Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

NO RM AP ME

Whole document

ge

NORMAPME is dedicated to looking after the interests of European small and medium enterprises in standardization. We appreciate the intensive work of ISO/TMB/WG SR over the last five years but have to recognize that - NORMAPME is the only true representation of SMO interests in this ISO 26000 project - SMO stand for more than 95% of all possible ISO 26000 users, and that - their main concerns and proposals have not been sufficiently taken into account when drafting the FDIS. More details offered the following comments. We remain convinced that the entire wisdom on SR guidance contained in the FDIS could easily be expressed in half the number of words and that such a shorter document would be much easier to use. NORMAPME is ready to contribute to the further improvement of the guidance standard, on the basis of our comments. We recommend for any further work that SMO interests are properly represented, on a global scale. In particular, we believe that, in order to establish balanced representation of stakeholders, SMOs should be represented by an additional category of stakeholders; hence, SMOs should constitute an independent 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 23 ISO electronic balloting commenting template/version 2001-10

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

2010) ISO is seeking “full and formal backing” from the D-Liaison organizations. NORMAPME is not in a position to express this full and formal backing. NO RM AP ME Whole document ge The NWIP requirement: “applicable to all types of organizations …” is not met. According to N049 Design Specification and its annex “New Work Item Proposal”, see NWIP’s Annex A, item 3, this requirement should be met: “…the standard should be applicable by all types of organizations (e.g. regardless of their size, location, the nature of their activities and products, and the culture, society and environment in which they carry out their activities.)” Volume, language, lacking comprehensibility (“easy to understand”), and a high level of detail make the document not applicable unless an organization has specialists for social responsibility matters; thus the document is not applicable to all organizations and particularly not to SMOs. Proposal: shorten the document and focus on social responsibility issues of greatest effect and global acceptance Clarify the statement in lines 437/438 saying that there is an explicit exclusion of microorganizations in the scope of this standard. Lines 437/438 should also clarify that for all other types of small organisations the applicability of the standard should be assessed in line with the principle of proportionality respective of their size, and the adaptability of the standard

-

-

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

NO RM AP ME

Whole document

ge

NWIP requirement: “limiting proliferation of SR sector standards …” is not met. According to N049 Design Specification and its annex “New Work Item Proposal”, see NWIP’s Annex B, little c), this requirement should be met: “…limiting the proliferation of SR sector standards;” We have not seen WGSR addressing this requirement.

recommendations to their activities. Although criteria for better social behavior of organizations is increasingly discussed, and we see more sector or branch standards are published, often in the form of a sector’s code of conduct; the FDIS does not offer options to stop this trend. To the contrary: by lines 164 and 165 (This International Standard is not intended to prevent the development of national standards that are more specific, more demanding, or of a different type.) the FDIS explicitly denies this requirement! Proposal: start work on this NWIP requirement by e.g. identifying the criteria for emerging SR sector standards, analyzing the substance of SR sector standards and the deltas to the FDIS, and amend the FDIS accordingly. At many instances the document is not considered as easy to understand: The level of detail has lead to far too many recommendations, making it impossible for the user to distinguish between what is important and what is not. This will provoke a considerably expensive consulting business. This is contradictory to the goal of “promotion of a more social responsibility behavior. Proposal:

NO RM AP ME

Whole document

ge

NWIP requirement: “easy to understand…” is not fulfilled. In N049 Design Specification, lines 63 and 64, this requirement reads: “The language must be clear, understandable and objective throughout the guidance standard. “ The purpose and intent of this NWIP requirement, as agreed by the ISO/TMB/SAG Special Advisory Group was to make an involvement of external

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

advisors, consultants etc. unnecessary.

1) prioritize the different recommendations or suggest a system of criteria for an organization to prioritize them 2) conduct a user survey to identify all instances of lacking comprehensibility and revise the document accordingly. The document should not extend beyond 40 pages. An 80 pages volume could only be justified if 50% of it offers practical guidance in form of good practical examples. Proposal: a 40 page volume can be achieved without loss of substance by
-

NO RM AP ME

Whole document

ge

Volume; self-containing document vs. referencing other sources; non-applicability, particularly to SMOs Particularly SMOs will not study some 80 pages in order to find guidance eventually valuable for them. The immense volume was articulated in CD comments by various ISO member bodies and DLiaison organizations. We don’t understand the WG SR Secretariat’s “observation” (reply in column 7 of the comment template), in preparing for the Quebec meeting: “This issue has been considered in some detail during earlier WG SR meetings where a previous decision was taken, often on the basis of a careful compromise. It is thus strongly advised that 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 is proposed to be rephrased. “For the purpose of this International Standard, SMOs include those very small organizations referred to as “micro” organizations.” .

Deleting redundancies and broader explanations in the document itself Referencing other valuable sources instead of developing own guidance proposals; e.g. the core subject Human Rights can be dealt with by referencing the United Nations’ declaration UNDHR and briefly describing how best to apply it. E.g. guidance on the Environment can be dealt with by referencing the ISO 14000 series and briefly

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

NO RM AP ME

Introduction, scope and other subclauses

Lines 49/50; 454/456; 714; 2957;

ge

Relevance of all core subjects to every organization; inconsistency of statements The term “relevant” calls for action. The document needs consistency in this regard to be applicable: 1 relevance of all ... to every… “While not all parts of this International Standard will be of equal use to all types of organizations, all core subjects are relevant to every organization. It is the individual organization's responsibility to identify what is relevant and significant for the organization to address, through its own considerations and through dialogue with stakeholders.” Comment: this statement can be read in many ways; firstly, that all core subjects are relevant (i.e. have to be taken into account), and then that the organization has to decide itself what is relevant to address. This is a contradiction in itself. 2 relevance of all … to every… “….be aware that when reviewing all seven core subjects and identifying the relevant issues, the organization’s own context, conditions, resources and stakeholder interests should be taken into account, recognizing that all core subjects, but not all issues [will be relevant] for every organization;”

describing how to apply these standards. Proposal: Change lines 49 onwards by replacing “are relevant” with “may be relevant” so that it reads: “While not all parts of this International Standard will be of equal use to all types of organizations, all core subjects are may be relevant to every organization”. Additionally: include a sentence like “It is at the organization’s discretion to decide, according to the concerns expressed by its stakeholders, whether a core subject is relevant to it or not or to what degree.” Further: delete the repetitive statements on this relevance from the other indicated lines.

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

Comment: depending on the kind of activity of an SMO, it will not be considered acceptable that all core subjects should always be relevant. 3 relevance of all ... to … every… “…responsibility. Every core subject, but not necessarily each issue, has some relevance for every organization.” and in clause 7.3.2.1 Determining relevance “All the core subjects, but not all issues, have relevance for every organization. The degree of relevance of the…” Comment: if all core subjects are supposed to be relevant to an organization and the organization decides about the degree of relevance, this degree can be zero, in other words: it can be decided that a core subject is not relevant. NO RM AP ME 2 Terms and Definitions Various definitions ge Various definitions don't meet the requirement of the ISO/IEC Directives Definitions are not in line with the ISO/IEC Directives Part 2 which says on page 48: C.1.5 Drafting of definitions • C.1.5.1 Rules for the drafting of definitions are given in ISO 10241. • C.1.5.2 A definition shall not take the form Proposal: rework the definitions so that they all meet the requirements of the ISO/IEC Directives

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

of, or contain, a requirement. such that it can replace the term in context. Additional information shall be given only in the form of examples or notes (see C.3.9). C.1.5.4 A definition given without an indication of its applicability may be taken as representing the general meaning of the term. Special meanings in particular contexts shall be indicated by designating the subject field (see C.3.6). The requirements of C.1.5.2 and C.1.5.3 are not met by a number of definitions, in particular those on “social responsibility” itself and on “sphere of influence”. During the commenting phases this deficiency was repeatedly mentioned and one can only wonder that it had been ignored in spite of ISO representatives taking part in the process. NO RM AP ME NO RM 2 Terms and Definitions 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 this way without having a formal process in place. Definition international norms of behavior this definition reads “2.11 international norms of behaviour Proposal: Add a note that reads NOTE To act accordingly does not require a formal process.

• C.1.5.3 The form of a definition shall be

2 Terms and Definitions

Line 212

Proposal: Reword this definition to:

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

AP ME

expectations of socially responsible organizational behaviour derived from customary international law, generally accepted principles of international law, or intergovernmental agreements that are universally or nearly universally recognized. This definition is not a definition because it contains undefined 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 behaviour Customary international law, generally accepted principles of international law, or intergovernmental agreements (such as treaties and conventions) that are universally or nearly universally recognized. NOTE 1 (as it stands) add NOTE 2 In any case of doubt about, or potential conflict with, international norms of behaviour, national law prevails. add NOTE 3: give 5 examples for customary international law and expectations expressed therein add NOTE 4: give 5 examples for generally accepted principles of international law and expectations expressed therein add NOTE 5: give 5 examples for intergovernmental agreements that are universally recognized and expectations expressed therein add NOTE 6: give 5 examples for intergovernmental agreements that are nearly universally recognized and expectations expressed therein

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

To make this part “easy to understand”, make sure that selected expectations don’t overlap and are not in conflict with each other. NO RM AP ME 2 Terms and Definitions Line 248 to 256 ge Definition social responsibility The current definition is not in line with the requirements of the ISO/IEC Directives because a. it contains requirements and the bullet points and b. it cannot replace the term “social responsibility” where it occurs in the text The explanations and requirements currently contained in the definition itself should go into notes. Proposal: Change text into a shorter and easier to understand definition that reads: 2.1.18 social responsibility responsibility of an organization for the impacts of its decisions and activities on society and the environment NOTE 1 Such a behaviour

-

contributes to sustainable development; takes into account the expectations of 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, services and processes. NOTE 3 Relationships refer to an organization’s activities within its sphere of influence.
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 9 of 23 ISO electronic balloting commenting template/version 2001-10

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

NO RM AP ME

2 Terms and Definitions

Line 222 onwards

ge

Definition organization The current definition reads 2.12 organization entity or group of people and facilities with an arrangement of responsibilities, authorities and relationships and identifiable objectives This wording contradicts the scope and seems particularly unrealistic when reading the sentence from line 437: “For the purpose of this International Standard, SMOs include those very small organizations referred to as “micro” organizations.” Please note that this statement is proposed to be deleted. The definition 2.1 on accountability explains that an organization has its governing bodies. This reads as if every organization has one or more levels and governing bodies. This is not realistic for SMO. Key words like governing bodies, management structure, functions, positions, authority for and delegation of responsibility are missing in the current definition.

Proposal: Use this practice-proven definition: “Social unit of people systematically arranged and managed to meet a need or to pursue collective goals on a continuing basis. NOTE1 Organizations have a management structure that determines relationships between functions and positions, and subdivides and delegates roles, responsibilities, and authority to carry out defined tasks.” 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 the formal management structures referred to in the definition of an organisation above may consider the standard inapplicable to it.

NO

2 Terms and

Line 265

ge

Definition stakeholder

Proposal:

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

RM AP ME

Definitions

onwards

The draft definition reads 2.20 stakeholder individual or group that has an interest in any decisions or activities of an organization This definition has the potential to disqualify the whole document because “an interest” and “any decisions or activities” are undefined terms. By this definition everyone/anyone simply declaring “an interest” would be a “stakeholder”. This is not in line with the general understanding of “stakeholder” as “affected parties”, which is correctly explained in lines 768-769 (“Stakeholders are organizations or individuals that have one or more interests in any decision and activity of an organization. Because these interests can be affected by an organization…”) Also lines 778/805/3218 reference to “stakeholders being affected”.

Use the ICC proposed definition that reads “Individual or group significantly affected by an organization’s activities.” And add a NOTE that reads “It is up to an organization to determine whom to consider a stakeholder.”

2.1.19 NO RM AP ME

Line 257 onward

Definition sphere of influence: the current definition “sphere of influence range/extent of political, contractual, economic or other relationships through which an organization (2.12) has the ability to affect the decisions or activities of individuals or organizations” is not applicable to micro-organizations and smaller organizations. They will argue that they don't have

Proposal: Rephrase lines 437 and 438 as proposed in order to clarify that microorganizations are excluded from the scope of this standard.

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

the sphere of influence. NO RM AP ME NO RM AP ME 3.3.4 437/438 te “For the purpose of this International Standard, SMOs include those very small organizations referred to as “micro” organizations.” The statement sentence in line 437/438 in the SMO box is proposed to be rephrased.

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 part of social responsibility and, therefore, agree on an extensive chapter concerning human rights within the ISO 26000. Different sub-chapters urge organizations to promote human rights in the public, to raise human rights issues with authorities, to facilitate access to education etc. We think that actively promoting human rights at governmental institutions and political work in this field is not the primary duty or responsibility of (non-governmental) organization. In consequence, the should be eliminated: following sentences

Proposal: to eliminate those recommendations from the text of the sub-chapters concerned. However, it could be useful to add a general remark on these issues in chapter 6.3.2.2. (Considerations) that could run as follows: “Organizations should in general seek to promote human rights also in the public whenever deemed feasible.”

1077, 1078 (this only concerns human rights education and should be replaced by the general phrase mentioned above); 1234-1235;
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 12 of 23 ISO electronic balloting commenting template/version 2001-10

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

1238, 1239; 1250; 1274, 1275; 1279 1280 (2nd part of the sentence); 1336, 1337
NO RM AP ME 3.3.4 Lines 394/396 te This sentence “Social responsibility should be an integral part of core organizational strategy with assigned responsibilities and accountability at all appropriate levels of the organization.” clarifies that an organization has various levels and shared responsibilities, which generally is not the case for SMOs. Expressions like -

Proposal: Solve the contradiction between this sentence and the definition of “organization” by adapting the latter one.

NO RM AP ME

Box 3 on SMOs

Line 436 to 472

te

top management integrated approach to managing an organization’s activities and impacts …to remedy immediately all negative consequences of its decisions …that appropriate levels of transparency are preserved

Change this language based on interviews with several SMOs of different but samplerepresentative sizes. Avoid negative language, as if SMOs generally take decisions and undertake actions that will have negative consequences.

-

NO RM AP

Box 3 on SMOs

Lines 460 463

…are not supposed to be SMO language and will rather be detrimental to the acceptance of the guidance standard. The following statement may be wrongly interpreted to infer that SMOs should produce the guides themselves. This would be unrealistic. It should be

Proposal: if the FDIS maintains stating that “… SMO should seek assistance… in developing practical guides and programs for

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

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ME

NO RM AP ME

4 Principles

Lines 519 to 669

ge

reiterated that an SMO has neither the resources nor the know how to develop guides on the standard of applicability to a range of SMOs. This activity should be performed by the sectoral associations who may have the resources, experience and the broader familiarity with the needs of the various sectors. ‘SMOs should seek assistance from relevant government agencies, collective organizations (such as sector associations and umbrella or peer organizations) and perhaps national standards bodies in developing practical guides and programmes for using this International Standard. Such guides and programmes should be tailored to the specific nature and needs of SMOs and their stakeholders Redundancies Respecting the good intent of clause 4, it seems evident that it addresses primarily larger organizations with transnational operations so that SMOs will not find it applicable. Further, parts like 4.8 on Human Rights overlap with the Human Rights section of clause 6. Other parts 4.x are redundant with similar statements in clauses 3, 5, 6 and 7. This is confusing and will be judged as not easy to understand.

using this international standard.” it admits implicitly that it is not practicable to all types and sizes of organizations as required by its scope. In consequence either the scope should be clarified or the sentence in lines 460-2463 should be clarified. Proposal: The text to read, ‘Practical guides should be produced by the government agencies, collective organizations (such as sector associations and umbrella or peer organizations) and perhaps national standards bodies for the provision of assistance to SMOs in their interpretation of the standard and its relevance to them. Proposal: Combine the principles of clause 4 with the core subjects’ clause 6 in order to shorten the text and avoid any overlaps. If this merger of clauses 4 and 6 seems not feasible, the bullet points (“an organization should…”) should be deleted in all sections 4.x to help reduce the mentioned confusion.

NO RM

4.3 Transparenc

Lines 550 to 572

ge

As written this requires detailed information that is not available in smaller organizations.

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

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

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(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

AP ME

y

This section is another indicator that the whole document addresses larger organizations and does not fulfill the NWIP requirement of being applicable to all organizations. 645 - 658 Te Complicity: It is quite comprehensible that complicity has both legal and non-legal meanings. It is also true that this issue has been subject to lengthy discussion in WG SR. However, in terms of legal meanings the definition is lacking a clear reference to an “intentional” element in its attempt to find a legal definition in line 649. As regards the reference to “omission” as equivalent to an illegal act further explanation appears to be necessary.

as they feel fit.

NO RM AP ME

4.7

Proposal: A serious definition could contain the following wording: Unless the law expressly provides for criminal liability based on negligence, only intentional conduct shall attract criminal liability The use of the term “complicity” which is a legal term in many national legal systems leads to different interpretations in the context to these legal systems. Consequently, it might be useful to use terms which are used in a more general context. As a general remark it is clear that the more we use abstract definitions the more we have to explain what is meant by it. Moreover, the more we define the more we lose the aim to develop a guideline for practical use. In the end, it would seem to be worthwhile to develop a short SMO-friendly guideline and a further developed separate document providing more practical information including definitions.

ge

NO

5.2

Line 682 to

te

SMOs won't feel any appeal for this section if

Proposal: Shorten the text of this abstract

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

RM AP ME NO RM AP ME

Recognizing social responsibility 5.3 stakeholder identification and engagement

763

addressed to them; they will miss more practical guidance.

presentation and add some practical examples and guidance that make the section easier to understand. Proposal: Shorten the text of this abstract presentation and add some practical examples and guidance that makes the section easier to understand.

Lines 764 to 868

ge

This chapter seems to be a theoretical deduction or abstract presentation of the topic. SMOs generally (like the violin manufacturer in Northern Bavaria) know their stakeholders quite well and don’t have the capacity to investigate the details of a stakeholder identification and engagement process. They rather invest all energy into their survival.

NO RM AP ME

6.2 Organization al governance, related expectations and actions

Lines 971 to 994

ge

There is confusion over the statements “create a system of economic and noneconomic incentives promote fair representation of underrepresented groups encourage effective participation of all levels of employees in the organization’s decision making on issues of social responsibility balance the level of authority, responsibility and capacity of people who make decisions on behalf of the organization keep track of the implementation of

Proposal: Clarify that section 6.2 is applicable for small and micro organizations only in some parts.

-

-

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

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(7) Secretariat observations on each comment submitted

decisions to ensure that these decisions are followed through and to determine accountability for the results of the organization’s decisions and activities periodically review and evaluate the governance processes of the organization”

NO RM AP ME

6.3.7 Human rights issue 5: Discriminatio n and vulnerable groups

Lines 1217 to 1220

ge, te

clearly indicate that FDIS is written for larger organizations, not for small (less than 50 persons), and not at all for micro organizations (less than 10 persons): it is not realistic to believe that SMO have the mentioned “structures and procedures” in place, as asserted in line 967 to 970. The text reads: “Discrimination can also be indirect. This occurs when an apparently neutral provision, criterion or practice would put persons with a particular attribute at a disadvantage compared with other persons, unless that provision, criterion or practice is objectively justified by a legitimate aim and the means of achieving that aim are appropriate and necessary.” Its content is theoretically correct but not easy to understand, particularly not for SMOs. This text serves only as an example for offering shorter and easier understandable texts in clause 6.

Proposal: Change text to “Discrimination can include also particular attributes 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

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

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(7) Secretariat observations on each comment submitted

RM AP ME

clause

to 1427

Respecting the content, at instances its description is rather theoretical, written in a pedagogical style, and creating confusion in relation to other “instruments”. 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. In countries where all 8 issues are covered by regulation, the whole core subject “human rights” will not be considered relevant, while the document says in various lines that all core subjects are relevant to all organizations. With all due respect for the good intent of this clause, it is written in the spirit of (see line 1611) “Trade unions… have a particularly important role to play…” This clause is industry biased and clearly written for larger organizations and particularly for those acting internationally.

this section and use the UNDHR and ILO documents as basis, select the most important rights and give more practical guidance on how best to follow them. To avoid users feeling misled, include the statement that “in case of doubt national law prevails”. It can’t be the role of ISO or of an ISO standard to try introducing rights the practicing of which may lead to conflicts with issued national law. Delete issue 8 because it overlaps in a confusing way with section 6.4 on Labour Practices. .

NO RM AP ME

6.4 Labour Practices

Lines 1428 to 1737

ge

Proposal: focus this clause on fewer issues and explain better HOW organizations could readily practice them. Good and easy-to-understand examples, derived from good practices, should be added.

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

It can easily be understood as if the recurrent theme were “Sharing benefits, not sharing risks with an organization owner”. Thus, owners of SMOs, most of them private persons and family oriented, will feel very uneasy and may chose to disregard the whole document because of this clause, particularly micro organizations. Much of the text is covered by its handbook character and educational style; some motivating and convincing practical examples would be more helpful, particularly for SMOs. A rewrite without industry bias is necessary. NO RM AP ME 6.5 Environment Lines 1738 to 2035 ge Recognizing its good intent and content, this clause seems to be written for larger organizations and particularly for those acting internationally. Its applicability to organizations like doctors, natural healers, offices, homeopaths, schools, religious organizations, not-for-profit organizations like “Medecins sans frontiers”, architects, engineering offices, lawyers and many others is basically limited to the responsible use of water. Addressing the issues by referencing other tools like the series ISO 14000, providing priorities of problems and kind of actions, and underlining them with 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 demonstrate how they manage environmental problems, so that there is no need to involve external parties like consultants, auditors or certifiers.

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

users. NO RM AP ME 6.6 Fair Operating Practices Lines 2036 to 2172 ge The actions on this core subject as proposed for these issues, 1. Anti–corruption 2. Responsible political involvement Lines 49/50 3. Fair competition 4. Promoting social responsibility in the sphere of influence 5. Respect for property rights can be relevant for larger industry organizations but won't be considered relevant for SMO like pharmacies, doctors , natural healers offices, homeopaths, schools, religious organizations, not-for-profit organizations like “Medecins sans frontiers”, architects, small engineering offices, lawyers, retailers, craftsmen of all kinds, gardeners, hair cutters, bakeries, car repair shops, Nachbarschaftshilfen (associations of neighbours providing help with shopping, cleaning, gardening, etc. to those less able in the neighbourhood), Kindergartens, Homes for senior citizens and other “social institutions”, Hospitals, while the scope claims that all core subjects are relevant to all organizations.
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 20 of 23 ISO electronic balloting commenting template/version 2001-10

Proposal: Mention at the beginning of 6.6 that the degree of applicability of this core subject “Fair Operating Practices” varies for organizations according to their size and type.

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

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NO RM AP ME NO RM AP ME

6.6.3 Anticorruption

Line 2080

Ge, te

The bullet point “establish and maintain an effective system of internal controls to counter corruption” indicates that the whole document is written for larger organizations. This issue is addressed to larger organizations only; SMO will feel overtaxed and micro organizations will see this issue totally irrelevant for them.

6.6.4 Responsible political involvement

Line 2090/2091

Ge,te

Change this bullet to “as appropriate to the size of the organization establish and maintain effective means of internal controls to counter corruption” Make the applicability dependent on the size of organization by adding to 2089 the underscored words “According to their possibilities organizations may support public political processes…

NO RM AP ME

6.7 Consumer issues

Lines 2173 to 2540

ge

While respecting its good intent, this section is excessively large (consumer issues are but a small part of society related issues) and causes problems because it addresses items just from a consumer perspective while the same item is dealt with at other places, like
-

Proposal: Focus this clause on genuine consumer issues Issue 2: Protecting consumers’ health and safety Issue 4: Consumer service, support, and dispute resolution Issue 6: Access to essential services Issue 7: Education and awareness

“sustainable consumption” in 6.7 and sustainable resource use in 6.5 Fair marketing in 6.7 and fair competition in 6.6 are too similar to be dealt with separately.

Such content-related overlaps lengthen the document unnecessarily and confuse users. Since consumer goods/services are regularly manufactured/offered by larger organizations (a typical good is household equipment), the entire set of consumer issues will not be seen relevant by the

and refrain from the explanatory style, thus shortening clause 6.7 from now 16,3% of the whole clause 6 to some 7%; integrate the other issues into the other relevant sections:
-

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

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

vast majority of SMOs so that they may deny the relevance of the whole core subject.

-

6.7 Issue 3: Sustainable consumption into 6.5 Issue 2: Sustainable resource use

NO RM AP ME

6.8

Lines 2541 to 2889 whole clause

While lines 2549/2550 describe the flexibility of relevance to an organization (“The area and the community members affected by an organisations impacts will depend upon the context and especially upon the size and nature of the organization’s impacts.”) the details further down in lines 2635/2636 demonstrate that the spirit of this clause is directed to larger organizations: “When developing plans for community involvement and development, an organization should seek opportunities to engage with a broad range of stakeholders (see 4.5, 5.3 and Clause 7).” Such a general recommendation realistically is not directed to SMOs and particularly not to micro organizations. “Community” versus “society”: at almost each instance in this clause the term community can be replaced by society. It would make a lot of sense to integrate clause 6.8 into clause 3 Understanding social responsibility so that redundancies are avoided and that the benefits of “society involvement and development” are presented in a motivating way at the beginning of the document.

6.7 Issue 5: Consumer data protection and privacy into 6.6 Issue 5: Respect for property rights Proposal: Delete 6.8 as a core issue and integrate its content into clause 3 Understanding social responsibility This way, redundancies are avoided and the benefits of “society involvement and development” are presented in a more motivating way at the beginning of the document.

-

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

Template for comments and secretariat observations

Date: July 2010

Document: ISO/FDIS 26000:2010(E)

NORMAPME Comment ISO/TMB/WG SR

1 MB1

2 Clause No./ Subclause No./ Annex (e.g. 3.1)

(3) Paragraph/ Figure/Table/ Note (e.g. Table 1)

4 Type of comment2

5 Comment (justification for change) by the MB

(6) Proposed change by the MB

(7) Secretariat observations on each comment submitted

This would also contribute to considerably reducing the volume of the document. NO RM AP ME 7.4.2 Setting the direction of an organization for social responsibility Line 3112 to 3114 Ge,te The phrase reads: “Detailed plans for achieving the objectives, including responsibilities, timelines, budgets and the effect on other activities of the organization, should be an important element in establishing the objectives and the strategies for their achievement.” Again, this is a clear indicator that clause 7 and the whole document is written for larger organizations, not for SMOs, because SMOs regularly don’t need such detailed plans to behave in a socially responsible manner. Proposal: Change sentence to “According to the organization’s size, more detailed plans for achieving the objectives, timelines, budgets etc. can be helpful.”

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

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