Frequently Asked Questions about Compliance

For a word that means so many different things to different people, it makes sense to ensure that we’re all on the same page when it comes to our understanding of compliance. Particularly so when it comes to the manufacture and supply of promotional products, where the meaning and application of the term differs from company to company. And with the industry focus shifting more and more toward compliance, I thought that for this week’s column a review of some of the most frequently asked questions that we get about compliance might be helpful.

Many suppliers have adopted a “code of conduct” but what does this really mean?

In general, “code of conduct” refers to the policies a company holds related to their social accountability policy. Some companies have expanded the scope of the code of conduct to include codes of practice related to broader manufacturing concerns.

A code of conduct is a step in the right direction for suppliers and manufacturers of promotional products. At the moment, the code is being treated by many suppliers as a philosophical statement and by adopting these guidelines suppliers are purportedly showing their commitment to compliance responsibility. However, in order for a code of conduct to be substantiated, this statement needs to be actively adhered to by suppliers and manufacturers. Without commitment to the journey, compliance will never have the proper guidelines that the promotional products industry requires.

The factories we use have certifications from World Responsible Accredited Production (WRAP) and Fair Labor Association (FLA). How does this fit into compliance?

While many suppliers and manufacturers use WRAP and FLA programs, they really only address one area of compliance—social accountability, which is just part of the picture. To truly ensure that everyone in the promotional products industry upholds the same values and responsibility, there needs to be commitment to a code of conduct to complement these programs. While social accountability is a good starting point for the industry, these programs alone don’t constitute a fully developed compliance program required for conducting business in today’s market.

Some companies rely on factory audits to measure compliance. Is this enough?

Undoubtedly, factory audits are an important tool to measure a company’s ability to adhere to social responsibility guidelines. However, factory audits as a sole means of measuring compliance don’t address other equally important areas of compliance, such as product safety. Factory audits only provide a snapshot of a company’s ability to comply and, like any scheduled event, audits give companies time to put their best foot forward and tie up any loose ends that may exist in regards to compliance. But do these same companies operate as compliantly every other working day of the year? Probably not. Unfortunately, this is often the reality of factory audits and these alone do not provide a true reflection of a factory’s performance on a day-to-day basis.

If a supplier carries out safety tests on their products, does this mean they are compliant?

Like auditing and social accountability programs, safety testing is an essential part of compliance. Reporting test results for the purposes of compliance is a natural step in the right direction; often, however, factories send outdated reports from tests that were carried out on similar but nevertheless different products. So while safety testing is considered best practice to measure the effectiveness of a compliance program, it’s not considered a compliance program in and of itself.

What about your company? Are you committed to the same idea of compliance as explained in here? Do you spend time and invest money and resources ensuring your products are compliant and that your customers are protected or is this a goal for the future, but something not quite yet in place? Do you have any of your own questions to add to this list? You can read more about the industry change toward compliance in the Promo Marketing article, Collaborating for Compliance.

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