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Frequently Asked Questions

Updated 5/8/19

What is the objective of YESS?

To create an industry-wide approach to encourage yarn spinning mills to develop and implement risk-based due diligence management systems to avoid sourcing cotton produced with forced labor. An important first step of the YESS initiative was to develop the YESS Standard and YESS Workbook.

 

Who created YESS?

YESS was created by staff at Responsible Sourcing Network (RSN), a project of As You Sow, and consultant Liz Muller, and input from the YESS Working Group, which is comprised of representatives from international apparel brands and experts in the areas of cotton, human rights, and ethical and sustainable clothing. Liz Muller, of liz muller & partners, was the lead author in the drafting of the YESS Standard and YESS Workbook. Liz has experience with a similar program in the minerals supply chain auditing smelters (Responsible Minerals Initiative). To create the YESS Standard and Workbook, RSN founder and vice president, Patricia Jurewicz, and Liz Muller researched and/or conducted feasibility assessments at 16 spinning mills and five gins in Bangladesh, India, Turkey, and Uzbekistan. Extensive outreach to brands, yarn spinners, and other stakeholders occurred throughout the development and piloting of the YESS Standard, with over 200 comments from the public consultation phase incorporated into the standard where appropriate.

 

What is the YESS Standard?          

The YESS Cotton Standard (YESS Standard) is the cornerstone of the YESS Initiative. It is based on the internationally supported Organisation for Economic Co-Operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector (OECD Due Diligence Guidance). The YESS Standard was developed as a specific, practical framework to assess the operations, management systems and practices of cotton yarn spinning mills. More precisely, it is a guide for a spinner to avoid sourcing cotton inputs that have a high risk of involving forced labor in their production.

 

What is the YESS Workbook?

The YESS Assessment Workbook & Summary of Findings (YESS Workbook) is a standardized spreadsheet to use during a YESS assessment. In addition to gathering basic information about the spinning mill undergoing the assessment, it is a framework to gather information about a spinner’s cotton inputs, transactional information, and management systems. It also has a section to collate findings from an assessment and any follow up items with any corrective actions. Some sections are completed by the spinner and some by the assessment team.

 

How does the YESS Standard align (or differ) from the OECD Due Diligence Guidance?

The YESS Standard was written to align with the OECD Due Diligence Guidance, but it has not yet undergone an alignment assessment with the OECD Due Diligence Guidance. The guidance specifies that all enterprises, regardless of size, have a responsibility to carry out due diligence in order to avoid and address the potential negative impacts of their activities and supply chains. The YESS Standard only applies to a spinner’s supply chain.

 

Why does YESS focus on spinning mills?

Spinning mills are the point the cotton supply chain where lint from various origins around the world is mixed with other sources and converted into yarn. By developing and implementing an industry-wide system that will encourage and support yarn spinners to identify, address, and mitigate forced labor in cotton sourcing, YESS will increase transparency and demand for responsible cotton, and reduce the demand for cotton produced with forced labor.

 

What do spinners have to do to comply with the YESS Standard?

A cotton spinning mill that voluntarily chooses to participate in the YESS Standard will be expected to develop a responsible sourcing policy, and supporting procedures and management systems to avoid purchasing cotton that poses a risk of forced labor occurring during cotton production. The policy will need to include sections on risk management, adherence to the YESS Standard, and supplier expectations. Enforcement of the policy must occur by robust management systems that track information flows and feedback records. With this framework, the spinning mill will assess the source of cotton inputs it receives to avoid sourcing cotton that has a high-risk of forced labor occurring in its production. Once a full YESS program is in place, a spinning mill would likely be assessed once a year by a trained and approved third-party auditor, who will assess the spinning mill’s due diligence management systems regarding cotton inputs that have a high risk of involving forced labor in their production.

 

What are the incentives for spinners to meet and undergo an assessment using the YESS Standard?

As legislation and regulations to address forced labor in supply chains increase in consumer markets, brands are responding by requiring actors within their entire supply chains to implement due diligence measures. The YESS Standard outlines the elements of a strong due diligence management system based on the OECD Due Diligence Guidance. The YESS Standard was designed to integrate and strengthen systems commonly implemented at spinning mills and allow spinners to meet brands’ requirements through one standard—and one annual assessment—that would be recognized industry-wide. YESS hopes that results of the initiative will be stronger relationships between different supply chain actors and continuous improvement for the industry.

 

How are "high-risk countries" defined?

YESS defines high-risk countries as those that have a high risk of forced labor in their cotton production. YESS created a methodology to determine which countries should be considered high-risk that utilizes the two International Labour Organization (ILO) conventions on forced labor: C029: Forced Labour Convention, 1930 and C105: Abolition of Forced Labour Convention, 1957. There must be sufficient evidence of high-risk countries, meeting at least three of ILO’s indicators of forced labor. The indicators fall under the following categories: Unfree recruitment, work and life under duress, impossibility of leaving employer, and menace of penalty. YESS compiled evidence from numerous sources to determine which countries meet the requirements to be on the high-risk list. Currently, the high-risk country list includes: Benin, Burkina Faso, China, Kazakhstan, India, Pakistan, Tajikistan, Turkmenistan, and Uzbekistan. YESS understands that not all cotton from these countries was produced with forced labor, and that there may be cotton produced with forced labor that does not originate in these countries. YESS will review and revise the list periodically.

 

Why is Syria not considered a high-risk country?

Syria's risk of harm from its cotton sector stems from conflict but not from forced labor. Since the YESS Standard is only focused on forced labor; Syria is not determined to be a high-risk country under YESS. Syria is added to the Emerging Risk List on the YESS website so it can be periodically reviewed and changed accordingly.

 

What is a “red flag” and how does it differ from “risk of harm”?

A red flag is a concern, discrepancy, or another suspicious activity in a spinner’s supply chain. Examples include—but are not limited to—altered documents; inconsistencies in paperwork; concerns about a supplier’s legitimacy; refusal to validate the origin of cotton; or cotton being claimed to originate in a country not known to produce and/or export cotton.

Risk of harm is actual or potential exposure to harm of individuals, groups, or the environment as a result of an enterprise’s activities. In other words, a red flag could be thought of as a warning that risk may be present—and thus additional due diligence is required to determine if the risk is actually or potentially present.

 

Why does YESS only pertain to forced labor and not other decent work standards?

RSN has a long history of facilitating a unified position of global apparel brands to end government-orchestrated forced labor in Uzbekistan. YESS expands that effort by identifying and addressing forced labor in any country that has a high-risk of forced labor in its cotton industry (as defined by the ILO’s conventions and indicators). Additionally, there is interest by brands to have a solution that will address forced labor in their materials supply chains due to growing forced labor-specific legislation. With this said, YESS will enable engagement of the farm-to-spinner segment of the supply chain, which could, in turn, be expanded to address other decent work issues in the future.

 

Does YESS assess for forced labor inside spinning mills?

No. The aim of YESS is to eliminate forced labor at cotton farms by helping spinners develop and implement strong management systems to support responsible sourcing policies and practices. A spinner that meets the YESS Standard should be in a better position to deliver and manage expectations set by other initiatives to assess and verify factory labor conditions.

 

Would YESS help brands and retailers comply with national and international legislation?

Most of the modern slavery legislation that exists or is being introduced includes a reference to “duty of care.” This means that companies have to disclose the actions they are taking to identify and address forced labor. YESS is the only initiative that addresses forced labor in the production of conventional cotton. When YESS moves into an implementation phase, and brands and retailers participate with YESS, they would be able to include in their mandatory disclosures their support for and involvement with this industry-wide initiative that aims to eradicate forced labor from their cotton supply chains.

 

Does YESS capture environmental data on the cotton that spinners are using?

No, YESS is designed to prevent cotton harvested with forced labor from entering a spinning facility. It does not capture environmental information or impacts associated with the cotton.

 

Does YESS compete with SLCP?

RSN is a signatory to the Social & Labor Convergence Project (SLCP), and contributed to the forced labor section of the SLCP data tool. Since the SLCP data tool only focuses on the labor conditions within a facility, and not how materials are sourced, the two efforts complement one another.

 

Does YESS duplicate the work of BCI, CottonConnect, Cotton Made in Africa (CMiA), Fairtrade, and others?

There is not duplication of work because the main focus of the above initiatives (which YESS refers to as “farm-level schemes) is on training, working directly with, and assessing cotton farmers (and gins, in some instances). YESS is focused on engaging and assessing yarn spinners’ due diligence management systems that allow the spinners to keep cotton produced with forced labor out of the supply chain.

 

Will YESS consider cotton produced with farm-level schemes like BCI, CottonConnect, CMiA, Fairtrade, or others as low-risk cotton even if it was produced in a high-risk country?

YESS requires extra due diligence for all cotton that originates in a high-risk country. The farm-level schemes need to undergo an evaluation to determine which ones are sufficient to ensure their cotton does not pose a high-risk of involving forced labor during its production. As of the date of publication of these FAQs (5 May, 2019), no farm-level scheme has yet to be fully evaluated to meet a YESS determination of low-risk. Refer to the YESS website and an updated version of the FAQs for future updates.

 

Who has been funding YESS and how will it be funded in the future?

The creation of the YESS Standard was funded with grants from Humanity United, The Moriah Fund, and The Walt Disney Company’s Supply Chain Investment Program. Members of the YESS Working Group provided additional financial and in-kind support. YESS is now actively looking for financial support from foundations, corporations, and government agencies to build and sustain a YESS program.

RSN’s intention is that after successfully piloting the YESS Standard, it would be adequately resourced with widespread support by the cotton apparel and home goods industries. RSN and the YESS Working Group are open to and actively exploring options to further develop, implement, and fund YESS and then have it continue as a stand-alone initiative or integrate it into an existing initiative.