APPENDIX 2
Memorandum from Traidcraft Exchange
1. BACKGROUND
Traidcraft Exchange is a charity whose mission
is to contribute to poverty eradication by promoting fair and
ethical trading with disadvantaged communities in developing countries.
Our activities embrace capacity-building with ethically orientated
small enterprise development organisations in developing countries;
promotion of market access for small producers; public information
and awareness-raising in the UK about fair and ethical trade and
ethical business; and policy work to inform and influence debate
amongst decision-makers in government, business and the voluntary
sector. Traidcraft Exchange is linked with Traidcraft plc, a trading
company which for 20 years has been importing and selling products
from disadvantaged producers in developing countries, and providing
development support to those producers. Traidcraft plc's sales
are now worth some £7 million per year.
We warmly welcome this opportunity to submit
evidence to the International Development Committee's Enquiry
on the future of the Commonwealth Development Corporation (CDC).
As CDC and the Department for International
Development (DFID) point out in their Memoranda to the Committee,
CDC is the Government's main instrument for directly mobilising
investment in developing countries. The fundamental purpose of
the conversion CDC into a Public-Private Partnership is to allow
CDC to increase the volume of this investment. It is essential
that these funds should make the maximum possible contribution
to the elimination of povertyin keeping with the November
1997 White Paper. Furthermore, we believe it is vital that every
aspect of CDC's operations should follow, and should be seen to
follow, the highest possible ethical standards. This submission
is based on these two principles.
2. TARGETING POVERTY
The new legislation
We warmly welcome the commitment by CDC and
DFID to ensure that in future CDC continues to target investment
to the poorest countries. We are concerned, however, that tensions
may arise between this commitment and the requirements of CDC's
new private investors for high returns on their investment. Enshrining
the commitment to poverty elimination in the legislation establishing
the new Partnership would give clear direction to the new body
and provide a firm reference point for all future investment decision-making.
Recommendation: The legislation establishing
the new Public-Private Partnership should state explicitly that
the Partnership's objective is to contribute to the elimination
of poverty.
Co-ordination with DFID and consultation with
civil society
DFID's activities in-country are guided by Country
Strategy Papers (CSPs) that match DFID's overarching policy objectives
to local priorities. All CSPs are to be reviewed within the next
two years. DFID has announced there is to be greater involvement
of civil society organisations, both in the UK and in-country,
in the preparation of CSPs than hitherto. DFID is also committed
to supporting the implementation of National Sustainable Development
Strategies.[16]
Increased private investment flows should be fully consistent
with this framework.
Recommendation: CDC activities should
be planned within the framework of DFID Country Strategies. Comprehensive
consultation with civil society organisations should be conducted,
and all documents should be publicly available.
Specific provision for Small and Medium Enterprises
Small and medium-sized businesses can be particularly
important in creating employment and livelihood opportunities
for the poor. We note that DFID states in its submission to the
Committee that CDC will continue to offer finance for smaller
businesses and may manage programmes for micro-enterprises on
behalf of the Department.[17]
These activities might not necessarily be attractive to the CDC's
new private investors and there may be pressure on CDC to give
less attention to this areato the detriment of the organisation's
development objectives.
Recommendation: The new CDC should make
specific provision for support to small and medium-sized businessesfor
example a target for a percentage of all new investment each year.
3. ACHIEVING THE
HIGHEST POSSIBLE
SOCIAL AND
ETHICAL STANDARDS
We warmly welcome CDC's "commitment to
be a leading ethical and socially responsible investor".[18]
As a significant source of private investment in developing countries,
CDC can play an important role in demonstrating ethical practice
to the international business community, contributing to increased
social responsibility throughout the private sector. It will also
be essential for CDC to be able to demonstrate the highest ethical
standards if it is to attract the discriminating ethical investors
it intends to target.
Formal commitment to international standards
Conventions agreed under the International labour
Organisation (ILO) constitute internationally agreed standards
in areas such as the elimination of child labour, basic wages,
health and safety at work, freedom of association, etc. The government
is committed to these standards,[19]
which form the basis, for example, of the work of the DFID-supported
Ethical Trading Initiative. CDC is already beginning to implement
guidelines for working and living standards in CDC-managed business
that in many instances exceed the basic ILO standards. Nonetheless,
it would be helpful to secure explicit commitment to these international
agreed core labour standardsas a floor, not a ceilingthrough
the new CDC legislation.
Recommendation: The new CDC legislation
should provide explicitly that CDC will as a minimum implement
ILO Conventions, and will pursue the highest possible social and
labour standards, throughout its operations.
Timetable for achieving standards
As noted above, CDC is pursuing a programme
to implement high working and living standards in its managed
businesses. These account for only 14 per cent of its total investment
portfolio.[20]
It will therefore also be important to ensure that the highest
possible standards are achieved in businesses in which it holds
an equity stake but which it does not directly manage, and those
to which investment flows through intermediary funds supported
by CDC.
Recommendation: DFID should set timetables
for CDC to develop and implement procedures for securing the highest
possible social and ethical standards in its managed businesses,
non-managed businesses in which it holds equity, and businesses
supported through intermediaries.
It is now widely accepted in business circles
that corporate social responsibility requires a commitment to
the social and economic well-being of the local communities in
which a company is operatingand that such a commitment
enhances a company's reputation with the public and amongst shareholders,
ultimately contributing to profitability. Many opportunities will
arise for the new CDC not only to reap these benefits, but also
to enhance its contribution to development and poverty elimination
through appropriate community initiatives. Partnerships could
be developed with local or international NGOs to promote local
development. These could extend beyond the "conventional"
approach of simply donating fundsfor example by providing
management expertise to local small business support programmes.
Recommendation: All CDC managed businesses
should establish a community development fund, in which they should
invest 1 per cent of their annual profits. These funds should
be used for local economic and social development initiatives
and should be overseen by local community representatives. Other
businesses receiving investment directly and indirectly from CDC
should be encouraged to do the same. A similar fund should be
established by CDC centrally, under the control of the CDC Stakeholder's
Council (see below).
4. SECURING TRANSPARENCY
AND ACCOUNTABILITY
We warmly welcome the CDC's intention to "have
and report on a code of ethical policy and practice which meets
international best practice".[21]
As noted above, it is important that CDC should be seen to be
achieving the highest standards in this area. Some aspects of
the standards that are appropriate are discussed above. While
CDC will be financially responsible to its investors, its development
objective means that it will need to demonstrate accountability
to a wider group of stakeholdersincluding local communities
in developing countries, non-governmental organisations, UK and
developing country governments, Parliament, and the public.
Social Accounting as a tool for transparency and
accountability
Social Accounting, or Social Auditing, is a
technique gaining increasing acceptance in business for analysing
and documenting the variety of a business' relationships with
its diverse stakeholders, and for assessing its performance in
relation to the interests of these different groups. Shell International
and the Co-operative Bank are among the leading UK companies that
have recently published social accounts. Other companies are currently
in the midst of such exercises. A key feature of the social accounting
methodology is that it requires external verificationcertification
by an organisation external to the company that appropriate procedures
have been followed in seeking the views of all stakeholder groups.
Social accounting would be an ideal tool for demonstrating to
all interested partiesincluding CDC investors, staff, local
communities in developing countries, UK and developing country
governments, Parliament, non-governmental organisations and the
publicwhether the new CDC is achieving its development
objectives as well as generating return on investors' capital.
This technique should be adopted in relation to the CDC's activities
as a whole, not merely for reporting on the ethical policy.
Recommendation: The legislation establishing
the new CDC should require the views of all the organisation's
stakeholders to be reflected in the Annual Report, through a technique
such as social accounting.
By the same token, social accounting would also
be valuable in documenting the social impact of all the businesses
receiving CDC investment.
Recommendation: CDC's ethical policy
should require the production of annual Social Accounts by all
businesses receiving investment from CDC.
A CDC Stakeholders' Council
Accountability to CDC's stakeholders would be
strengthened by the establishment of a formal mechanism as part
of the new structure to be established by legislation. A CDC Stakeholders'
Council, consisting of representatives of development NGOs, UK
government, Parliament, investors, local communities, developing
country governments, and CDC staff and management, could provide
formal review of CDC's activities and work with CDC to ensure
that ethical best practice is being followed. Such a Council should
have formal powers to issue advice to and seek information from
CDC. It would act as one means of communication with stakeholders,
facilitating the social accounting process referred to above.
Recommendation: A CDC Stakeholders' Council
should be established, composed of representatives of all stakeholder
groups, to provide a formal mechanism for securing accountability
and transparency.
Traidcraft Exchange
26 June 1998
16 Cf the OECD Development Assistance Committee target
that all countries should be implementing National Sustainable
Development Strategies by 2005. Back
17
DFID Memorandum, paragraph 6.2. Back
18
CDC Memorandum, paragraph 4.2. Back
19
Cf White Paper, paragraph 3.36 Back
20
CDC Report and Accounts 1997. Back
21
CDC Memorandum to Committee, paragraph 4.4. Back
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