit of people systematically arrangedand managed to meet aneed or to pursuecollective goals on a continuingbasis.

NOTE1 Organizations have amanagementstructure that determinesrelationshipsbetweenfunctionsand positions, andsubdivides and delegatesroles,responsibilities, andauthority to carry outdefinedtasks.

Based on:http://www.businessdictionary.com/definition/organization.html (November 2009)

Proposal: add to the definition further notes

NOTE2 An SMO which does not have theformal management structures referred to inthe definition of an organisation above mayconsider the standard inapplicable to it.

NO 2 Terms and Line 265 ge Definition stakeholder Proposal:




http://www.businessdictionary.com/definition/need.htmlhttp://www.businessdictionary.com/definition/need.htmlhttp://www.businessdictionary.com/definition/goal.htmlhttp://www.businessdictionary.com/definition/continuing.htmlhttp://www.businessdictionary.com/definition/continuing.htmlhttp://www.businessdictionary.com/definition/management.htmlhttp://www.businessdictionary.com/definition/management.htmlhttp://www.businessdictionary.com/definition/structure.htmlhttp://www.businessdictionary.com/definition/relationship.htmlhttp://www.businessdictionary.com/definition/relationship.htmlhttp://www.businessdictionary.com/definition/function.htmlhttp://www.businessdictionary.com/definition/function.htmlhttp://www.businessdictionary.com/definition/function.htmlhttp://www.businessdictionary.com/definition/position.htmlhttp://www.businessdictionary.com/definition/position.htmlhttp://www.businessdictionary.com/definition/roles.htmlhttp://www.businessdictionary.com/definition/roles.htmlhttp://www.businessdictionary.com/definition/roles.htmlhttp://www.businessdictionary.com/definition/responsibility.htmlhttp://www.businessdictionary.com/definition/authority.htmlhttp://www.businessdictionary.com/definition/authority.htmlhttp://www.businessdictionary.com/definition/task.htmlhttp://www.businessdictionary.com/definition/task.htmlhttp://www.businessdictionary.com/definition/organization.htmlhttp://www.businessdictionary.com/definition/organization.htmlhttp://www.businessdictionary.com/definition/goal.htmlhttp://www.businessdictionary.com/definition/continuing.htmlhttp://www.businessdictionary.com/definition/management.htmlhttp://www.businessdictionary.com/definition/structure.htmlhttp://www.businessdictionary.com/definition/relationship.htmlhttp://www.businessdictionary.com/definition/function.htmlhttp://www.businessdictionary.com/definition/position.htmlhttp://www.businessdictionary.com/definition/roles.htmlhttp://www.businessdictionary.com/definition/responsibility.htmlhttp://www.businessdictionary.com/definition/authority.htmlhttp://www.businessdictionary.com/definition/task.htmlhttp://www.businessdictionary.com/definition/organization.htmlhttp://www.businessdictionary.com/definition/organization.htmlhttp://www.businessdictionary.com/definition/need.html


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Definitions onwards The draft definition reads2.20 stakeholderindividual or group that has an interest in anydecisions or activities of an organization

This definition has the potential to disqualify thewhole document because an interest and anydecisions or activities are undefined terms.

By this definition everyone/anyone simplydeclaring an interest would be astakeholder. This is not in line with the general

understanding of stakeholder as affectedparties,which is correctly explained in lines 768-769(Stakeholders are organizations or individuals thathave one or more interests in any decision andactivity of an organization. Because these interestscan be affected by an organization)

Also lines 778/805/3218 reference to stakeholdersbeing affected.

Use the ICC proposed definition that reads

Individual or group significantly affected byan organizations activities.

And add a NOTE that readsIt is up to an organization to determinewhom to consider a stakeholder.

NO

RMAPME

2.1.19 Line 257

onward

Definition sphere of influence:

the current definition sphere of influence

range/extent of political, contractual, economic orother relationships through which an organization(2.12) has the ability to affect the decisions oractivities of individuals or organizationsis not applicable to micro-organizations and smallerorganizations. They will argue that they don't have

Proposal: Rephrase lines 437 and 438 asproposed in order to clarify that micro-

organizations are excluded from the scope ofthis standard.






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the sphere of influence.

NORMAPME

3.3.4 437/438 te For the purpose of this International Standard,SMOs include those very small organizationsreferred to as micro organizations.

The statement sentence in line 437/438 inthe SMO box is proposed to be rephrased.

NORMAPME

6.3.2.2

6.3.6.2

6.3.7.2

6.3.9.2

: 995 -1427 te We consider human rights as an integral partof social responsibility and, therefore, agree onan extensive chapter concerning human rightswithin the ISO 26000.

Different sub-chapters urge organizations topromote human rights in the public, to raisehuman rights issues with authorities, tofacilitate access to education etc. We think thatactively promoting human rights atgovernmental institutions and political work inthis field is not the primary duty or responsibility of (non-governmental)organization.

In consequence, the following sentencesshould be eliminated:

1077, 1078 (this only concerns human rightseducation and should be replaced by thegeneral phrase mentioned above);1234-1235;

Proposal: to eliminate thoserecommendations from the text of thesub-chapters concerned. However, itcould be useful to add a general remarkon these issues in chapter 6.3.2.2.

(Considerations) that could run asfollows: Organizations should in generalseek to promote human rights also in thepublic whenever deemed feasible.






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1238, 1239;1250;1274, 1275;1279 1280 (2nd part of the sentence);1336, 1337

NORMAPME

3.3.4 Lines394/396

te This sentence Social responsibility should be anintegral part of core organizational strategy withassigned responsibilities and accountability at allappropriate levels of the organization. clarifies thatan organization has various levels and sharedresponsibilities, which generally is not the case forSMOs.

Proposal: Solve the contradiction betweenthis sentence and the definition oforganization by adapting the latter one.

NORMAPME

Box 3 onSMOs

Line 436 to472

te Expressions like

- top management

- integrated approach to managing anorganizations activities and impacts

- to remedy immediately all negativeconsequences of its decisions

- that appropriate levels of transparencyare preserved

are not supposed to be SMO language and willrather be detrimental to the acceptance of theguidance standard.

Change this language based on interviewswith several SMOs of different but sample-representative sizes.

Avoid negative language, as if SMOsgenerally take decisions and undertakeactions that will have negativeconsequences.

NORMAP

Box 3 onSMOs

Lines 460 -463

The following statement may be wrongly interpretedto infer that SMOs should produce the guidesthemselves. This would be unrealistic. It should be

Proposal: if the FDIS maintains stating that SMO should seek assistance indeveloping practical guides and programs for






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ME reiterated that an SMO has neither the resourcesnor the know how to develop guides on thestandard of applicability to a range of SMOs. Thisactivity should be performed by the sectoralassociations who may have the resources,experience and the broader familiarity with theneeds of the various sectors.SMOs should seek assistance from relevantgovernment agencies, collective organizations(such as sector associations and umbrella or peerorganizations) and perhaps national standardsbodies in developing practical guides and

programmes for using this International Standard.Such guides and programmes should be tailored tothe specific nature and needs of SMOs and theirstakeholders

using this international standard. it admitsimplicitly that it is not practicable to all typesand sizes of organizations as required by itsscope. In consequence either the scopeshould be clarified or the sentence in lines460-2463 should be clarified.

Proposal: The text to read, Practical guidesshould be produced by the governmentagencies, collective organizations (such assector associations and umbrella or peerorganizations) and perhaps nationalstandards bodies for the provision of

assistance to SMOs in their interpretation ofthe standard and its relevance to them.

NORMAPME

4 Principles Lines 519to 669

ge Redundancies

Respecting the good intent of clause 4, it seemsevident that it addresses primarily largerorganizations with transnational operations so thatSMOs will not find it applicable.

Further, parts like 4.8 on Human Rights overlap withthe Human Rights section of clause 6. Other parts4.x are redundant with similar statements in clauses

3, 5, 6 and 7.

This is confusing and will be judged as not easy tounderstand.

Proposal: Combine the principles of clause 4with the core subjects clause 6 in order toshorten the text and avoid any overlaps.

If this merger of clauses 4 and 6 seems notfeasible, the bullet points (an organizationshould) should be deleted in all sections4.x to help reduce the mentioned confusion.

NORM

4.3Transparenc

Lines 550to 572

ge As written this requires detailed information that isnot available in smaller organizations.

Clarify that this guidance is meant for largerorganizations and that SMO may use it only






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y This section is another indicator that the wholedocument addresses larger organizations and doesnot fulfill the NWIP requirement of being applicableto all organizations.

as they feel fit.

NORMAPME

4.7 645 - 658 Te

ge

Complicity: It is quite comprehensible thatcomplicity has both legal and non-legal meanings. Itis also true that this issue has been subject tolengthy discussion in WG SR. However, in terms oflegal meanings the definition is lacking a clearreference to an intentional element in its attempt

to find a legal definition in line 649.

As regards the reference to omission asequivalent to an illegal act further explanationappears to be necessary.

Proposal: A serious definition could containthe following wording:

Unless the law expressly provides for criminalliability based on negligence, only intentionalconduct shall attract criminal liability

The use of the term complicity which is alegal term in many national legal systemsleads to different interpretations in the contextto these legal systems.

Consequently, it might be useful to use termswhich are used in a more general context.

As a general remark it is clear that the morewe use abstract definitions the more we haveto explain what is meant by it. Moreover, themore we define the more we lose the aim todevelop a guideline for practical use. In theend, it would seem to be worthwhile to

develop a short SMO-friendly guideline and afurther developed separate documentproviding more practical information includingdefinitions.

NO 5.2 Line 682 to te SMOs won't feel any appeal for this section if Proposal: Shorten the text of this abstract






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Recognizingsocialresponsibility

763 addressed to them; they will miss more practicalguidance.

presentation and add some practicalexamples and guidance that make thesection easier to understand.

NORMAPME

5.3stakeholderidentificationandengagement

Lines 764to 868

ge This chapter seems to be a theoretical deduction orabstract presentation of the topic.

SMOs generally (like the violin manufacturer inNorthern Bavaria) know their stakeholders quitewell and dont have the capacity to investigate thedetails of a stakeholder identification andengagement process. They rather invest all energyinto their survival.

Proposal: Shorten the text of this abstractpresentation and add some practicalexamples and guidance that makes thesection easier to understand.

NORMAPME

6.2Organizationalgovernance,relatedexpectationsand actions

Lines 971to 994

ge There is confusion over the statements

- create a system of economic and non-economic incentives

- promote fair representation of under-represented groups

- encourage effective participation of alllevels of employees in the organizationsdecision making on issues of social

responsibility

- balance the level of authority, responsibilityand capacity of people who make decisionson behalf of the organization

- keep track of the implementation of

Proposal: Clarify that section 6.2 isapplicable for small and microorganizations only in some parts.






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decisions to ensure that these decisions arefollowed through and to determineaccountability for the results of theorganizations decisions and activities

- periodically review and evaluate thegovernance processes of the organization

clearly indicate that FDIS is written for largerorganizations, not for small (less than 50 persons),and not at all for micro organizations (less than 10persons): it is not realistic to believe that SMO havethe mentioned structures and procedures in place,

as asserted in line 967 to 970.NORMAPME

6.3.7 Humanrights issue5:Discrimination andvulnerablegroups

Lines 1217to 1220

ge, te The text reads:Discrimination can also be indirect. This occurswhen an apparently neutral provision, criterion orpractice would put persons with a particular attributeat a disadvantage compared with other persons,unless that provision, criterion or practice isobjectively justified by a legitimate aim and themeans of achieving that aim are appropriate andnecessary.

Its content is theoretically correct but not easy tounderstand, particularly not for SMOs.

This text serves only as an example for offeringshorter and easier understandable texts in clause 6.

Proposal: Change text to

Discrimination can include also particularattributes like religion or belief, disability, age,race or sexual orientation.

Screen whole clause 6 accordingly.

NO 6.3 whole Lines 1079 ge Human rights issues Proposal: To avoid users confusion, rewrite






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clause to 1427 Respecting the content, at instances its descriptionis rather theoretical, written in a pedagogical style,and creating confusion in relation to otherinstruments. The issues

1: Due diligence

2: Human rights risk situations

3: Avoidance of complicity

4: Resolving grievances

5: Discrimination and vulnerable groups

6: Civil and political rights

7: Economic, social and cultural rights

8: Fundamental principles and rights at work

are not relevant where regulated by law. Incountries where all 8 issues are covered byregulation, the whole core subject humanrights will not be considered relevant, while thedocument says in various lines that all coresubjects are relevant to all organizations.

this section and use the UNDHR and ILOdocuments as basis, select the mostimportant rights and give more practicalguidance on how best to follow them.

To avoid users feeling misled, include thestatement thatin case of doubt national law prevails.

It cant be the role of ISO or of an ISOstandard to try introducing rights thepracticing of which may lead to conflicts withissued national law.

Delete issue 8 because it overlaps in aconfusing way with section6.4 on Labour Practices.

.

NORM

APME

6.4 LabourPractices

Lines 1428to 1737

ge With all due respect for the good intent of thisclause, it is written in the spirit of (see line 1611)

Trade unions have a particularly important role toplay

This clause is industry biased and clearly writtenfor larger organizations and particularly for thoseacting internationally.

Proposal: focus this clause on fewer issuesand explain betterHOW organizations could

readily practice them.

Good and easy-to-understand examples,derived from good practices, should beadded.






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It can easily be understood as if the recurrent themewere Sharing benefits, not sharing risks with anorganization owner.

Thus, owners of SMOs, most of them privatepersons and family oriented, will feel very uneasyand may chose to disregard the whole documentbecause of this clause, particularly microorganizations.

Much of the text is covered by its handbookcharacter and educational style; some motivatingand convincing practical examples would be more

helpful, particularly for SMOs.A rewrite without industry bias is necessary.

NORMAPME

6.5Environment

Lines 1738to 2035

ge Recognizing its good intent and content, thisclause seems to be written for larger organizationsand particularly for those acting internationally.

Its applicability to organizations like doctors, naturalhealers, offices, homeopaths, schools, religiousorganizations, not-for-profit organizations likeMedecins sans frontiers, architects, engineeringoffices, lawyers and many others is basically limited

to the responsible use of water.

Addressing the issues by referencing other toolslike the series ISO 14000, providing priorities ofproblems and kind of actions, and underlining themwith practicable examples would be more helpful for

Proposal:Restructure this clause by- referencing other tools like the series

ISO 14000,- providing priorities of problems and

kind of actions, and- underlining them with practicable

examples.

Proposal:Provide tools with which

particularly SMOs can readily demonstratehow they manage environmental problems,so that there is no need to involve externalparties like consultants, auditors or certifiers.






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users.

NORMAPME

6.6 FairOperatingPractices

Lines 2036to 2172

Lines

49/50

ge The actions on this core subject as proposed forthese issues,

1. Anticorruption

2. Responsible political involvement

3. Fair competition

4. Promoting social responsibility in the sphereof influence

5. Respect for property rightscan be relevant for larger industry organizations butwon't be considered relevant forSMO like

pharmacies, doctors , natural healers offices,homeopaths, schools, religious organizations,not-for-profit organizations like Medecins sansfrontiers, architects, small engineering offices,lawyers, retailers, craftsmen of all kinds, gardeners,hair cutters, bakeries, car repair shops,Nachbarschaftshilfen (associations of neighboursproviding help with shopping, cleaning, gardening,etc. to those less able in the neighbourhood),

Kindergartens, Homes for senior citizens and othersocial institutions, Hospitals,

while the scope claims that all core subjects arerelevant to all organizations.

Proposal: Mention at the beginning of 6.6that the degree ofapplicability of this coresubject Fair Operating Practices varies fororganizations according to their size andtype.






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NORMAPME

6.6.3 Anti-corruption

Line 2080 Ge,te

The bullet point establish and maintain an effectivesystem of internal controls to counter corruptionindicates that the whole document is written forlarger organizations.

Change this bullet to

as appropriate to the size of the organizationestablish and maintain effective means ofinternal controls to counter corruption

NORMAPME

6.6.4Responsiblepoliticalinvolvement

Line2090/2091

Ge,te This issue is addressed to larger organizations only;SMO will feel overtaxed and micro organizations willsee this issue totally irrelevant for them.

Make the applicability dependent on the sizeof organization by adding to 2089 theunderscored words

According to their possibilities organizationsmay support public political processes

NORMAPME

6.7Consumerissues

Lines 2173to 2540

ge While respecting its good intent, this section isexcessively large (consumer issues are but asmall part of society related issues) and causesproblems because it addresses items just froma consumer perspective while the same item isdealt with at other places, like

- sustainableconsumption in 6.7 andsustainable resource use in 6.5

- Fair marketingin 6.7 and fair competition in6.6 are too similar to be dealt withseparately.

Such content-related overlaps lengthen the

document unnecessarily and confuse users.

Since consumer goods/services are regularlymanufactured/offered by larger organizations (atypical good is household equipment), the entire setof consumer issues will not be seen relevant by the

Proposal: Focus this clause on genuineconsumer issues

- Issue 2: Protecting consumers healthand safety

- Issue 4: Consumer service, support,and dispute resolution

- Issue 6: Access to essential services

- Issue 7: Education and awareness

and refrain from the explanatory style, thusshortening clause 6.7 from now 16,3% of thewhole clause 6 to some 7%;

integrate the other issues into the otherrelevant sections:

- 6.7 Issue 1: Fair marketing, into 6.6Issue 3: Fair competition






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vast majority ofSMOs so that they may deny therelevance of the whole core subject.

- 6.7 Issue 3: Sustainable consumptioninto 6.5 Issue 2: Sustainableresource use

- 6.7 Issue 5: Consumer dataprotection and privacy into 6.6 Issue5: Respect for property rights

NORMAPME

6.8 Lines 2541to 2889wholeclause

While lines 2549/2550 describe the flexibility ofrelevance to an organization (The area and thecommunity members affected by an organisationsimpacts will depend upon the context and especiallyupon the size and nature of the organizationsimpacts.) the details further down in lines2635/2636 demonstrate that the spirit of this clauseis directed to larger organizations: Whendeveloping plans for community involvement anddevelopment, an organization should seekopportunities to engage with a broad range ofstakeholders (see 4.5, 5.3 and Clause 7). Such ageneral recommendation realistically is not directedto SMOs and particularly not to micro organizations.

Community versus society: at almost eachinstance in this clause the term communitycan bereplaced by society. It would make a lot of sense to

integrate clause 6.8 into clause 3 Understandingsocial responsibilityso that redundancies areavoided and that the benefits of societyinvolvement and development are presented in amotivating way at the beginning of the document.

Proposal: Delete 6.8 as a core issue andintegrate its content into clause 3Understanding social responsibility

This way, redundancies are avoided and thebenefits of society involvement anddevelopment are presented in a moremotivating way at the beginning of thedocument.






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This would also contribute to considerably reducingthe volume of the document.

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7.4.2 Settingthe directionof anorganizationfor socialresponsibility

Line 3112to 3114

Ge,te The phrase reads:Detailed plans for achieving the objectives,including responsibilities, timelines, budgets and theeffect on other activities of the organization, shouldbe an important element in establishing theobjectives and the strategies for their achievement.Again, this is a clear indicator that clause 7 and thewhole document is written for larger organizations,not for SMOs, because SMOs regularly dont needsuch detailed plans to behave in a sociallyresponsible manner.

Proposal: Change sentence to

According to the organizations size, moredetailed plans for achieving the objectives,timelines, budgets etc. can be helpful.





Documents

NORMAPME Draft Comment on ISO/FDIS 26000 July 2010