« Sustainable Purchasing » ISO/PC 277 - JISC · Result of voting Ballot Information Ballot reference ISO/CD 18617.2 Ballot type CD Ballot title Sustainable purchasing Opening date

Association Française de Normalisation 11, rue Francis de Pressensé F – 93 571 La Plaine Saint Denis cedex http://www.afnor.fr SIRET 775 724 818 00205

« Sustainable Purchasing » ISO/PC 277

Date:

2014-09-19 Doc. Number:

N 048

Assistant:

Sandra PAROT

AFNOR

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[email protected]

Your contact:

Laurence DOUVILLE

AFNOR

Direct line : + 33 (0)1 41 62 86 06

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Caroline REIS

ABNT

Direct line : + (21) 3974 2385

[email protected]

Amended ballot results – ISO/CD 18617.2

COMMENTARIES/

DECISIONS

Due to technical issues, we received additional comments from USA. Therefore, the ballot results on ISO CD 18617.2 "Sustainable procurement" have been amended and they are attached. The comments will be addressed during the next ISO/PC 277 meeting, to be held in Singapore on 2014-11-03/07. With regard to this resolution of comments, the decision on next step will be made during this meeting.

FOLLOW UP �� For resolution of comments during the 3rd ISO/PC 277 meeting

SOURCE ISO/PC 277 Secretariat

Result of voting

Ballot Information

Ballot reference ISO/CD 18617.2

Ballot type CD

Ballot title Sustainable purchasing

Opening date 2014-06-07

Closing date 2014-09-13

Note

Member responses:

Votes cast (29) Argentina (IRAM)Australia (SA)Austria (ASI)Belgium (NBN)Brazil (ABNT)Canada (SCC)Chile (INN)China (SAC)Colombia (ICONTEC)Costa Rica (INTECO)Côte d'Ivoire (CODINORM)Denmark (DS)Egypt (EOS)Finland (SFS)France (AFNOR)India (BIS)Ireland (NSAI)Israel (SII)Italy (UNI)Japan (JISC)Netherlands (NEN)Nigeria (SON)Norway (SN)Serbia (ISS)Singapore (SPRING SG)Sweden (SIS)Switzerland (SNV)United Kingdom (BSI)United States (ANSI)

Comments submitted (4) IFPSMMexico (DGN)Poland (PKN)Thailand (TISI)

Votes not cast (0)

Questions:

Q.1 "Do you agree to the circulation of the draft as a DIS?"

Votes by members Q.1

Argentina (IRAM) No

Australia (SA) Yes withcomments

Austria (ASI) We abstain

Belgium (NBN) We abstain

Brazil (ABNT) No

Canada (SCC) Yes withcomments

Chile (INN) Yes withcomments

China (SAC) Yes

Colombia (ICONTEC) No

Costa Rica (INTECO) No

Côte d'Ivoire(CODINORM)

We abstain

Denmark (DS) No

Egypt (EOS) Yes withcomments

Finland (SFS) We abstain

France (AFNOR) No

India (BIS) Yes withcomments

Ireland (NSAI) We abstain

Israel (SII) Yes

Italy (UNI) Yes withcomments

Japan (JISC) No

Netherlands (NEN) No

Nigeria (SON) Yes

Norway (SN) No

Serbia (ISS) Yes

Singapore (SPRINGSG)

We abstain

Sweden (SIS) No

Switzerland (SNV) We abstain

United Kingdom (BSI) Yes

United States (ANSI) Yes

Answers to Q.1: "Do you agree to the circulation of the draft as a DIS?"

6 x Yes China (SAC)Israel (SII)Nigeria (SON)Serbia (ISS)United Kingdom (BSI)United States (ANSI)

6 x Yes with comments Australia (SA)Canada (SCC)Chile (INN)Egypt (EOS)India (BIS)Italy (UNI)

10 x No Argentina (IRAM)Brazil (ABNT)Colombia (ICONTEC)Costa Rica (INTECO)Denmark (DS)France (AFNOR)Japan (JISC)Netherlands (NEN)Norway (SN)Sweden (SIS)

7 x We abstain Austria (ASI)Belgium (NBN)Côte d'Ivoire (CODINORM)Finland (SFS)Ireland (NSAI)Singapore (SPRING SG)Switzerland (SNV)

Comments from Voters

Member: Comment: Date:

Argentina (IRAM) Comment File 2014-09-0923:07:22

CommentFiles/ISO_CD 18617.2_IRAM.doc

Australia (SA) Comment File 2014-09-1200:44:27

CommentFiles/ISO_CD 18617.2_SA.doc

Brazil (ABNT) Comment File 2014-09-1219:25:32

CommentFiles/ISO_CD 18617.2_ABNT.doc

Canada (SCC) Comment File 2014-09-1221:28:49

CommentFiles/ISO_CD 18617.2_SCC.doc

CommentFiles/ISO_CD 18617.2_IRAM.doc

CommentFiles/ISO_CD 18617.2_SA.doc

CommentFiles/ISO_CD 18617.2_ABNT.doc

CommentFiles/ISO_CD 18617.2_SCC.doc

Chile (INN) Comment File 2014-09-1303:31:14

CommentFiles/ISO_CD 18617.2_INN.doc

Colombia (ICONTEC) Comment File 2014-09-1104:01:12

CommentFiles/ISO_CD 18617.2_ICONTEC.doc

Costa Rica (INTECO) Comment File 2014-09-1321:42:47

CommentFiles/ISO_CD 18617.2_INTECO.doc

Denmark (DS) Comment File 2014-09-1318:49:59

CommentFiles/ISO_CD 18617.2_DS.doc

Egypt (EOS) Comment File 2014-09-1310:18:03

CommentFiles/ISO_CD 18617.2_EOS.doc

France (AFNOR) Comment File 2014-09-1211:36:13

CommentFiles/ISO_CD 18617.2_AFNOR.doc

India (BIS) Comment File 2014-09-1107:50:09

CommentFiles/ISO_CD 18617.2_BIS.doc

Italy (UNI) Comment File 2014-09-1114:09:39

CommentFiles/ISO_CD 18617.2_UNI.doc

Japan (JISC) Comment File 2014-09-1210:34:23

CommentFiles/ISO_CD 18617.2_JISC.doc

Netherlands (NEN) Comment File 2014-09-1213:19:29

CommentFiles/ISO_CD 18617.2_NEN.doc

Norway (SN) Comment File 2014-09-1110:13:49

CommentFiles/ISO_CD 18617.2_SN.doc

Singapore (SPRINGSG)

Comment File 2014-09-1513:34:11

CommentFiles/ISO_CD 18617.2_SPRING SG.doc

Sweden (SIS) Comment File 2014-09-0910:44:57

CommentFiles/ISO_CD 18617.2_SIS.doc

CommentFiles/ISO_CD 18617.2_INN.doc

CommentFiles/ISO_CD 18617.2_ICONTEC.doc

CommentFiles/ISO_CD 18617.2_INTECO.doc

CommentFiles/ISO_CD 18617.2_DS.doc

CommentFiles/ISO_CD 18617.2_EOS.doc

CommentFiles/ISO_CD 18617.2_AFNOR.doc

CommentFiles/ISO_CD 18617.2_BIS.doc

CommentFiles/ISO_CD 18617.2_UNI.doc

CommentFiles/ISO_CD 18617.2_JISC.doc

CommentFiles/ISO_CD 18617.2_NEN.doc

CommentFiles/ISO_CD 18617.2_SN.doc

CommentFiles/ISO_CD 18617.2_SPRING SG.doc

CommentFiles/ISO_CD 18617.2_SIS.doc

Comments from Commenters

Member: Comment: Date:

IFPSM Comment 2014-09-1115:54:39

IFPSM votes against the current document, but it is not ready yet for the enxt phase. See comments in theannex.

IFPSM Comment File 2014-09-1115:54:39

CommentFiles/ISO_CD 18617.2_IFPSM.doc

Mexico (DGN) Comment 2014-09-1221:30:29

Yes.

Poland (PKN) Comment File 2014-09-1211:23:56

CommentFiles/ISO_CD 18617.2_PKN.doc

Thailand (TISI) Comment File 2014-09-0503:39:41

CommentFiles/ISO_CD 18617.2_TISI.doc

CommentFiles/ISO_CD 18617.2_IFPSM.doc

CommentFiles/ISO_CD 18617.2_PKN.doc

CommentFiles/ISO_CD 18617.2_TISI.doc

Template for comments and secretariat observations Date: 2014-09-19 Document: PC277N037 Project: ISO CD 18617.2

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US 743 NA

NA NA Editorial Style in the document moves from Third Person to Second Person. Section 6, integrating sustainability into the procurement process, takes a second person “You should do this, you should think of this” approach. Other sections are written in a more neutral approach. I remember discussions on how the first section is written for general management, second section for procurement decision makers, third section (section 6) for procurement professionals. The shift in styles is jarring, when read at one sitting. I realize that the thought was that not all sections would be read by all people.

Pick one style and write the entire document to that style. Or, add information in the “General” section to indicate the audience for each section.

US 744 NA

NA NA Editorial In general, need to be more consistent with use of bullets and sub bullets through the entire document

Proofer should review and make changes as appropriate.

US 745 NA

NA NA Editorial In general, need be careful about citing external sources and ensure permissions have been obtained to use tables, cases, graphs, etc.

DS 731

Ge The DS NMC to PC277 cannot approve on the preset draft af being ready for next step. More discussions and revisions are needed. The NMC is in process of developing technical comments to be submitted asap.

AR 001

ge The spirit and terms of the proposed text does not fully coincide with the established scope.

Throughout the text - reference supply chain instead of

value chain - avoid the use of business oriented

language - reference policy, not strategy - ISO 26000:2010 should not be

reinterpreted

CA 002

ge The draft ISO document is not well introduced/positioned. It is very challenging for a candid reader to understand where the

Overall - No change if Part I is to be circulated together with Part II.


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document stand and what purpose it serves versus social responsibility, Copenhagen, etc.

CA 003

ge It would have been helpful to know which countries did adopt the current ISO 26000 and if the draft document could apply to those who did not adopt it. A possible way to help the reader could be to attach a list of web links where to find info on countries’ positioning and work on this.

Overall - No change.

CA 004

Although it is intended to both private and public organizations, the draft document is lacking consistency throughout the various sections as to whom the directions provided are intended to. Some sections are clearly less applicable to the Public Sector. For example, Section 5.2, on Supporting People, invites organizations to review their HR programs. Many of these programs, however, are departmental. The GoC, as an organization, can hardly follow the quite prescriptive steps as proposed.

Another example is the text box on page 18 which refers to “the ability of the organization to engage government”. What if the organization is government? One way to read this is to consider a lower level (e.g. municipal/provincial) government to influence GoC and, in turn, for GoC to influence an international body such as UNO. This should be further clarified.

To the contrary, NGOs (=non government organizations?) are listed among External stakeholders (Table 2, p.17). This presupposes that the document is intended at

Overall – No change. Addressing this might require changes throughout the document for more clarify which may be challenging at this stage.


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governments.

CA 005

ed There are numerous style, typos, grammar and style errors in the draft document which are expected to be corrected. Section 6 is hard to follow because of references to Sections 3, 4 and 5 that are obviously not the right numbers.

An executive summary would be much appreciated.

Plain language should be used for the intro page (page vi) as the key concepts have not been defined at this point in the text.

Numerous acronyms are used, some of which are not even defined. A list of acronyms that the reader could refer to at any point in reading would be very helpful.

The Table of Content should be reformatted using indents for sub-sections to help the reader navigate through it.

Two sections (Setting Priorities and Enabling People) have the number 5.2. This is the case in both the Table of Content and the core document. The latest of these two sections, and all following ones should be renumbered.

Section 4 (p.4ff including subsections) is way too long. It should set the table for Section 5. It is too long, too complex and there are repeats within this section and between sections 4 and 5.

Section 4.3 (p.5): “Organizations involved in

Errors to be corrected throughout the document.

Will one be included?

Inclusion of Part I might or might not resolve this.

Will one be included?

To be fixed.

To be fixed.

No change. It may be too late to rewrite at this stage.

300 – Replace involved in with committed to


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Social Responsibility” – we may want to rather say support or commit.

CA 006

all ge Supply chain, supply chains, value chain should all be defined and then used consistently. Currently not consistent.

Please provide consistent usage of these terms.

CA 007

all ge Stakeholder term needs clarification and consistency. These terms are used and create confusion: relevant supply chain stakeholders, key stakeholders, necessary stakeholders, wider stakeholder community, internal stakeholders, external stakeholders, stakeholder groups, stakeholders.

Please provide consistent usage of these terms.

CA 008

Before an organization develops and implements a ‘Governance framework’ the organization should use ‘Due diligence’ to identify the actual and potential negative social, environmental and economic impacts of its procurement decisions and activities, with the aim of avoiding and mitigating those impacts.

Add clause on ‘due diligence’ such as provided in clause 7.3 in ISO 26000:

‘Due diligence in the context of sustainable procurement is a comprehensive, proactive process to identify the actual and potential negative social, environmental and economic impacts of an organization's procurement decisions and activities, with the aim of avoiding and mitigating those impacts.

Due diligence may also entail influencing the behaviour of suppliers, where they are found to be the cause of human rights or other violations in which the organization may be implicated.

In any due diligence process, an organization should consider the country context in which it’s supplier operates or in which its supplier’s activities take place; the potential and actual


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impacts of its supplier’s activities; and the potential for negative consequences resulting from the actions of other entities or persons whose activities are significantly linked to those of the organization.

CA 009

Consequently, organizations are encountering increasing complexity - and confusion - in their drive to become sustainable. In determining their sustainability strategies, unless they are limiting their improvements to recycling and carbon emissions, they are increasingly finding a labyrinth of complexity through which they must navigate (habitat loss, ocean acidification, invasive species, black market bushmeat trade, counterfeited brand goods, child/sex trafficking, species extinction, food security, ecosystem services disruption, conflict minerals, rights violations, pollution, cruelty, contaminated water, poverty, etc.) only to find in the end that they are still faced with a quagmire of unintended consequences and tipping points. These increasing levels of uncertainty and complexity go well beyond the capabilities of traditional risk management since damages incurred will affect future generations long after acountable parties have gone. The possibility of harmful unintended consequences, therefore, must be prevented, as expounded through the adoption of the Precautionary Principle. For this procurement guideline to meet its objectives of supporting sustainability, it must ultimately show organizations how to consider, operationalize, evaluate, and measure their own, and their suppliers’,


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outcomes against the official ISO definition of sustainable development.

CA 010

Traditional risk management techniques are impotent to achieve that task. Unintended consequences are usually unanticipated and often don’t even emerge in the perpetrator's lifetime (whether an individual's or a corporation's), leaving future generations to deal with whatever mess is left behind. The uncertainty of the future, compounded by complexity of becoming fully sustainable in all aspects of anthropogenic activity, must eventually drive organizations to simplify. Societal and environmental stakeholders, present and future, together with their emerging requirements, must be considered and planned for now, if any claims of sustainability are to be made. For a system attribute to be capable of being used as selection and measurement criteria, such as for sustainable procurement, it must be operationalized within its process framework before it can yield its metrics. For sustainable development, and its three dimensions of economic, social, and environmental performance, the most suitable measurable attribute that best serves ISO principles and objectives is “harm”, as governed and measured against the operational (precautionary) principle to “first do no harm”.

This attribute can serve a measurement framework to any organization to determine what they are required to do - even for the


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future - to plot a strategic path that will eventually reverse engineer their operations from unsustainable (harmful) to fully sustainable (benign impact and replenishment).

CA 011

“First do no harm” supports the Precautionary Principle recommended by ISO 26000. It has also been tried and tested, and while not perfect, the operationalization of first do no harm has enabled medical profession to progress well beyond its primitive roots through to relatively mature, responsible, ethical outcomes, and in doing so, provides far better protection to society as a result.

As society moves inevitably toward more empathic, collaborative behaviours as an evolutionary response to survival, these adaptations mean that organizations who are unwilling to commit to pursuing their own objectives while first doing no harm to others will themselves become the outliers, alienating themselves from their customers and from society.

Because first doing no harm is such a futuristic, long-term strategy, seemingly impossible to reach, it’s critical that a graduated, feasible, and traceable approach (such as a maturity model) be used to increase the organization’s capability to become fully sustainable. This will enable them to plan for, and eventually, introduce, adopt, and implement fully sustainable practices as quickly as possible. In doing so, new design requirements, leading to new material and


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production requirements, aimed at first doing no harm, can be communicated and cascaded through the supply chain (similar to what quality did) to instigate new innovations and research and development activities.

CA 012

The measurement of a system attribute that can be applied to environmentally- and socially-negative impacts enables a structural process approach to sustainable development. It can achieves harm-free outcomes by defining its process framework with first do no harm as its measurable process objectives, with levels of maturity staging progress along its unique maturity path. This framework, based on ISO 15504, could provide an organization with the capability to become fully sustainable in all aspects of its business.

Also, by operationalizing its avoidance of harm (as in "first do no harm”), the organization can maintain control over the redesign of its business as it charts its progress to changing its social and environmental footprints. Once this is done systematically, harms are avoided through corrective actions, since avoiding harm is a preventive method anyway.

As a sustainability maturity model, its life cycle processes will support a systems of systems structure to provide visibility into the complexity of relationships that are impacted by anthropogenic activities.

CA A systems of systems (SoS) representation of organizational, economic, social, and environmental system interactions makes


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013

explicit the complexity of interdependencies and interactions that must be accounted for if human activity is really committed to reverse the upswell of anthropogenic damage already threatening societies' existing standards of living.

A systems engineering framework will also provide the most accurate - and undeniable - representation of the sometimes unpredictable reach to where harms extend beyond the originator's immediate or anticipated sphere of influence. Harms often extend into future generations, far beyond perceived spatial and temporal boundaries, outreaching and outlasting current generations. This model’s focus on the far future will support a structure in which the negative impacts from social and environmental performance are accounted for and can begin the process for reversing away from negative impacts. It can begin the process of reversing the damage, and in turn, influence its supply chain to do the same.

CA 014

There may never be a way in which even science can reliably predict how to protect future generations’ rights to life with basic needs met and freedom from imminent harm. Despite this fact, to be effective and to gain permanence, organizations must be able to approach their transformation from unsustainable to sustainable at their own pace, yet remain in synch with the urgency demanded by customers, stakeholders, and the systems environments in need of mitigation.


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Without taking aim at avoiding harm, deliberate or negligent harms are more likely to persist. For this reason, Canada offers its firm belief that the best purpose of 18617-2 is as a practical document. It can become immediately useful to readers by supporting the realization that the complexity of procuring sustainably requires a change in the mindset and the current operating paradigm of organizations. This is essential for them to proliferate, down through their supply chains, their new needs for sustainability use the measurement of harm as the negative impact countering efforts to become fully sustainable. In doing so, 18617 will lay the foundation for a library of sustainable procurement documents that all seek to measure and in turn learn to avoid harmful impacts as a necessary prerequisite to building a “sustainable system of systems model” (using the proven systems engineering techniques of JTC10).

CA 015

18617 can introduce the concept of harm when discussing impacts, as those are what need to be managed and avoided. Guidance which helps organizations think about upstream design processes and what they should specify to procurement sets up an infrastructure capable of evolutionary development and adaption, one that can become receptive to innovation and change, rather than resisting it. Through effective governance, courageous visions, and long-term strategic planning (with 10, 20, 50, and 100-year strategies as the


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norm), sustainable procurement can become the catalyst which triggers the cascade of innovation that begets benign renewables, intolerance of poverty, social justice, and prevention of all manners of cruelty. With sustainable procurement elevated to the status of critical, collaborative interdependency, it should be able to:

(1) generate awareness of the complexity of the issues surrounding sustainable development so that realistic, but aggressive, long-term strategies (aimed at 20, 50, 75 & 100 years) can be developed which make meaningful social and environmental changes while not being overwhelmed by that change

(2) trigger a recognition of previously-unrecognized improvement opportunities as part of the transition from unsustainable to more sustainable activities, methods, processes, materials, systems, etc.

(3) provoke organizations to establish aggressive but realistic goals and objectives for SD

CA 016

(5) enable the definition of clearly-defined SD requirements designed to trigger competitive innovation cascades down through the supply chain in response to the new requirements being adopted by an emerging market of stakeholders.

(6) offer new organization-supplier partnerships opportunities to emerge in pursuit of innovation as a result of collaborative


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research and development activities into initially, less harmful products and services, moving to benign or net neutral mode of operations, always with the goal being fully sustainable, therefore, to beneficial and replenishing outcomes, not harmful to social or environmental systems, and therefore fully sustainable.

(*harm inventory = as complete an inventory of all existing and potential harms perpetrated against any internal or external system, living or non-living, dynamic or static, in order to achieve a purposed outcome, in accordance with current scientific evidence, or, in lacking such evidence, with the Precautionary Principle)

CL 017

ge A native speaker should revise the English edition, there are many spelling and grammatical errorsit does not read as if it were written by a native speaker.

Please review the wording and grammar of the entire document by native of English to improve their understanding and study

DS 018

Ge The DS NMC to PC277 cannot approve on the preset draft af being ready for next step. More discussions and revisions are needed. The NMC is in process of developing technical comments to be submitted asap.

US 746

1, Xxx Xxx Editorial The notion of embedding sustainable development or corporate responsible actions into all operational and functional parts of the businesses has become the mantra of leading sustainable development companies.

‘Integrating’ should be replaced with the word ‘Embedding’

EOS/ EG 019

5 Title te The standard does not state any requirements but provides guidance on how’s and gives many examples.

It is proposed to change the title to be "Guidance on sustainable procurement”


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So, it’s a guidance document similar to ISO 26000 "Guidance on social responsibility”

EOS/ EG 020

ge This CD is very lengthy and needs a systematic re-organization.

Omit repeated phrases/sentences in the Standard e.g. there is no need to mention the principles (4.2.2) and core subjects and issues (pages 7 & 11) of social responsibility as it is sufficient to indicate the reference.

EOS/ EG 021

ed There are some linguistic mistakes in this CD. *Correct the linguistic mistakes e.g. adding "s" to "asses" in 6.2.2, making spaces between "inasmuch" in 4.4.1 to be "in as much" …etc.

*Omit the repeated phrases e.g. "this policy" in 4.4.2

INTECO 022

ge It would be useful to have a section explaining that in the case of public procurement, this guideline should be followed taking into consideration existing regulations that frame the relationships with suppliers and subcontractors, as well as the procurement process in general.

It would be included an explication like this on the introduction.

INTECO 023

ge The term “CSR” people is used in different parts of the text. So change CSR to SR like ISO 26000.

INTECO 024

Change wording to maximize positive impact that could provide the supplier/subcontractor. It is possible to get a positive and negative impact on the three axis (environmental, social and economic).

Sustainable procurement in general terms means making sure that the products and services an organization buys have the least negative and most positive environmental, social and economic impacts as feasible.

INTECO 025

ge Change SMEs by SMOs. In the ISO26000 it is mentioned SMOs because includes any type of organization: enterprise, institution,

SMOs


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company, etc.

INTECO 026

Change measure improvement by monitoring performance, the norm should aim measuring the real performance

monitoring performance and take corrective action if necessary

IT 027

ge The scope should be reformulated because something seems to be missing between the words “for” and “stakeholders”, this in order to clarify that this standard is not only intended for stakeholders but for all kind of organizations interested in integrating sustainable procurement in their activities and decisions.

More generally, the scope should be more aligned with the contents of the whole text of the document.

IT 028

ge The document as it is now, seems not to be applicable to every kind of organizations, in particular to SMEs and to public organizations procurement and tendering processes.

IT 029

ge The document is still not fully harmonized yet because there are references and recalls to sections which are not quoted in the index for example line 259, 622, 856, 867, 894.

IT 030

ge The concept and definition of supply chain (including the concept of sphere of influence) need to be more elaborated and harmonized with others international instruments of social responsibility


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JP1 031

ge JISC disapproves the concept of standardizing sustainable procurement.

JP2 032

ge The relationship between ISO 26000 and CD2 is unclear. Although, previous observation noted that they will take care of the alignment, there is still no alignment between ISO 26000 and CD2.

JP3 033

ge The idea of certification in the document is contradicting idea from ISO 26000.

JP4 034

ge Multi stakeholders review is needed for this document.

JP5 035

ge Liaison between “PPO for ISO 26000” is necessary.

PL 036

ge This Standard according to Scope provides guidance to organizations integrating sustainable development within procurement, independent of their activity or size, as described in ISO 26000.

We propose do not use CSR in standard.

SA 037

ge Different terms are used throughout the document to refer to the same idea:

• “Products and services” Vs’ “goods and services”

• Social Responsibility Vs’ Corporate Social Responsibility

• Business, organisation, corporate, purchasing organisation, buying organisation

• Buyer Vs’ procurer

Standardise terms used in the document

Ensure that these terms don’t exclude public organisations such as governments


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• Supply chain entity Vs’ supplier

SA 038

ge We think that the sections of the standard that specifically target decisions makers/executives lack impact, even though the majority of the content is relevant.

They should be largely redrafted, both on their structure and style.

Redraft the sections ‘Introduction’ and ‘Fundamentals’

Include an ‘Executive Summary’ section.

SA 039

ge References to all related international standards and protocols should be included.

Most important references will be:

• UN Global Impact

• OECD

• GRI

• UN Protect Respect and Remedy Framework

• UN Guiding Principles on HR

• SDG’s.

SA 040

ge We would like to see a final summary with a checklist of steps to take.

Adding a checklist at the end of the standard.

SA 041

ge We would like to see a table of abbreviations. Adding list of abbreviations and acronyms.

SA 042

ge There are few mentions of the contractual aspects of sustainable procurement.

Include references to the development of the contract throughout the procurement process:

• Planning – Integrate sustainability considerations in the contracting strategy, within the Procurement Strategy

• Selection – Include clauses in the Draft Contract sent to and adapt them


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if needed in the Final Contract

• Manage: Review and adapt Contract if needed

SN 043

Include the importance of openness in case of findings in the supply chain (communications to media and stakeholders on uncertainties and challenges, findings of concern.

…it is important with of openness in case of findings in the supply chain

SN 044

How to monitor suppliers in this area may be included – eg. Inspections by in-house inspectors

Inspections by in-house inspectors

INTECO 045

0 ge Consider including the PDCA cycle, to encourage the continuing improvement of the sustainable procurement process. It could be included in the introduction of the document.

Include PDCA cycle

CA 046

All All All te Today’s organizational leaders are ill-equipped to operate and succeed using any sustainability approach, whether it be triple bottom line as introduced by ISO 26000, or another approach despite their need and desire to do so.

Consequently, requirements specifications to suppliers are likely to be still too slow to change the status quo, not reaching the accelerated pace we need to preserve our current standards of living (according to both OECD’s and IPCC’s latest reports). That means that without an immediate and comprehensive approach that will at least attempt to generate fully sustainable procurement specifications for new products that are fully sustainable, organizations are more than likely to see more of the same, limited to GHG emissions and a few other well-publicized issues, and not varying significantly

Canada will be submitting a PAS document (Sustainable Development Maturity Model) based on ISO/IEC 330xx, once ISO/IEC/JTC1/SC7/WG10 has completed its transition arrangements for models currently complies with ISO/IEC 15504 Process Assessment.

This PAS sustainability maturity model embeds 3BL processes and requirements as purposes, and outcomes and in doing so operationalized the ISO definition of sustainable development. This systems model stages the maturity to a series of levels that will enable the organization to structure its strategic plans to achieve sustainability goals by measuring its own and its supply chain’s progress.


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from the present.

The difficult analysis required to transition from unsustainable to fully sustainable is so much more complex than originally anticipated. Just admitting to the depth and scope of the pervasiveness of unsustainability requires a Herculean effort, demanding far more effort than organizations are sometimes willing to admit, even to themselves. The prospects are overwhelming. So entrenched are we in unsustainable practices,that it is difficult for most of us to even comprehend what the alternatives will look like, given our history, experience with, and excellence for engineering all things harmful.

For a commercial organization to tell its shareholders that its legacy is harm, that it is an unsustainable business, that its core competencies will be, by all standards of morality, designated for extinction is too high an admission to make without a well-considered transition plan already in place (e.g. from an oil producer to a renewable energy producer), given existing investments in equipment, processes, methods, capital investments, etc.

For this PAS to be successful, the concept of harm must be introduced into this draft as the operationalization of the principles of ISO 26000. Therefore, to make this happen, Canada offers, in addition to its upcoming PAS submission, to either:

(1) edit the current draft of 18617 and provide a word document with tracking changes kept on, either in advance of the Plenary or immediately after, to demonstrate how this operationalized principle of first do no harm would read in the current draft or (2) set up an ad hoc SWG to engage in one or a series of working web-based teleconferences as a joint effort in editing the current draft for the same purposes as in (1), to demonstrate the first do no harm precautionary principle. These telecoms could take place either before or after the Plenary, as the member bodies see fit.

FR 047

All Ge France will turn its vote into positive if French important comments aiming to ensure consistency with ISO 26000 and procurement operationality are approved.

FR 048

All Ge Need to use terminology more consistent with ISO 26000 such as social responsibility, SMOs, consumer and customers …

Review the text


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CO 049

All document

All document

Te We disapprove the document due to comments explained onwards. We don’t find applicability for Small and Mediums companies. In our country 92% of the companies are small and medium.

NL 050

Ge Check UK and American spelling, like s and z use in analyse.

IFPSM 051

General Ge Described professional procurement instead of sustainable procurement. This applies for all other paragraphs in chapter 6

Provide practical guidance on how sustainability should be implemented

IFPSM 052

General Ge Many of the illustration do not add value to the document, also many of the illustrations promote a certain specific methodology while other methodologies are also available

Remove the illustrations and create a number of flow charts that support the structure of the standard.

IFPSM 053

General Ge Described professional procurement instead of sustainable procurement. This applies for all other paragraphs in chapter 6


IFPSM 054

General Ge Many of the illustration do not add value to the document, also many of the illustrations promote a certain specific methodology while other methodologies are also available



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IN 055

General te Product, goods, works, services, utilities have been interchangeably used in the document.

Same terms to be used throughout the documents.

NL 056

- General Ge This new standard is recommended to be used in connection with ISO 26000, however it will be drafted to be used stand-alone.

This implicates that ISO 18617 should include important content of ISO 26000, like the seven SR principles, the seven cores subjects and 37 issues, sphere of influence concept, due diligence, complicity, priority setting, definition of social responsibility and its relationship with sustainable development etc.

Where possible: ‘Looking through the eyes of procurement’ is key to the reader.

Make it very clear to the reader where ISO 26000 content is being used by:

- Using help boxes, for example (f.e.). explaining sphere of influence concept, due diligence, priority setting, complicity

Note. The boxes in 5.4.2. regarding influence and due diligence are heading in this direction

- Creating Annex, f.e. table with 37 issues

- Quoting ISO 26000, f.e. by underlined text

Add also:

- Figure 1 of the ISO 26000 framework (into an Annex)

- Some crucial definitions like ‘social responsibility’, ‘sustainable development’, ‘stakeholder’. See: comment clause 3

NL 057

General Ge Use of illustrations: many of the illustration do not add value to the document, also many of the illustrations promote a certain specific methodology while other methodologies are also available


058

SA

P15 One of the critical issues our members have found is that their relationship is with the Tier 1 providers. Tier 1 providers then have the relationship with the next layer of contractors etc etc. Where the impact is being felt can be some layers away from the initial contract with Tier 1 and the question becomes what legal right does the company have over the contractors way down the supply chain?

A contract will need specific clauses to ensure that the purchasing organisation can have control on what’s happening in the supply chain. Examples of clauses include:

• Provision to assess/audit all parties involved in the supply chain;

• Obligation of the supplier to inform the purchasing organisation of any material impact in the supply


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market/supply chain

SG 059

Whole draft GE While the draft generally scopes procurement as applicable to both product and services, there are several places in the draft where services have been left out. See e.g. 3.26, 4.44

US 747

42 Contents Editorial ‘Integrating’ should be replaced with the word ‘Embedding’

US 748

64 Contents Editorial ‘Integrating’ should be replaced with the word ‘Embedding’

SA 060

109-131 Introduction ge This clause should be completely redrafted to enable readers (especially decision makers) to get a better understanding of what this document is about.

Apply the following structure for the introduction (max. 1 page):

1) Audience

2) Intention – Purpose

Should include a reference of the fact that this standard is a guidance document.

3) Context – Drivers

Should include references to the following drivers: global and national dynamics, investors interests, transparency required by customers and communities, regulation by governments

4) Business Case – Why?

- Create Value

- Mitigate Risks

NL 061

110 Introduction ge Include the complete title/name of ISO 26000 ISO 26000, the international guidance on Social Responsibility


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SN 062

110-122 Introduction TE The first part of the present introduction contains very little information of real value to the understanding and use of the standard.

Redundant and should be deleted.

US 749

110 Introduction 1st Editorial I think Universally recognized might be too strong. I know that the US has not universally recognized 26000 as the final word on social responsibility.

…providing universally recognized guidelines…

US 750

111 Intro Para 1 Editorial The procurement function is a key player, the word “may” is not strong enough

Sentence should read: The procurement function is considered a key player…

US 751

116 Intro Para 2 Editorial Sentence is not grammatically correct “Globalization and open markets often drive organizations to share the same concerns at an international level.”

US 752

116 Introduction 2nd Editorial We are missing ‘and’ & ‘an’ Globalization and open markets, often….same concerns at an international level.

US 753

119 Introduction 3rd Editorial Clearer sentence The current and forthcoming energy……and their consequences, may cause reactions…

US 754

119 Intro Para 3 Ed “energy situation” is probably not an accurate description

“energy market conditions” may be better

US 755

119 Introduction Editorial It is better to take a more global/holistic view than to focus just on energy.

Replace “current and forthcoming energy situation,” with “Growing demands on the worlds resources”

US 756

119 Introduction Editorial In the three introductory paragraphs the notion of sustainable procurement contributing the eco-efficiency of a business and/or introducing innovation and thereby delivering a reduction in an organisations operational costs, is not covered.

US 757

119 – 120

Intro Para 3 Ed Sentence that starts with “Current and forthcoming…” is vague and imprecise

We’d need to clarify precisely what this sentence means – perhaps that organization actions may cause reactions that are


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detrimental to the organization’s reputation?

IFPSM 063

119 Introduction Te Examples are all environmental Include child labour, liveable income, social dialogue

IFPSM 064

119 Introduction Te Examples are all environmental Include child labour, liveable income, social dialogue

NL 065

119 Introduction Te Examples are all environmental Include child labour, livable income, social dialogue

SN 066

119 Introduction TE If retained, not only energy should be addressed, but resource depletion and use of human resources should also be included at this stage

See comment above

INTECO 067

119 - 120

ge Do not limit the justification to the subject of the corporation or organization image. It could be justified as well as is described on the whole document on the basis of risk management, and cost and negatives impact reductions

AR 071

120 te Good practices for sustainable procurement should benefit the reputation and not the image of the organization.

“… detrimental to the organization's reputation.”

US 758

121 Technical Treat all references to “stakeholders” to include natural systems not only in relation to


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anthropocentric orientation. Perhaps consider adding a statement relating to “stakeholder” to this Introduction, and a proper meaning within the definitional section, where this could be made clear. This is a very important term overall in understanding how this standard is supposed to work, under what circumstances, and in relation to who/what and why.

AR 068

123 te The phrase is not properly constructed. “This transversal document is a valuable tool to achieve the following main targets:”

SN 069

123 Introduction ge

The new standard is referred to as transversal. This could lead to confusion. Therefore it is simply suggested that the new standard is labeled as the new standard.

This standard will be a valuable tool to achieving the following main targets:

NL 070

125 Introduction Te Contractors is only part of the group Use ‘suppliers’

US 759

127/135/262

various Editorial ‘Integrating’ should be replaced with the word ‘Embedding’

US 760

130 Intro Para 5 Ed Extra space before sustainable procurement. Proofer should catch

AR 072

130 ed A bullet is missing.

SN 073

130 Introduction ge

If it is a target, it has to be reformulated, since the "facilitation" is an activity and not a target.

Improve the understanding of sustainable procurement", through a practical and operational approach.

FR 132 Introduction Te Clearly specify that it is up to each Add the proposed text:


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074

organization to implement the standard in part or as a whole, according to its context.

“these principles and guidelines are considered relevant to any organization. However, they can be applied in part or in full, depending on the context of the organization, its CSR stakes and its ability to influence relevant stakeholders in a continuous improvement process”

SN 075

135-138 Scope

The name of the standard should be more specific in order to avoid misunderstanding that this standard is "a guideline of a guideline". We can assign a similar name independent of ISO 26000. The link between this standard and ISO 26000 is already included in the point 2. As a normative reference (line 143)

This International Standard provides guidance to organizations and their stakeholders integrating sustainable development within procurement, independent of their activity or size.

INTECO 076

145 Ge Include the following definitions on “Terms and definitions”:

Value chain

Supply chain

Life cycle

CO 077

145 3 Te/ Ed

Include the terms and definition of: Budget, Approval Budget, Financing, Payment, Payment Schedule, Schedule

NL 078

145 3 Te Terms and definitions now indicates that the reader should ‘apply definitions given in ISO 26000’. However it is uncertain if the user of ISO 18617 will also buy ISO 26000

Add some important definitions of ISO 26000:

- Social responsibility

- Sustainable development

- Stakeholder

- Stakeholder engagement

- Due diligence

- Sphere of influence

SE 079

145 3 te Promotion of universal design is an additional principle under clause 6.7.2 in ISO 26000. A

Add the definition of Universal Design from the


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procuring organisation who has that mindset is working aligned with UN Convention on the Rights of Persons with Disabilities. In that sense that organisation also is in line with Clause 6.3 about Human rights in ISO 26000. When promoting Universal design the organisation are dealing with risks as avoiding discrimination and excluding big groups of users/costumers or workers. If the thinking for procurement is right from the outset with the promotion of universal design in mind, the quality of the organisations output can be improved. The quality of the output is going to benefit all humans.

It is much more expensive to be forced to subsequent procurements when deficiencies are revealed than it is to avoid deficiencies in accessibility and usability for all users/costumers/workers right from the start by promoting Universal design in the procurement process.

The Committee on the Rights of Persons with Disabilities has in the general comment nr 2, paragraph 4, clearly stated that accessibility should be an integral part of the sustainable development agenda. In paragraph 15 the application of Universal design is recommended for all new goods, products, facilities, technologies and services to ensure accessibility for all. There are also several references to procurement in the comment.

Below: “Universal design” is added in two clauses therefore the definition should be added.

DRAFT ISO/IEC GUIDE 71 as follows:

universal design

design of products, environments, programmes and services to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design

[SOURCE: United Nations Convention on the Rights of Persons with Disabilities, Art. 2]

Note 1 to entry: Universal design shall not exclude assistive devices for particular groups or persons with disabilities where this is needed.


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SE 080

145 3 Te The acronym SME need to be defined as it is widely used in the draft.

Add definition of SME to the definitions section.

SE 081

145 3 te Due Diligence is a key method which is related to in paragraph 4.4.4. A definition should be added.

Add the definition of due diligence from ISO 26000.

SE 082

145 3 te The term “purchasing” still occur in the draft standard for example in line No. 273. If the term is to be used it should appear in the definitions clause.

If the term purchasing remains in the standard it should be defined and included in the definitions clause.

EOS/ EG 083

145 3 Terms and

definitions

ed "Terms and definitions" are not arranged alphabetically.

Re-arrange the two definitions of 3.11 & 3.12 to become 3.28 & 3.29 according to the alphabetical order for ease of reference.

SN 084

145 3. Terms and

definitions

GE The fact that a lot of essential terms are identified, but not defined, may result in major comments at a later stage if the final definition changes the understanding of the text

Terms which are not critical to the understanding of the text, and where dictionary explanations could be used, should be deleted.

EOS/ EG 085

145 Clause 3 te Some definitions are still missing (to be filled) in the ISO/CD 18617.2.

We propose the following definitions for some of such missing terms stipulated in Clause 3 of the CD:

3.3 business ethics: A set of principles and criteria that govern and direct the organization against its behaviour towards stakeholders in a socially responsible manner. (ISO 26000)

3.4 ecolabel: A label which identifies overall, proven environmental preference of a product or service within a specific product/service category.

3.6 fair business practices: Respecting the law; practicing accountability and fairness in dealings with other businesses, including


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suppliers.

3.10 labour practices: All policies and practices relating to work performed within, by or on behalf of the organization, including subcontracted work that should promote productivity to contribute to sustainable development. (ISO 26000)

3.19 procure: Dynamic process that comprise a set of steps that the purchaser passes by in case of selecting the best among the available substitutes to take a decision of procurement to fulfill his needs and expectations.

3.24 satisfactory working conditions: Decent conditions of work with regard to wages, hours of work, weekly rest, holidays, health and safety, maternity protection and ability to combine work with family responsibilities.

Note: Fair and appropriate consideration should be given to the quality of conditions of work as they greatly affect the quality of life of workers and thus enhance their performance and productivity that contribute to economic and social development.

3.28 Sustainable: Providing products and services with high quality and efficiency and the lowest environmental and most positive social and economic impacts for the sake of the quality of life of end users.

SA 086

145-256 3 Review definitions to make them consistent (e.g. Procurement, Sustainability, Sustainable Procurement). Where ever possible use existing definitions (e.g. from ISO, World Bank).

US 145, et Technical Include definitions for “environmental” and environmental


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761 seq. “environment”. These terms should not only be anthropocentric-focused, but include focus on eco-systems – e.g., flora and fauna – which may exist with value independent of direct human “needs”.

A descriptive term referencing a characteristic of a system, use or process outcome involving the natural world, and relating not only to the interests and well-being of affected human and other anthropocentric entities and organizations, but also to natural systems, flora and fauna, eco-systems, etc.

US 762

147 – 149

The definition of “absolute rights” is not understandable as written

CL 087

147 3.1 te We have added the environmental rights, in form of integrative management in the human being scopes.

according to the Human Rights, civil and political, economic, social, cultural and environmental rights

AR 088

147-149 te The term absolute rights has not being defined in any international norm of behavior as defined in ISO 26000:2010.

Delete this definition.

US 763

149 Xxx Xxx Editorial The term “Human Rights” should be defined. Similarly, the following terms “civil and political, economic, social and cultural rights” all are without context, and no indication is given as to why they are considered “absolute”. Suggest that the text avoid establishing ‘hierarchies’ of rights. Calling some rights “absolute” implies that others are not.

Suggest referring to the “International Covenant on Civil and Political Rights” and the “International Covenant on Economic, Social, and Cultural Rights.”

CL 089

150 3.2 te best offer it is one that considers social, ethical and environmental aspects of production processes and phases of recruitment

IN 090

150 3.2 te best offer To be defined


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CL 091

153 3.3 te business ethics behavior of an organization that is based on honesty, fairness and integrity. This implies concern for people, animals and the environment, and a commitment to address the interests of stakeholders

IN 092

153 3.3 te business ethics To be defined

AR 093

154 te The use of business oriented language should be avoided.

“Organizational ethics”

CL 094

156 3.4 te ecolabel declaration that indicates the environmental aspects of a product and/or service.

Note: a label or environmental declaration can present the form of a declaration, symbol or graph in the label of a product or package, in the literature of a product, in technical bulletins, in announcements or in publicity, among others.

[SOURCE: ISO 14025:2006, definition 2.1]

IN 095

156 3.4 te ecolabel To be defined

SN 096

158 Terms and definitions

te

There is several fair trade labels that include many of the elements included in this standard. A definition of the term should be included.

3.5 Fair trade

CL 097

159 3.5 te environmental declaration is already defined in ISO 14020.

claim which indicates the environmental aspects of a product or service NOTE An environmental label or declaration


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may take the form of a statement, symbol or graphic on a product or package label, in product literature, in technical bulletins, in advertising or in publicity, amongst other things. [SOURCE: ISO 14020:2000, definition 2.1]

SE 098

159 3.5 te ISO 15392:2008 = “Sustainability in building construction - General principles”. It is more relevant to use the general definition for this term in the 14000-series and refer either to ISO 14020, ISO 14040 or ISO 14025.

Change the definition to reference either to ISO 14020, ISO 14040 or ISO 14025.

AR 099

161 te In order to be coherent with ISO’s current trend, good(s) and service(s) should not be used.

“… environmental aspects of any product(s) or service(s)”

(This change applies throughout the whole text)

CL 100

163 3.6 te fair business practices practices that promote a healthy relationship between the company that buys products or services and other that providing them. Potential risks in relationships should be identified, this can be done through a process of due diligence [1] [2]. However, this interaction must be free of bribery, favoritism and/or complicity (legitimate equal opportunity for all participating providers) in a transaction that gives guarantees for the respect of the confidentiality of the information and/or products and services of the participating companies [3]. [1] Commission of the European Union [2] OECD Guidelines [3] Michael Bendixen Russell Abratt (2007) Corporate Identity, Ethics and Reputation in Supplier–Buyer Relationships Journal of


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Business Ethics (2007) 76:69–82 DOI 10.1007/s10551-006-9273-4

IN 101

163 3.6 te fair business practices To be defined

CA 102

164 3.6 te This standard applies to all organizations not just ‘businesses’ and ISO 26000 has already defined ‘Fair operating practices’ in cl 6.6.1.1

Replace ‘Fair business practices’ with ‘Fair operating practices’ and use definition in ISO 26000 cl. 6.6.1.1 Organizations and fair operating

‘Fair operating practices concern ethical conduct in an organization's dealings with other organizations. These include relationships between organizations and government agencies, as well as between organizations and their partners, suppliers, contractors, customers, competitors, and the associations of which they are members.

IN 103

166 3.7 te gateway review To be defined

CL 104

169 3.8 ed Spelling error

measurable representation of the condition or status of oerations, management, or conditions

measurable representation of the condition or status of operations, management, or conditions

AR 105

171 ed “p” is missing. operations

IN 171 3.8 ed Oeration Operations (Spelling mistake)


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106

US 764 171

Terms and Def

3.8 Ed “operations” misspelled Proofer should catch

CL 107

178 3.10 te labour practices the labour practices of an organization comprising all policies and practices related to the work being done within, by or on behalf of the organization, including work subcontracted [4]

[4] ISO 26000:2009

IN 108

178 3.10 te labour practices To be defined

SE 109

178 3.10 te Definition should reference to ILO standards and national labour standards.

Adapt definition from ILO standards and national legislation as relevant.

DS 732 181-191

3 3.11 – 3.12 Te Responsibility shall be assessed in the full supply chain perspective and based on a risk approach. An organization cannot delegate responsibility to other actors in the value chain.

CA 110

189 4 te Focus should be on reducing ‘harmful impacts’ on workers as well as the environment.

Sustainable procurement should also promote ethical and socially responsible behaviour in the supplier. (ISO 26000)

Replace with:

A process whereby organizations meet their needs for goods, works and utilities in a way that achieves value for money on a whole life basis in terms of generating benefits not only to the organization, but also to society and the economy, whilst minimizing harmful impacts on the environment, workers and society.


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CA 111

189, 255 3.10, 3.29 te ISO 26000 has already defined Labour practices in cl 6.4.1.1

Use definition in ISO 26000 cl. 6.4.1.1 Organizations and labour practices

The labour practices of an organization encompass all policies and practices relating to work performed within, by or on behalf of the organization, including subcontracted work.

IN 112

190 3.1. Responsible purchase policy To be defined / elaborated

CL 113

192 3.13 ed Spelling error



CA 114

193 ge A definition of life cycle needed, besides life cycle assessment. Does life cycle include in-service support?

193 - Add this definition of Life Cycle beforehand: From inception, through engineering design and manufacture, to service and disposal of manufactured products.

CL 115

197 3.14 te local supplier provider that offers a product or service to the organization and it is based in the same geographic market it (ie, no cross-border payments to the supplier are made). The term "local" may refer to the surrounding community operations, to a region within a country, or a country [5]

[5] GRI G4

IN 116

197 3.14 te local supplier To be defined

IN 117

200 3.15 te maturity matrix To be defined


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IN 118

203 3.16 te mutually beneficial relationship To be defined

CL 119

209 3.18 te The sections talks about a policy, but it should not be enough with the intention. Instead, it should consider including a formal and public document.

intentions and direction of an organization including a formal document, as formally, approved and expressed by its top management, duly known by the pertinent stakeholders.

IN 120

212 3.19 te procure To be defined

SE 121

215 3.20 What is meant by traffic? … as in logistics or as in dealing, in operations or in services?

Change “traffic” to “transport”.

AR 122

217-218 te In some organizations, procurement may not be a function, but in all organizations procurement involves one or more processes.

The enumeration included is not exhaustive.

“Organizational process/es for obtaining or buying product(s) or service(s) that include/s specifications development, value analysis, supplier market research, negotiation, buying activities, contract administration, inventory control, traffic, receiving and stores, among others”

CL 123

232 3.24 te satisfactory working conditions the satisfactory working conditions are related to decent work and include salaries and other forms of compensation, working hours, rest periods, holidays, disciplinary and dismissal practices, maternity protection and welfare issues, such as drinking water, sanitation, collective dinning rooms and access to medical services.

IN 124

232 3.24 te satisfactory working conditions To be defined


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PL 125

234 3.24 te We propose following definition:

“working conditions providing safe work environment and allowing workers to meet their social needs”

AR 126

234-235 te The definition of social responsibility established in ISO 26000:2010 should be included because, as the standard will be based on ISO 26000, it should not lead to reinterpretations.

social responsibility

responsibility of an organization (3.X) for the impacts (3.X) of its decisions and activities on society and the environment (3.X), through transparent and ethical behaviour (3.X) that

- contributes to sustainable development (3.X), including health and the welfare of society;

- takes into account the expectations of stakeholders (3.X);

- is in compliance with applicable law and consistent with international norms of behaviour (3.X); and

- is integrated throughout the organization (3.X) and practised in its relationships NOTE 1 Activities include products, services and processes. NOTE 2 Relationships refer to an organization's activities within its sphere of influence (2.19).

The following definitions, as established in ISO 26000:2010 should be included: organization, impact of an organization, environment, ethical behavior, sustainable development, stakeholder, international norms of behavior.

INTE 239 te Include a new definition: subcontractor (line include definition of subcontractor


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CO 127

358 “suppliers” and “subcontractors” are mentioned as different stakeholders).

SG 128

239 3.26, page 3 GE supplier

organization or person that provides a product or service

US 765

240, 241 Editorial Add words at the end: “…or service” [“organization or person that provides a product or service”]

“organization or person that provides a product or service”

INTECO 129

241 te The supplier definition mentions an organization or person that provides a product, this definition is taken from ISO 9000 but that document explains: product can be good or services, however this explanation is not included in the present document. We propose to include "service".

Organization or person that provides a product and/or service.

US 766

244 – 246

Technical “state of the global system” is unclear. Suggest using better language. Suggest moving past the now archaic Brundtland definition of ‘sustainability’ by incorporating non-anthropocentric considerations. [Cf. USG EO 13423, describing the meaning of “sustainable”, in part, to include “conditions, under which humans and nature can exist in productive harmony, that permit fulfilling the social, economic, and other requirements of present and future generations of Americans…”]

“The operational state of business and commerce which includes environmental, social and economic considerations under which humans and nature can exist in productive harmony, and that permit fulfilling the social, economic, and other requirements of present and future generations.”


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AR 130

248 te There’s no need to define sustainable. Delete

IN 131

248 3.28 te sustainable To be defined

IT 132

251 3.29 te Is there an ISO official definition of “sustainable procurement”? otherwise it is suggested to develop an official ISO definition

SE 133

251 3.29 Minimizing damage on the environment will be difficult to achieve as a practical objective in reality.

Change current text to – “whilst significantly reducing negative impacts on the environment” as used in context of the UN work on Sustainable Public procurement Initiative (SPPI).

US 767

251-256 Terms and Def

3.29 Tech Is this a universally accepted definition of “sustainable procurement”. I do find it quite solid, but it does reflect a certain point of view.

Perhaps compare to other definitions.

CA 134

251 and 363

3.29 & 4.4.2 ge Definition of sustainable procurement is wide and three-fold (society, economy and environment).

Overall - No change to the ISO Draft. Canada Defence Procurement Strategy may or may not need to be amended to better support worldwide results as opposed to Canada-wide results.

FR 135

252 3.29 Te Complete sustainable procurement definition, taking into account, for example, this proposal, and also the need to be consistent

Sustainable procurement is procurement that : - incorporates criteria encouraging the protection of environment or creating value for environment, improves social development,


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with ISO 26000 (paragraph 6.5.2.2) and promotes economic growth ; - takes into account the interests of all stakeholders involved in the procurement ; - allows "smart" savings in relation to the needs and encouraging sobriety in energy and resource use ; - identifies the main environmental impacts associated with each product or service based on a comprehensive life-cycle assessment [Source: Plan national d’action pour les achats publics durables]

NL 136

253 3.29, 4.2.1 te These are two definitions of sustainable procurement which do not 100% cover the same ground.

Stick to the definition of 3.29.; this is also used by the UNEP. Another definition which is short and clear: “Using procurement to deliver long term social, economic and environmental benefits". The advantage of this alternative definition is that it does not deal with “minimizing negative impacts” but with “maximizing benefits” which is closer to the consensus of what CSR should be.

AR 137

253-256 te The proposed definition does not cover the broad spectrum of the triple bottom line approach.

A process whereby organizations access their demands for products and services by applying the triple bottom line approach, incorporating all the extrinsic costs associated with its responsibilities and impacts on the social and environmental arena

NOTE 1: the triple bottom line approach incorporates into organizational decisions the three dimensions within the notion of sustainability: social, environmental and financial.


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US 768

254 & 268

“whole life basis” – it’s not defined otherwise so far as I know. Should it be defined separately to have real meaning in this definition of sustainable procurement?

US 769

255 3.29 Editorial ‘Minimising damage’ to the environment is no longer seen as enough or acceptable. If the standard is to have longevity it should reflect actions that deliver best practice.

Replace ‘whilst minimizing damage’ with ‘without causing damage’

SA 138

257 ge The Section 4 Fundamentals should be redrafted and restructured to be more impactful for decision makers.

Apply the following order for Section 4 and change the headings:

4. Principles of Sustainable Procurement

4.1. Principles of Social Responsibility (ex 4.2.2.)

4.2. Sustainable Procurement as a function of Social Responsibility (new)

4.3. What is Sustainable Procurement (ex. 4.2)

4.4. Why procure sustainably? (ex. 4.3) - Drivers - Business Case

Rewrite the content so that this section is shorter, more straightforward and more impactful.

NL 139

257 4 4.2 Te It is unclear for the reader what terms like ‘social responsibility’ and ‘sustainability’ really

Add (ISO 26000) help box that explains social responsibility, sustainable development and its


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mean. Explain these important wording. relationship.

BR 140

258 - 262

4.1 TE This text should be moved to introduction clause.

This kind of explanation is more appropriate to the Introduction clause.

Move the text to the introduction clause.

SN 141

258-262 4.1 Introduction

to fundamental

s

TE The paragraph is intended to be of informative nature and should be covered in Introduction

Paragraph is redundant and should be deleted.

BR 142

259 - 262

4.1 TE It's expected that clause 4 also consider the sustainable procurement strategy.

Replace the text, including: “and strategy”.

The first section of this standard This clause aimed at being utilized by the top management of an organization to define the strategy and policies in connection with sustainable procurement. As a result it will consider the question of what sustainable procurement is what the main issues that led an organization are to implement it and how to integrate sustainability in procurement policies and strategy.

In addiction the clause's content should also consider and discuss the aspects on how to develop a sustainable procurement strategy

IFPSM 143

263 4 4.2 Te It is unclear for the reader what terms like ‘social responsibility’ and ‘sustainability’ really mean. Explain these important terms.

Add (ISO 26000) help box that explains social responsibility, sustainable development and its relationship. Add a list of definition of terms.

IFPSM 144

263 4 4.2 Te It is unclear for the reader what terms like ‘social responsibility’ and ‘sustainability’ really mean. Explain these important terms.

Add (ISO 26000) help box that explains social responsibility, sustainable development and its relationship. Add a list of definition of terms.


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CL 145

264 4.2.1 Paragraph 1

te This paragraph comments on the environmental impacts that products and services produce. However, it emphasizes only on negative environmental impacts, and does not consider new production processes that can even generate positive environmental impacts.

The next paragraph also talks about “minimizing damage to the environment” but does not include, and we think it should, positive environmental impacts. Sustainable procurement in general terms means making sure that the products and services an organization buys have the lowest environmental and most positive social and economic impacts as feasible.

Sustainable procurement in general terms means making sure that the products and services an organization buys have the lowest negative and most positive environmental, social and economic impacts as feasible.

BR 146

265 4.2.1 TE Sustainable procurement in general terms means making sure that the products and services an organization buys have the lowest environmental and most positive social and economic impacts as feasible. (impacts may be positive or negative in all dimensions)

Sustainable procurement in general terms means making sure that the products and services an organization buys will minimize negative impacts and maximize the positive ones, in all dimensions of sustainability: environmental, social and economic, considering the limits of influence and governance of the buying organization.

CA 147

265, 266 4.2.1 te Focus should be on reducing ‘harmful impacts’ on workers as well as the environment.

Sustainable procurement should also promote ethical and socially responsible behaviour in the supplier. (ISO 26000)

In ISO/CD 18617.2 Line 660, Clause 5.4.1 General

States that ‘In addition to being responsible for

Replace with:

Sustainable procurement in general terms means making sure that the products and services an organization buys have the lowest harmful environmental and worker impacts and the most positive social and economic impacts feasible.’


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its own decisions and activities, a procurement organization may have the ability to affect the behaviour of suppliers with which it has relationships.’

Add another paragraph:

‘In its purchasing decisions, an organization should take into account the environmental, social and ethical performance of the products or services being procured, over their entire life cycles as well as the ethical and socially responsible behaviour of supplier.’

AR 148

266 te As to align text with the globally accepted definition of procurement, the word obtains should be added.

“… an organization obtains and buys have …”

SN 149

266-265 General ed

The environmental issue should be included in a positive form. If environment is presented in the current manner, then we are accepting that procurement always has a negative impact on the environment.

Sustainable procurement in general terms means making sure that the products and services an organization buys has the outmost positive social, environmental and economic feasible impact.

AR 150

267 te The term goods should be replaced. “ … to meet their needs for products, services … ’

CL 151

267 4.2.1 Paragraph 2 ed The sentence is too long. Sustainable procurement allows an organization to meet their needs for goods, services and work making fiscal sense and generating benefits for both to the organization and to society.

BR 152

268 4.2.1 ED Why to address fiscal sense here? If yes, there should be addressed other dimensions as well: labour, environmental, ethic etc. Environmental damages have already been addressed in the sentence before.

As such, sustainable procurement allows an organization to meet their needs for goods, services and work in a way that both makes fiscal sense on a whole life basis in terms of generating benefits not only to the


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organization, but also to society and the economy, whilst minimizing damage to the environment.

NL 153

268 4.2.1 te The meaning of “fiscal sense” in this respect

is unclear. Replace “fiscal” by “financial”.

SN 154

268 4.2.1 general

TE fiscal is not the most appropriate term, life cycle should be introduced

, services and work in a way that both makes economic sense on an entire life cycle basis…

US 770

268 Editorial Unclear what the term “whole life basis” means here. Clarify this term, define it, change it to something more understandable, or remove it altogether.

US 771

268 4.2.1 2nd para Editorial Replace ‘benefits’ with ‘value’

US 772

269 4.2.1 2nd para Editorial Replace ‘whilst minimizing damage’ with ‘without causing damage’

US 773

269 Technical Clarify the meaning of the term “the economy”. If this is meant to be a reference to the third-leg of the ‘triple-bottom-line’ (environment, social, economic), then it is important to clarify that “economic” is primarily a reference to the economic condition of stakeholders of a company –not the company’s financial performance. An example would be the economic effects on workers, their families and adjacent communities resulting from the ‘sustainability’ deeds or misdeeds of a company (such as environmental pollution or injurious/abusive working conditions).

“As such, sustainable procurement allows an organization to meet their needs for goods and services and work in a way that, together, both makes fiscal sense for on a whole life basis in terms of generating benefits not only to the organization, benefits society, promotes but also to society and the economy the economic condition of stakeholders, whilst and minimizes minimizing damage to the environment.”


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SN 155

269 General ed

The environmental issue should be included in a positive form.

… economy, whilst positive impact on the environment

US 774 270 Technical

The adjective “good” in relation to use of the word “procurement” is undefined and should be clarified to the extent it does not allow for a subjective meaning, or struck from the text (recommended).

“Sustainable procurement is good procurement and should not be viewed…”

SN 156

271 General ed

It is important to show the importance of having a balanced and well thoughtful base for procurement activities.

…idealistic goal but as a reasonable, practical and achievable objective for ….

BR 157

273 - 274

4.2 TE To more clarity of the text. The issue is not only the consideration of requirements. In fact, purchase is important because the organization is committed with CRS or SD. The mention to "fair and just commerce" should be deleted in order to avoid confusion with other issues such as "fair trade" and other kind of initiatives.

The concept of sustainable development should be defined.

Replace the text for:

Purchases and supplies have become essential aspects when an organization considers requirements for commits itself to sustainable development. and fair and just commerce.

Include the definition of "sustainable development' in Terms of definitions.

US 775

273 – 274

Editorial Re-write to replace “have become” with “are”. “Purchases and supplies have become are essential aspects when an organization considers requirements for sustainable development, social responsibility, and fair and just commerce.”

US 776

273 – 274

Technical Either objectively define the terms “fair and just” in relation to “commerce”, or remove them as undefined (and possibly undefinable) terms. Consider replacing with “good business practice.”

“Purchases and supplies have become essential aspects when an organization considers requirements for sustainable development, social responsibility, and fair and just commerce good business practice.”


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BR 158

275 - 282

4.2.1 TE Certainly, ISO 26000, which provides guidance on social responsibility, is one of the references for developing the sustainable procurement standard, but it should not be a premise and should not be cited throughout the standard

After all, ISO 26000 is a standard about social responsibility and not about sustainability, and it is not cover the environmental, social and economic aspects.

Exclude: In this respect, ISO 26000:2010 Guidance on social responsibility is an important reference for an organization pursuing to implement Social Responsibility and therefore to improve their contribution to sustainable development.

It may be recalled that social responsibility is the responsibility of any organization for the societal and environmental impacts of its decisions and activities.

Acting in a socially responsible manner implies integrating social, economic and environmental criteria for decision-making purposes and accepting accountability for the impacts of decisions and activities on society and the environment..

FR 159

278 4.2.1. Te In the definition of social responsibility, social development is not mentioned. Indeed societal is not social.

It may be recalled that social responsibility is the responsibility of any organization for the social and environmental impacts of its decisions and activities.

SN 160

278-279 TE Sentence is redundant and should be deleted Delete

US 777

278 – 279

Editorial Strike use of the word “societal”, and replace with language consistent with common understandings of the ‘triple-bottom-line’, i.e., “social, economic, environmental” in relation to impacts.

“It may be recalled that social responsibility is the responsibility of any organization for the societal and environmental social, economic and environmental impacts of its decisions and activities.”


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US 778

280 Editorial Replace the word “implies” with “includes”.

SN 161

280-282 TE Sentence is redundant and should be deleted Delete

SA 162

283 ge Make current Section 4.2.2 to Section 5 and change title

Section 5 - Sustainability into the Procurement Policy

FR 163

284 4.2.2 Te Need to improve the reference to ISO 26000 regarding responsibility

Add “According to ISO 26000, the sphere of influence is a range/extent of political, contractual, economic or other relationships through which on organization has the ability to affect the decisions or activities of individuals or organizations. The ability to influence does not, in itself, imply a responsibility to exercise influence.”

NL 164

284-297 4.2.2 te The document does not state how the general CSR principles of the ISO26000 are translated to procurement.

Accountability

Each organization should be accountable for its own impacts on society, the economy and the environment. Therefore the focus for sustainable procurement should be ‘how do we shift accountability to the supplier’. The sustainable procurement policy and practice can be tested by the question ‘Does our procurement practice encourage or discourage the supplier to embrace accountability on social responsibility’.

Transparency

Each organization should be transparent in its decisions and activities that impact society


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and the environment.

An organization should encourage their suppliers to be transparent. An organization that is not transparent on their own CSR practice does not encourage their supplier to be transparent. Mutual transparency is the basis for stakeholder dialogue and long term collaboration.

Ethical Behaviour

Each organization should behave ethically and promote ethical behaviour. Ethical behavior is defined by international standards, but should be applied to an organization by the organization. The supplier should define ethical behavior fitting for the supplier. An organization that enforces their code of ethics on a supplier does not shift accountability.

Respect for stakeholder interests

Each organization should respect, consider and respond to the interests of its stakeholders. Organization should respect the interests of the supplier and vice versa.

Respect for the rule of law

Each organization should accept that respect for the rule of law is mandatory. An organization may expect a suppliers to abide by the law and should test compliance as


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situations require such action.

Respect for international norms of behaviour

Each organization should respect international norms of behaviour. An organization may expect a suppliers to abide by the international norms of behaviour and should test compliance as situations require such action.

Respect for human rights

Each organization should respect human rights and recognize both their importance and their universality.

An organization may expect a supplier to abide by the International Bill of Human Rights and expect the suppliers to be aware of human rights violations in their supply chain, regardless of the size of the supplier.

US 779

291 Technical Treat all references to “stakeholders” to include natural systems not only in relation to anthropocentric orientation. Perhaps consider adding a statement relating to “stakeholder” to this Introduction, and a proper meaning within the definitional section, where this could be made clear. This is a very important term overall in understanding how this standard is supposed to work, under what circumstances, and in relation to who/what and why.

Stakeholder

An individual, group of people, organization or other class of entities or biological systems which possess interests standing to be affected through the actions and undertakings of a vendor or supplier. Stakeholders are not limited to anthropocentric entities or those possessing, expressing or encompassing human values or interests, but include


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natural systems, flora and fauna, eco-systems, etc.

US 780

294, 295 Technical Re-draft. It is necessary to either replace or define the terms “international norms of behavior.” One alternative would be “principles of responsible business conduct”, which could be defined with references to sources such as the UN Guiding Principles on Business and Human Rights, as well as the OECD Guidelines for Multilateral Enterprises. The “principle of respect for the rule of law” also requires additional clarification in order to avoid interpretations that could potentially conflict with other important principles highlighted in this standard (e.g., “human rights” and so-called “absolute rights”). Emphasizing respect for the “rule of law” does not define which laws necessarily must be respected – particularly when (again) those laws may conflict with each other (e.g., local versus national laws, national versus international laws), or conflict with other valued rights (again, “human rights”, “absolute rights”, etc.). Some local or national laws in the world are inherently unjust and, as a matter of principle in a sustainability standard, should possibly not be “respected” – e.g., Uganda’s anti-gay laws, Sharia law, “Jim Crow” and apartheid laws, abusive child labor laws, private use laws designed only to further an economic special interest and facilitate corruption, etc. This could be clarified by adding “consistent with principles of responsible business conduct” after “rule of

“Respect for international norms of behaviour: principles of responsible business conduct [see UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multilateral Enterprises]: an organization should respect international norms of behavior apply principles of responsible business conduct while adhering to the principle of respect for the rule of law consistent with principles of responsible business conduct.”


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law.”

AR 165


SE 166

296 ed Text should be formatted as bullet. Change format to bullet.

CL 167

296 4.2.2 Paragraph 2 ed There’s a bullet missing ��Respect for human rights:

FR 168

296 4.2.2 Ed Bullet missing Add a bullet before “respect for human rights …”

IT 169

296 4.2.2 te (Bullet needed)

NL 170

296 4.2.2 ed The last sentence is a principle and should therefore be a bullet as well

Change sentence into a bullet

US 781

296-297 Fundamentals

4.2.2 Ed Bullet missing Proofer should catch

FR 171

297 4.2.2 Te After line 297, add a paragraph about the equal treatment of the supplier.

Organizations should treat suppliers equally and without discrimination and should act in a transparent and proportionate manner. Obviously, competition should be open and the design of the procurement can’t be made with the intention of unduly favouring or disadvantaging certain suppliers. Accordingly organizations should base the award of


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contracts on the most economically advantageous tender. The most advantageous tender may include the best price-quality ratio, which should be assessed on the basis of multi-criteria, such as, among others, economic, life-cycle costing, risks, value creation, qualitative, environmental and/or social aspects etc, linked to the subject-matter of the contract in question.

CA 172

298 4.3 ge Should GoC adopt the Standard, we would be expected to support all five key business drivers of procurement sustainability (finance, risk management, organizational commitments and goals, responding to increasing stakeholder expectations, and attractiveness.

Overall - No change to the ISO Draft. Canada Defence Procurement Strategy may or may not need to be amended.

CO 173

298 4.3 Te The buyer does not prepare, adopt or apply any technical standard that does not apply to the functionality or prescribe any evaluation procedure with the purpose or effect benefit a single supplier, placing at a disadvantage to other suppliers.

NL 174

298-336 4.3 te Change numbering and start with organizational driver

Start with organizational driver

SN 175

299-301

Why procure

sustainably ed This sentence should be direct and precise to

accept sustainable procurement.

By practicing sustainable procurement an organization shall contribute to sustainable development. Organizations involved in Social Responsibility are committed to have a sustainable procurement process.

BR 176

299-302 4.3 TE Practising sustainable procurement is one of the ways an organization can contribute to sustainable development. Organizations involved in Social Responsibility should consider having a sustainable procurement process. It is a practice which can influence, among other things, the perception of its performance particularly in terms of image, of

Replace the text for:

Practising sustainable procurement is one of the ways an organization can contribute to sustainable development and, at the same time, to have a better performance of its operations in social, environmental and economic dimensions. Organizations involved


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competitive advantage and of its stakeholder relationships.

We should always consider that the organization goes to SP due to its commitments with CSR or SD. There are many organizations that "arrived" to SP from SD concerns and were not involved formally in CSR initiatives.

Besides, practising SP helps the organization to deliver sustainable outcomes and goes beyond just the perception about its performance.

in Social Responsibility should consider having a sustainable procurement process. It is a practice which can influence, among other things, its ability to achieve the desired outcomes, including the perception of its performance particularly in terms of image, of competitive advantage, operational efficiency and of its stakeholder relationships.

SN 177

299-302 4.3 ED Vague argument stating “one way” Practising sustainable procurement is a strong tool which an organization can use to contribute to sustainable development. Organizations committed to Social responsibility should hence implement a sustainable procurement process. An implemented sustainable procurement process may improve the organizations stakeholder relations, and hence strengthen its image and its competitive advantage accordingly.

DS 733 300

4.3 Te PC277 needs to discuss the use of shall or should. Although the standard is not for certification and “should” normally shall be used, other ISO standards e.g. ISO 14044 uses “shall” to make sure that the user gets the anticipated results of using the guidance.

CA 178

302 Annex I ed Some vocabulary (e.g. favor, discretionary, etc.) used in the draft document might be problematic as it could lead suppliers to think that there is now room for favoritism by the Government of Canada (GoC). On the other

302 - Replace competitive advantage with business positioning

438 - Replace favour their access to contacts with allow their […]


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side, if such vocabulary is not meant to be interpreted literally but rather in the spirit of the proposed approach, there might be no issue. Annex I of the present document provides examples of the vocabulary potentially problematic.

439 - Replace making its policy favour with making sure that its policy does not create barriers to

1029 - Leave reward as is

1033 - Replace reward with encourage

1111 - Replace shortlist with assess

1115 - Replace discretionary with optional

1117 - Leave ahead of as is

1165 - Replace rewarding with accounting

1167 - Replace qualitative judgments with a more informal approach

1222 - Leave customer of choice as is

INTECO 179

302 Change the order of the terms, and replace image by reputation.

… of competitive advantage, its stakeholder relationships and reputation. Furthermore it contributes to the promotion of human rights and the improvement in worker’s labor conditions.

INTECO 180

302 Change the order of the terms, and replace image by reputation.

… of competitive advantage, its stakeholder relationships and reputation.

IT 181

302 ge We suggest to rephrase: It is a practice which can influence, among other things, the perception of competitive advantage, of its stakeholder relationships and of its performance particularly in terms of image.

AR 182

303 te The phrase is not grammatically well constructed.

“Seeking sustainability should not be considered as optional and should be integrated in the procurement process.”


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SN 183

303 ED ….should integrate…. …should be fully integrated…..

BR 184

303 4.3 2 TE The quest for sustainability should be optional for organizations

Remove the part of the first sentence "should not be considered optional"

CL 185

303 4.3 Paragraph 2 ed Spelling error

Seeking sustainability should not be considered as optional and should integrate in the procurement process

Seeking sustainability should not be considered as optional and should integrate the procurement process

SE 186

303 4.3 2nd paragraph

ed Suggestion: Use the word ”but” instead of ”and”

Change text to: “…but should be..”

SN 187

303 Why

procure sustainable

ed Minor changes. Seeking sustainability should not be considered as optional and should be integrated in the procurement process.

US 782

303 4.3 2nd para Editorial Replace ‘integrate in’ with ‘be embedded into’

NL 188

303-333 4.3 GE Adjust 5 business drivers: including most used Cost Value Risk

4.3 Why Procure sustainably?

………………………

Seeking sustainability should not be considered as optional and should integrate in the procurement process. Beyond legal rules, there are many reasons for practicing sustainable procurements. They can be summarized by five key business drivers:

• Cost reduction: achieve operating


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economies by purchasing more efficient and/or better quality goods and services; Reduce costs economic cost of supply chain disruptions (e.g., product recall, financial penalties; minimize the cost of elimination of products at the end of their life; added income from recycling programs; be more demanding from the outset in terms of better quality products. Some products that at first might appear more expensive are, on more detailed analysis, cheaper over the whole life of the product.

• Value creation: an organization’s performance in terms of social responsibility and sustainability may have impacts for its image, its competitive advantages and its attractiveness for customers, employees and investors. Opportunities are; create new business based on shared value; develop the market’s capacities and strive for innovation and improved competitiveness; additional revenue through innovation with regard to eco-friendly products/service; added revenue from increased sales of green products/services; attract investors as well as new talents. Marketing may serve as vectors for incorporate sustainability into procurement.

• Risk management: CSR practices may influence brand value, market share, market cap, legal exposures, financial liabilities, moral/ethical exposures, (in) security of supply, price fluctuations and


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the risks associated with operating licenses, boycott from bad suppliers’ practices (e.g., child labour, local pollution, waste management)..

• Organizational ethics, commitments and goals: the commitments and goals of an organization’s policy are the expression of the business culture, values and ethics, sense of moral obligation in relation to business needs.

• Responding to increasing stakeholder expectations: organizations and their stakeholders are ever more conscious of the importance of taking due account of social responsibility and sustainability issues. Organizations are under increasing pressure to take account of environmental and social factors and deploy sustainable initiatives.

AR 189

304-305 te Ethical commitments are also extremely important.

Delete “s”: sustainable procurement.

As to avoid the use of business oriented language replace ” business drivers” by “organizational drivers”.

“Beyond ethical commitments and legal rules, there are many reasons for practising sustainable procurement. They can be summarized by five key organizational drivers:”

BR 304 - 4.3 TE The five 'business drivers' presented are not Replace ‘‘(...) there are many reasons for


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190

305 exhaustive and may restrict the understanding of the applicator that is based on other drivers, including those related to public procurement that are not well covered in this list.

practicing sustainable procurement. They can be summarized by five key business drivers’ for ‘‘(...) there are many reasons for practicing sustainable procurements, such as some drivers listed below:’

US 783

306 4.3 Bullet points Editorial “Increasing legal compliance’ appears to be a missing bullet point. Increasingly Governments are imposing regulations that obligate companies to operate more sustainably. e.g. Restrictions on waste to landfill, supplier diversity, carbon disclosure ect.

CO 191

306 4.3

Te La financing of purchasing is a matter for the buyer. The supplier shall ensure that he has the legal, technical, commercial and financial capacity to deliver the product within time, cost and agreed quality. The buyer shall define the payment schedule for ensuring proper handling commercial purchase.

NL 192

306 4.3 ed “Purchasing more efficient” should relate to life cycle cost efficiency.

Change into ”Purchasing according to life cycle cost efficiency”.

AR 193

306-333 te The order given to the bullets does not evidence the significance of each driver.

Rewrite in the following order: Organizational commitments and goals: Responding to increasing stakeholder expectations: Risk management: Financial drivers: Attractiveness:

BR 194

306 - 333

4.3 TE The public authority is not fully taken into consideration in 'business drivers' listed and the statement 'beyond the law' undermines the laws that already provide or require that governments have policies focused on sustainable procurement.

Add as a driver:

Transformative potential of procurements: like businesses, but supported by public policy, the government has a fundamental role not only in fostering an innovative and more sustainable market, but also on education, mobilization


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and awareness in general society. Public procurement is a key to advancing in building a sustainable economy.

NL 195

306-333 4.3 te Bullet list driver ‘value creation (shared value)’ is missing.

Add bullet: Value creation: as procurement joins with business development structured CSR analysis can lead to innovation, creating new products new markets that create value for both procurement, stakeholders and have a positive impact on society (shared value).

AR 196

307 te The term goods should be replaced. “ … and/or better quality products and services …’

BR 197

307 4.3 1st bullet TE Disposal its more generic and technical correct than "elimination"

Include 'proper disposal', replacing text for:

• Financial drivers: achieve operating economies by purchasing more efficient and/or better quality goods and services; minimise the cost of proper elimination disposal of products at the end of their life; be more demanding from the outset in terms of better quality products and improved competitiveness; ...

BR 198

309 4.3 GE Provide definitions for the terms “value chain” and “supply chain” in the topic 3 “Terms and definitions”.

Include:

value chain – chain of activities that an organization performs in order to deliver a valuable product or service;

supply chain – chain of suppliers encompassing the organization delivering the product or service to the customer and its low tier suppliers;


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SN 199

309 Why

procure sustainable

ed Minor changes. ...intervene throughout the value and the supply chain; ….

NL 200

310 4.3 ed Innovation should get more focus. Make “innovation” a separate (sixth) bullet.

US 784

311 Fundamentals

4.3` Ed Please avoid the word “cheap”. Has negative quality connotations in the US and North America in general

In this instance, “more cost effective” is appropriate and more accurate.

CO 201

312 4.3 Te The risk matrix should be based on the technical aspects in specific international standards that ensure their functionality, neither in terms of design nor descriptive characteristics.

CA 202

312 to 314, 339

4.3, 4.4.1 te Moral/ethical exposures include ‘reputational risk’ associated with suppliers that do not behave in an ethical and socially responsible way.

Replace with:

‘Risk management: treat the applicable categories of risk, namely legal exposures, financial liabilities, moral/ethical exposures, (in) security of supply, price fluctuations and the risks associated with operating licences and being seen to purchase from a supplier that does not behave in an ethical and socially responsible way.’

BR 203

312 and 316 - 317

4.3 2nd bullet TE Change "namely" for "including". That is not an exhaustive list.

Delete the last sentence, because is not a driver, or an explanation of a driver, is more a recommended operation.

Include 'including legal exposure', replacing text for:

• Risk management: treat the applicable categories of risk, namely including legal exposures, financial liabilities, moral/ethical exposures, (in) security of supply, price fluctuations brand and the risks associated


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with business continuity, loss of contracts and the risks associated with and operating licences. The organization also needs to engage in the mapping of its economic, legal, environmental and social threats and opportunities and develop policies for managing them. All significant sustainability impacts should be identified and addressed as part of any comprehensive risk management strategy.

SN 204

316-317 ED The last sentence has a different character than the first part of the bullet point.

Should be moved to another part of the document as it is operational in its character

CO 205

316-317 4.3 Te/ Ed

…All significant sustainability impacts should be identified and addressed as part of any comprehensive risk management strategy…

Align to international terms and call it “impacts”. Second part of the text must be first

BR 206

318 4.3 3rd bullet TE “Organizational commitments and goals: the commitments and goals …” – goals is a quantitative expression of objectives, as per the suggested added definition above (3.17)

Change “goals” to “objectives” (twice)

CO 207

318-321 4.3 Te …Organizational commitments and goals: the commitments and goals of an organization’s policy are the expression of the business culture, values and ethics in accordance with which the organization functions. That demonstrates the necessity for any procurement function to develop policies that are in harmony with the organization’s overall strategy. In other words, corporate commitments should be visible within the organization’s policy (being it formalized or not) and the operational deployment of it. This deployment should be reflected in its


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procurement practices (reduction of late payments, development of innovation etc.).

AR 208

319 te As to avoid the use of business oriented language replace ”business culture” by “organizational culture”.

“…are the expression of the organizational culture, values …”

BR 209

320 4.3 TE The precedent phrase doesn't demonstrate the need, but justifies it.

Replace 'demonstrate' for 'justifies the necessity for procurement function to… '

BR 210

324 4.3 TE reduction of late payments (it could go beyond this idea – we may not say that it is acceptable to have some late payments)

change to: fair commercial terms and conditions

PL 211

325 4.3 te Sustainable organization shall not only respond to stakeholder expectations but also create them. (example: some groups of consumers are not aware of or not interested in environmentally friendly components or raw material of the products their buy; example: some groups of consumers prefer more layers of product packaging)

Add “creating stakeholder expectations”

Responding to increasing stakeholder expectations and creating them…..:

.

FR 212

327 4.3 Te Some of ISO 26000 issues are major aims for some organizations and must be mentioned

Add, after “issues”, “such as environment, social issues …”

BR 213

327 – 328

4.3 4th bullet TE “Organizations are under increasing pressure to take account of environmental and social factors and deploy sustainable initiatives.”

The statement: “…to take account of environmental and social factors”, does not include economic factors

Change to:

Organizations are under increasing pressure to take account of environmental, economic and social factors and deploy sustainable initiatives, considering its limits of influence and co-responsibility throughout the supply


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chain.

CO 214

329 4.3 Te / Ed Attractiveness: marketing may serve as vectors for incorporate sustainability into procurement. An organization’s performance in terms of social responsibility and sustainability may have impacts for its image, its competitive advantages and its attractiveness for customers, employees and investors. Giving prominence to the deployment of sustainable procurement may thus boost sales and attract investors as well as new talents.

It is stange. It would be better to eliminate the underline phrase. The rest of the text is easy to unserstand and says the same.

IN 215

329 4.3 ed marketing may serve as vectors for incorporate sustainability

marketing may serve as vectors for incorporateing sustainability

AR 216

329-333 te The whole bullet attractiveness is written in business oriented language.

“Reputation: is an important asset of the organizations and can be defined as the sum of impressions held by organization's stakeholders. The key point in reputation is not what the organization insists through an image but what others perceive it to be.”

BR 217

332 – 333

4.3 TE One important driver is also innovation. The norm could address sustainable procurement also from the opportunity point of view, not only as a risk management approach.

Include in the last sentence: Giving prominence to the deployment of sustainable procurement may thus boost sales and attract investors as well as new talents, access to new markets and new business opportunities.

US 785

333 Fundamentals

4.3 Ed “…as well as new talents” is not grammatically correct

Use “talent”.

BR 218

334 - 336

4.3 ED This paragraph is not a conclusion about the drivers. Has no relation with the previous text.

Remove the text


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It should be deleted.

US 786

337 4.4 Editorial Replace ‘Integrating’ with ‘Embedding’

BR 219

337 4.4 ED Is better to use "organization" than "your" Integrating sustainability in the your organization’s procurement policy

IN 220

337 4.4 ed Integrating sustainability in your procurement policy

Integrating sustainability in your organizational procurement policy

BR 221

338 4.4.1 ED The paragraph starting in the line 359 is the fourth bullet?

Add the bullet.

CA 222

339 4.4.1 te From ISO 26000 Add:

Organizational governance is the system by which an organization makes and implements decisions in pursuit of its objectives.

CL 223

339 4.4.1 Paragraph 1 ed Spelling error

Governance is an essential driving force to sustainable procurement inasmuch as it enables…

Governance is an essential driving force to sustainable procurement in as much as it enables…

SN 224

339 4.4.1 ED The sentence from “inasmuch” is a repetition of content of social responsibility and hence redundant

Delete

BR 225

339 - 341

4.4.1 TE To be consistent with the title, we suggest inserting 3 paragraphs. The first one saying that many organizations have a sustainability policy or a CSR policy, being it formally stated or not.

That the existence of that policy turns natural

Many organizations have views and aims commitments about sustainable development or social responsibility. These constitute what can be called an organizational sustainability policy. This organizational sustainability policy usually is formalized in a document, which are


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to deploy it into sustainable procurement.

That the approach to sustainable procurement can be gradual.

Than we can talk about governance.

When talk about Governance, SP should be embedded in it. That's seems more proper than saying that Governance is an essential driving force. What is intend to say is that since governance enables the organization to assume its responsibilities, than, as a logical consequence, SP should be embedded in it.

Sustainability was added since the motivation for an organization to implement SP is not only due to CSR concerns.

a declaration of intent and a direction of an organization expressed by its top management. In some cases that policy is not formalized, which is more commonly the case in SMEs. In a way or another, this policy states the views, intentions and commitments of the organization regarding sustainability or SR.

Being consistent with the organization’s sustainability policy leads naturally to the integration of sustainability in the organization’s procurement practices. This can be done consistently by means of the establishment of a sustainable procurement policy, which can gradually evolve to embrace all the procurement activities of the organization.

It can be useful to consider the implementation of sustainable procurement gradually, starting from a restrict number of products and services to an evolving increasing number of items. This graduality can also consider a maturity approach to widespread the initiative through all the organization.

To implement SP effectively, it should be it should be embedded in the organization’s Governance

Is an essential driving force to sustainable procurement in as much as it enables the organization to assume responsibility for the impacts of its decisions and activities and takes account of social responsibility and sustainability both internally and in terms of its relationships.

To integrate sustainability in the procurement


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policy the organization should consider:

• Establish Policy formation for a sustainable procurement policy, which should be interrelated to the organization’s global strategy, policy and objectives and integrate criteria of social responsibility and sustainability issues.

NOTE In many cases, particularly for SMEs, it is possible that the organization’s global strategy, policy and objectives exist, but are not formally documented.

• to integrate and deploy sustainable procurement, establishing The strategic integration and deployment of sustainable procurement, whose objectives should that reflect the concept of cost-effectiveness, i.e. the evaluation of overall performance including the costs and revenues generated as well as the attainment of social, societal and environmental goals. The These objectives should equally enable the implementation of mutually beneficial relationships between the organization and its stakeholders both within (the other functions of the organization) and outside (suppliers, government etc.).

• Carry out the The operational deployment of sustainable procurement, commencing with the implementation of a strategy and an action plan. Reporting will be required to monitor overall activity, analyze


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variances against the defined objectives and should strive for continuous improvement in sustainable procurement policy functioning. The strategy and the action plan should apply throughout the supply chain and encompass both

• Responsible communication: establish appropriate ways to because the organization should share its commitments, progress and results related to sustainable procurement, aiming. The purpose is to inform its stakeholders as to the extent of application of it sustainable procurement, engage in dialogue and facilitate the operational implementation of the programme in conjunction with suppliers by providing them with guidance

CA 226

340 The document keeps referring to both sustainable procurement and social responsibility, sometimes arbitrarily. This is confusing. Section 4.4.2 (p.6) is a good example.

340-341 - Remove and takes into account […] relationships and replace with on the organisation, society and economy, and environment.

DS 734 342 4.4.1 Te

Are there 3 or 4 issues

CO 227

343-345 4.4.1 Te If each issue is going to be addressed more specificaly later just mention each issue and then develop it under each title. it makes more sense and is easier to read.

AR 228

346 te As the scope of the standard refers to all types of organizations, the note should not only refer to SMEs.

“NOTE In many cases, particularly for SMOs, it …”


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SN 229

346 ED Note should be removed to the end of the paragraph

NL 230

346

4.4.1 te Throughout the document, many concessions are made for SME’s. In this case, also a small organization can professionalize its sustainable procurement, and it’s not much effort to simply write down a brief strategy, policy and some objectives in no more than half an A4 paper.

Delete the SME comment, or explain that such formalisation can be very brief for an SME.

AR 231

347 te Add a note explaining SMOs. Note: Small and medium-sized organizations are organizations whose number of employees or size of financial activities fall below certain limits. The size thresholds vary from country to country. For the purpose of this International Standard, SMOs include those very small organizations referred to as “micro” organizations.

INTECO 232

355 te It mentions the need to develop a strategy, but in line 563 it mentions “an action plan”.

Decide which term would be used. does strategy mean a broader concept that includes the action plan, as wells the policy?

AR 233


IT 234

359 4.1.1 te Not clear the link of the sentence with the rest of the chapter


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CL 235

359 4.4.1 Paragraph 3 ed There’s a bullet missing ��Responsible communication;

CO 236

359 4.4.1 Ed It should be used the definitions established in OCDE

FR 237

359 4.4.1 The way to conduct economic analysis on supply has to lead to good purchasing decision at each step of the process. Refer here shortly to “global cost and value creation method” and describe it later in governance sub chapter with more detail

Add :

• Economic analysis at each step of the process, referring to global cost and value creation method. What is “global cost and value creation method (source: ObsAR, France, august 2014):

FR 238

359 4.4.1 Ed This should be a 5th bullet Add a bullet before “responsible communication”

SN 239

359-362 ED The text should a separate bullet point where governance of communication is the message.

Arrange in separate bullet point.

AR 240

364 te ISO 26000:2010 states (3.3.5):

Although many people use the terms social

“An organization usually has views and aims about social responsibility. “


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responsibility and sustainable development

interchangeably, and there is a close relationship between the two, they are different concepts.

…

Social responsibility has the organization as its focus and concerns an organization's responsibilities to society and the environment. Social responsibility is closely linked to sustainable development. Because sustainable development is about the economic, social and environmental goals common to all people, it can be used as a way of summing up the broader expectations of society that need to be taken into account by organizations seeking to act responsibly. Therefore, an overarching objective of an organization's social responsibility should be to contribute to sustainable development.

The principles, practices and core subjects described in the following clauses of this International Standard form the basis for an organization's practical implementation of social responsibility and its contribution to sustainable development. The decisions and activities of a socially responsible organization can make a meaningful contribution to sustainable development.


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BR 241

364 4.4.2 TE Social responsibility it’s not the same of sustainability, Sustainability includes social responsibility, but the opposite it’s not true. Thought the standard, several terminologies are used: social responsibility and sustainability issues, sustainability or SR, social responsibility or sustainable development issues. The standard provides guidance on integrating sustainability in the procurement process, so we suggest replacing the terms “social responsibility”, “sustainability or SR”, “social responsibility or sustainable development issues “with “sustainability” throughout the standard.

An organization usually has views and aims about sustainability sustainable development or social responsibility.

CL 242

364 4.4.2 Paragraph 1 ed There are duplicate words In a way or another, this policy this policy states the views, intentions and commitments of the organization regarding sustainability or SR

In a way or another, this policy states the views, intentions and commitments of the organization regarding sustainability or SR

BR 243

364 - 369

4.4.2 TE/ED Move to the beginning to the clause.

The text 'this policy' is repeated.

Remove the text.

In a way or another, this policy this policy states the views, intentions and organization’s commitments regarding sustainability or SR.

SN 244

364-376 4.4.2 ED The text is no sufficiently precise to provide real guidance, and is somewhat a repetition of other general statements. Redundant and should be deleted.

Delete.

CA 245

365 4.4.2, 4.4.4 ed The expression organizational sustainability policy is somewhat overused in that the concept that that is referred to seems to vary. The first paragraph of Section 4.4.2 (p.6) makes it similar to a vision while the 3rd and 4th paragraphs rather refer to a written policy document expected to guide procedures. The

365 – Replace policy with vision

380-381 – Replace should be reflected […] policies with should be consistent with other policy instruments relating to procurement and to sustainability.

391-409 – No change.


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last paragraph and bullets on page 7 also seem to refer to a formal policy document, as well as Section 4.4.4 (p.10).


NL 246

367

4.4.2 te Throughout the document, many concessions are made for SME’s. In this case, also a small organisation can professionalise its sustainable procurement, and it’s not much effort to simply write down a brief policy in no more than half an A4 paper.

Delete the SME comment, or explain that such formalisation can be very brief for an SME.

AR 247

368 te Comment on SMEs should be taken into account (lines 346).

“… which is more commonly the case in SMOs.”

AR 248

368 ed “this policy” is repeated. Delete “this policy” once

SE 249

368 ed Text repeated. Delete one occurrence of “this policy”.

CO 250

368 4.4.1 Ed … this policy this policy states the … Eliminate the repeated term

FR 251

368 4.4.2 Ed Twice ‘this policy’ Delete ‘this policy’

IN 252

368 4.4.2 ed this policy To be deleted (repetition)

IT 253

368 4.4.2 ed Repetition (“this policy”)


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CO 254

368-369 4.4.2 Te … this policy states the views, intentions and commitments of the organization regarding sustainability or SR.

This was already stated it points 346 and 347. no need to repeat.

CL 255

370 4.4.2 Paragraph 2 te This paragraph does not add any important information to this section, it is unnecessary.

Delete

AR 256

372-373 te Comment on the relationship between social responsibility and sustainable development should be taken into account (line 364).

“…make their first approach to social responsibility issues …”

US 787

372-375 Fundamentals

4.4.2 (second para)

Ed The precise meaning of these two sentences is unclear to me.

Need to clarify.

IT 257

372-376 4.4.2 te Probably not 100% necessary….

CA 258

373 4.4.2 ge There is some lack of clarity re the concept of sustainable procurement being about the what and/or the how of procurement. For example, Section 4.4.2 (p.6) reminds that “some organizations make their first approach [...] starting with a concern on what they purchase while the document as a whole seems to rather address how to procure sustainably.

373 – No change.

BR 259

377 - 379

4.4.2 ED After the two previous paragraphs this one seems repeated

If the idea is to reinforce the message, so the text should be replaced.

Replace the text

Remove The expression of how to deal with those responsibilities can be the establishment of a sustainability policy.


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The first step in sustainable procurement is an organization establishing a sustainable procurement policy, which should clearly set the intentions and goals the organization is striving to achieve through its procurement.

Hence, a first step to an organization which aims to implement sustainable procurement should be establishing a sustainable procurement policy, setting the intentions and goals to achieve through its procurement process.

CO 260

377-379 4.4.2 Te Eliminate this paragraph Already explained aboved. no need to repeat.

SN 261

380 Alignment of

org…. ed

We should avoid to use this standard as an guidance.

…. It should provide clear frame of requirement to all stakeholders and should be reflected ….

CO 262

380-382 4.4.2 Te Perhaps to make things clearer and shorter this could be stated right after point 345. easier to just explain that policy is important and briefly describe why and how to address the issue.

AR 263

381-382 te Comment on the relationship between social responsibility and sustainable development should be taken into account (line 364).

“This helps ensure that social responsibility issues are fully aligned and incorporated throughout all levels of the organization.”

SN 264

381-382 4.4.2 ED Sentence is redundant and should be deleted Delete

AR 383-384 te Comment on the relationship between social responsibility and sustainable development

“The sustainable procurement policy should be clearly aligned to the wider organizational


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265

should be taken into account (line 364). policy or strategy for social responsibility,”

CO 266

383-390 4.4.2 Te Eliminate: …” Therefore, sustainable procurement can be a natural part of the organization’s procurement policy and overall strategy, helping set out a clear orientation of making it a component of the organization’s overall policy.”

Quite repetitive. would eliminate and, again, address the issue of policy after line 345.

US 788

385 4.4.2 5th para Editorial Replace ‘does not have’ with ‘It should not’

BR 267

388 4.4.2 TE "Organizational ethos" is not a term widely comprehensible by all the organizations.

Replace the tern by its meaning or include the definition of "organizational ethos" in the terms and definitions clause. We suggest to use the term “culture”

BR 268

391 4.4.2 TE Include some guidance on what the SP Policy should address.

Insert the text for:

Top management should establish a sustainable procurement policy that

— is appropriate to the purpose of the organization

— provides a framework for setting sustainable procurement objectives, and

— includes a commitment to satisfy applicable requirements.

NL 269

391-400 4.4.2 GE Define its policy clearly and precisely • An elaboration with regards to clear qualitative and quantitative objectives and policy choices (commitments).

., Establish the commitment at board level (procurement manager or director). Also appoint the tasks, responsibilities and


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authority;

SN 270

392

Alignment of org….

ed The recommendation should also include the benefit for the organization.

Reflect its own values and display its sense of commitment to sustainable development that are compatible with the organization mission, vision and or objectives.

BR 271

393 4.4.2 ED Put the three pillars as the second bullet. Include the text, reordering:

• Take into account the three pillars of sustainable development: economic, social and environmental considerations.

BR 272

393 - 394

4.4.2 TE To clarify what kind of risks and opportunities we are talking about.

Include 'on sustainability issues', in the text for:

• Assess the applicable risks and opportunities on sustainability issues in terms of its activities and therefore, of its products and services

AR 273

399-401 te The three pillars of sustainable development should be taken into account when designing policy, not at the time of its implementation.

“When establishing the sustainable procurement policy, the three pillars of sustainable development: economic, social and environmental considerations and the seven core subjects found in ISO 26000:2010 should be considered.”

SN 274

401 onwards

Highlight the importance of monitoring beyond 1st tier, also 2nd tier suppliers

…it is important with proper monitoring beyond 1st tier, also 2nd tier suppliers

NL 275

401-442 Incl Figure 1 GE Double, too much One figure include the text 412-440 ‘with take into account..

NL 276

402 4.4.2 ed The structure of the ISO 26000 should be followed.

Change “considered” into “used”.


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FR 277

407 4.4.2 ed “Fair operating principles” is replaced line 425 by “fair business principles”. It should be the same terminology in both sentences.

Replace “operating” by “business”.

BR 278

410 4.4.2 Figure 1 GE ISO 26000’s core subjects are already in evidence in the text, and the “holistic approach” is part of ISO 26000, not ISO 18617. In order to keep the focus I would withdraw Figure 1.

Withdraw Figure 1

US 789

410 Fundamentals

Figure 1 Ed Graphic quality should be improved

CO 279

410 4.4.2 Figure 1 Te Eliminate Figure 1 If it is established in ISO 26000, the graph seems unnecesary.

AR 280

412-413 te Consideration of ISO 26000:2010 should be strengthened.

“When considering the ISO 26000:2010’s core subjects to establish the sustainable procurement policy, it should be useful to take into account : “

BR 281

412 - 442

4.4.2 TE Clear reference for ISO 26000 as the source on core subjects.

We should avoid to replicate ISO 26000 text here.

The text is confusing looking to the content of the SP policy, as described previously and enters into much detail.

The reference to ISO 26000's core subjects is enough.

Replace all the text with :

ISO 26000 gives guidance about the core subjects.

When considering the ISO 26000’s core subjects to establish the sustainable procurement policy, it may be useful to take into account the following:

· Human rights: the sustainable procurement policy should incorporate respect for human rights, the promotion of absolute rights and the control of risks to human rights. According to this, risks to human rights are prevented mainly by integrating human rights


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in the organization’s general policy. To this end, it is advisable that the organization joins proactive initiatives to promote human rights;

· Labour practices: the sustainable procurement policy should ensure satisfactory working conditions and social protection. Then, their procurement policy should establish or conserve balanced relations between the supplier and its employees, and should include at least the recommendations of the ILO; Environment: the sustainable procurement policy of the organization should promote the sustainable use of resources, prevent pollution, mitigate climate change and adapt to it, protect the environment and restore natural habitats;

· Fair business practices: the sustainable procurement policy should promote the establishment of balanced business relations, especially on the price of the purchased products or services, on terms of payment for the supplier and on an implementation of a balanced and stable contractual relationship. It should promote also an equitable distribution of the costs and benefits of the implementation of Social Responsibility and environmental issues and reduce the customer-supplier dependency. Finally, it is recommended to respect the supplier’s property rights and to prevent, detect and correct risks of corruption;

· Consumer issues: in order to take into


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account consumer’s rights, the sustainable procurement policy should promote the protection of consumer health and safety, promote sustainable consumption and deliver consumer service, support or complaint and dispute resolution. It is also recommended to promote fair operating practices in terms of sales and marketing, information and contracts;

· Community involvement and local development: it is recommended to systematically assess the offer from local suppliers and favour their access to contacts. The organization should also consider making its policy favour local offer results, as it could have beneficial effects on the local social fabric and ecosystem. These criteria should be considered throughout the procurement process from top management to buyers and their main impacts on the relevant stakeholders should be assessed and taken into consideration.

PL 282

413 4.4.2 8th para te * Societal issues: the sustainable procurement should promote goods and services delivered by vulnerable groups, such as cooperatives of elderly and disabled people, ethnic minorities, homeless or long-term unemployed, in order to support their social inclusion

Add “Societal issues”

AR 283

413-414 te ISO 26000:2010’s core subject Organizational governance should be taken into account.

“Organizational governance: sustainable procurement should be inserted in the organizational governance structure, within which principles of social responsibility and


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respect for interested parties should be incorporated in the decision-making processes.”

AR 284

413-414 te ISO 26000:2010’s core subject Organizational governance should be referenced.

“Full information: ISO 26000:2010 sub-clause 6.2”.

CL 285

414 4.4.2 Paragraph 8 – 1st point

te This paragraph talks about human rights. I think it should consider including topics about the Ruggie Framework.

Add NOTE NOTE Esta mirada se complementa con los principios rectores de derechos humanos de ONU

AR 286

414-417 te Comment on absolute rights should be taken into account (line 148).

ISO 26000:2010 states: An organization should:

⎯ respect and, where possible, promote the rights set out in the International Bill of Human Rights.

“According to this, an organization should respect and, where possible, promote the rights set out in the International Bill of Human Rights.”

CA 287

414 - 417 4.4.2 te Focus should be on promoting or encouraging suppliers over which the organization has influence, to be ethical and socially responsible

Replace with:

Human rights: the sustainable procurement policy should incorporate respect for human rights, the promotion of absolute rights and the control of risks to human rights.

To respect human rights, organizations have a responsibility to exercise due diligence to identify, prevent and address actual or potential human rights impacts resulting from the


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activities of their suppliers over which they have influence and who may be the cause of human rights violations in which the organization may be implicated.

CO 288

414-417 4.4.2 Te Alternate drafting: the sustainable procurement policy should incorporate respect for human rights through the integration of HR's to the organization's general policy.

In the interest of making things easier and faster to read when mentioning each point briefly develop it.

AR 289

414-442 te When referencing the importance of the core subjects of social responsibility according to ISO 26000:2010, it is important to respect the wording of that standard, since it is consistent as a whole in the framework of the holistic agreed view of SR.

In this regard, especially in the wording proposed for core subjects "Fair operating practices", "Consumer issues" and “Community involvement and development” the proposed text deviates from ISO 26000:2010’s original text, situation that can generate confusion in partial interpretation and do not reflect the guidance given in ISO 26000:2010.

US 790

415 Technical See previous comment. Defining certain rights as “absolute” risks qualifying other rights.

AR 290

417 te Joining proactive initiatives to promote human rights does not fall within the domain of the procurement processes.

Delete: To this end, it is advisable that the organization joins proactive initiatives to promote human rights;


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AR 291

417-418 te ISO 26000:2010’s core subject Human rights should be referenced.


CL 292

418 4.4.2 Paragraph 8 – 2nd point

te This paragraph talks about labour practices but does not consider the importance of replicating these practices to the rest of the organization or the suppliers, contractors and distributors.

Labour practices: the sustainable procurement policy should ensure satisfactory working conditions and social protection. Then, their procurement policy should establish or conserve balanced relations between the supplier and its employees, and should include at least the recommendations of the ILO;

Labour practices: the sustainable procurement policy should ensure satisfactory working conditions and social protection. The procurement policy should establish or conserve balanced relations between the supplier, contractors and distributors and its employees, and should include at least the recommendations of the ILO;

US 791

418 – 421

Technical If the intent is to define “satisfactory working conditions and social protection” as recommended by the ILO, then include ILO reference in the first sentence. If the ILO does not define these terms specifically or completely, then it should be clarified exactly what is meant by “satisfactory” in relation to working conditions, and “protection” in relation to social. If there is a legal explanation of these terms in whichever country or locality this standard is being applied, then reference should be made here to “all applicable laws defining or mandating working conditions and social protections.” Thus, an employer’s sustainable procurement ‘policy’ (consider substituting ‘practice’) should “ensure

Include ILO reference


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adherence to all applicable legal requirements and international standards …”

CA 293

418 – 421

4.4.2 te Replace with:

Labour practices: the sustainable procurement policy should encourage satisfactory working conditions and social protection for their supplier’s workers based on recommendations of the ILO;

AR 294

420 te The supplier employees are not the only persons to be considered.

ISO 26000:2010 states (6.4.1.1): “The labour practices of an organization encompass all policies and practices relating to work performed within, by or on behalf of the organization, including subcontracted work. Labour practices extend beyond the relationship of an organization with its direct employees or the responsibilities that an organization has at a workplace that it owns or directly controls.”

“…between the supplier and its direct and indirect workers, and …“

AR 295

420-421 te Not all the recommendations of the ILO should be included.

“… should include at least the fundamental rights at work identified by ILO:

⎯ freedom of association and effective recognition of the right to collective bargaining;

⎯ the elimination of all forms of forced or compulsory labour;


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⎯ the effective abolition of child labour; and

⎯ the elimination of discrimination regarding employment and occupation.

INTECO 296

420-421 The “recomendations” concept is not clear Change “recommendations” for “ILO Declaration on Fundamental Rights at Work”

AR 297

421-422 te ISO 26000:2010’s core subject Labour practices should be referenced.


CA 298

422 – 424


Environment: the sustainable procurement policy of the organization should promote in its suppliers the sustainable use of resources, prevention of pollution, mitigation of greenhouse gases and adaptation to climate change, protection of the environment and restoration of natural habitats;

AR 299

424-425 ISO 26000:2010’s core subject The environment should be referenced.


AR 300

425 te “Fair business practices” should be replaced because that’s not the name given to the core subject in ISO 26000:2010.

“Fair operating practices”

CO 425 Te The agreed payment schedule between the


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301

buyer and the supplier must ensure the economic balance to the parties.

SA 302

425 4.4.2 Fair Business practices ought to include paying fair amount of taxes

Provide additional comment in text that a company should pay its fair share of taxes i.e. not avoid tax

AR 303

425-431 te As ISO 26000:2010 should not be reinterpreted,

”It should promote also an equitable distribution of the costs and benefits of the implementation of Social Responsibility and environmental issues and reduce the customer-supplier dependency.” should be deleted.

“Fair business practices: the sustainable procurement policy should promote the establishment of balanced business relations, especially on the price of the purchased products or services, on terms of payment for the supplier and on respect for established contractual terms.

It should stimulate procurement of socially responsible products and services, as a way to influence its value chain towards responsible practices without replacing the natural role of the state in this area. Finally, it should ensure respect for supplier’s property rights and prevent, detect and correct risks of corruption;

US 792

425 – 431

Technical Regarding fair business practices – recommend striking this paragraph for the reason that the subject involving a company’s contractual and performance relationship with its supplier (including price of products/services, payment, etc.) have little connection with the subject of “sustainability” which involves the effects (environmental, social, economic) on involuntary (i.e., non-contractual/non-financially interested) stakeholders. Topics involving how a

Remove fair business practices paragraph


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company conducts business with other companies at arms length are fully and completely covered under the applicable law of contracts with resort to jurisdictional courts of law, as well as the established principles of the free market. Numerous other standards exist to rate or certify the business performance of companies which are routinely used by investors and other market-oriented entities who do not rightly qualify as “stakeholders” the interests of whom this standard purports to address.

SE 304

426 4.4.2 te The guidelines given to the user of the standard in this section is not clear.

Clarify how the organisation should promote the business relations in relation to the price.

FR 305

430 to 431

4.4.2 te "Finally, it is recommended to respect the supplier's property rights and to prevent, detect and correct risks of corruption." is a poor way to cover the corruption issue .

Modify the sentence as follows: "Finally, it is recommended to respect the supplier's property rights and implement actions organizationwide to avoid any risk of corruption." ?

DS 735 431

4.4.2 Public procurement is typically framed by legislation.

Add: respect of national and international regulations on public procurement

AR 306

431-432 te ISO 26000:2010’s core subject Fair operating practices should be referenced.


AR 307

432-436 te ISO 26000:2010 should not be reinterpreted. “Consumer issues: in order to take into account consumer’s rights, the sustainable procurement policy should promote the


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protection of consumer health and safety, promote sustainable and responsible consumption of the product /s or service/s supplied and respect fair marketing and sales practices. It should also provide the consumer a fair complaint resolution system.

NOTE: According to the approach given in ISO 26000:2010 / 6.7.1.1, within the framework of the core subject consumer issues, the term consumer could be applicable to customers procuring product/s or service/s for commercial purposes.”

CA 308

432 – 436

te This clause is related to the organizations policy related to its relationship with its consumers. It should be left in if it can be changed to reflect the relationship between the supplier and the consumer such as how a supplier could influence sustainable consumption of the organizations consumers.

Remove:

Consumer issues: in order to take into account consumer’s rights, the sustainable procurement policy should promote the protection of consumer health and safety, promote sustainable consumption and deliver consumer service, support or complaint and dispute resolution. It is also recommended to promote fair operating practices in terms of sales and marketing, information and contracts;

SG 309

434 4.4.2, page 9

GE The draft ISO on Sustainable Purchasing should not be inconsistent with the international obligations taken on by the respective signatories.

AR 436-437 te ISO 26000:2010’s core subject Consumer “Full information: ISO 26000:2010 sub-clause


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310

issues should be referenced. 6.7”.

AR 311

437 te “Community involvement and local development” should be replaced because that’s not the name given in ISO 26000:2010 to that core subject.

“Community involvement and development”

CA 312

437 ge Could also include fair trade, same sourcing, diversity or minority sourcing, social enterprise sourcing

Add “as well as fair trade, same sourcing, diversity or minority sourcing, social enterprise sourcing”

AR 313

437-440 te As ISO 26000:2010 should not be reinterpreted, “The organization should also consider making its policy favour local offer results, as it could have beneficial effects on the local social fabric and ecosystem.” should be deleted.

“Community involvement and development: it is recommended to systematically assess the offer from local suppliers and favour their access to contacts. The organization should also seek to reduce the possibility of negative impacts on health or the environment of the product/s or service/s delivered to the community.

CA 314

437 – 440


Community involvement and local development: The procurement policy should include a requirement to systematically identify assess and consider giving preference to local suppliers of products and services and contributing to local supplier development where possible as well as undertaking initiatives to strengthen the ability of and opportunities for locally based suppliers to


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contribute to value chains, giving special attention to disadvantaged groups within the community;

SA 315

437-440 4.4.2 te Concept of favouring local suppliers - Government procurement at Commonwealth level expressly does not permit favouring of local suppliers as contrary to FTA etc.

Add in words to indicate that these options should only be pursued if they are permitted by local law.

Also use ‘encouraging’ instead of ‘favouring’ and rewrite the paragraph in the way ‘to create conditions for the local suppliers to compete successfully’.

FR 316

438 4.4.2 Te It’s impossible to promote local development in public procurement. This practice is prohibited in international agreement (WTO).

Delete “local”.

FR 317

438 4.4.2 Te It’s impossible to promote local development in public procurement. This practice is prohibited in international agreement (WTO).

Replace “favour …” with “take into account”

IT 318

438 4.4.2 ed Contacts or contracts?

US 793

438 Fundamentals

4.4.2 Ed Use of the word “favour” could be problematic.

Suggest rewriting to; “…it is recommended to systematically assess the offer from local suppliers and increase their access to contacts.”

AR 319

440-441 te ISO 26000”2010’s core subject Community involvement and development should be referenced.



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CA 320

441 ge The document suggests that all seven core subjects found in ISO 26000 (Social Responsibility Standard) be considered when establishing the sustainable procurement policy. Although considered may not mean that suppliers would need to abide by every element, one may wonder if some suppliers and even some countries would be excluded from doing business with GoC.

441-442 Replace with: While striving to support these core elements, organizations should consider the impact on the market, especially in areas where it may be limited to very few to one supplier only. A buying organization would not want its policy to be restrictive to the point where some key/necessary suppliers or even countries would be excluded from the procurement chain.

SE 321

443 4.4.3 This section must also mention the importance of seeking transformative solutions in purchasing and procurement.

“Transformative solutions are defined as solutions that use global and equitable sustainability as the reference. Based on this perspective the criteria for such solutions are in most cases at least 80% reduction of natural resources and/or GHG reductions in relation to how a function/service is provided conventionally in today’s society. This kind of improvement is what is needed in order to support poverty alleviation and allow nine billion people to use functions/services within the carrying capacity of the planet. Transformative solutions often provide a function/service in a totally new way compared with the conventional way of providing the function/service.”

Three examples of transformative solutions:

“1. Technology solutions such as video meetings instead of air travel to meetings,

Add text in new bullet: “Procurement should seek transformative solutions to fulfil needs prior to solutions that achieve incremental or gradual improvements”

A definition of Transformative solution should be added in Chapter 3, taking into account both environmental and social aspects.


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teleworking instead of commuting with a car, e-books instead of paper books.

2. Integrated solutions such as smart e-health, education and e-governance where new technology solutions are implemented together with new ways of organizing the way the services are provided.

3. System solutions that turn earlier problems into opportunities such as buildings that are net producers of renewable energy instead of using large amounts of electricity, or mobility solutions such as carpools, public transport and telework that include storage of intermittent renewable energy.”

Thus, Transformative solutions can be in form of technical or social innovations but might just as well be in form of organizational changes or other routines or better defined needs making other kind of solutions, and transformative ones, possible to achieve.

Citation from: http://www.pamlin.net/new/wp-content/uploads/Public-procurement-and-transformative-solutions-1300409-s.pdf

SN 322

443 4.4.3 ED The text in the bullet points should be more focused and redundant text should be deleted.

Example; first and second bullet point:

• Sustainability objectives

• Impacts of importance to the procurer and goals relevant for the supply chain


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CA 323

443 and 585

4.4.3. 5.2 ge Among key considerations (4.4.3, p.9) is the fact “one size does not fit all” and that “high priority issues should be addressed first”. The reader will not understand what is actually meant until having read about priority mapping (Section 5.2) and learned that the more significant issues (e.g. categories of supply less supportive of social responsibility) would call for an action plan.

455 - Add the following at the end: Section 5.2 introduces an approach to setting priorities and developing action plans.

BR 324

444 - 445

4.4.3 TE The bullets were SP principles. These key considerations are not only applicable to the SP policy and strategy, but to SP as a whole.

Replace text for:

The following key considerations should be taken into account when developing implementing a sustainable procurement policy and strategy

US 794

444 & 446

Editorial Add the word “more” as a modifier of the word “sustainable” to read: “more sustainable”. Complete this edit throughout the text of the entire standard, as applicable.

AR 325

445 te The term strategy is not defined and never used before. Delete strategy.

“… sustainable procurement policy:”

INTECO 326

445 Same as line 355

AR 327

447 te The use of business oriented language should be avoided.

“… delivering organizational objectives …”


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IN 328

449 4.4.3 te through strategic procurement techniques through strategic procurement policy /techniques

INTECO 329

450 ed Change the order of the sentence, the adjective comes before the noun, i.e.: Focus on impacts material to the procurer by Focus on material impacts to the procurer.

Focus on material impacts to the procurer:

BR 330

450 4.4.3 2nd bullet ED Term “procurer” is used Use “organization” , to avoid the introduction of an additional term

AR 331

456-460 te Paragraph is unclear.

Does it refers to process or to product?

Seems contradictory to the spirit of the standard.

Rewrite the paragraph

FR 332

456 to 460

4.4.3 te "The sustainablility practices of the supplier in their own organization should be a secondary consideration" is not acceptable. Sustainable procurement implies influence on stakeholders in order to promote human rights, loyalty, environment practices and so on. This may imply better management of the organization of the supplier.

Delete this sentence.

SA 333

456-460 4.4.3 te Our Committee does not agree that the sustainability practices of the supplier in their own organisation should be a secondary consideration unless this represents a risk to the purchasing organisation.

In our opinion, the behaviour of the supplier ALWAYS represents a risk to the purchasing organisation. This is especially important to

It should be clearly stated that both the sustainability of goods and services AND the sustainability practices of the supplier in their own organisation are of importance.


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Government purchasing organisations as there can be major reputational damage if it is revealed that goods and services have been purchased from a company with a poor sustainability or social responsibility record.

INTECO 334

458 te The sentence “The sustainability practices of the supplier in their own organization should be a secondary consideration....” should be rephrased, since it goes against life cycle thinking (and it´s up to each organization to define its scope when defining their sustainability objectives).

The sustainability practices of the supplier in their own organization should be considered as it might represent a risk to the purchasing organization (e.g. labour standards).

CA 335

459 te Don't agree that sustainability practices of the supplier should be a secondary consideration.

Remove the word “secondary”

AR 336

460 te Labour standards can never be a risk. “(e.g. not compliance with labour standards)”

IT 337

461 4.4.3 te The title/concept of “manage demand” is probably not crystal clear. We think we should refer to “effectiveness” or similar concept

AR 338

461-462 te Paragraph is unclear.

Manage demand should not be included as a key consideration for sustainable procurement.

Manage demand is under the purview of public policy.

If the intention is to include fair trade this should be clearly said.

Delete bullet


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BR 339

461 - 462

TE Manage demand: the most sustainable way to procure is not to buy at all or to keep demand to a minimum by operating the business more efficiently.

Change to

Management demand: operating the business more efficiently, buying only what is actually needed (considering other options as rental, for example). It also means: review of the buying demands and decide to buy in a way to ensure the operation of the business more efficiently.

SA 340

461-462 4.4.3 te Align with 922-923 and reword the text: ‘When analysing the need, think about what sustainable alternatives deliver the same outcome in a better way.

AR 341

465 te The bullet does not only refer to Tier 1.

Replace Tier 1 by Supply chain.

“Supply chain: the overall supply …”

IT 342

465-475 4.4.3 ge “the stated principle of “Tier one is not the only one” is not properly deployed in the standard. The standard does not provide any help for implementation of the principle”

AR 343

466 te Labour standards can never be a risk. “(e.g. not compliance with labour standards)”

AR 344

466 te Comment on SMEs should be taken into account (lines 346).

Replace SMEs by SMOs

AR 345

468 te The term goods should be replaced. “ … to more sustainable products, works … ’


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SE 346

468 4.4.3 te Universal design should be a part of the list. Add “and universally designed” after “sustainable”.

SN 347

468

Key consid…

ed

A new bullet should be included after line 477 to adapt sustainable procurement to new knowledge and constant changes in the society and environment.

Encourage innovation and adapt to changes in the society, environment and climate: the process should encourage innovation related to more sustainable goods, works and services, through effective market research and use of outcome specifications.

BR 348

474 4.4.3 10th bullet ED “minority business” is not clear Delete

CA 349

476 te Don’t agree that these issues can only be considered if legally required. It sounds like legal issues can choose to cause harm.

Remove “unless there is a legal obligation to do so”.

INTECO 350

476 and 477

We propose to include policies that come of any type of organization. The positive discrimination can come not only from legal obligations.

However, this needs to be set in the context of full and fair opportunity and not positive discrimination unless there is a legal obligation or mandatory policy to do so.

FR 351

477 4.4.3 Te Need for effective bridges (effective connection objective with organizations such as the 0ECD) and for increased coherence with other international reference frames which support and strenghten ISO 26000

- ILO (already integrated) - OECD: use precise recommendations

stemming from textile and extractive sectors

- GRI, U.N Global Pact: reporting

Add in line 477 “Due diligence and corruption: it means first to have a clear internal and external communication, to elaborate the policy and to choose the tools used, secondly to put into practice the policy through controls, audits, training courses, management of the employees and top management, tools of denunciation.., thirdly to evaluate, correct and communicate annually to the Staff and stakeholders the results and the corrective actions on fraud and corruption”


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- International research reports (John Henke)

Note that ISO 26000 has to be dynamic and include evolution of best practices (cf 6.1 of ISO 26000)

IN 352

477 4.4.3 te New bullet Develop and maintain strategy for continuous cost reduction and improvement in the overall value proportions of products and services.

CO 353

478 4.4.4 Te Implementation of a reporting system enabling monitoring of both policy and effective progress, and performance.

NL 354

478 4.4.4 Key steps ge Maybe we could include a figure and visualize the steps.

See earlier figure Dutch Wheel

NL 355

478 4.4.4 Key steps ge In these steps a relation with the corporate SR process/policy should be made. For example if the is on corporate level a stakeholder matrix, this could be used in these steps

Do align these steps with the SR policy/process on corporate level.

SG 356

478 4.4.4 page 10

GE The above steps should be integrated into the process of sustainable procurement which may then be

engaged on the basis of the following five key phases:

· Prepare the sustainable procurement process from source by identifying stakeholders,


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determining requirements and analysing profitability based on product/service lifecycle and product/service cost

data;

· Define precise specifications reflecting the key social responsibility issues and sustainability

issues and including details of specific technical environmental features, production methods, the

use of specific criteria, as well as procedures for verification of compliance;

· Select suppliers on the basis of principles of social responsibility, life cycle approach and of

Product/service lifecycle costs;

AR 357

478-512 te Wording of section 4.4.4 should be simplified since it is repetitive.

“Key steps process: Implementing a policy of sustainable procurement requires: -Mapping the suppliers chain and establishing a communication plan for each audience; -Defining and prioritizing targets and indicators for each type of supplier identified; -Educating and empowering the suppliers in a cooperative and solidarity manner;


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-Monitoring the suppliers chain by the specific indicators defined; and -Reporting results.”

BR 358

478 - 512

4.4.4 TE The text is related to the process of SP and not to the policy and strategy. In general terms, what is about is referred in clauses 5 and 6, in more detail.

Remove all the text.

US 795

478 - 512

Technical The “materiality process” referenced in the title to this section is not (clearly) addressed in the section. The second bullet at line 484 references “characteristics of the organization’s environment, products and suppliers.” If this is meant to infer a materiality process, it is neither clear nor prescriptive (as in, e.g., referencing a spend analysis, which appears in Table 1 at line 562). The paragraph beginning at line 508 references “materiality and priorities”, but only declares that they should be “considered and integrated” in the procurement process, further mentioning that the concepts are treated in more detail in following chapters, but without identifying which ones or where. The “materiality process” stated in the title to the section is fundamentally important to the policy and practice of carrying out sustainable procurement. It should be highlighted in some detail within the bullets under implementation, as well as those under key phases, as appropriate.

[Rather than re-draft the section, on second review of this section (4.4.4) and section 5.2 “setting priorities”, I would comment that 1) the subjects appear to relate and/or overlap, 2) they appear to each concern aspects of determining ‘materiality’ whether they reference that term or not, and 3) they might better communicate this complex but important subject by re-organizing and re-drafting both sections into a single coherent analysis or descriptive. At the least, they should not exist as two separate sections which fail to give reference or acknowledgement in relation to the other].

SN 359

479 4.4.4 ED The text in the bullet points should be more focused and redundant text should be deleted.

Delete redundant text


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IN 360

480 4.4.4 ed installing Initiating

US 796 480

Editorial In this first bullet, suggest inserting the word “material” before “value chain”. In addition, replace “installing dialogue with” with “engaging”.

“Mapping the material value chain: installing dialogue with engaging suppliers and identifying stakeholders as well as the organization’s sphere of influence”

US 797 482

Technical In the second bullet, explain or expand so as to shed light on doing specifically what in relation to performing “due diligence”. What does this term mean or what action(s) does it refer to? If this is a reference to “human rights due diligence” as set out in the Guiding Principles On Business And Human Rights (see UNHR: http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf), then suggest this be made clear. Further on in the same sentence, consider including reference to the organization’s policy “and/or performance”. “Performance” can be used to set a baseline from which to measure objective progress, and represents a more concrete form of implementation in sustainability.

“Performing due diligence [explain what this is and how to do it] and prioritising according to the organization’s sustainability policy and/or performance and identified aspects and impacts, including the consideration of the guiding principles of ISO 26000, based on the characteristics of the organization’s environment, products and suppliers”

NL 361

482 4.4.4 Key steps ge The term due diligence is used. Maybe we should be specific what we mean with this

Due diligence according the definition/explanation of ISO 26000


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term.

NL 362

482

4.4.4 te Prioritizing what? Change into “prioritizing CSR issues and risks throughout the value chain”.

US 798 484

Editorial Clarify what is meant by the “organization’s environment”. Does this refer to the organization’s environmental policy? actions? outcomes? etc.?

US 799 485 –

487

Editorial In this third bullet, clarify what is meant by the word “cooperation” in the value chain. Also, clarify that “exerting a positive effect on sustainable development” is concerned with “material suppliers” (if this is, in fact, what it is concerned with).

US 800 488

Technical In this fourth bullet concerning monitoring of the value chain, (again)

1) suggest inserting the clarifying terms “relevant/material” prior to “value chain”. 2) Further in the sentence, when referencing “development of tools for measuring progress…” explain “toward what and from what?” From a baseline? Should a baseline be established first from which to monitor or measure progress? Consider clarifying this, and/or using the term “measuring performance” instead.

“Monitoring of the relevant/material value chain: development of tools for measuring progress [explain toward what and from what?] performance, identifying variances and engaging in remedial action”


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IN 363

489 4.4.4 te engaging in remedial action engaging in proper feedback and remedial action, wherever required

US 801 490

Technical Clarify what kind of “reporting system” is referred to. Reporting what, and on what basis? In addition, change “effective progress” to “effective performance”. The word “performance” is a more objective term, and more appropriate in this context. “Progress” is more subjective, and thereby of less overall comparative value.

“Implementation of a reporting system [what kind?] enabling monitoring of both policy and effective progress performance.”

SN 364

491

Key (procu..)

te Include a new bullet; Evaluation. The evaluation is important for the feedback to the organization.

Evaluation of the procurement activities after period not longer than 4 years (depending upon the organization’s needs).

FR 365

492 4.4.4 Te Reinforce the standard’s overall structure by following developments in chapter 5

- Chapter 4: announces the relevant paragraphs of chapters 5 and 6

Redraft as proposed: These concepts will be treated in more detail in the following chapters related to organizational aspects of sustainable procurement (chapter 5):

• Define the conditions to establish a SP policy and organize the sustainable procurement function through a clear view of major SP stakes and priorities (5.1 and 5.2)

• Focus on people involved in the sustainable procurement process (5.3)

• Define the governance structure necessary to achieve the objectives related to social responsibility (5.4)

• Consider that an organization should


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respect through clear engagements (5.5) and appropriate performance measurement (5.6) the interests of its stakeholders since it is responsible for the impacts of its décisions

The above steps should also lead to integration into the process of sustainable procurement which may then be engaged on the basis of the following five key phases described in chapter 6:

• Prepare (6.2) the sustainable procurement process from source by identifying stakeholders, determining requirements and analysing profitability based on product lifecycle and product cost data;

• Define precise specifications (6.3) reflecting the key social responsibility issues and sustainability issues and including details of specific technical environmental features, production methods, the use of specific criteria, as well as procedures for verification of compliance;

• Select suppliers (6.4) on the basis of principles of social responsibility, life cycle approach and of product lifecycle costs;

• Sign contracts (6.5), issue orders and monitor execution. Contractual clauses must be agreed on for purchases of both products and services; it is also


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recommended that compliance with contractual requirements be monitored;

• Assess the experience (6.6) acquired and suppliers’ performance, including input from customers; then adjust policy based on findings; and finally, develop recommendations with a view to continuous improvement.

Materiality and priorities have to be considered and integrated with consistency in the different steps of sustainable procurement implementation, even if some aspects such as the respect of regulation, business ethics and the fight against corruption must be fully respected. These concepts will be treated in more detail in the following chapters related to organizational an operational aspects of sustainable procurement.

CO 366

496 4.4.4 Te Once it has the purchase estimated total value, ensure the budget, the total financing and set the supplier payment schedule.

SA 367

497-499 4.4.4 te This section is about prescriptive specifications, which is at odds with lines 468-469 which state a preference for outcome specifications. I think it is more common to go with an outcome specification, supported by statement of important principles to be considered in achieving the outcome rather than telling the supplier details of what production methods they must use etc

Align with 468 to 469.

US 802

497 Fund 4.4.4. Ed Use of “precise” may be problematic “accurate” may be better


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SE 368

498 4.4.4 te Universal design should be a part of the list. Add “requirements for universal design” after “features”.

CO 369

499 4.4.4 Te Use specific criteria in technical standards, as well as procedures for verification of compliance.

SE 370

500 4.4.4 8th bullet te Change wording to a more general approach applicable both for public and private sector.

Change “Select suppliers” to “Award contracts”.

US 803

502 Fund 4.4.4 Ed Sign contracts is rather abrupt language “Finalize contractual agreements” or “arrive at contractual agreement” are alternative suggestions

NL 371

503-853 GE Chapter 5: supplier code is missing SUPPLIER CODE

An important part of your SRP policy is a code of conduct for suppliers. By establishing a code of conduct and having this signed, you can explain to suppliers why you believe CSR/sustainability to be important, and what you expect of them in this area.

A supplier code is a document that reflects which standards and requirements (in the field of ethics and SRP) suppliers must comply with, whereby international agreements on SSR (OECD, ILO, ISO 26000, etc.) are endorsed as much as possible.

A supplier code can also be used for other objectives. For instance, for your subcontractors, if you yourself are a main


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contractor; or for companies with whom you form a joint venture. Reference can be made to a supplier code in the supply or procurement terms and conditions. This creates a legal means of redress that can be employed if the code is violated.

A supplier code usually contains the following elements:

• local legislation and regulations • environmental management • working conditions: health and safety

of employees, freedom of association with others, no child and forced labour

• working conditions: working hours, wage, contracts

• dealing with own suppliers • fair business practices (no corruption,

fair competition)

Sending a code of conduct to a supplier should always be in conjunction with informing or notifying suppliers. For instance, in the form of an accompanying letter or a personal conversation.

• The effect of a code of conduct is greater if you have a good relationship with your suppliers, since they are more likely to follow your wishes and to listen to your arguments. After all, a code of conduct is not a compulsory instrument, but is intended to help the


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supplier. This is because the suppliers themselves can benefit from it if they make their business practices sustainable (see the benefits of sustainable enterprise, such as better motivated staff, less sickness leave, no environmental fines, etc.).

NL 372

503-853 GE Chapter 5 collaborate in your supply chain (initiatives)

SUPPLY CHAIN INITIATIVES

In order to make the supply chain of products that you as a company import and/or sell sustainable.

You can consult the database of the International Trade Centre or the Ecolabel Index and A2 of ISO 26000.

MAKE CONTACT WITH OTHER COMPANIES

Every company is a link in a chain of suppliers and customers, in which each link provides its own contribution. Supply chains can only be made sustainable through cooperation. You should thus attempt to seek out solutions for supply chain issues by consulting with suppliers and other partners, such as fellow SMEs , buyers, intermediaries and matchmakers.


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If there is not yet any collaboration in your sector, take the initiative yourself and talk to colleagues, sector organizations, suppliers and the government.

By collaborating with fellow companies, you can increase your influence on common suppliers in terms of sustainability. Collaboration can also result in interesting initiatives, such as jointly developing innovative products.

IFPSM 373

503-853 Chapter 5 GE Chapter 5: clear structure for procurement professionals is missing, no link with key steps mentioned earlier in 4.4.4.

5.1 Governing procurement

• Current content 5.3 Governing procurement

• Current content 5.4.2 engaging internal stakeholders

• Current content 5.5 Measuring and improving performance: organizational indicators for Social Responsibility

• Current content 5.2 Enabling people

5.2 Mapping the value chain

• Add: Identification of stakeholders within value and supply chain

• Current content 5.4.2 determining stakeholders: assessing sphere of influence

• Add: help box to be drafted, based upon ISO 26000


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5.3 Due diligence and priority setting

• Current content 5.2 Setting priorities • Add: With new help box, based upon ISO

26000 • Add: Due diligence (+ help box to be

drafted, based upon ISO 26000) • Add: Country and product characteristics • Add: Characteristics of suppliers (

5.4 Engaging within the value chain

• Current content 5.4.2 determining stakeholders

• Current content 5.4.2 determining stakeholders: exercising influence

• Current content 5.4.2 determining stakeholders: engaging the supply chain

• Current content 5.4.2 determining stakeholders: engaging industry peers and other external stakeholders

5.5 Monitoring of the value chain

• Current content 5.5 Measuring and improving performance: outcome indicators


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5.6 Report on Policy and progress

• Current content 5.5 Measuring and improving performance: reporting

Add: Help box on SR indicators, related to GRI

IFPSM 374

503-853 Chapter 5 GE Chapter 5: clear structure for procurement professionals is missing, no link with key steps mentioned earlier in 4.4.4.


• Current content 5.3 Governing procurement









• Current content 5.2 Setting priorities • Add: With new help box, based upon ISO

26000


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• Add: Due diligence (+ help box to be drafted, based upon ISO 26000)

• Add: Country and product characteristics • Add: Characteristics of suppliers (











NL 375

503-853 Chapter 5 GE Chapter 5: clear structure for procurement professionals is missing, no link with key



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steps mentioned in 4.4.4. • Current content 5.3 Governing procurement









• Current content 5.2 Setting priorities • Add: With new help box, based upon

ISO 26000 • Add: Due diligence (+ help box to be

drafted, based upon ISO 26000) • Add: Country and product

characteristics • Add: Characteristics of suppliers (


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FR 376

508 to 510

4.4.4 Te Important principle to be enhanced in the document

Move these words into bold characters and repeat this sentence at the beginning of new chapter 5.2

US 804

508 Technical I don’t know what a “materiality process” is; it’s not a word we use in describing US company functions, and it’s not defined in this standard. It’s used also in the title to this


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section, and it creates confusion

US 805

509-510 Fund 4.4.4. Ed Awkward sentence structure Recommend: “…even if some aspects such as respect of regulation, business ethics and anti-corruption measures are to be fully respected.”

INTECO 377

509 We propose to change wording because the respect of regulation, business ethics and the fight against corruption should be a part of materiality and priority analysis.

Materiality and priorities should be considered and integrated in the different steps of sustainable procurement process, including aspect such as the respect of regulation, business ethics and the fight against corruption need to be fully respected.

IT 378

509-510 4.4.4 te “even if… (…) respected”. We suggest to delete this sentence (obvious and in any case connected to the materiality considerations).

SA 379

513 ge Retitle current Section 5 which becomes Section 6

Section 6 - Sustainability into the Procurement Function

FR 380

513 5 Te Good idea to use examples to illustrate the standard’s concepts, but substantial adjustments are required. For various reasons:

- Neutrality of references cited, in order to avoid the direct or indirect of a private organization (advantage gains)

- Mix international references and refer to well-known international references

- Only mention useful examples in order to illustrate a complex concept; remove it otherwise for the sake of readability

- Not to present recommendations in the form of examples: either remove, or else, reformulate it in order to put

New drafting is proposed through annexes proposed for chapter 5 As regards chapter 6: needs to be discussed in Singapore


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the recommendation forward

SE 381

513 5 ge/te The standard is applicable to all organisations and not limited to Industry.

Change “Industry peers” to “Peers” where it appears.

SE 382

513 5 and 6 te Clause 5 and 6 are too detailed and overlapping each other, for example the table on line 807 and the example on 844. The standard will benefit from merging clause 5 and 6 and moving detailed recommendations and examples to an informative annex.

Consider merging clause 5 and 6 and moving detailed recommendations and examples to an informative annex.

AR 383

513-1347

te The proposed wording of sections 5 and 6: -results too operational. The previous sections referred to concepts, these ones move up to detailed descriptions; -uses business oriented language (e.g. 7 times refers to CSR); -references to processes that are unique to each organization; -given that the standard applies to all types of organizations, results too prescriptive; -the excessive amount of examples dilute fundamental concepts.

Sections 5 and 6 should be rewritten, taking into account the consensus achieved on sections 1 to 4 and the comments provided in the previous column.

BR 384

513 5 ED The titles within this chapter shall be numbered, as sub items.

The suggestion is:

Number the titles

5.1 Setting priorities

5.2 Enabling people

5.2.1 General

5.2.2 Organizational culture

5.2.3 Performance management


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5.2.4 Developing competence


5.3.1 General

5.3.2 Governance groups

5.3.3 Accountability

5.3.4 Procedures and systems

5.3.5 Guides

5.3.6 Assurance

5.4 Engagement

5.4.1 General

5.4.2 Determining key stakeholders

5.4.3 Engaging Internal stakeholders

5.4.4 Assessing capacity of influence

5.4.5 Exercising influence

5.4.5.1 Engaging the supply chain

5.4.5.2 Engaging industry peers and other external stakeholders

5.5 Measuring and improving performance

5.5.1 General

5.5.2 Metrics and Indicators

5.5.2.1 Organizational indicators

5.5.2.2 Outcome indicators


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5.5.2.3 Macro-economic indicators

5.5.3 Reporting

5.5.4 Benchmarking

FR 385

514 5 Te To enable compliance with ISO 26000 (and avoid risk of non-compliance of this new standard with ISO 26000)

– Need of precise transposition of ISO26000 issues into SP issues

– Need of a comprehensive map of risks as well as opportunities in order to be compliant with ISO26000 materialty concept

– Need to support ISO26000 concepts through a comprehensive and operational method

– Make the determination of the key stakeholders more compliant with procurement and ISO 26000 contexts.

These are essential prerequisites for implementing other organizational issues described in chapter 5 in order to stay in line with ISO26000 relevance principle

Redraft as suggested in Annex A Replace existing table 2 with the one proposed in Annex A

SN 386

515-516 Whole document

5 ED/TE In order to find the text comprehensible and applicable for the user as guidance on sustainable procurement, the whole document needs a clearer structure.

It would be beneficial with “to the point” instructions on how to practically pursue a sustainable supply chain management with a triple bottom line (3BL) perspective.

The statement on these lines is clear evidence that the development of this

ISO /CD 18617 must be rewritten and edited in line with Annex SL, with a systematic and structured process oriented focus on 3BL perspectives covering economic, environmental and social aspects of a sustainable purchasing practise.


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standard should be governed by ISO Directive Annex SL. By applying the structure and common text of Annex SL, the user community would more easily be prepared to include Sustainable Procurement into their existing management system structure. Thousands of potential users of ISO 18617 globally already have ISO 9001 and ISO 14001 systems. It is crucial that ISO, in order to gain legitimacy In user communities

BR 387

515 - 521

5.1 TE This kind of wording is typically for the introduction of the standard.

It would be more useful for the reader to see, here, an overview about the organizational conditions that will be described in the next 5.x clauses.

Additionally, this idea has already been explored in chapter 4.

Move to Introduction clause, changing how it’s written, so that users will have a brief overview as noted on other comments;

SE 388

518 Ed Spelling. Change tis to its.

IN 389

518 5.1 ed tis its

IT 390

518 5.1 “its” instead of “tis”

DS 736

518 5.1 Ed tis

this

IT 391

519-520 5.1 te “if this has not been done, the core subjects and issues identified in ISO26000 are


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recommended…”

Question: can we accept that an organisation interested to apply this standard has not identified stakeholders and material issues? These activities should be the basis for an approach based on sustainability.

We propose to simply refer to the ISO26000 core subjects.

SA 392

519-520 5.1 ed Rewrite the last sentence so it reads along the line that this is an indicative guideline based on ISO 26000 and it can be tailored based on the national and organisational context.

NL 393

520 GE Issue table ISO 26000 towards appendix Make one figure/table with figure 1 and places into the appendix

SN 394

520 5.1 ED A reference to ISO 26000 with chapter is sufficient. Details in annex

Detail reference to ISO 26000 in annex

IT 395

522 ge The document should focus on the materiality especially in chapter 5.2 “setting priorities”

FR 396

522 5.2 Te Need for effective bridges (effective connection objective with organizations such as the 0ECD) and for increased coherence with other international reference frames which support and strenghten ISO 26000 - ILO (already integrated) - OECD: use precise recommendations


- GRI, U.N Global Pact: reporting - International research reports (John

Henke)

OECD textile recommendations and John Henke Study regarding partnership benefits are already included in annex A


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Note that ISO 26000 has to be dynamic and include evolution of best practices (cf 6.1 of ISO 26000)

IT 397

522 5.2 te The title of this section should be connected with the concept of “materiality” rather than “priority”. Chapter 5.2 describes the materiality assessment process.

SN 398

522 5.2 TE This is part of the procurement process, and definitely not a part of 5. Organizing for sustainable procurement. Organizing is: Assigning responsibilities, training, allocating resources, developing systems etc. Prioritising and its outcome is part of the procurement process

Move 5.2 to a later chapter.

IT 399

522-585 5.2 ed Correct numbering because there are two points 5.2

SN 400

523 A threshold of contract value may be set in order to use sustainability criteria for large contracts only

In order to use sustainability criteria for large contracts, the threshold of contract value must be…

BR 401

523 5.2 TE Insert a text that links prioritization to the SP policy and the gradual approach. In addition, it introduces the concept that the sustainability issues should be related with the business and activities of the organization and its impacts. It cross-references also ISO 26000 as a fundamental reference.

This clause should be renumbered as 5.1

Include the text:

Organizations buy a great amount of different products and services. In order to implement sustainable procurement, the organization should start gradually. Besides, the organization should prioritize the products and services according to the materiality of sustainability issues and its related impacts. These sustainability issues should be related to the organizations business and the impacts of its activities. ISO 26000’s core subjects should be considered when identifying the sustainability issues related with the


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organization.

NL 402

523 5.2 Setting priorities

ge The relation between the steps 4.4.4 and 5.2 should be made clear.

Include a figure or explanation between the different steps.

NL 403

528 5.2 diagram Current diagram is overarching chapter 5 and 6. The bullets are not in line with the steps in chapter 5 and also 6. The right diagram could add value and bring insight into where explanation of specific steps can be found

Create overarching graph in line with chapter 5 and 6 (and also referring to where explanation is found).

BR 404

528 - 529

5.2 TE The figure is confusing. For experts it can be understood, but it could be misunderstood. It could be read as each level being preferable than the previous one.

Remove the text and the figure

An example is illustrated bellow.

This priorization does not apply to different countries neither to public organizations. It is a specific situation.

NL 405

530-584 GE Remove Heat Mapping and the steps. It’s one of the methods.

A useful recourse for performing a supply chain analysis is mapping your Value Chain. By answering the following questions:

• What are the core processes in your supply chain?

• How is the supply chain organized? • Who are the important actors and

partners in the supply chain? • How do products, services, payments

and information flow through the supply chain?

• What are the external influences that influence performance in the supply chain?

You can map your supply chain by going through the following steps:

• Perform a 'spend analysis' (see figure


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below). This is a list of all products and services that you procure. For each product and each service that you procure, establish which supplier(s) you procure this from and in which country it is manufactured.

• For composite products, attempt to ascertain the most significant raw materials and/or semi-finished products and ascertain where these come from.

• If possible, verify how and by whom products are transported.

• For each product and each service that you deliver yourself, establish what the supply chain looks like after your company (users, waste, etc.).

• You now know which steps (where possible, filled in specifically with names of suppliers) there are before and after you in the supply chain, including the transportations.

US 808

530 – 584

Org the Procurement Fundtion

5.2 entire Heat Map section

Ed Inconsistent in using upper case/capital letters in reference to Heat Map or Map

Proofer should catch

BR 406

531 - 584

5.2 TE New 5.2 section as per Annex II Change the item as shown by the Annex I

View Annex I – pages 32 to 33

IN 407

532 5.2 te Only four steps have been given and not five as mentioned in line 532

Details of the missing step to be given

US 806 532

Org the Procuremen

5.2 Ed Need a Header for this section, the text starts describing heat mapping in an abrupt way

Add header, such as “Constructing a


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t Function that is not first apparent to the reader. Sustainable Purchasing Head Map”

FR 408

537 5.2 Te It’s not recommended in public procurement regulations to have local boroughs for goals.

Delete the example.

US 807

537 Org the Procurement Function

5.2, Example

Ed “borough” is a UK centric term “area” or “region” may be more relevant. Not a huge concern by the way.

INTECO 409

541- 562 Define if "Table 1 Map: issues against categories to establish priorities" it's the same than heat mapping mentioned on line 894.

In addition, in line 542 - 550 never mention than the map of table 1 is the best tool to do the analysis and do not open the possibility to use other than will give acceptable results.

On the other hand, the Table 1 does not include explanatory notes for interpreter the colors and his meaning.

Finally, we propose to send every tool and examples to an annex like ISO 26000.

BR 410

543 - 545

5.2 step 2 TE Based on the category overview a ‘value chain map’ can be created, understanding where products and services originate. This goes beyond tier one to consider any supply

Value chain and supply chain are used throughout the text interchangeably – there is a need of a better conceptual explanation, in the text and also in the Terms and Definitions


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chain impact in connection to risks and opportunity (company objectives).

at chapter 3.

CL 411

546 5.2 Step 2, Paragraph 2

te These priorities come too directly from the organization’s point of view, without considering a consulting or a co-construction process, taking into consideration the supplier’s opinion.

This is best done as a collective exercise between procurement people, internal customers and those who have knowledge to contribute from other parts of the business.

This is best done as a collective exercise between procurement people, internal customers, those who have knowledge to contribute from other parts of the business and a consulting or a co-construction process, taking into consideration the supplier’s opinion.

NL 412

552-557 5.2 GE Additional help box for 5.2 Setting priorities Help box – Determining relevance, significance and priority of SR issues

Determining relevance, significance and priority of SR issues All the seven core subjects of SR, but not all 37 SR issues, have ‘relevance’ for every (procurement) organization. An organization should review all core subjects to identify which SR issues are relevant. Generally considered: the stronger the SR issue is connected to the core business and law and regulation, the stronger its relevance. The relevant SR issues can have different types of impact (negative or positive) on stakeholders and the social, ecologic and economic environment. This is called the ‘significance’ of the SR issue. Stakeholders, like suppliers, should be involved in the identification of the significance of the SR issue. Relevant issues that are generally considered to be significant are non-compliance with the law; inconsistency with international norms of behaviour; potential violations of human rights; practices that could endanger life or health; and practices that could seriously affect the environment.


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Stakeholders can also have an impact on the organization (negative publicity in the press, pressure from politics or a consumer boycott). In ISO 26000, however, this impact is not a criterion for significance. It still is a factor to be taken into account when determining whether an issue is relevant and possibly also when setting priorities. Priorities should be established for the SR issues that are relevant and significant. Hereby the (procurement) organization has the opportunity to create competitive advantage, by setting more ambitious SR objectives. The (procurement) organization can choose to be more proactive in taking action and minimizing negative impacts and enlarging positive impacts for certain SR issues. Examples of relevance, significance and priority criteria:

Help box prioritizing short.docx

NL 413

561 5.2 Table 1 te ISO 26000 core subject “Human rights” is missing.

Include ISO 26000 core subject “Human rights” in the table.

NL 414

561 5.2 Table 1 te This priority mapping should be done at the level of all 37 CSR issues of the ISO 26000 for procurement / supply chains.

Include all 37 ISO 26000 CSR issues in the table.


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SN 415

561 Step 2 Table 1 ed The legend is missing in the example.

A =

G =

R =

CA 416

562 ge This table is limited as it only appears to prioritize risks but not opportunities.

IT 417

562 5.2 te (table 1) G,R,A in the map must be explained

IT 418

573 5.2 te “stakeholder engagement is necessary to deliver the action plan…”. The object of the stakeholder engagement must be described, it is not clear the reference to the “delivery” of the action plan.

SA 419

575-578 te We think that we should provide more guidance on the ‘How far do you go’.

The 575-578 section should be rewritten to refer to the following actions:

• Assessment and on-going review of impacts + Identification of where in the whole supply chain (= what tier)

• All impacts with a high level of risk should be considered, regardless of the tier impacted. However, your level of willingness may depend on considerations such as the value associated with the contract, the market share your represent for the supplier, the sphere of influence.

IT 420

580 5.2 te We think that the case of FMCG cannot be considered a good case in term of sustainability; it is a risk to define it “clear and unambiguous”. Even if clear in term of


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company’s communication, it is a risk to “approve” (using the terms “clear and unambiguous”) the behavior of this company. “the point at which their brands appears on the product” can be at very latest stages, in the majority of cases also after the moment in which the company has a legal responsibility. We suggest to look for another example.

The risk is also to go against one of the principle stated earlier (“Tier 1 is not the only one”).

SN 421

581 Step 5 ed Check the numeration. Step 4 – Capture learning and review.

IT 422

583 5.2 te “material changes to the business or supply chain”. We suggest to add “or to the organizational sustainability policy”

CA 423

585 5.2 ge Section 5.2 (p.12) is quite prescriptive as to how to set priorities for sustainable procurement. Step 1 (about organizational goals) calls for precise and measurable results (for example: 20 % of suppliers from local boroughs). This is well in line with Key Industrial Capabilities (KICs).

522 - No change.

IT 424

585 5.2 ed Numbering incorrect (double “5.2”)

NL 425

585 5.2 ge Two times paragraph 5.2. The second paragraph 5.2 (enabling people) comes too soon in the guideline document. First, the practice of sustainable procurement should be dealt with in detail, before discussing how to enable people.

Move 5.2 backwards in the document Should be placed before

5.4. Engagement


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PL 426

585 5.2 Correct numbering

SN 427

585 5.2 TE This should be the real paragraph 5.2 as it is part of organizing

US 809

585 Org the Procurreme

nt Func

5.2?? GE Numbering seems to go off here, 5.2 first appeared back at line 522

Have someone go through and correct all section numbering.

PL 428

587 5.2.1 1st para "Effective delivery of sustainable procurement policy and strategy requires that all personnel involved in procurement decision, including production or service planning personnel, or engaged with suppliers in any capacity (...)

Add

“…including production or service planning personnel…”

BR 429

587 - 591

5.2.1 1st paragraph

GE It is important to address that people must be enabled on the shift from purchasing the lowest price good or service to purchasing the good or service that fits better the organization sustainable procurement policy needs and interests.

Effective delivery of sustainable procurement policy and strategy requires that all personnel involved in procurement decisions or engaged with suppliers in any capacity, understand the reasons for implementing sustainable procurement as well as how to play their part in implementation, and are given the means to do so. This involves changing the top management mindset, as they need to comprehend since basic information – like the shift from buying lowest price item to buying more sustainable items – to more specific information, as such details on the risks and opportunities on the procurement to the organization. This can include not only purchasers but budget holders, specifiers, internal customers, quality management, technical specialists and operational managers as well as CSR professionals.

SN 594 5.2.2-5.2.3 594-605 te Enabling people is crucial. To make any


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430

company’s sustainability effort to become anything more than just a one-time inspirational speech, it needs to be more specific on “How to” enable and engage people.

It should also be clearly stated that since this is a new concept, that might contrast previous practices, it is vital that it is a topic that is regularly put on the agenda through in-house seminars, team meetings, in performance appraisal interviews etc.

BR 431

595 5.2.2 TE Introducing a relatively new concept to people requires the right organizational culture. (there is no right culture…)

Introducing a relatively new concept to people requires the right integration to the organizational culture.

US 810

596 Organizing the

Procurement Funct

5.2.2 ED Is the term “can do” understood globally Perhaps, “a culture that embraces change”?

SN 432

600 5.2.3 For an organization that wants to measure team members’ personal performance with regards to sustainability, a manager needs to identify good parameters. It would be useful to give examples of what concrete parameters a supply chain manager could use to measure individuals.

FR 433

606 5.2.4 Te - Introduction must better be in connection with CSR

- We need to mention communication (whenever necessary, in other sub-chapters, as requested in Brasil) because enabling people doesn’t rely only on training

- We must be more specific about conditions of training and communication efficiency, aiming at

Redraft “enabling people” sub-chapter as suggested in Annex B


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breadth as well as depth of tools implemented to really help relevant stakeholders

- We must be more specific on the necessary range of internal and external stakeholders involved in training and communication (not only purchasers)

- We must be more specific about how human resource management must be conducted in order to be compliant with SP policy

NL 434

607

5.2.4 Be more explicit category expertise is needed Add sentence: In depth category expertise is needed to understand the relation to CSR issues.

BR 435

609 - 610

5.2.4 TE The text is redundant. Exclude the second phrase.

Procurement organizations should identify the learning and development needs of those involved in the procurement process. Sustainable procurement should be captured into all relevant professional training.

FR 436

610 5.2.4 te The top management has to settle the appropriate and needed conditions in favour of a real responsible and collaborative relationship with suppliers and subcontractors. This issue is addressed for example by the 4th domain of the label Relations fournisseur responsables. & 5.2.4 “Developing competence” covers training, but we do not see in the standard recommendations about the management of wages nor path career for buyers (responsible

Add: "Procurement organizations could settle a coherent payment policy for its people and by the way promote best practices related to sustainable procurement policy, eg suppliers relationship negotiation timeframe, and not only cost savings negotiated".


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procurement targets, payment policy for buyers…).

FR 437

610 5.2.4 te Reinforce the individual commitment about fair business practices.

Modify the sentence by adding: “sustainable procurement should be captured into all relevant professional training and then, all procurement organization’s member should be individually committed to its principles, in particular to implement fair business practices when conducting supplier selection phase.

US 811

611-613 ORganizting the

Procurement Function

5.2.4 ED Suggest some changes to clarify and clean up.

“Other considerations might be job shadowing or internal/external job exchanges; training; participation in relevant social media groups; sharing best practices; working in project teams and engagement with associations or other organizations focused on sustainability.”

DS 737 614

5.2.4 Te Some interested parties are missing Include: municipal, regional and state interested parties

FR 438

618 5.3 Te - Introduction must better be in connection with CSR

- Real need to stress on specific risks regarding this sub-chapter, because experience shows a lot of problems

- Add reference to global cost and value creation method because this kind of economic approach should be the main backbone of SP decisions

- Add a recommendation regarding a need to search and for active contributions to best practices because they are fast moving worldwide and there is a risk of discrepancy between those up-to-date best practices and operating management

- Developments related to exercising influence look better in this sub

Redraft “governance sub-chapter” as suggested in Annex C


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chapter (governing procurement) - Synthesis current redaction and

highlight main recommendations

- Add John Henke illustration in order to fully support recommendations regarding governance

- NL 439

618 5.3 ge This paragraph is quite general of character. We should discuss the added value of it.

SN 440

618 5.3 TE/ED Governance is part of leadership Paragraph 5.3.1, 5.3.2 and 5.3.3 should be moved together with Policy, leadership etc

IT 441

636-638 5.3.3 te Too detailed and specific suggestion, not possible to generalize. We suggest to remove the sentence.

SN 442

642 Contractual obligation such as a supplier code obliges the supplier to upheld international standards and national laws in core sustainability areas. This may be included as a separate chapter.

Include contractual obligation as a separate chapter.

NL 443

646 5.3.5 Change Guides in Change title 5.3.5 Guidance & Methods

Add the following:

These guidance documents can be based on the following principles:

life cycle costing

true pricing,

inclusive economy circular economy

IT 444

647 5.3.5 te We suggest to remove “‘soft’ documents such


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as”. The subject can be “tools and guidelines”

US 812

647 Org the Proc

Function

5.3.5 ED “Soft” will confuse some. Do we mean electronic? And why would we specify format? Or, so we mean tools other than policy and procedures?

Clarify meaning and use more precise language.

US 813

650 Org the Proc

Function

5.3.5 ED Are there more that we can list? Ecolabels, management systems, and…?

Analytical tools, industry regulations, etc? A list should have more than two items.

US 814

650 5.3.5 Guides

Technical Instead of simply saying ecolabels, why not give some direction.

Guides on ISO 17065/Guide 65 accredited ecolabels, ……

IT 445

654 5.3.6 te We propose to change the sentence “Existing assurance process should be modified to embed sustainability” in “Existing assurance process should embed sustainability”

CA 446

655 5.3.6 te Existing assurance processes should be modified to embed sustainability. Typically this would include audits, gateway reviews, management reviews and external verification.

IT 447

655 5.4 te Not clear the inclusion of “management review” in the chapter of assurance.

We propose to modify last sentence “…external verification” including “and certification”

FR 448

656 5.4 Te Chapter should be synthetized to focus on 4 main principles to build and conduct engagements in order to comply with ISO 26000

- Reciprocal interest, - Relevance, - Responsible communication,

Redraft “engagement” sub-chapter as suggested in Annex D


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- Motivation source to invite stakeholders to improvement

EOS/ EG 449

656 5.4 Engageme

nt

te This clause tackles stakeholder identification and engagement, precisely (internal, supply chain and industry peers and other external stakeholders).

*Adding "Stakeholder identification and" before "engagement" in 5.4.

*Replacing the word "determining" with "identifying" in 5.4.2 the same term as used in ISO 26000.

EOS/ EG 450

656 5.4 Engageme

nt

te There is another stage before stakeholder engagement and after their identification.

Indicate "prioritization of stakeholders" based on mutual influence/power and interest.

EOS/ EG 451

656 5.4 Engageme

nt

te There is a normative reference that should be mentioned in this Subclause for Stakeholder identification and engagement.

Refer to "AA1000 Stakeholder Engagement Standard".

EOS/ EG 452

656 5.4 Engageme

nt

ed Many subclauses need sub-numbering 5.4.3 Engaging internal stakeholders

5.4.3.1 Assessing capacity of influence

5.4.3.2 Exercising influence

5.4.4 Engaging the supply chain

5.4.4.1 Illustration of supply chain engagement techniques

5.4.5 Engaging industry peers and other external stakeholders.

CA 453

656 and 866

5.4 & 6.2.1 ge Section 5.4 (p.18) invites organizations to assess their capacity to influence their supply chains. Military procurement organizations most probably can’t, as none of the seven proposed leverage element seems applicable.

The proposed approach is then to seek ways to increase our leverage to enable mitigation (e.g. offer capacity-building support to the supply chain; work on regional basis to incentivise improvements, etc.). Some GoC

656 - No change. Leverage elements are good although potentially not applicable to military procurement. Government of Canada procurement policies and tools should address issues where applicable.

710 - At the end of first paragraph of Exercising Influence, insert the following: Government organization should be careful not to unduly favour a potential supplier by directly supporting its efforts towards sustainability.


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programs may support this (e.g. Built in Canada Innovation Program – Military; Subventions, etc.). However, fairness issues would emerge, should Government directly support a supplier’s capacity building.

Section 6.2.1 (p.25) raises similar issues.

Moreover, if efforts to enable mitigation prove unsuccessful, it is suggested to be prepared to end the relationship with the supplier. This is not applicable to areas of limited market such as military procurement.

More specifically, government organizations should not directly support any sustainability measure to be assessed as part of an open procurement process.

866 - No change if proposed change above is done.

722 - End paragraph with unless the requirement is an absolute necessity for the organisation (e.g. refraining from purchasing the good would result in death or serious harm to people).

CA 454

658 5.4 ge Section 5.4 (p.17) on Engagement starts with a statement to the effect that an organization is responsible for the impacts of its decisions and activities. One could argue that people rather than organizations are responsible, hence the necessity to identify the responsible people within the organization, which is not done. Moreover, stating that “it may be necessary to engage in specific meetings with senior executives” (p.18) presupposes that senior executives are not actually responsible.


685-687 – Replace with: Senior executives remain responsible for the decisions of their organizations. They are the ones who should set specific priorities for change management, such as a major contract renewal or action plan on a sustainability issue. They should develop specific communication plans and set up working groups as needed to develop specific plans and initiatives. Their leadership is key in achieving sustainable procurement.

IT 455

658-661 5.4.1 This is a general principle that could be included also in the previous part of the standard

BR 456

661 5.4.1 TE To be consistent with prioritization instead of hear mapping

Replace 'priority map' by 'prioritization' in the text:

There will be situations, determined by the priority map prioritization, where a procurement organization will have a


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responsibility to exercise influence.

BR 457

663 - 664

5.4.1 ED Footnotes should not be used in standards in the way that is used here. Moreover, there is no need to repeat a principle form ISO 26000.

Remove the text:

A basic principle of social responsibility is that an organization should respect and consider the interests of its stakeholders that will be affected by its decisions and activities. Change management towards sustainable procurement practices requires the engagement of key players such as internal stakeholders and suppliers. Few outcomes can be delivered without their full contribution.

IT 458

664 5.4.1 Typo (“1”)

US 815

664 5.4.1 2nd paragraph

Editorial Delete the erroneous 1

….and activities. 1 Change management….

BR 459

668 - 669

5.4.1 TE Referring to the SP policy is clearer and appropriate here.

Replace 'social responsibility' by 'sustainable procurement policy' in the text:

Stakeholder engagement assists the organization in addressing its social responsibility sustainable procurement policy by providing an informed basis for its decisions.

IT 460

671 5.4.2 te Title, we suggest to add “of the procurement process”

BR 461

672 5.4.2 ED To have an explanation before going into the example.

Include the text:

The organization should consider mapping their key interested parts stakeholders in relation to its sustainable procurement initiative.

BR 673 - 5.4.2 ED Include 'an example of a' in the text:


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462

674 The table below shows an example of a typical range of key stakeholders to engage from a procurement perspective and why they should be engaged:

SN 463

675 Investors may be included as a stakeholder Investors

BR 464

675 5.4.2 Table 2, Column

'Examples

Line 'Internal

Stakeholders'

TE Include the text

Substitute “CSR professionals” to “CSR/Sustainability professionals”

IN 465

675 5.4.2 Table 2 row 3

ed Customer facing propls Customer facing propls people

IT 466

675 5.4.2 Table te Typo “propls”

Add in "Supply chain" among stakeholders: Workers

Substitute in Internal Stakeholder: "Workers" instead of "Operational People"

US 816

675 Org the Proc Func

Table 2 Ed Do individual consumers need to be added to External Stakeholders “Who”?

US 817

675 5.4.2 Table Editorial Don’t know what a propls is

Customer facing people propls

CA 677 ge Table 2 add stimulate innovation and Add: stimulate innovation and collaborate on


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467

collaborate on issues of mutual benefit to supply chain stakeholder groups.

issues of mutual benefit to supply chain stakeholder groups.

BR 468

680 - 681

5.4.2 TE To be consistent with prioritization instead of heat mapping

Replace priority map by 'prioritization process' in the text:

The first engagement related to sustainable procurement is likely to be the priority map prioritization process.

BR 469

690 5.4.2 TE We should use Organization instead of procurement organization through the whole document

Replace 'Procurement organizations' by The organization in the text:

Procurement organizations The organization should consider their ability to influence their supply chains.

BR 470

710 5.4.2 TE The example in the box at line 723 is better placed just after line 710.

Move the example.

IN 471

718 5.4.2 te New Add (v) after (iv) Early involvement of supplier in the planning stages for improvements.

US 818 729

Org the Proc Func

Table on page 19

Tech Uses term Lobbying May need to note “lobbying, if legal”

BR 472

736 - 738

ED This doesn't add to the text. We suggest removing it.

The first phrase should be stated on the first paragraph as a small warning on the influence of the organization influence of the suppliers.

Remove the second sentence:

A fair and proper process based on engaging the most relevant suppliers should be developed. The interest (or interests) of suppliers should be genuine. Effective supplier engagement is based on good faith and goes beyond public relations. Also, the organization should be conscious of the effect of its


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decisions and activities on the interests and needs of its suppliers. It should have due regard for its suppliers as well as their varying capacities and needs to engage with the organization.

BR 473

739 - 743

5.4.2 ED Put the list with bullets for more clarity. Replace text

- a clear purpose for the engagement is understood;

- the suppliers’ interests have been identified;

- the relationship that these interests establish between the organization and the supplier is direct or important;

- the interests of suppliers are relevant and significant to sustainable development; and

- the suppliers have the necessary information and understanding to make their decisions.

BR 474

744 - 746

5.4.2 TE To be clearer about what we are talking about.

Replace the text:

A procurement The organization should encourage suppliers to identify their sustainability aspects and impacts core issues and act accordingly. Mutual analysis will lead to appropriate dialogue related to the priority heat map prioritization made by between the procurement organization and supplier.

FR 475

745 5.4.2 Te In public procurement, mutual analysis between the procurement organization and supplier is in frequently forbidden by public procurement regulations

Add “when possible”

BR 476

747 - 748

5.4.2 ED Remove 'procuring' from the text:

Various techniques of engagement can be


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used depending on how ambitious the procuring organization’s objectives are regarding…

BR 477

751 - 767

5.4.2 TE The text doesn't add for clarity. Doesn’t shows techniques, only outlines a profile’s classification. Isn’t much helpful. Remove the text.

Remove the text

NL 478

751-769

GE Illustration of supply chain engagement techniques should be clear that this is one example..

Include the illustration in help box in an Annex

IT 479

755 5.4.2 te Typo “organisations”

SN 480

755 Illustration of supply…

ed A word is misspelled. … organizations …

INTECO 481

756 A tool is presented but is does not mention how to use it.

As well as the last observation, we propose to send all the tools to an annex.

It’s important to explain what is purchaser ambition on the footnote or similar.

IT 482

757-758-759

5.4.2 757: table te Considering that the most frequent action undertaken by the purchasers is to audit the suppliers, we suggest to include “audit or monitoring actions” where ambition and competence are low.


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US 819


Case Study on page 20

Tech What compelling story does this tell to illustrate the successes or outcomes of the establishment of the school?

Need more concrete illustrative output or a different case.

IN 483

763 5.4.2 te Using a balanced scorecard Using relevant / balanced scorecard

FR 484

768 5.4.2 Te Direct or indirect references to private companies are not appropriate

Delete this table

US 820


Case Study on page 20

Ed Where are the facts cited from? Attribution Need to add attribution for statistics

BR 485

769 ED This is a better place to put this text (moved from the 6.2.4. Analyse the market)

Include the text and the figure:

Consider the market position between the buyer and the market. The diagram below can be used as a guide.

Figure XX - Market engagement Matrix

In areas where significant leverage exists, it is possible to influence or even move markets to a higher level. Where there is less leverage, it is necessary simply to evaluate and select the most sustainable option. Leverage should not just be considered in financial terms. Some suppliers will be attracted to the idea of developing more sustainable goods or services for a small customer with a view to


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creating more competitive advantage with larger ones. Leverage can also be improved through collaboration with other purchasing organizations, with due consideration to ethical issues and competition law.

IT 486

769-1148-1343

5.4.2 te We require to avoid the inclusion of examples based on private initiatives or not inter-governmental initiatives

NL 487

770 5.4.2 Government is an important stakeholder to organize a level playing field when CSR is not evident from competition perspective

Government can be an important stakeholder to organize a level playing field, especially in cases where more sustainable initiatives are insufficiently competitive. In these cases a company or industry can exercise influence by working with government to set policy and standards.

SE 488

772 5.4 ge/te Trade unions are natural external stakeholders that should be mentioned explicitly. Upholding ILO-standards is not possible without a dialogue with trade unions.

Add Labour unions to the list of stakeholders.

US 821


5.4.2, page 21

Tech Legal considerations Sentence on line 781 should end with “and complies with applicable laws.”

CA 489

782 5.5 ge The Measuring and Improving Performance Section (p.21) reminds the reader that the procurement function should define key performance indicators, put in place systems to collect and analyse the data and use them to support its sustainable procurement approach. Such requirement is highly problematic for GoC because of its numerous stakeholders and their various (sometimes incompatible and often outdated) computer systems, security of information issues, lack of

782 - No change. Government of Canada works at addressing its data management issues.


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resources for ensuring integrity of the information, etc.

EOS/ EG 490

782 5.5

Measuring and

improving performanc

e

ed Many subclauses need sub-numbering.

The same as mentioned in proposed change for 5.4 "Engagement".

FR 491

782 5.5 Te Need for effective bridges (effective connection objective with organizations such as the 0ECD) and for increased coherence with other international reference frames which support and strenghten ISO 26000 - ILO (already integrated) - OECD: use precise recommendations



Henke) Note that ISO 26000 has to be dynamic and include evolution of best practices (cf 6.1 of ISO 26000)

Has been integrated in annex A

With clear explanation to view ISO26000 as dynamic through a relevant illustration regarding OECD anti-corruption recommendations in extractive business

FR 492

782 5.5 Te Introduction must better be in connection with CSR Chapter should be restructured to focus on 4 main principles to build reporting in compliance with ISO 26000:

- Main goals are to assess maturity of the organization, and invite to further improvement

Redraft ‘reporting’ sub-chapter as suggested in Annex E


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- Use well established and known indicators and methodologies such as GRI, DJSI

- Ensure relevance in accordance with the main SP issues

- Use reliable information sources using internal data, external stakeholders’ perception, data and also benchmarking

CA 493

788 te Add: define goals and targets to kpis. Add: define goals and targets to kpis

BR 494

794 - 796

5.5 ED Replace the text:

Metrics are the raw data we that are collect collected to understand performance. Indicators are the information we to use to manage with.

BR 495

801 5.5 TE Just better explain the ideas and introduce the subject. The subsequent items don’t have text explaining what each specific kind of indicator is.

Include the text:

There are different types of indicators that can be considered. Among them there are:

- organizational indicators: those related with the measurement to monitor the achievement of the organization’s policy, objectives and goals etc.;

- outcomes indicators: those related with the measurement of the outcomes of the sustainable procurement policy implementation and the results of the sustainable procurement process in itself;

- macroeconomic indicators: those related with the performance of the organizations, especially those aspects that


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are affected by the sustainable procurement process.

NL 496

802-810 5.5 te The context and use of the maturity matrix remains unclear. What is the objective of this matrix? Shouldn’t the issues be / relate to the 37 CSR issues of the ISO 26000?

INTECO 497

807 We recommend to set the example as an annex

NL 498

807-810 Figure GE Example of a maturity matrix drop this

BR 499

808 5.5 Matrix TE It is important to have an example of a maturity matrix. However, the matrix used it’s difficult to read and it contains a lot of non-international references/ expressions, such as Heat Map, Cobham technical guidance, red impacts etc.

We suggest using another one, more easily understandable and presented in a way to illustrate the idea but also, as it was done in examples in ISO 31010, to give the idea and avoid copying.

We suggest to change the example using the Flexible Framework from DEFRA, as shown below:

US 822

808 Org the Proc

Function/Measuring

Maturity Matrix

(Figure ??)

Tech People will take this literally and possibly be confused.

Need to a)either “neutralize” this and make more generic or b)provide explanatory text. IF LEFT IN MUST CITE SOURCE and gain permission to use?

IT 500

809 5.4.2 Table te Too long, too complex. “what it is Cobham RSCM”?


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BR 501

816 - 818

5.5 ED The example mentioned is now at the Annex A. Therefore, doesn’t make sense no longer make the reference.

Remove the text

This is linked to the example shown in Setting Priorities to show how objectives and goals can flow down to measures for the supply chain.

NL 502

819 GE Example of outcome indicators drop this

INTECO 503

833-836 5.5 Content The paragraph suggests that the macro-economic indicators analysis is an input for the strategy process. We would like to add the idea that social, economic and environmental indicators analysis should be an input for the strategy, so the organization can match its goals with the country most relevant/material challenges.

Economic, social and environmental indicators

These are not typically used at the supply chain level. However, it is suggested that the organizations use such indicators to inform overall strategy and to align its goals with the most relevant challenges of society. An example would be social return on investment (SROI), which may, in turn impact on the objectives for the supply chain and the criteria for making procurement decisions.

CA 504

835 5.5 ge According to the Measuring and Improving Performance Section (p.21), time is needed for the impact of a sustainable procurement program to flow through from organizational indicators, to outcomes and eventually to have an impact on the macro-economic impact of the organization. Organizational indicators (p.21-22) and outcome indicators (p.22) are introduced and examples are provided, while the only paragraph under macro-economic indicators (p.23) simply states that these are not typically used at the supply chain level. GoG’s Value Proposition approach

835– Insert the following before overall strategy.: An example is the value proposition approach which considers the evaluation of additional elements to enable “leveraging of the spend” such as the capability, capacity and commitment of a bidding firm to contribute to the socio-economic objectives. Bidders may present a value proposition with respect to sustainability, innovation, emerging technology, HR development, technology transfer, capital and infrastructure investment. The value proposition approach may also support enhancements to existing policies in terms of


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incorporates macro-economic indicators. participation of small and medium enterprises and aboriginal firms as well as local content.

Replace An example would be social return with Another example would be social return.

BR 505

837 - 842

5.5 TE The organization should define if it will report its sustainable procurement performance, as well as how to report its results. It is a choice, not mandatory.

It is not necessary to exemplify how to report.

Reporting

The organization should determine if and how it will report its sustainable procurement performance. It is important to report sustainable procurement performance openly and transparently. This can be part of

the organization’s annual report, a separate CSR report or part of a more formal reporting process with independent assurance.

Exclude the figure.

IT 506

844 5.4.2 te In term of reporting, a better example could be using the typical info requested by the GRI in relations to supply chain management.

“What it is BAP”?

FR 507

844 5.5 Te Direct or indirect references to private companies are not appropriate. No need for example.

Delete this table

BR 508

844 - 845

5.5 Figure GE The illustration doesn’t add relevant information for the reader.

Withdraw Report Example Illustration

NL 509

844-847 GE Reporting example drop this


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NL 510

845-1347

6 6.2.3 ge Described professional procurement instead of sustainable procurement

This applies for all other paragraphs in chapter 6


NL 511

847 5.5 ge Examples like these should not be given, unless then guideline provides an extensive and complete list of standards.

Delete examples.

BR 512

848 - 850

To add more clarity to the text. Using indexes is one way to make benchmarking. But is not the only one.

Insert the text

An organization might choose to benchmark itself against peer organizations. One way to do this is by means of comparison to formally established indexes. As an example, there There are a number of robust corporate responsibility measurement indexes available. These are not limited to supply-chain activities but take into account all aspects of an organization’s business practices including supply-chain.

BR 513

850 - 853

ED This is a list of proprietary initiatives. The list is not need to understand the text. Just remove

Remove the text:

The main indexes are: Business in the Community Corporate Responsibility Index, Dow Jones Sustainability Indexes and FTSE4Good. Alternatively, public reporting initiatives such as GRI may be used to provide transparency and benchmarking opportunities.

INTECO 514

851

852

The section mentions some indicators; we recommend to include them in an annex as examples. From line 851 to 852 we suggest to keep the option of using any other indicator

IN 515

852 5.5 te FTSE4Good Not Clear


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SA 516

854 ge Retitle current Section 6 which becomes Section 7

Section 7 - Sustainability into the Procurement Process

FR 517

854 6 Te Reinforce the standard’s overall structure by following developments in chapter 5: Chapter 6: reconsider paragraph 6.2 Planning, which becomes to some extent redundant with the new drafting of paragraphs 5.1 and 5.2

To be discussed in Singapore

FR 518

854 6 Te - ‘procure to pay' part of the process has to be described with more precise recommendations in contract management chapter

- Referencing/dereferencing part of the process has to be described with more precise recommendations in selection step

- Partnership, collaborative relationship and SMOs development part of the process has to be described with more precise recommendations in contract management step

- Dependence management of the process have to be described with more precise recommendations in selection, contract management and contract review steps

- Use of mediation part of the process have to be described with more precise recommendations in contract management step


SN 519

854 6 TE The standard should as far as possible give clear guidance on sustainable procurement, hence a description of basic procurement activities in which sustainability considerations and decisions are inherent,

New heading: 6 Sustainable procurement process


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should be outlined in the standard. The chapter therefore needs a more specific heading

SN 520

854 6. Contents te

The communication and reporting part is important and therefore it should be included as a separate chapter. Great benefit may be achieved by organizations if the information flow is organized in a proper manner. Information, communication and reporting is included indirectly in several parts, however it should be a core pare that is highlighted in the document as an essential part.

Chapter 6: Communication and reporting

US 823

854 6 Editorial Replace ‘Integrating’ with ‘Embedding’

NL 521

855 6.1 6.1 ed The purpose should be explained in this section and the connection with the company strategy should be made.

The aim of chapter 6 is to zoom in on the actual procurement process where sustainability is the guiding principle. At all times the sustainable procurement process should be in accordance with the corporate sustainability policy to ultimately prevent friction between the policy and the procurement process.

FR 522

856 6.1 Ed What do sections 3, 4 and 5 refer to ? Delete references to these sections

NL 523

856 6.1 6.1 ed The word ‘senior’ is out of place Remove ‘senior’

NL 524

856 6.1 6.1 ed Management and decision - makers of what? Management or decision makers who create conditions in the area of procurement in their


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own organization

NL 525

856 6.1 ed The numbers are not referring to the right section/clause

BR 526

856 - 857

6.1 1st paragraph

ED There are errors on section numbers reference.

Sections 4 and 5 focus on strategic and organizational aspects of sustainable procurement for senior management and decision makers. Section 6 addresses the procurement process and is intended for procurement professionals and similar or associated functions.

BR 527

856 - 858

6.1 ED This text is more appropriate to the introduction.

Move text to introduction clause

NL 528

857 6.1 6.1 ed Procurement professionals and similar or associated functions of what?

Change: Procurement professionals and similar or associated functions who are responsible in the area of actual procurement for their organization

US 824

857 Integrating sustainabilit

y into the Proc

Process

6.1, para 1 Ed Refers to Section 5, should be Section 6 Update

NL 529

859 6.1 6.1 te Why? Miss the why?

BR 530

860 - 861

6.1 ED The main idea is to integrate sustainability into the existing procurement process that already exists within the organization. It’s better to say that directly.

Replace the text

When integrating sustainability into the procurement of goods and services, a recognised procurement process should be


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used.

The adoption of sustainable procurement should be in the form of integrating sustainability in the organization’s current procurement process, instead of creating a parallel specific “sustainable procurement process”.

US 825

860 6.1 2nd para Editorial Replace ‘integrating’ with ‘embedding’

NL 531

861 6.1 Figure xx ed Xx should be a number both in text as the figure itself

Figure 1

IFPSM 532

862 6.1 Figure xx ge Use the final structure as agree in the resolution (Brazil) this document is about sustainable procurement not about general professional procurement

Chapter6:

Integrating sustainability into the procurement process(es)

1.1. Sourcing and preparation of the process

1.2. Sustainability aspects of goods or service specification

1.3. Sustainability aspects of supplier selection

1.4. Sustainability aspects of contracting, ordering and monitoring

1.5. Evaluate, adjust and improve performance on sustainability aspects

NL 533

862 6.1 Figure xx ge Use the final structure as agree in the resolution (Brazil) this document is about sustainable procurement not about general

Chapter6:

Integrating sustainability into the procurement


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professional procurement process(es)

1.6. Sourcing and preparation of the process

1.7. Sustainability aspects of goods or service specification

1.8. Sustainability aspects of supplier selection

1.9. Sustainability aspects of contracting, ordering and monitoring

1.10. Evaluate, adjust and improve performance on sustainability aspects

SE 534

863 Figure xx, 6.1

te The text should be applicable to both public and private sector.

Change “Selection” to “Contract awarding” as it appears in the figure and text.

EOS/ EG 535

865 6.2 Planning

6.2.1 General

te It is necessary after identifying, analyzing and evaluating the risk(s) to take actions to prevent its/their occurrence.

Adding a fourth key element to the procurement process i.e. risk management and to be inserted after "Risks and opportunities" .

NL 536

865-993 6.2 Te One could argue much of this chapter belongs in chapter 5. In any case some of the text is redundant, whether it will be chapter 5 or 6

Consider where the topic procurement strategy belongs and remove redundant text:

• 6.2.2 parts on mapping, working groups, etc.

6.2.3 stakeholder consultation (and diagram)

NL 537

867 6.2 6.2.1 ed project or strategy Delete: “or strategy” or change: or product group


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BR 538

867 6.2.1 TE To clarify that to integrate sustainability into the process some things are need. It’s also good to show where are the main interfaces of the process and the sustainability issues and ISO 26000 core subjects.

Include text:

It is assumed that the organization already has a sustainable procurement policy and also has made some kind of prioritization. The approach to SP has already been established. Therefore, what is need then is to start buying according to the SPP and the prioritization. This is done incorporating sustainability in the procurement process.

The Figure XXX.2 shows the relation between the SPP, the prioritization, the approach and the procurement process.

BR 539

867 - 868

6.2.1 ED In the following section, change “you” by “organization”

Replace 'you' by 'the organization'

This stage is aimed to define the best sustainability strategy for a specific procurement project or strategy. While it might take time initially, it enables you the organization

US 867 Inte sust into the proc

6.2.1 Ed Awkward English syntax Sentence could read, “This section is intended


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826 process to define…”

NL 540

868 6.2 6.2.1 te These points are part of the elements 874 and further

NL 541

874 6.2 6.2.1 te Three elements There are more elements …

NL 542

874 6.2 6.2.1 ed to the process To the sustainable strategy

BR 543

874 - 884

6.2.1 ED The wording “process” is not clear of what process we’re talking about.

Besides, we think to have a descriptive text before the set of proposed questions.

We prefer to talk of “sustainability risks and opportunities”

Replace the text:

There are three key elements to the process consider in planning the purchase:

• Sustainability Risks and opportunities: the identification of the relevant sustainability issues related with the product or service to be purchased. Some questions should be made, such as: What are the major sustainability risks and opportunities related to this specific good or service? What plans can we be put in place to mitigate these risks and/or seize these opportunities? The starting point for this process is the priority map prioritization described in Section 5.

• Business need: what is the actual need that led to the purchasing? How do our the requirements lead to increased sustainability impacts? Some questions should be made, such as: Is there really a need to buy such product or service? Can we the organization change our the requirements to minimise the sustainability issues related se impacts and how can we do that be done? We It should be noted the advice in Section 3 that


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demand management is important and the most sustainable option is not to purchase at all.

• Market analysis: the feasibility of the supply of actual products or services complying with the requirements that will be set, including those addressing the sustainability issues, should be investigated. Some questions should be made, such as: What is the capability of the supply market to address our the organization’s sustainability risks/opportunities and to meet our the business needs? Do we Do the organization need to build the capability of our existing suppliers or to find new ones? Can the market exceed our the expectations?

NL 544

875 6.2 6.2.2 ge Risk and opportunities These are two different strategies / elements

NL 545

880 6.2.1 6.2.1 Ge The sentence should be removed, purchasing is not per definition ‘bad’

We should note the advice in Section 3 that demand management is important and the most sustainable option is not to purchase at all.

Business need: how do our requirements lead to increased sustainability impacts? Can we change our requirements to minimize these impacts and how can we do that?

•

IN 546

886 6.2.1 ed project procurement strategy project procurement strategy

BR 547

886 - 887

6.2.1 ED The wording “overall project sustainable procurement strategy” is not clear in the context of this chapter. We suggest simplifying the text to overcome doubts about mentioning an “overall project”.

Replace the text:

All these elements should then be embedded in your overall project a sustainable procurement strategy, so that sustainability considerations become part of strategic


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decision making

NL 548

888 Figure xx ed Xx should be a number Figure 2

BR 549

888 - 890

6.2.1 ED To clarify Replace the text in the figure and in the sub clause:

Assess sustainability risks and opportunities

NL 550

890 6.2.2

6.2.3 6.2.2 6.2.3

ed Swich the paragraphs.

First: Business needs – 6.2.2

Second: Market analysis – 6.2.3

TH 551

890 6.2.2

ed “asses” should read “assess”. Replace “6.2.2 Asses risks and opportunities” with “6.2.2 Assess risks and opportunities”.

INTECO 552

894 ed It mentions a “heat mapping, described in section 4” but there isn´t any mention to heat mapping in section 4, maybe it is the one mention in section 5.

BR 553

894 - 898

6.2.2 ED To clarify the purpose of conducting a sustainability risks and opportunities analysis on the product itself and clarify that now we are not talking about the prioritization, just use the same technique to identify the major issues of the product.

Include the text:

The prioritization, Heat mapping, described in section 5, was made in relation to the sustainability issues that are relevant to the organization, according to the SPP. Many times, that prioritization is made on great classes or categories of products and services. Once a product or service category is prioritized, then the sustainability risks and opportunities of the individual products and services should be analysed against the same sustainability issues. Is a useful technique to undertake such an analysis. In other words,


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the heat mapping prioritization completed when ‘setting priorities’ of the organization considers the category of product/service as a whole.

NL 554

894-906 6.2 6.2.2 te Delete Heat mapping see earlier comment NL on line number 530-584

Rewrite to the practice of procurement for assessing risk and opportunities. Explain at a tactical level how . Provide tooling. For example CSR risk checker of the Netherlands.. Also terms used in line numbers 912-916. Further explanation is needed.

BR 555

900 - 901

6.2.2 ED To clarify the need of a multidisciplinary approach.

Include ' a multidisciplinary' in the text:

This analysis should not be done in isolation. Quite the opposite, identifying the real sustainability issues requires a multidisciplinary approach to capture knowledge from:

BR 556

908 6.2.2 TE There are various ways to achieve this result. A small WG is a good one but we should prevent to say how something should be done. We should focus on “what”.

Remove the text

A small working group should be formed to carry out this exercise.

BR 557

908 - 910

6.2.2 ED Clarifying the text Replace the text:

In addition to identifying sustainability risks and opportunities, the group organization should consider the potential solutions and mitigation plans that could be implemented.

BR 558

912 - 913

6.2.2 TE The use of the concept of life cycle should be reinforced, as a complementary to sustainability risk analyses. The life cycle approach should always be used.

Together with sustainability risk and opportunity assessment, Using a life cycle approach should be used can be helpful at this stage.

BR 559

915 - 916

6.2.2 - GE Expand the explanation Even though the technique is mostly used to assess environmental impacts (e.g. through the ‘life-cycle assessment’ method), the same


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approach can be applied to all sustainability issues, in other words, an analysis that take also into account economic and social dimensions.

NL 560

917 6.2.3 6.2.3 ed The paragraph name should match the name in 6.2.1

Business needs

FR 561

917 6.2.4 and 6.2.3

Te It is more logical to deal with ‘analyse supply market’ before ‘analyze needs’ Invert 6.2.4 and 6.2.3

NL 562

919 6.2.3 ed Sentence does not add value to the message. Delete: This enables ….. the need.

BR 563

919 - 920

6.2.3 ED To clarify. This enables the key sustainability risks and opportunities to be addressed by robustly challenging the need

FR 564

931 6.2.3 Te Other design technics can be relevant Add Functional economy and eco design

BR 565

931 - 932

6.2.3 TE Do not refer to specific technical as “value engineering”

Exclude rows 931 and 932

BR 566

934 6.2.3 ED To clarify Secondly, you the organization should consult key internal stakeholders

IN 567

934 6.2.3 ed Secondly, you should consult key internal stakeholders

Secondly, you the organization should consult key internal stakeholders. The change to be uniformly applied in the document.

NL 568

934-943 6.2.3 Ge Redundant with 751-757 Merge (belongs in chapter 5 but graphic is


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better)

BR 569

938 - 939

6.2.3 ED To clarify At this stage, you the organization may also think about nominating a ‘champion’ to support your this approach.

NL 570

940 6.2.3 Figure xx ed Xx should be a number Figure 3

BR 571

940 - 945

6.2.3 TE The figure and example doesn’t add very much. Could create confusion without further explanation.

Remove the text, the figure and the table

NL 572

941 6.2.3 ed Some introduction to the table with an example of cleaning service to highlight how the example contributes to the text.

Figure xx demonstrates the relation between the stakeholders’ interest of a process versus its power over this process, and how to involve/engage them in the implementation of sustainable procurement.

CA 573

943 & 6.3 ge An interesting approach to sustainability risks management is introduced on page 27 where it is suggested to identify demand-related opportunities and to engage stakeholders into an action plan. The proposed approach, however, is somewhat simplistic and hardly applicable to the GoC’s governance structure. Capitalizing on demand-related opportunities to meet sustainability targets looks quite challenging in such context. Section 6.3 (p.29) on definition of specs to include sustainable aspects raises similar issues.

930 - Insert the following paragraph after the bullets: Where external stakeholders participate in determining the demand like for some government organizations, it may be necessary to engage them upfront in examining options.

994 - No change. Second paragraph under 6.3.1 addresses complex governance such as governments.

NL 574



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NL 575

946 6.2.4 6.2.4 ed The paragraph name should match the name in 6.2.1

Market analysis

BR 576

947 - 950

ED To clarify Replace the text

The objective is to gain a deep understanding of the existing and future capability of the supply market to support your the organization’s sustainability needs, while providing the same or improved level of price and quality of service. Make also sure you the organization understands if your the sustainability requirements reduce the level of competition and/or your the organization’s buying power.

NL 577

949 6.2.4 Te Sustainability requirements can also increase the level of competition

Add ‘increase’

BR 578

951 6.2.4 TE Make the point of Public procurement and some constrains that can exist there.

Include the text:

In some cases, there are some constraints to conduct the analysis of the supply market. This is particularly the case of public organizations, where they can be subjected to specific legislation for procurement. Sometimes, legislation limits the ability of the organization to interact with potential suppliers

SE 579

952-95-4 6.4.2 te Current text may appear stigmatizing. Change “disadvantaged populations and communities” to “neglected and structurally discriminated against..”. Delete examples in brackets.

BR 580

952 - 953

6.2.4 TE/ED Always refer to the organization. Substitute “priority map”, which is a concept that wasn’t explained yet (despite is easily understandable) by “prioritization”.

Replace the text:

If these issues are identified as significant in the priority map prioritization, you the organization should make sure your that the


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market research includes local suppliers

FR 581

955 6.2.4 Te Need for effective bridges (effective connection objective with organizations such as the 0ECD) and for increased coherence with other international reference frames which support and strenghten ISO 26000 - ILO (already integrated) - OECD: use precise recommendations



Henke) Note that ISO 26000 has to be dynamic and include evolution of best practices (cf 6.1 of ISO 26000)

Add “When doing that, care must be taken of OECD recommendations to prevent from unsecure and opaque outsourcing :

• Formalize commitments

• Independent, effective, comprehensive audits

• Strengthen penalties for outsourcing unreported

• Train the buyers to identify risks

• Create a website for suppliers

• Develop effective partnerships with strategic suppliers to secure the supply chain

• Communicate on audit results”

BR 582

960 - 969

6.2.4 ED Fits better there. Move text to Clause 5 (Enablers)

INTECO 583

961-963 We suggest to set the tool as an example in an annex

It’s important to explain what is purchaser ambition on the footnote or similar.

NL 584

962 6.2.4 te Figure xx market engagement matrix on line 962 is very close to figure xx stakeholders interests and influence matrix on line 940; explain the differences.

Explain the differences between matrix 962 and matrix 940. And / or introduce the matrix with a more specific text

NL 585


BR 586

974 6.2.5 ED Always refer to the organization. Replace the text

The procurement strategy describes how to


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deliver the best outcome for your the organization’s procurement.

NL 587

974-975 6.2.5 Remove text, does not ad d value Remove text, does not add value

BR 588

981 6.2.5 Paragraph 2 TE We recommend to insert the word RECYCLING as an example of strategic directions related to sustainability.

The recommended demand-related approach (elimination, reduction, reuse, RECYCLING),

NL 589

985 6.3 ge Specifications Sustainability aspects of goods or service specification

BR 590

990 6.2.5 ED To clarify. The organization should make sure Decisions SHOULD BE are supported and agreed by all key stakeholders

US 827

992 Inte sust into the proc

process

6.2.5., last para

Tech “Gateway Review” – is that widely understood This is a widely used term in formal project management. I’d be OK including it, if we think the term is widely understood. Or perhaps provide short definition of the gateway review process?

BR 591

994 6.3 ED Specification is a type of document that conveys the requirements. According to the characteristics of the organization and also of the characteristics of the requirements (what is needed to be addressed as a result of the sustainability issues), sometimes these requirements will put in another documents such as conditions for tender, conditions for prequalification and even in the contract. Is better to talk here of the more generic category, that is the requirements.

Replace Specifications with Requirements

NL 592

994 6.3 6.3.1 Te This should be more obligatory. Once a decision is taken on the procurement strategy, the specifications (…) can be


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finalized accordingly and should contain sustainable elements in order to ensure sustainable aspects are incorporated into the purchasing decision.

BR 593

996 6.3.1 - TE The logic is the reverse of what was stated here – first you specify, then you can finish your planning accordingly.

Once a decision is taken on the specification, the procurement strategy can be finalized by incorporating sustainability requirements and market information about available sources.

BR 594

996 - 1001

6.3.1 TE Specification is a type of document that conveys the requirements. According to the characteristics of the organization and also of the characteristics of the requirements (what is needed to be addressed as a result of the sustainability issues), sometimes these requirements will put in another documents such as conditions for tender, conditions for prequalification and even in the contract. Is better to talk here of the more generic category, that is the requirements.

Avoid using “specs” instead of specifications, for clarity. Avoid to use synonymous. Use always the same word to express an idea.

Include the text:

Once a decision is taken on the procurement strategy, the specifications requirements should be defined and put in a document or set of documents (or sometimes specs, brief or scope of work) such as a specification and other applicable documents can be finalized accordingly. Sometimes there will be only one document, the specification, but in some other cases there will be different documents addressing the requirements, accordingly with the organization’s culture, such as a draft contract, the establishment of prequalification criteria etc... It is possible that the specification will have the requirements that are directly related with the product or service and other documents, such as the contract and other tender documents, will have the requirements applicable to the production and process methods or to the supplier’s organizational requirements.

When establishing the requirements, the results of the sustainability risks and opportunities should be considered; including those related with ISO 26000’s core subjects. The sustainability aspects should be translated in objective and verifiable


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requirements. Some of these requirements apply directly to the product or service. Some other will apply to the production and processes methods used to deliver the product or service and some others to the supplier organization in itself.

Using the specification and related documents to incorporate sustainable elements is the most effective means of ensuring sustainable aspects are incorporated into the purchasing decision.

Inclusion of sustainability requirements in specifications should be done in coordination with key stakeholders, in order to reflect practical and technical considerations.

DS 738 1001

6.3.1 Te Make sure that suppliers are at the market Edit text accordingly

NL 595

1003 6.3.1 6.3.1 te The items in 6.3.2 should be addressed as one bullet tot this list. The text in 6.3.2 can then be skipped

IN 596

1004 6.3.1 te Specs should be compliant with laws and fundamental rights defined in ISO 26000

Specs should be compliant with state & country laws and fundamental rights defined in ISO 26000 are majority covered.

NL 597

1004 6.3.1 ed “Laws and fundamental rights” does not form the correct reference to ISO 26000.

Remove ‘defined in ISO 26000’

Add bullet: Apply the “seven CSR core subjects of ISO 26000”.

US 828

1004 Inte Sust into the proc

process

6.3.1, third para

Ed Spell out “specifications”

US 1004 6.3.1 First bullet Technical The language makes it sound like the Spec Specs should be compliant with local laws and


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829 needs to be compliant with laws defined in ISO 26000

fundamental rights social responsibility defined in ISO 26000.

BR 598

1004 - 1008

6.3.1 TE To be consistent with “specifications and other requirements documents”.

Always refer to the organization.

Replace the text

• Specifications and other requirements documents should be compliant with laws and fundamental rights such as those defined in ISO 26000,

• Define the sustainability requirements without any risk of bias or connivance,

• All specifications and other requirements documents should be transparently and effectively communicated to potential suppliers,

• Allow for fair competition, and doing so pay particular attention to SMEs and their capacity to respond to your the organization’s requirements.

NL 599

1007 6.3.1 te Extra sentence, to give room for more creative offers.

Describe your relevant sustainability goals to enable bidders how their proposals contribute to your companies’ sustainability ambitions.

IT 600

1007-1008

6.3.1 te This sentence must be better clarified. We cannot expect that for all kind of purchases the SMEs can be able to answer.

CO 601

1009 6.3.2 Te Make technical specifications using the specific technical standards to ensure functionality. In the global market there similar international and national standards which can be validated to ensure equal treatment of suppliers.

BR 602

1009 6.3.2 TE Specification is a type of document that conveys the requirements. According to the characteristics of the organization and also of

Replace the text

Types of specifications requirements


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the characteristics of the requirements (what is needed to be addressed as a result of the sustainability issues), sometimes these requirements will put in another documents such as conditions for tender, conditions for prequalification and even in the contract. Is better to talk here of the more generic category, that is the requirements.

The text refers to types of requirements, not of specifications. All the examples are of technical specifications, at least in many countries, all those are referred as “technical specifications”.

The description of “technical specifications” there is of a descriptive specification, the kind of what is called “design standards” compared with “performance standards” in the terminology at the WTO/TBT, as an example or also as used in ISO Guide 2.

NL 603

1010-10-19

6.3.2 Te Where do specification on company behaviour belong? (vs product specs – i.e. bad companies selling bad products and good companies selling bad products)

Pending

BR 604

1010 - 1017

6.3.2 TE Specification is a type of document that conveys the requirements. According to the characteristics of the organization and also of the characteristics of the requirements (what is needed to be addressed as a result of the sustainability issues), sometimes these requirements will put in another documents such as conditions for tender, conditions for prequalification and even in the contract. Is better to talk here of the more generic category, that is the requirements.

The text refers to types of requirements, not of specifications. All the examples are of

Replace the text

There are different types of specifications requirements that can be used:

• Technical Descriptive: those that specify a physical characteristic of the product or service (= attribute), e.g. recycled content, mercury-free, or the way in which the product or service is manufactured or delivered (= process) e.g. organic or sustainably managed timber and fisheries.

• Performance: define the performance standards to be met by the product or


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technical specifications, at least in many countries, all those are referred as “technical specifications”.

The description of “technical specifications” there is of a descriptive specification, the kind of what is called “design standards” compared with “performance standards” in the terminology at the WTO/TBT, as an example or also as used in ISO Guide 2.

It was included “or services” to be consistent with the use of products and services in the whole standard.

deliverable service. For example, standards of care and number of clients for a social care service

• Functional: define the proposed function to be fulfilled by the product or service required. For example, the strength and durability of concrete to be supplied, energy/fuel efficiency,

NL 605

1013 6.3.2 Ed Sentence should end with ‘,’ instead of ‘.’. Change into ‘,’

NL 606

1015 6.3.2 Ed Sentence should end with ‘,’ Add ‘,’

NL 607

1017 6.3.2 Ed Sentence should end with ‘.’ Instead of ‘,’. Change into ‘.’

BR 608

1019 – 1022

6.3.2 TE Requirements instead of specifications Replace text

Generally, a combination of performance and functional specifications requirements are preferred as they enable suppliers

SE 609

1021 6.3.2 te Universal design should be part of examples. Add “universal design” after “better safety for users”.

BR 610

1022 - 1023

6.3.2 TE Requirements instead of specifications Be careful when using technical descriptive specifications requirements


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NL 611

1023 6.3.2 ed Functional specifications can open windows for alternative techniques or business models, that the tenderer never thought of.

BR 612

1024 6.3.3 TE The term “compulsory” is many times associated with the idea of what is required by legislation. For that reason, we suggest to use the term “minimum”, because these are the minimum requirements to comply with.

On the same direction, “preferable” would better fit with the ideas addressed, because they are not in nature “optional”, but much more preferable or complementary. That’s why we suggest using “preferable”.

Compulsory Minimum and optional preferable specifications requirements

CA 613

1024 6.3.3 ge Section 6.3.3 about compulsory and optional specifications (pp.30-31) reminds the reader of the risk to restrain the competition and exclude capable suppliers in limited markets. The use of optional specs is recommended in such cases.

1024 - No change.

BR 614

1025 – 1028

6.3.3 TE Requirements instead of specifications, in order to be more general.

Specifications Requirements can be:

• Compulsory minimum …

• Optional preferable …

US 830

1026 6.3.3 First bullet Technical As written this feels like compulsory requirements can only be about product performance

Compulsory when they establish minimum acceptable product or sustainable performance,….

BR 615

1032 6.3.3. - TE It is not the buyer that decides the specification of what will be bought, but the requester area. During planning, there will be opportunities to develop any other types or forms of specification that may be fit.

In addition to these two main options, during planning step it may be considered using additional techniques such as variants in order to reward better alternative solutions.

NL 616



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CA 617

1042 6.3.4 te Additional information should be provided to explain external verification mentioned in Clause 5.3.6.

Change title from

‘Third party certifications’ to Enhancing the credibility of suppliers reports and claims about sustainability

Add new information after line 1077:

There are many ways that a supplier can enhance the credibility of its reports and claims about sustainability, including:

. making reports about performance on sustainability comparable both over time and with reports produced by peer organizations, recognizing that the nature of the report will depend on the type, size and capacity of the organization;

. providing a brief explanation of why topics omitted from reports are not covered, to show that the organization has made an effort to cover all significant matters;

. using a rigorous and responsible process of verification, in which the data and information are traced back to a reliable source to verify accuracy of that data and information;

. processes used to develop the statistics available; and

. reporting conformance to the reporting


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guidelines of an external organization.

INTECO 618

1042 6.3.4 Include a footnote:

The application of a certification from a third party should be assessed if applicable according to the law of the country, the organizational policy or the characteristics of the supply chain.

NL 619

1042 6.3.4 6.3.4 Ge The paragraph can be shortened to just stating there is third party certification and a reference to specific norms.

SN 620

1042 6.3.4 In this sentence it should be underlined that eco and fair trade labels vary in terms of requirements, and that some of them might actually not meet the company’s newly established standards.

Before using a label to inform a purchasing decision, it is important to check what criteria the label requires and who awarded the label – this is to check that it is truly impartial and to ensure that it meets your sustainability objectives.

BR 621

1042 – 1053

6.3.4 TE The title is not appropriate looking to the text, since it deals not only with certification, but also with other types of declarations.

Besides, according to ISO conformity assessment, certification is always a third party conformity assessment and should be avoided the use of expressions such as “self-certification”

The consideration of the contribution of Eco labels and other types of certifications is divided in two aspects:

- to consider the criteria used to award the labels as reference to establish the requirements;

- the possible acceptance of these labels as an evidence of conformity to the requirements

Third party certifications Consideration of technical standards, and other sources of requirements, and conformity assessment

Different initiatives aim to assure better to prove through a third party the sustainability performance of a product/service or process related with specific aspects. Some of these initiatives focus on environmental issues, others on social aspects, on claimed sustainability aspects and others on quality or safety characteristics. Some of these initiatives allow the use of seals, marks or labels to identify those products or services that comply with the requirements set for those aspects. In many cases, the requirements are set in technical standards. They can use International, regional or international standards and also private


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Besides, there are other standards and regulations against which there are certifications in the market place. The consideration of such initiatives falls also in the two aspects.

It’s useful to make the point and clarify the use of such instruments.

standards. In some cases, they use as technical references for the aspects related with the claim what is called criteria. In some cases, the award of a mark, label or seal is the result of an independent third party assessment and in some other cases is mainly based in a self-claim.

They appear to offer a quick solution for buyers looking to specify sustainability requirements for processes, goods products or services. However, they still cover only a small range of industries and products/services.

Care should be taken when using these initiatives due to the different level of confidence that each specific initiative can have.

Labels are used to identify products or services (mostly operational and indirect spends) that have been certified as having certain properties. They are typically voluntary and awarded by impartial third parties.

For more information on Eco labels, see Global Eco labelling Network (GEN): www.globalecolabelling.net and ISO Standards 14020, 14021, 14024 and 14025

IT 622

1042-1076

6.3.4 te The standard does not mention the examples of framework for supply chain audit based on mutual recognition, like Sedex, AIM-Progress.

In our opinion, this kind of initiative, currently the most used to assess suppliers’ performance wrt sustainability, should be described together with the other certifications, being based on the same principle of “third party activity”. This concept can be included in this chapter or in other


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chapters (like the following, in relation to the Selection of suppliers).

US 831

1045 6.3.4 First paragraph

Technical This opening paragraph seems to be creating a bias against the use of 3rd party certifications. ISO has a standard now that helps define a good third party certification – ISO 17065. Why not utilize this reference and cite facts instead of opinions.

…..They appear to can offer a quick solution for buyers looking to specify performance or sustainability requirements for processes, goods or services. However, you need to ensure you understand what the verification/certification is for before simply referencing any third-party. they still cover only a small range of industries and products/services.

NL 623

1045 6.3.4 Te Add CSR issues. Most certificates cover only 1 or 2 of the 37 CSR issues. For many of the 37 issues no certification is in place at all.

However, they still cover only a small range of industries, products/services and CSR issues.

INTECO 624

1047 6.3.4 We suggest not mentioning directly just one example of eco labeling and create an annex with a detailed an expanded list

CL 625

1047 6.3.4 Paragraph 2 te It is not good to give publicity of particular organizations. I recommend alone to indicate ISO standards. For more information on ecolabels, see Global Ecolabelling Network (GEN): www.globalecolabelling.net.

For more information on ecolabels, see ISO 14020

SN 626

1047 Third part … te Fair Trade Labels should be included with a short explanation and referring to UNCTAD.

Fair trade label are …..

For more information on fair trade labels see United Nations Conference on Trade and Development (UNCTAD): http://www.unctad.info.

US 832

1052 6.3.4 2nd paragraph

Technical Why aren’t we using ISO 17065 to inform this discussion.

….it is important to check what criteria the label requires and who awarded the label to check that it is truly impartial. Third-party


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certification programs that obtain accreditation to ISO 17065 have gone through a rigorous process to prove their impartiality. …….

FR 627

1053 6.3.4 Te Direct or indirect references to any organization have to be avoided

Replace the reference to the website with reference to ISO 14024, ISO 14021 and ISO 14025

IN 628

1053 6.3.4 ed see Global Ecolabelling Network (GEN):

1053 www.globalecolabelling.net.

see Global Ecolabelling Network (GEN):

1053 www.globalecolabelling.net. Or any other state/ country level body

BR 629

1055 - 1058

6.3.4 TE The title is not appropriate looking to the text, since it deals not only with certification, but also with other types of declarations.

Besides, according to ISO conformity assessment, certification is always a third party conformity assessment and should be avoided the use of expressions such as “self-certification”

The consideration of the contribution of Eco labels and other types of certifications is divided in two aspects:

- to consider the criteria used to award the labels as reference to establish the requirements;

- the possible acceptance of these labels as an evidence of conformity to the requirements

Besides, there are other standards and regulations against which there are certifications in the market place. The consideration of such initiatives falls also in the two aspects.

Labels are different from declarations, which are a claim which indicates the performance aspects of a product or service. Environmental declarations are for instance increasingly being used by organizations to communicate the environmental performance of goods and services in a credible and understandable way. Such statements are intended to be relevant, verified and comparable to inform buyer’s decision making.

There are two different uses of this kind of labels in sustainable procurement. One way is to use the criteria based on which the Eco label is awarded as a basis to set the technical requirements for the product or service. Therefore, any product or service that met the requirements can be purchased, even without been awarded the Eco label.

The other possible use is to establish as a condition the product or service been awarded with the Eco label.

It should be noted that in some cases the second possibility is not allowed, usually due


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It’s useful to make the point and clarify the use of such instruments.

Labels are a type of declaration.

It’s useful to make the point that in some circumstances there are some restraints in the use of these tools.

It’s useful also to give information about guidance on Eco labelling and conformity assessment in ISO documents.

to legislation constraints. This is frequently the case of some legislation applicable to public procurement in some regions.

The same concept applies to the other examples of certifications, marks, seals and labels.

In an opposite situation, sometimes legislation requires a specific certification for a product or service. This is commonly the case with standards related with safety. In these cases, the requirements should require not only the fulfilment of the requirements set in the specific standard but also the proper certification.

There are several international standards related with Eco labelling (the ISO 14020 series) and conformity assessment (the ISO/CASCO standards and guides). Those documents give guidance on the use of conformity assessment procedures and the selection of the more appropriate conformity assessment tools to be considered.

FR 630

1060 6.3.4 Te Help public procurement to understand how management system can comply with regulation

Add at the end of paragraph : “MS can help in multi-criteria analysis or selection steps”

BR 631

1060 - 1064

6.3.4 TE It’s a better description of Management Systems Standards and what they deliver.

Management systems enable organizations to improve ensure their performance related with specific subjects through proper management together with a process of continuous improvement. An oversimplification is "Plan, Do, Check, Act". A more complete system includes accountability (an assignment of personal responsibility) and a schedule for activities to be completed, as well as auditing tools to implement corrective actions in


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addition to scheduled activities, creating an upward spiral of continuous improvement.

INTECO 632

1070 Remove references of standards and include issues like quality, environmental, security and others

FR 633

1071 6.3.4 Ed An ISO standard is currently developed Replace OHSAS 18001 with Pr ISO 45001

NL 634

1078 6.4 6.4 ge Selection Sustainability aspects of supplier selection

SE 635

1078 Heading te The text should be applicable to both public and private sector.

Change “Selection” to “Contract awarding”.

NL 636

1078 6.4.1 ge This paragraph is quite general of character. In each step of the procurement process a clear relationship with sustainable procurement should be made and explained how this should be brought into practice.

Describe sustainable procurement in practice.

SE 637

1080 6.4.1 ed The letter T is missing.

BR 638

1080 6.4.1 Paragraph 1 ED he objective …. The objective …

IN 639

1080 6.4.1 ed he objective The objective

NL 1080 6.4.1 Ed ‘he’ must be ‘The’. Change into ‘The’.


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640

BR 641

1080 - 1083

6.4.1 TE The selection is not to evaluate the ability of the suppliers to contribute to sustainability objectives. Since we are integrating sustainability into the procurement process, the objective of selection didn’t changed. What happens is that sustainability issues are making part of the organization’s requirements.

Replace the text

The objective of this stage is to evaluate the capacity of suppliers to comply with or exceed the organization’s requirements contribute to the sustainability objectives of the organization through supply of products or services. Therefore, when integrating sustainability into the procurement process, it means also the capacity of the supplier to contribute to the organization’s goals on sustainability through supply of products or services. Buyers should not evaluate suppliers on their approach of sustainability in general, but on specific requirements related to the customer/supplier relationship, particularly to the products or services to be purchased and used...

DS 739 1080

6.4.1 Ed He The

US 833 1080

Inte Sust into the proc

process

6.4.1 Ed Missing “T” at beginning of paragraph Proofer should catch

BR 642

1087 – 1090

6.4.1 TE Clarifying the concept of integrating sustainability into the purchasing process. Not creating a new one.

Use always organization.

• Prequalification usually focuses on overall capabilities of the supplier to deliver sustainability the desired outcomes,

• Tendering usually focuses on the capacity and commitment to deliver detailed and specific sustainability requirements, including sustainability requirements, for the product and service, which are described in the specs or other documents.

BR 643

1092 – 1094

6.4.1 TE When conducting supplier selection, make sure you the organization respect all legal


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requirements (e.g. public procurement regulations) and that you it promotes promote open and fair competition between potential suppliers. In doing so, the organization should pay particular attention to

NL 644

1099 6.4.2 6.4.2 Te The bold stated items can just be summed in bullets and that’s enough, no elaboration is required.

The bold stated items can just be summed in bullets and that’s enough, no elaboration is required.

NL 645

1099 6.4.2-6.4.5 Te This determines to much in detail HOW a company should do its selection process.

Just determine WHAT should be done in 6.4.1.

BR 646

1100 – 1102

6.4.2 TE Make the linkage with ISO 26000 core subjects.

Clarify the need to transparency on the prequalification requirements and highlight the need to legal aspects related with prequalification.

Replace the text

The purpose of prequalification is to gather information about the capability of suppliers to participate in tenders and in some cases to evaluate tenderers against go/no go criteria. The strategy needs to identify any sustainability criteria subject to this condition, including applicable ISO 26000’s core subjects, to ensure that it is agreed with stakeholders and made clear to the market.

The requirements for prequalification should be clearly established and take into account the applicable sustainability aspects. The organization should take into consideration:

- the sustainability risks and opportunities that are related with the supplier’s organization;

- the applicable legislation.

NL 647

1104 6.4.2 te Standards and codes are relevant methods for risk mitigation. However, we see many suppliers sign without further regard of the content of those codes. We note codes do not

Change last sentence. ‘As there are limits to imposing codes of conduct on suppliers it is recommended to require suppliers to develop their own sustainability code of conduct or


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necessarily stimulate suppliers to evaluate themselves

charter.’

BR 648

1105 - 1106

6.4.2 TE Change mandatory to minimum. Replace the text

for working conditions and human rights may be a mandatory minimum criterion.

SE 649

1106 ge/te ILO standard must be a mandatory criterion. Respect of labour standards is crucial and is required by ISO 26000.

Replace the word “may”. Insert the word “should” instead.

IN 650

1106 6.4.2 ed conditions and human rights may be a mandatory criterion

conditions and human rights may be a mandatory criterion.

BR 651

1106 – 1107

6.4.2 TE Rewording for more clarity. Replace the text

Sometimes, the An organisation establishes a sustainability code of conduct or charter with all the generic sustainability requirements. In this case, it may also decide to require suppliers to sign their own sustainability code of conduct or chartert this document.

BR 652

1109 – 1110

6.4.2 TE Levels of confidence in the conformity assessment are the relevant concept.

The degree of evidence is, in fact, different levels of confidence and risk of non-conformity that the organization accepts.

In this case is necessary a better definition for CONFORMITY ASSESSMENT

Organizations may choose different levels of confidence in the conformity assessment of the requirements established in the to use different degrees of evidence at various points across the procurement process

BR 653

1110 – 1113

6.4.2 TE Levels of confidence in the conformity assessment are the relevant concept.

The degree of evidence is, in fact, different level of confidence and risk of non-conformity that the organization accepts.

In this case is necessary a better definition for CONFORMITY ASSESSMENT

At the prequalification stage, it might be sufficient to request evidence of ethical trading and labour policies or by means of self-certification supplier’s declarations of conformity (self-claims) on those subjects. However, as the process progresses and potential suppliers are further shortlisted by the tender process, third-party audits and


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Instead “self-certification”, use the expression “suppliers declaration of conformity”.

Instead of a mention to third party auditors or specialist in-house auditors, is better to clarify and introduce the idea of 2nd party and 3rd party assessment.

other means of collecting evidence of conformity (second party or third party assessments) ors or specialist in-house auditors might then be used to provide further assurance. The choice of the most appropriate conformity assessment tools should be the result of a risk assessment of the consequences of a failure on the fulfilment of the conformity of the requirements.

NL 654

1111 6.4.2 What is meant by ‘self-certification’. We assume this should read self- assessment

Change ‘self-certification’. into self- assessment

PL 655

1112 6.4.2 3rd para (...) be used to provide further assurance.

Organizations shall avoid requesting from suppliers undergoing multiplied certification or auditing schemes. (Suppliers are often asked to bear the cost of several audits with similar scope order by holders of verious Code of Conducts)

Delete the last sentence

ITAIPU

656

1115 – 1116

6.4.2 TE To clarify that we are integrating sustainability into the procurement process. Talking about “other business criteria” can led to the idea that there are two sets of requirements: “sustainability requirements” and “business requirements”…

Use minimum instead of mandatory (or compulsory)

Replace text

Some prequalification criteria may be discretionary and can be used with other business criteria to inform a weighted evaluation to further shortlist suppliers who comply with all the mandatory minimum criteria.

NL 657


SE 658

1121 ed Text duplicated. Delete one “above”.


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NL 659

1121 6.4.2 Ed Two times ‘above’. Delete one.

BR 660

1121 - 1126

6.4.2 TE Use requirement instead of standard (to avoid confusion with technical standards).

Clarify, use sustainability issues and avoid a new concept (sustainability credentials).

Replace the text

The example above above could be used as a go/no go condition, with “Good” as a minimum standard requirement, or as a way of shortlisting if there are no minimum mandatory criteria.

If suppliers are deselected, it is good practice to formally notify them and provide a debrief. Suppliers should be made aware if and how their sustainability credentials fell short of the requirement (including those related with the sustainability issues), which in turn sends a clear signal to the market regarding the importance of sustainable business practices.

US 834

1121 6.4.2 First sentence after the

figure

Editorial I don’t know how far above I want to read, but above above is letting me know that it is probably farther then intended.

The example above above could be used….

DS 740 1124

6.4.2 te This is a requirement for public procurement Edit text accordingly

NL 661

1128 6.4.3 6.4.3 te Can be skipped

BR 662

1132 – 1135

6.4.3 TE To reinforce the idea of integrating sustainability into the procurement process.

Replace the text

This is a further opportunity to ensure suppliers fully understand the business opportunity and the commercial business expectations, including and sustainability issues le business expectations, and buyers should maximize this opportunity to promote


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competition and proactively influence suppliers.

CA 663

1135 te Add: and to encourage joint proposals from firms with complementary sustainability features (eg a large company can joint venture with a small sustainability oriented company).

Add: and to encourage joint proposals from firms with complementary sustainability features (eg a large company can joint venture with a small sustainability oriented company).

BR 664

1136 6.4.3 TE To take into account the particularities of public organizations.

Insert:

There could be some constrains due to legislation, particularly in the case of public organizations, in conducting such briefings.

NL 665

1137 6.4.3 6.4.3 Te The paragraph should emphasize ethics in the title

Transparency, accountability and ethics are …..

SA 666

1137 6.4.3 te Replace ‘scoring methodology’ with ‘evaluation methodology’.

BR 667

1139 - 1140

6.4.3 TE To maintain the concept of sustainability issues.

The organization should ensure the suppliers Make sure they fully comprehend the importance of all aspects of the proposal, including the sustainable business issues requirements.

NL 668

1147 6.4.2 Remove London case study or make anonymous

Remove London case study or make anonymous

BR 669

1147 (after)

6.4.3 TE Make the consideration that sometimes is not possible to use WLC.

Include text

It should be noted that in some cases, the use of WLC can be limited due to legal reasons. This is particularly the case of tenders of public organizations were a minimum price should be offered. Are these cases, the WLC


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approach can be used when establishing the minimum requirements, choosing among different solutions to be considered in the tender. On some other cases, the data needed won’t be available.

NL 670


NL 671

1150 6.4.3 te Figure xx example of tender question and evaluation criteria on line 1150 is quite similar to figure xx example for pre-qualification question and criteria on line 1119; both deal with fair cooperation.

Choose a different example for line 1150.

NL 672


NL 673

1152 6.4.3 6.4.3 te Here it can start again

SA 674

1152 6.4.3 te Make the reader aware of the burdens of multiple recording requirements. E.g. ‘Being mindful of multiple recording requirements by utilising existing international standards/matrixes, e.g. GRI.

This also should be added to the Contract Management section along with the reference to KPIs (line 1255).

BR 675

1152 - 1153

6.4.3 TE To clarify the text. Replace the text

The supplier with the best performance on the sustainability issues submission will not always win a tender competition if they he is are not competitive in other areas.


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BR 676

1156 6.4.4 TE This clause doesn’t address only assessment methods but also talks about compliance.

Replace text

Assessment methods and compliance

NL 677

1156 6.4.4 6.4.4 te Paragraph title can be dropped so the paragraph is lengthened till 1161

SA 678

1156 6.4.4 This section on assessment methods does not acknowledge adequately that suppliers may provide false and misleading information about their products and services ie greenwash

Provide additional information about what greenwash is and that independent third party verification and certification is a recognised guarantee for obtaining true information. This also relates to section 6.3.4 on third party certifications and ecolabels

BR 679

1157 -1183

6.4.4 ED reorganize the explanation as suggested Suppliers with unsustainable practices might be able to offer lower prices than suppliers with better conditions.

Unless Robust prequalification and tender processes and criteria are in place to ensure good minimum standards before the supplier is taken on, minimizing risks exposure, the organization could be constantly undermining its own sustainability policies, exposing itself to a wide range of risks, and giving a signal to the market that it undervalues sustainability against other issues.

NL 680

1162 6.4.4 6.4.4 Te Can be skipped

BR 681

1162 - 1164

6.4.4 TE Make the point that what the suppliers know is the tender documents, not necessarily the strategy.

Replace the text

The tender responses should be evaluated in line with the pre-agreed scoring strategy, usually set out in the procurement strategy


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The phrase “other ways to promote sustainable outcomes” is misleading. Its better just to say that there are ways to promote sust. outcomes. Doing in this way we avoid the idea of having parallel processes.

and publicized in the tender documents. The specification and other tendering documents should always capture the requirements, including the sustainab sustainability issues, le elements in as much detail as possible. However, there are also other ways to promote sustainable outcomes at the evaluation stage. There are some ways to promote sustainable outcomes.

NL 682

1165 6.4.4 6.4.4 Te The bold items and labels can be listed under 6.4.5

BR 683

1165 - 1166

6.4.4 ED Clause preferable to section, according to ISO rules.

Replace the text

The first and most common method consists of rewarding superior standards and performance, which is presented in the Requirements ‘Specifications’ section clause.

BR 684

1167 - 1172

6.4.4 TE Make the note that sometimes is not possible to do this.

Replace the text

Secondly, qualitative judgements can be used in some specific contexts. Suppliers, especially in service industries, may be requested to summarize within their tender response their experience and method in relation to sustainability the criteria. It should be noted that in some circumstances, this qualitative evaluations could be subjected to some constraints. This could be the case of legislation applicable to public procurement in some countries.

IN 685

1171 6.4.4 personal Personnel

BR 686

1173 - 1178

6.4.4 TE To have a more generic text (following the idea of integrating sustainability into the

Replace the text

Thirdly, fit for purpose assessments enable to


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procurement process).

Eco labels have criteria. Environmental Product Declarations refer to specific characteristics.

The credentials are for the product or service as a whole and should include sustainability issues.

“Testing” to clarify.

identify and properly evaluate products and services that might not be sufficiently robust, leading to higher repair and replacement costs. Other proposals might be over‑engineered, providing unwanted functionality or service at added expense. Neither extreme provides a sustainable solution and this should be reflected in the evaluation. Eco labels criteria, the characteristics stated in Environmental Product Declarations and other product standards can help to evaluate the sustainability credentials of a product, including the sustainability issues related. Alternatively, evidence based on trials/testing or other client references help to evaluate this important aspect.

IN 687

1177 6.4.4 te product standards can help to evaluate product standards at respective state/ country can help to evaluate

BR 688

1178 6.4.5 TE To make the point that in same cases legislation can limit the use of this option.

... help to evaluate this important aspect. It should been taken into account that in some cases legislative constrains can limit the use of this approach.

NL 689

1184 6.4.5 6.4.5 GE Make sustainability more tangible, state more clearly that sustainability should be monetized, rewarded etc..

BR 690

1188 - 1189

6.4.5 TE To maintain consistency in the terms used requirements, sustainability issues…

Requirements related to Sustainability elements issues should be included in the preparation of a negotiation meeting and/or a negotiation strategy,

BR 691

1192 - 1193

6.4.5 TE/ED Consistency of the terms • Requirements related with Sustainability specifications issues have been secured,

• Agreement has been made to take


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actions to manage sustainability risks identified in the earlier pre‑qualification or tender evaluation stage,

SN 692

1196 Selection of

… ed

This standard has to be more direct and specific.

Sustainability commitments are recommended to be written into the contract to ensure that the supplier……

DS 741

1196 6.4.5 Te Already when setting up the provisions of the call, sustainability aspects to be addressed in the supply should be described.

Edit text accordingly

NL 693

1199 6.4.5 Te ‘If it is not possible to negotiate contractual commitments, a more informal and flexible approach might be required to persuade suppliers to embrace sustainability initiatives.’

Refer back to 5.4.2 – exercising influence

IT 694

1205 6.4.5 te Substitute "Key stakeholders", instead of "Necessary stakeholders"

IT 695

1206 6.4.5 te “the wider stakeholder community should be informed of the new arrangements”. We suggest to remove this sentence, being a very high level expectation…

BR 696

1208 – 1209

6.4.5 TE Phrase not needed to the understanding. This in turn reinforces the importance of sustainable business practices within the supply market.

JP6 697

1210 6.5 te Although ISO 26000 is not intended for the contractual use, Clause 6.5 is indicating “Contract management”.

Remove the contractual use from the document.

NL 698

1210 6.5 6.5 ge Contract management Sustainability aspects of contracting, ordering


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and monitoring

NL 699

1211 6.5.1 6.5.1 ge Discuss in ‘general’ points being discussed in this chapter, as done before in other paragraphs

NL 700

1216 6.5.1 6.5.1 Ge The part can be dropped Delete

IT 701

1218 6.5.1 te Add: "In order to prevent adverse human rights impacts, it is important that internal decision making, budget allocation and oversight process within the organization enable effective responses to such impacts" (questa aggiunta riprende una parte del testo dei Guiding Principles on Business and Human Rights delle Nazioni Unite).

NL 702

1219-1236

6.5.2 The part can be dropped (is prof procurement – as is much of 6.5) – should be replaced with text on supplier dialogue if any. --? Should text be added on monitoring CSR behaviour beyond contractual requirements (based on risk analysis of sensitive categories)?

Refer back to 5.4.2 – Stakeholder dialogue and exercising influence.

BR 703

1220 – 1221

6.5.2 TE This is not guidance. Not needed. Delete. Sustainability commitments of an organisation should be reflected in the quality of the relationship with its suppliers.

FR 704

1223 6.5.2 Te In order limit costs (time spent and bills) for stakeholders and especially for SMOs, favour

- Limitation of questioning to key CSR issues

- mutualisation and use of efficient IT in suppliers CSR prequalification and



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controls - when doing that, pay attention to 2

issues: o avoid any extra cost for

suppliers and especially additional billing

o respect free competition rules o promote continuous

improvement in case of unsatisfactory controls instead of closing business

FR 705

1234 6.5.2 te Nothing on promoting mediation. This criteria is mandatory in the label Relations fournisseur responsables, which requests that the organization has to prefer this way, compared to lawyers and courts.

Add:

"The sustainable procurement policy should promote the use of mediation to solve any dispute between the organization and a supplier. For that purpose, it is recommended to appoint an internal ombudsman within the organization at the highest level in order to facilitate the dispute resolution. It is also recommended to identify repetitive roots causes for disputes and then define and coordinate action plan in order to improve sustainable and fair relationship. "

IT 706

1237 6.5.3 te Typo, “contract” instead of “contact”

BR 707

1243 6.5.3 TE Doesn’t add to the understanding delete. (potentially new)

NL 708

1246 6.5.4 6.5.4 Ge The part can be dropped


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BR 709

1247 - 1248

6.5.4 ED Consistency of the terms Linking the organization’s sustainable targets with the contract management plan puts sustainability firmly on the commercial agenda and helps sustain focus and momentum for sustainability

BR 710

1257 - 1258

6.5.4 ED Consistency of the terms At this point, the contract manager and supplier should revisit any sustainability risk and opportunity analysis

NL 711

1263 6.5.4 6.5.4 Ge Relocated to ’implementing the contract’

NL 712

1274 6.5.5 6.5.5 Ge The part can be dropped

BR 713

1278 - 1281

6.5.5 TE Not be a “prescriptive example”. Many organizations adopt a balanced scorecard methodology methodologies where sustainability criteria can be monitored alongside service, quality delivery, cost and technical requirements (balanced scorecard methodologies are an example of such approach). If any individual score result or combined score result shows a negative trend or falls below an agreed threshold, the supplier should be required to take corrective action.

BR 714

1282 6.5.5 End TE One way to incentivize suppliers is to recognize the best ones on sustainability bestowing them with awards or prizes

Add at the end: “Suppliers with outstanding performance regarding sustainability could be recognized through awards or similar initiatives, to foster their efforts towards continuous improvement of their goods and services.”

BR 1288 - 6.5.5 TE Audits are an example of a conformity It is good practice for organizations to carry


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715

1290 assessment tool. out periodic audits conformity assessments of suppliers throughout the life of the contract, especially for important and complex contracts, to verify that requirements are fulfilled, including those related with the sustainability claims issues and that work practices meet stated requirements.

NL 716

1288-1290

6.5.5 It is important procurement understands audits do not ensure compliance. Stress audits are a valuable focus instrument.

Add sentence: Please note audits do not ensure full compliance to standards. Audits will create focus on issues and create awareness on expected standards.

NL 717

1291 6.5.6 This subparagraph deserves more attention. Where appropriate, joint initiatives should be put in place to improve the sustainability issues identified when priorities were set. In some cases, the market may not be capable of delivering new or challenging sustainability standards. In this case supply chain development programs may be necessary to improve competence and capacity (see ‘Engagement’ section).

Add to on 6.5.6.

Examples of joint initiatives are sector initiatives to deal with labour conditions in their supply chain and share audit data or develop a sector code of conduct. Other issues that a sector can address is finding and developing alternatives to conflict minerals.

SA 718

1292-1296

te We think it also needs to be said that customers can also greatly assist their suppliers to improve the sustainability of their supply chains by using the power of their position as the buyer to express their clear preferences for sustainable products and services.

Include words to the effect that customers can also greatly assist their suppliers to improve the sustainability of their supply chains by using the leverage as the buyer to express their clear preferences for sustainable products and services.

NL 719

1303 6.5.7 6.5.7 ed Word ‘Extreme’ can be dropped

NL 1304 6.5.7 6.5.7 Ge The part can be dropped


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720

NL 721

1307-1310

6.5.7 Te Change approach to text as also used by UN If it is not possible to abandon the supplier relationship be able to demonstrate efforts made to mitigate abuse, recognizing the possible consequences of maintaining the relationship.

BR 722

1311 to 1324

6.5.8 All the item TE In this item should also be considered consumer products and those of immediate disposal, as the packaging in general and comparable as well as ensuring that these consumer products will be more sustainable as possible with respect to consumption, to reuse these containers, the correct disposal and post-consumer recycling.

It should also be added that suppliers must use standards for identifying materials to ensure the correct disposal of products and recycling

Some goods, equipment and infrastructure require elimination strategies to be developed by the end of its useful life, as well as consumer products such as packaging in general and comparable.

At this point, disposal options should be reviewed and assessed with the aim of minimizing environmental impacts, maximizing recycling and reuse and determining all opportunities to minimize landfill and pollution. Suppliers should use standards for identifying materials to ensure the correct disposal of products and recycling.

Unethical disposal can have significant remediation costs and damage reputation.

This includes ensuring consideration for disassembly, in the case of equipment and structures, and reuse at the design stage, optimum choice of components and materials in the specification to maximize recycling opportunities, and recovery of subsystems, materials and resources whilst minimizing the


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use of hazardous materials that could be dangerous and costly to dispose of.

CA 723

1319 ge Of course, disposal and end-of-life management could provide great opportunities to support social responsibility. It is recommended to factor the disposal requirements in throughout the design, procurement process and during operational phases.

1319 - No change.

CA 724

1319 to 1324

ge Should be moved up in the process because they should be considered earlier; end of life management issues such as product take back and reverse logistics should also be included.

Please move to to before 6.5.3

Add: “product take back and reverse logistics”

NL 725

1325 6.6 6.6 ge Contract review and lessons learnt Evaluate, adjust and improve performance on sustainability aspects

BR 726

1326 - 1327

6.6 TE The text doesn’t add to the understanding of the document. Remove it.

Remove the text

NL 727

1343 6.6 6.6 Te Can be skipped

BR 728

1343 – 1347

6.6 TE This text is not necessary and doesn’t add to the understanding of the document. Remove.

Remove the text

…publish lessons learned in detail and in a way that other organizations can learn. It is best practice to publish lessons learned in detail and in a way that other organizations can learn. These should not be marketing or public relations focused documents but genuine attempts to enable other


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organizations to learn from good and bad experience in delivering greater sustainability. An example of best practice would be the Learning Legacy website created by the London 2012 Olympic programme: http://learninglegacy.independent.gov.uk/.

FR 729

1347 6.5 te In addition to the british example about learning legacy, we could share the French approach with the Label Relations fournisseur responsables.

As figured out line 1119 & 6.4.2, add in a block as an example the list of criteria covered by the label Relations fournisseur responsables :

“Responsible Supplier Relations Label The following assessment criteria are used (some of which are mandatory):

1 – Protecting the interests of suppliers and subcontractors :

- Guarantee fair financial treatment for suppliers

- Promote sustainable and balanced supplier relations

- Treat suppliers equally

- Prevent corruption

2 – Impact of procurement on business competitiveness :

- Support industry consolidation and international development


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- Evaluate total procurement costs

3 – Integrating environmental and social concerns into the procurement process:

- Integrating the environmental performance of suppliers and subcontractors into the procurement process

- Contributing to regional development

- Integrating suppliers’ social performance into the procurement process

4 –Establishing the right conditions for a strong supplier-subcontractor relationship :

- Ensuring a professional approach is taken to the procurement function and processes

- Developing business relations and promoting mediation”

FR 730

1347 6.6 te In addition to the british example about learning legacy, we could share the French approach with the Label Relations fournisseur responsables.

Add the sentence :

“As an example at the nationlevel, through the creation of the Label Relations fournisseur responsables, France at the governmental level has collected and promoted a whole set of best practices in terms of sustainable procurement and by the way has shared how to measure maturity of the organizations and compliance : www.relations-fournisseur-responsables.fr. “


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DS 742

1348 Annex ge DS NMC recommends inclusion of an annex with references and links to relevant tools and initiatives for public and private procurement e.g.

- Ecolabelling schemes (Type I according to ISO 14024)

- Other labelling schemes e.g. on energy, organic products etc.)

- Regional green public procurement initiatives (e.g. EU GPP)

- Framework contracts of public or private procurement schemes

- National and international organizations of public and private procurement officers


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ANNEX I – For Comment - BR – LINES 531 – 584 Clause 5.2 – Type TE Considering that the Item 5.1 has been moved to introduction clause (comment BR – Lines 515 – 521 – 5.1 – Type TE), the item 5.2 will be renumbered to 5.1, as shown below: 5.1 Setting Priorities Organizations buy a great amount of different products and services. In order to implement sustainable procurement, the organization may start gradually. Besides, the organization should prioritize the products and services according to the materiality of sustainability issues and its related impacts. These sustainability issues should be related to the organizations business and the impacts of its activities. ISO 26000’s core subjects may be considered when identifying the sustainability issues related with the organization. (line 523) Not all categories of supply have the same impact. Setting priorities will enable organizations to deliver sustainable procurement efficiently and without adding unnecessary work and cost to internal staff and the supply chain. Sustainable procurement priorities are dependent on a number of factors such as:

� corporate and supply chain objectives, � categories of supply, � expenditure by category, � materiality of the impacts/issues (social, environmental, economic), � leverage over the supply chain, � nature and geographical location.

The priority setting process therefore takes place at a number of levels as the organization develops a better understanding of the supply chain. (line 530) Organizations may have their own methodology for setting corporate priorities, in which case these factors can be used to address sustainable procurement. There are also other methodologies that may be used for priority setting such as heat mapping, such as strategic sourcing matrix or materiality matrix. (line 546-557) The priorization priority map may be created by mapping the core impacts/issues to the categories of supply, taking into consideration: Relevance - the relative magnitude of the issue with respect to this category compared to other issues and categories Significance – the level of stakeholder concern and the long term consequences of failure to act Influence - the leverage of the procuring organization to improve performance Priority – the current level of priority expressed by societal expectations, stakeholders, the organization and procurement function goals A simplified example is shown below. The map may be filled, for instance, considering a kind of heat mapping (G=green, A=amber, R=red). Economic Issues Social Issues Ambiental Issues


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Categories

Eth

ics

Info

rmal

ity

etc.

Hea

lth a

nd

Saf

ety

Chi

ld L

abou

r

etc.

Ene

rgy

Wat

er

etc.

Pro

duc

ts Raw Materials

Equipment etc.

Ser

vice

s

Transport Maintenance Security etc.

Table 1: Map issues against categories to establish priorities Filling this map Prioritization may depend on information about sustainability issues by category that the organization doesn’t have. It should involve all key stakeholders, gathering information about the category, impact or supply chains, to establish the extent of the impact. (line 564-572) For each category action plans should be developed, considering the established priority. It may be necessary to adopt different tactics and priorities for suppliers within a category depending on their current performance, geographical location, ownership structure, etc. (line 575) Purchasers are often challenged to understand how far down a multiple tiered supply chain they should address sustainability impacts. There is no easy answer to this because it depends on the overall level of sustainability risk, overall significance of the impact, the position in the supply chain that has the most significant impact, leverage and resources available to address it. (line 582) It is recommended that the prioritization map is reviewed regularly or when there are material changes to the business or supply chain. This will enable learning to be captured and changing circumstances to be addressed.

Annex A 5.1 General: building a preliminary sustainable pro curement policy This section of the standard examines the organizational conditions that need to be created to enable sustainable procurement to be delivered consistently and continuously improved all over the whole organization. An essential first step is to define the sustainable procurement policy introduced in the previous section in the context of the organization and its supply chain. Which leads the organization to identify clearly and fully take into account its business nature, strategy, stakeho lders, material issues, goals and principles. When building this policy, a good startpoint is to analyse globally necessary coherence with ISO 26000 in the context of an organization. The following table helps identify, for all core subjects and issues of ISO 26 000, what can be the necessary transposition into the purchasing function.

TABLE OF 7 CORE SUBJECTS OF ISO 26000 AND ISSUES IN SUSTAINABLE PRO CUREMENT(according to 2010 version)

ISO 26000 CORE

SUBJECT

ISO 26000 CORE

SUBJECT ISSUE

SP ISSUE

ORGANIZA-TIONAL GOUVERNANCE

Definition and decision of a responsible procuremen t policy • Respecting the principles as given in ISO 26000 “accountability,

transparency, ethical behaviour, respect for stakeholder interests, respect for the rule of law, respect for international norms of behaviour and respect for human rights”

• Possibly formalized in a commitment document • Distributed internally for raising employees awareness • Being a support for dialogue with suppliers, allowing them to adjust their

policy and production Strategic integration of the responsible procuremen t policy

• It should be implemented on a strategic level and incorporated in the CSR criteria as well as “quality/cost/timeline” with: o The concept of “the best offer”: “overall economic performance”

including the costs related to the products’ life cycle, social and societal objectives, in particular, respect of the ILO, and environmental target

o Mutually beneficial relations with suppliers. • Principles for decision-making that call on responsibility of management

and in particular, with a collegial approach • Listing of the economic, legal, environmental and social risks (cf. table 2

list of risks) and opportunities; with identification of risk with dialogue with stakeholders

Operational implementation of the responsible procu rement policy: • Setting a strategy and an action plan for each purchasing family all over

the supply chain • Tracking and making concrete measurement of implementation • Asking suppliers in a priviledged position to act as relays in the

downstream deployment all over the supply chain and the purchasing process

Accountability a nd responsible communications inside and outside fo r transparency for :

• The principle of “accountability”, as explained in ISO 26000, should be applied to procurement policy, which is: “an organization should be accountable for its impacts on society, the economy and the environment”.

• Operational implementation with suppliers • Right image and conformity (stakeholders) • Crisis management

HUMAN RIGHTS 1) Due diligence Firm commitment to respect human rights into the pr ocurement policy ,

as recommended in ISO26000:

Eight major human rights issues must be taken into consideration in the organization's global sustainable development policy: due diligence, human rights risk situations, avoidance of complicity, resolving grievances, discrimination and vulnerable groups, civil and political rights, economic, social and cultural rights and fundamental principles and rights at work.

2) Human rights risk situations

Prevention of risk to human rights and dealing with any impacts into purchasing criteria:

• Promotion of “absolute rights”, fight against discriminations, refrain of taking advantage of situations where human rights are violated

• Implement process of surveillance, HR control and alerts 3) Avoidance of complicity

Avoidance of complicity all along the supply chain: As it is specified in ISO 26000 (6.3.5.2), an organization should “not enter into a formal or informal partnership or contractual relationship with a partner that commits human rights abuses in the context of the partnership or in the execution of the contracted work”

4) Resolvinggrievances

Promotion of human rights in supply chain by proact ive initiatives like: • Commitments as UN Global Compact or in an SP charter between the

organization and its suppliers • Creation of process of control of impacts internally and for suppliers

5) Discrimination and vulnerablegroups

Allocation of requisite budgets, resources and proc ess for respect of human rights policy in procurements:

Identifying critical points with suppliers, motivating suppliers to take their responsibilities, using means of assessment and control and plans of progress.

6) Civil and politicalrights 7) Economic, social and cultural rights 8) Fundamental principles and rights at work

LABOR PRACTICES 1) Employment

and employmentrelationships

Principle and means of guarantee of satisfactory wo rking conditions applied to the purchasing function, to the organiza tion and to its suppliers and subcontractors

• a balanced relationship between the supplier and its employees; • the quality of working conditions and a decent level of social protection

for the suppliers' employees; • the guarantees covering the health and safety of the employees and the

suppliers involved in the organization's activity

2) Conditions of work and social protection

3) Social dialogue

Conservation of balanced relations between the supp lier and its employees

• Best practices to limit social consequences in case of restructuring • Implementation of a HR management policy • Verification that strategic suppliers and key subcontractors, have their

own social responsibility policy or charter 4) Health and safety at work

Inclusion of recommendations encouraging its commit ted partners to implement best practices and go beyond local labor legislation :

In checking that working conditions comply with the legislation and national regulations and are as much as possible compatible with the applicable international labor standards.

5) Human development and training in the workplace

Develop employability of personnal: By promoting specific policies and training.

ENVIRONMENT 1) Prevention of

pollution Firm commitment in terms of environment:

In procurement policy and practices to prevent pollution, to make sustainable use of resources, to mitigate and to adapt to climate change, to protect the environment and to restore natural habitats

2) Sustainablereso

Prevention of pollution and of emissions of greenho use gases throughout the life cycle of the products or servic es bought

urce use • map out the environmental impacts and define and monitor the prevention plans

• research of alternative solutions • in classifying suppliers, to apply criteria that take account of the

prevention of pollution and emissions of GHG

3) Climate change mitigation and adaptation 4) Protection of the environment, biodiversity and restoration of natural habitats

Inclusion in procurement function of reuse, protect ion and restoration of biodiversity and ecosystems all along the entire supply chain:

Developing impact studies and repairing damages in collaboration with external stakeholders.

FAIR BUSINESS PRACTICES 1) Anti-

corruption A real commitment to respect the notions of ethics and good conduct and prevention of corruption in procurement policy and practices: This approach requires the inclusion in the purchasing policy of commitments including relevant recommendations and regulationsadressing the fight against corruption and a specific management system for:

• Being aligned with the public policies that are beneficial to society in the long term

• Avoiding manipulative or coercive behaviors • Promoting exchanges on good practices • Limiting risks of deviation caused by the use of transfer prices between

entities of the same organization. • Sharing commitments in a charter for example.

2) Responsiblepoliticalinvolvement

Establishment of balanced relations between the org anization and its suppliers in terms of:

• Prices, in respecting equity in terms of global costs and creation of value and equitable distribution of the costs and benefits all along the supply chain

• Payment terms for the supplier tending to be compliant with international best practices: 30 days, and as a minimum with local regulations. More broadly, a coherent payment policy has to be established for the organization’speople

• Promotion of best practices for the organization’s people relating more broadly to suppliers relationships (and not only cost saving negociations)

• Train and supervise all relevant professionals to get full individual commitment to the principles of sustainable procurement, especially for critical decisions such as conducting supplier selection

3) Faircompetition

Treating SMOs in an equitable manner in: • Reducing customer-supplier dependency by introducing greater flexibility

for small startups and developing companies. • Applying anti-trust and anti-dumping practices • Treating SMOs in an equitable manner (nondiscriminatory access,

allotment, …) 4) Promoting social responsibility in the value chain

Promoting social responsibility in the value chain As specified in ISO 26000(6.6.6.1): “An organization should consider the potential impacts or unintended consequences of its procurement and purchasing decisions on other organizations, and take due care to avoid or minimize any negative impacts. It can also stimulate demand for socially responsible products and services. These actions should not be viewed as replacing the role of authorities to implement and enforce laws and regulations.”

5) Respect for propertyrights

Respect for property rights all along the supply ch ain, for suppliers a nd subcontractors impacted by this issue:

Property rights cover both physical property and intellectual property and include:

• Other physical assets, copyrights, patents, geographical indicator rights, funds, moral rights and other rights.

• Broader property claims, such as traditional knowledge of specific groups, such as indigenous peoples, or the intellectual property of employees or others. As specified in ISO 26000 (6.6.6.7.1): “Recognition of property rights promotes investment and economic and physical security, as well as encouraging creativity and innovation.”

CONSUMER ISSUES 1) Fair

marketing, factual and unbiased information and fair contractual practices

Promotion of fair operating practices in terms of s ales and marketing, information and contracts:

By deploying sound communications with relevant internal departments as well as clients, consumers, end users

2) Protecting consumer’s health and safety

Participation to prevention of risks related to con sumer health and safetyby:

• Identifying and sharing all the input in its possession • Respecting the technical solutions chosen by the recognized

"specialists" in the prevention of risks to consumers. 3) Sustainableconsumption

Contribution to promotion of sustainable consumptio n : Working on a design of sustainable products and services with suppliers and subcontractors

4) Consumer service, support and complaint and dispute resolution

Providing necessary information for consumer servic e, support, and complaint and dispute resolution controlling its su pply chain and its suppliers.

• Validation of traceability of raw materials and check their health safety with clear labeling, specially, official labels controlled by regulators

• Encouraging business committed in social responsibility contribution 5) consumer data protection and privacy

To be described later

6) Access to essential services

Contribution to promotion of access to essential se rvices : Making sure that the suppliersguarantee this access and do not impede access to essential services by the population, even if this access is not protected in the country in question

7) Education and awareness

Contribution to education and awareness of consumer s The procurement function should contribute in giving necessary information allowing consumer to develop skills for assessing products and services and to raise awareness about the impact of consumption choices on others and on sustainable development. (In terms of: health and safety, legal information, labelling, instructions, characteristics and specificities, risks in use, environmental information…etc.)

COMMUNITY INVOLVEMENT AND LOCAL DEVELOPMENT 1) Community

involvement Firm commitment to favor community and local develo pment taken into consideration in procurement policy and practices:

In terms of involvement with the local population, job creation and skills development, education and culture and the development and transfer of technology.

2) Education and culture 6) Health

7) Social investment 3) Employment creation and skills development

The guarantee of positive impacts of the purchases on the local fabric, ecosystem, education and culture, health of communi ties and social investment

• According to ISO 26000 (6.8.7.2) study the possibility of giving preference to local product and services and of contributing, if possible, to the development of these suppliers.

• Take into account possible impacts of its purchases on health, education and culture and social investment policy.

4) Technology,development and access

Systematical asse ssment of the offer from local suppliers favoring t heir access to contracts:

• In analyzing the offer available from local suppliers • In taking measures intended to allow local suppliers to access its

contracts (allotting, networking, joint bids…) • In encouraging partnership and technology transfers, training and digital

economy • In launching entrepreneurship programs, development of local suppliers

and trying to strengthen economic resources and social relations that facilitate economic and social welfare or generate community benefits.

5) Wealth and income creation

This transposition reveals a range of relevant fields of action as regards responsible purchasing, covering also changing topics (e.g. the fight against corruption…) that are to be examined. Social responsibility is a dynamic concept, other fields of action or a more specific content within identifield fields of action may appear (see 6.1 ISO26000). As a very relevant example of the need to take into account more specific recommendations especially whenever the organization recognizes a major SP issue, like anti-corruption in the extractive business (and probably not only in this sector), we recommend to use OECD recommendations:

Country, sector, aggravating Risks

Corporate and business Opportunities

Tools and Methods to avoid fraud and corruption

Disastrous communication of fraudulent and questionable affairs Competitors could easily obtain information from the Staff Non respect of the law : lawsuits known by the suppliers and customers Mistrust in the company and its sales

Ethical communication towards the stakeholders Clean behavior of the Staff towards the stakeholders No lawsuits Confidence in the company and in its productions

Develop a "Code of Ethics" involving employees, top managers, even those not directly involved in the business (the OECD Convention, the Global Compact local law ...). Develop an anti-corruption policy. Communicate annually on its results internally and externally. Have it signed by employees, and business partners. Training courses inform on the R&O for the company and for them Cartography of the supply chain and risks

Human rights risk situations Funding of conflicts, armed groups, mafias, dictatorships that can afterward threaten the company

Labor, civil and political rights preserved No funding of dangerous groups Independence preserved

Comprehensive, independent and regular audits of the supply chain and of the documents relating to the procurement. Due diligence must be completed by independent controls of sellers. Immediate stop of any business in case of doubt

Non respect of at least the fundamental recommendations of the ILO.

HR management policy in the sellers’ and buyers’ companies based on the recommendations of the ILO

Indicate in contractual documents the compliance with the law, and company policy. Establish a form of certification to ensure that it has been observed

No control on environmental impacts of the procurements No control of the origin, of the producers, of the ownership

Control on environmental impacts of the procurements Master of the origin, of the producers, of the ownership

Clearly identity and check the real producers and the means of production Forbid the use of dangerous methods and substances for employees and customers

Mistrust of suppliers and customers Dependence on doubtful partners Missing, false documents Tax controls : payment of fines and penalties

Confidence of suppliers and customers : master of the sales Control of the supply chain Independence towards all the stakeholders Clean Sales and purchasing documents Taxes, fees, royalties paid

Follow the buyers’ relations with sensitive personalities. Ensure that suppliers comply with the ethical commitments. Check the certifications of documents submitted upon receipt (certificates of origin, export licenses...). Build alertness on payments from an amount to be determined. Create a device in validation steps of the commercial chain and payments with defined roles.

False information on the origin of the procurement

Right information on the origin of the procurement

Clearly identity the producers : independent audits and controls of the documents and production sites

Exploited Local producers Diversions of local resources and funds Local development slowed

Valued local resources and social relations Economic and social welfare for local substances producers and communities

Secure and enhance the local relationships Follow assistance plans with communities to ensure they are not misused and underutilized

All SP issues are not to be implemented at the same time and their importance varies from an organization to another; it depends on its business nature, its size, and its maturity in the implementation of the process. Each organization will have to make choice of priorities. For some organizations it might be useful at this stage to build a preliminary sustainable procurement policy at strategic level with senior management who has a go od view of business priorities and can confront it to ISO 26000 transposed issues. It is recommended deciding appropriate priorities i n issues in order to finalize the sustainable procu rement policy. For that purpose we suggest to apply ISO 26000 clause 5 main recommendations for choosin g priorities:

• “Two practices of social responsibility: an organization's recognition of its social responsibility, and its identification of and engagement with its stakeholders”.

• “Determine relevance and significance of core subjects and issues to an organization” and "establish priorities for addressing issues"

• To assess the relevance of the issues and the relative importance of different stakeholders, the standard suggests several criteria, including the level of impacts (p ositive or negative) of decisions and activities of the organization .

Positive impacts are opportunities connected to ISO26000 core subjects in line with business such as:

CORE SUBJECTS EXAMPLES OF OPPORTUNITIES

ORGANIZATIONAL GOUVERNANCE

• Cost reduction of products and services (including social and environmental benefits)

• Promotion of suppliers CSR practices (through, for instance, a better integration of CSR performance into purchasing processes)

• Extension of sphere of influence

HUMAN RIGHTS • Reduction of significant incidents • Better understanding of aggravating risks

LABOR PRACTICES • Promotion of fair relationships between employers and employees (through

trade union, if local laws recognizes freedom of association) •

ENVIRONMENT

• Reduction of GHG emissions • Reduction of pollutants • Promotion of eco labeled products • Better market recognition

FAIR BUSINESS PRACTICES

• Reduction of penalties in case of corruption • Création de filières …… development of industrial sectors ???

CONSUMER ISSUES • Better information for the consumer • Gain competitive advantage by providing clients with a deeper information on

CSR impacts of products / services that are sold COMMUNITY

INVOLVEMENT AND LOCAL

DEVELOPMENT

• Support SME, local companies, support diversity, disabled persons, etc • Support local employment

Negative impacts, both internally and externally, are risks also connected to ISO 26000 issues in line with business such as:

CORE SUBJECTS RISKS

ORGANIZATIONAL GOUVERNANCE

• Stakeholders calling senior management or the purchasing function into question,

• A degraded image, inside and outside the organization, depending on the visibility of the initiative and the communications.

HUMAN RIGHTS

• Risks of labor conflict, legal • Financial risks, as well as risks in terms of reputation and image in the eyes

of purchasing authorities and end customers. • Situation in which its practices contradict its commitments • Contagious effect inside the organization by external social risks

LABOR PRACTICES

• Legal and financial risks, due to poor knowledge of or the failure to respect applicable regulations, and, consequently, the application of financial penalties;

• Operational risks, such as the breakdown of the supply chain, if the employees in partner organizations block production in order to demand better working conditions;

• Social risks, in particular if the organization asks suppliers to work on the organization's site when the organization's treatment of these workers is significantly different, to the extent that it might prompt action by the personnel representatives;

• A risk in terms of image, if NGOs intervene through publications in the media or social networks.

ENVIRONMENT • The over-consumption of natural resources, operational and financial risks,

including ecological accidents and their impacts on human beings and the

ecosystem

FAIR BUSINESS PRACTICES

• Higher economic risks for suppliers, a fact that makes one of the links in the chain, and consequently the organization itself, more fragile;

• Economic efficiency reduced, thereby destroying value and increasing hidden costs on both sides;

• The level of risks increased incurred by the organization, if a strategic supplier should default;

• Possible financial penalties or legal sanctions if the regulations are breached or the costs of a conflict, if the established contracts or agreed rules of partnership are not respected;

• • Risk of image from customers and its suppliers, if malpractice is published; have an adverse effect on customer / consumer satisfaction and the corresponding income, if the quality of the service or the product deteriorates due to suppliers lower down the value chain.

CONSUMER ISSUES

• Result in the loss of markets or opportunities due to a poorly adapted offer and, consequently a loss of income and customers,

• • Result in the deterioration of the organization's reputation, both internally and with intermediate customers, purchasing authorities and end consumers, for example due to the poor quality of the product/service, causing damage that is made public in the media.

COMMUNITY INVOLVEMENT AND

LOCAL DEVELOPMENT

• Making the economic and social fabric more fragile, especially if the customer organization has a significant impact on the local economy (examples include difficulties in recruiting, specialization in one type of agriculture to the detriment of the agriculture that meets local needs for food);

• The development of favoritism and bias; • The deterioration of the organization's image and reputation, internally, locally

and with purchasing authorities and consumers, for example if the organization fails to respect the fundamental principles applying to working conditions, the environment and public health.

The objectives is to determine stakes which can be opportunities, risks, or both risks or opportunity depending on the maturity of the organization This working stage blends 5 distinct analyses and a summary, in order to establish a CSR stakes mapping (risks and opportunities) of procurement. This second phase synthesis will allow: · Achieving a sustainable procurement policy · Prioritizing operational processes described in chapter 5

How do you map the CSR stakes of procurement? The following outlines 6 distinct stages in order to gradually lead the organization to a better understanding of the important social responsibility stakes related to procurement: Notes:

1. Each stage makes it possible to assess specific risks and opportunities (Gross or Net measure) 2. Risk/opportunity, gross or net? Where possible, it is recommended to complete this analysis in net

terms , in order to assess the actual and current exposure to a risk and/or to an opportunity, when the mapping is drawn. This choice allows each stage to take into account actions already under way : O Detection/monitoring devices already implemented for risk reduction and for a better assessment of the residual risk at the time when analysis is undertaken (for instance, a calculation of the Net risk, after carrying out social audits of suppliers who might be a threat to fundamental human rights) O Projects and procedures already implemented to exploit specific opportunities, which make it possible to focus future action examination towards new opportunities remaining to be explored (for instance, residual opportunities limited to future additional stakes which would neutralize previous gains linked to business opportunities long underway with strategic suppliers)

5.2.1 Mapping procurement strategic stakes and map CSR impacts It is a question, here, of inviting the organization’s “senior management” to look at medium and long term perspectives, and to fairly question the CSR impact of its strategic choices as regards procurement overall. Such high level of questioning makes it possible to integrate strategic evolutions and major structural changes under way under consideration, which can have an impact on the evolution of the CSR added-value to be brought by procurement in the future. This first stage would for instance consist in questioning the organization’s strategic choices such as externalization, enhancing subcontracting abroad, increased partnerships, merge & acquisitions, which can have big impact on the way to conduct business in the future and can be looked upon as a new and strong RSO stakes. 5.2.2 Mapping internal and external stakeholders’ CSR stakes Observation: a SP policy is not only the responsibility of procurement management or of purchasers. It derives from the involvement of a large number of internal and external stakeholders ( in practical words “with whom do we make procurement? ) of which it is necessary to map the roles and responsibilities.

5.2.2. Map CSR stakes for each purchasing

stakeholder

5.2.3. Map CSR stakes per purchasing

categories

5.2.4. Map CSR stakes for suppliers

5.2.5. Map CSR stakes for purchasing processes

5.2.6. Consolidation, overview and

prioritization of the stakes identified in prior

5.2.1. Identify strategic stakes in procurement

and map CSR stakes

stakeholder’s

capacity to

influence

procurement

decisions

The table below shows a typical range of key stakeholders to engage from a procurement perspective and why they should be engaged: Stakeholders Groups Example s (Who) Examples of objectives (Why)

Supply chain • Suppliers (rank 1, 2…) • Subcontractors • Industry groups • Trade associations

• Deliver specific sustainability requirements

• … • Create value based on sustainability

programs. • Participate in sustainability

development programs.

Customers

• Consumers • Consumers groups • Distributors • (B2B) OEM, contractors…

• To know expectations, satisfaction • … • Have coherent strategies • xx

Employees

• Organization employees • Subcontractors employees • Trade unions

• Empowerment • … • Social dialogue

Society

• Community, territory • Public sector • NGO’s • Other institutions

• Community involvement • Public contracting bases • For a constructive dialogue • Collaborate on issues of mutual benefit

Others • CSR agencies • Other consultants • Technical experts

• CSR evaluation bases • … • …

This analysis can be then conducted more thoroughly in two directions : - One axis related to “the stakeholder’s capacity to influence procurement decisions” - One axis related to “the stakeholder’s involvement or awareness in SP issues

Opportunity : new business due to

better adressing customers’ real CSR

commitment and expectations

towards suppliers

stakeholder’s involvement or awareness in SP

issues and stakes

Do with

(sponsors)

Inform

(champions,

opinion leaders)

Convince

(important

contributors)

Minimal

effort

stakeholder’s

capacity to

influence

procurement

decisions

5.2.3 – Mapping purchase categories’ SP stakes SP stakes can differ greatly from one category of purchases to another, in simple words “what we buy” . It is, in this regard, recommended to map purchase categories in light of the 7 fundamental questions of the ISO 26000 standard. This analysis can be conducted combining for major factors : - The purchase volume (in relative share of total purchases spend) of the studied category - “Intrinsic” (or “gross”) risks and opportunities for the category, taking into consideration each of the 7 fundamental questions of the ISO 26000 standard - Risk prevention measures and of opportunities already implemented - Location of suppliers and subcontractors including production factories (with necessary focus on “country” risk and attached CSR stakes) This mapping of the organization’s various purchase categories’ CSR stakes could then look like the following: Category of

product / services

Governance

Human rights

Labor Practic

es

Environment Fair practic

es

Consumers issues

Community involvemen

t and developme

nt Category 1 Category 2 Category 3 Category 4 Category 5 … Catégory n 5.2.4 - Mapping suppliers’ CSR stakes Supply chain responsability depends on suppliers, in simple words “to whom do we buy” . We also need to consider the level of trust in the business relation between a client and a supplier. It is thus recommended to assess the CSR risks and opportunities attached to suppliers based on 2 dimensions:

In red: very high

stake

In orange:

median stake

In green: weak

stake

Risk : under-estimation of clients’

CSR interest in SP matters

generating risk of lower market

share

Example

stakeholder’s involvement in SP issues

orawareness of the importance of CSR

customers

Commerc

ial/marke

ting

Function

Given the high number of suppliers and sub-contractors an organization is liable to be in relation with, we recommend to conduct this analysis with the 5 following guidelines in order to address correctly important CSR issues addressing a wide variety of situations:

1. Procurement organizations should consider their ability to influence their supply ch ain through suppliers . This should be done through systematic evaluation of the organization and its relationship with its supply chain. Where possible this should be integrated with a wider commercial evaluation of the supply chain. An example is given below. Influence (leverage) is considered to exist where the organization has the ability to affect change in the practices of the supply chain entity. Leverage may reflect one or more of a number of factors, such as:

a. whether there is a degree of direct control between the organization and the supplier; b. the terms of contract between the organization and supplier; c. the proportion of business the organization represents for the supplier; d. the ability of the organization to incentivize the supplier for improved performance in terms of future

business, reputational advantage, capacity-building assistance etc.; e. the reputational benefits for the supplier of working with the organization, and the reputational harm of

that relationship being withdrawn; f. the ability of the organization to collaborate with other purchaser to incentivize improved performance; g. the ability of the organization to engage government in requiring improved performance by the supplier

through implementation of regulations, monitoring, sanctions, etc.

2. It is strongly recommended to carry out this analysis by identifying lower rankin g suppliers and subcontractors, including risks linked to products manufacturing sites location , and this obviously only if CSR stakes deserve such deeper understanding. This analysis – to keep in line with OECD recommendations that followed the April 2013 RANA PLAZA accident – may result in the identification of several configurations which allow a better control of subcontractor linked risks:

• Which are the “rank #1 suppliers” of subcontracting chains, which in this case can have a strong

influence on the supply chain? They are “do with” suppliers, which will be able to thus contribute, for example, to a better traceability of the social and environmental compliance of the line production of products sold to the end-customer.

• It is recommended to work in close collaboration with these suppliers to identify, in true transparency, stages in the supply chain which present the most risks. Because of the key function that they play in the examination and the risks control of the supply chain, it will be necessary to encourage these suppliers to share their methods, the results of their various assessment provisions, training and audit set up for their own suppliers and subcontractors, in order to create the conditions for a better control of the supply chain.

• How well are subcontractors known, and CSR risks associated to them? OECD studies have demonstrated that the risk level increases noticeably with the lack of information on subcontractors effectively used. Are the subcontractors known declaratively via suppliers of higher ranking? Does it reflect reality in all circumstances? In the event of an important (intrinsic) risk), it will also be necessary to encourage strategic suppliers –whether they be the “to convince” or the “Do with” type – to conduct supplier and subcontractor audits, and

capacity to influence

suppliers of the

organization

« Strategic » suppliers

« Non-strategic »

suppliers

Do with

Promote? Monitor

Convince

supplier’s CSR maturity level

Low high

even maybe to evaluate the CSR awareness of their purchasing practices. The examination of all these root causes (internal or external to rank 1 supplier) will make it possible to identify risk factors and to prevent them on the whole chain.

• Have natural and legal persons who have a major influence in business relationships – such as traders, merchants, intermediaries, distributors, etc. – been sufficiently informed of who the suppliers are?

3. The ISO 26 000 standard however invites to pay attention to non strategic suppliers because they can be very numerous, have high impact on CSR issues such as territory development, social issues. a common risk for the organization, is to be concerned only about strategic suppliers and to neglect the “small non-strategic” suppliers as well as their CSR maturity.

4. Examine with what suppliers the organization has developed partnership and also what is the quality and depth of this partnership . Studies conducted in the USA by John Henke have shown the importance of partnership with (in particular) strategic suppliers to reduce risks as well as increase opportunities for both players:

New Study Shows Automakers Could Increase Profits b y Improving their Supplier Relations Detroit, August 4, 2014 – Conclusion: • “Our study proves that the most significant economic impact a supplier has on its OEM customers’ profits comes from

the non-price related benefits the supplier brings to the automaker,” said Henke. • “In fact, our calculations show that across the six major automakers, on average, 51 percent of the automakers’ profit

per vehicle can be accounted for by the relations the OEM has with its suppliers. That contribution is comprised of supplier price concessions which are as little as 5 percent of the total supplier profit contribution when relations are particularly good (see graph above, Supplier and Managerial Contribution to OEM Profitability).

• "The results clearly show that the OEM interested in improving its profitability should definitely look to its suppliers, not to squeeze them for lower prices, but to work toward achieving better relations with them, and by working to develop and then maintain sustainable long-term positive relations with them.”

• It is important to realize, said Henke, that while the OEM Profitability and Supplier Relations Study focused on the auto industry, the results clearly apply to companies in every manufacturing industry.

5. For an important SP stake, focus has to be made on opportunity as well as risk and integrate supplier

CSR maturity in both cases . The following table illustrates how risks can lead to opportunity and value creation when CSR maturity of the supplier progresses

Type of relationship in place with

supplier

Monitor Convince Not to forget Do with

Risk example

No visibility regarding sub-

contractors

No guarantee of social standards

No incentive for supplier progress

No implementation of SP commitments

Poor traceability of the supply chain

No lobbying for CSR in the

client’s sphere of influence despite efforts

sometimes made by suppliers

If no leverage due to impossible partnership with suppliers, then = high risk

Opportunity Example

Reputation Traceability of supply chains

Operational

Co-innovation: supplier’s R&D is housed with the

client

Improvement of suppliers RSO

practices

Strategic

Support to the territories

Support to

SMOs

Support to local employment

Lack of

economic risks but strong

levers for CSR

Managerial

Better control of supply chains (filiere breeding)

Cost pooling (for verification,

training, etc.)

Global cost reduction through a better breakdown capacity of

the life cycle of purchased goods

Development of innovation

capacities

Examples of Supplier’s RSO level of maturity

Weak High

5.2.5 – Mapping the CSR stakes of procurement proce sses The purchasing and procurement functions have their own responsibility, which can be independent or partly connected to characteristics of business (categories of supply) and external responsibilities such as supplier’s responsibility. This responsibility is, in practical words, “how procurement is conducted” and can be described through its procurement process: the way it is designed as well as the way it is implemented in relation with stakeholders and especially suppliers. It is therefore relevant to examine each step of the purchasing of the procurement process and assess CSR impacts For instance:

- When global cost and value creation represents an important stake for a category, weaknesses in planning and specification steps might generate additional risks in environment, social issues as well as poor economic consequences in the long term for the buyer

- absence of supplier qualification or weakness of selection step, especially when facing too often “urgent needs”, may imply the selection of risky suppliers in terms of human risks (example: textile fashion business imposing fast changes in collections were one of the causes of poor control on subcontractors and of the RANA PLAZA accident)

- On the contrary, the overload of supplier qualification and evaluation can discourage very small business to respond to calls for tenders.

- Poor contract management might generate conflicts with suppliers, or generate risks and cost on SME’s willing to avoid conflict with their buyer

- Absence of partnership with strategic suppliers can generate poor product innovation including CSR issues - Payment terms, pricing conditions and conflicts management may affect SME’s ability to remain alive and

weaken human rights and working conditions of employees, including subcontractor’s employees, and therefore also have an impact on development of territories

- Etc. Therefore, it is critical to assess the impacts of purchasing proces s according to CSR performance, on each of the 7 fundamental questions of ISO 26000 :

Procurement process

Governance Human

rights

Labor Practic

es

Environment

Fair practice

s

Consumers issues

Community involvemen

t and developme

nt Planning Specifications

Selection Contract Management

Etc.

Contract Review

It is appropriate, for an appropriate consolidation of risks and opportunities linked to the process, to take into account the complexity and organization mode of the procurement function and break the analysis into each relevant main process filiere :

• Process implemented by unit branch within a very large corporation or public organization • Framework contract filiere against other filieres • Customized process applied to main categories of supply against other general categories • …

Red: bad maturity on an

important CSR issue (poor or

un-adapted means to

address major risks and

opportunies)

Orange: intermediate

maturity (good practices with

exceptions) or CSR impacts

(acception of existing risks

given a small category of

supply)

Green: good level of

maturity, limitation of CSR

impacts (consistent

and/or adapted means to

address CSR stake of the

category)

5.2.6 – consolidate and prioritize risks and opport unities The objective at this step is to describe how materiality principle recommended in ISO 26000 can be designed within an organization. The completion of this objective needs to consolidate and prioritize risks and opportunities that have been identified through previous steps: top management vision, stakeholders, categories, suppliers and process. The “importance” of an identified item can be establish ed for example through group discussion with internal and external experts representing relevant stakeholders :

• Rating of risks: combination of gravity and frequen ce criteria (for example, the most important risks are those with very high impact and liable to occur, such as RANA PLAZA)

• Rating of opportunities: combination of importance of impacts and cost/complexity of

implementation (for example “quick wins” have an interesting impact and little cost and should be implemented quickly)

Cartography of risks and opportunities are a major input and should help for different purposes:

• Refine the preliminary sustainable procurement strategy and policy than has been established in step 5.1 with senior management based on a clearer view of major risks and opportunities relating to sustainable procurement

• Set priorities and action plans according to a structured view of risks and opportunities importance Based on this, each major change management (being addressed later in this chapter, from 5.3 to 5.6) as well as process impact (described in chapter 6) for organizing the procurement function towards sustainability will be influenced:

• In its content (for example first training modules and essential KPI’s could be prioritized according to what is considered “important” in the sustainable procurement policy and corresponding engagements)

• In the rythm and necessary steps of implementation

Opportunity#8

Impact

Risk#7

Opportunity#5

Opportunity#3 Risk#4

Risk and opportunity#1 Risk#2

Risk and oppotunity#6

Fréquence (risk dimension) or cost/complexity of implementation

(opportunity dimension)

Annex B

5.3 Enabling people

Effective delivery of sustainable procurement policy and strategy, effective and ambitious, requires that all personnel involved in procurement decisions and process or engaged with suppliers in any capacity, understand the issues and the reasons for implementing sustainable procurement as well as how to play their part in implementation, and are given the means to do so. This can include not only purchasers but budget holders, specifiers, internal customers, quality management, technical specialists and operational managers as well as CSR professionals.

People tasked with delivering sustainable procurement need to be enabled to do so through organizational culture, performance management, training and support.

Organizational culture

Introducing a relatively new concept to people requires the right organizational culture. Inspirational communication from senior management, a “can do” culture and an environment where innovation and appropriate risk taking is encouraged will facilitate effective implementation. Key people should be encouraged to network and become involved in relevant groups to share learning and benchmark performance provided engagement with these groups can add value to the business.

Developing competence and awareness

Competence may be seen as a fusion of knowledge, skills and attitude. Applying a sustainable procurement strategy requires acquisition of new knowledge and developing skills and awareness to apply that knowledge practically.

Procurement organizations should identify the learning, sensitization and development needs of those involved in the procurement process. Sustainable procurement should be captured into all relevant professional training and information tools.

Other considerations might be job shadowing or job exchanging internally or externally, attending conferences, joining appropriate online social media groups, sharing learning and good practice or working in a specific project team.

Procurement professionals should not be expected to be sustainability experts: the organization needs to ensure that professional sustainability advice and support is available for them.

As a consequence, procurement professionals and especially purchasers cannot fully achieve sustainable procurement practices without ensuring that key stakeholders and budget holders also have the necessary skills and knowledge. To accomplish this goal, we suggest to develop training with 2 objectives:

- Cover a sufficient “breadth” of training/awareness raising: to make sure that there is a good level of representativeness of each internal stakeholder. For instance, purchasers, prescribers, financial controllers, financiers, lawyers, suppliers, etc: all exert a direct influence on SP matters

- to ensure a level of “depth” sufficient for each actor concerned: to make sure that training/awareness modules are adapted to the sphere of influence of each stakeholder and to the stakes involved, with sufficient repetition of key messages and continuing education until a sufficient project appropriation is reached (expected changes witnessed in the field). For example, trainings adjusted to the different audiences involved can be envisaged, while blending participants in order to foster transversal practices:

o Supplier and prescriber specification draft training: eco-design, life cycle, value analysis, circular economy…

o Global cost and and value creation training for financial controllers and purchasers o Training on a responsible management of payment deadlines for purchasers, supplier accountants

and for suppliers themselves o Etc,

Lack of relevance of the training/sensitization program for relevant stakeholders will represent an important limitation (and risk) in itself in the deployment of SP within an organization, just as shows the following matrix:

Level of depth

of SP training

Results

It is recommended that the priority map is reviewed regularly or when there are material changes to the business or supply chain. This will enable learning to be captured and changing circumstances to be addressed.

Performance management

The procurement function should review its existing arrangements to ensure that the following elements reflect the organization’s sustainable procurement policy and objectives:

• recruitment and induction programmes,

• staff job descriptions and personal development plans; and

• individual objectives and related reward and recognition packages, with particular attention on the way variable elements of remuneration are built in order to integrate SP issues. Examples of individual objectives (EIA) are:

o % of products subjected to a global cost of products and services analysis, for financial controllers o % of contracts which permitted the introduction of innovative CSR agreements (e.g., support to

associations, to startups, day work for cleaning companies, etc…) o Monitoring of the percentage of suppliers being paid later than the 60 day deadline, for

accountants o % of the suppliers under CSR risk who were put under scrutiny AND supervision

(together with progressive failure clauses, in the case of serious non-compliance)

Level of breadth of SP training

Eveyone is trained.

Know what they must

do…and do it well

Everyone is

informed.

Nothing changes

Nobody knows

what he must

do

Some react.

Others do not

see the point

Annex C


According to ISO 26000, the governance side of a project is the most important factor. As a result, a clear governance structure is essential for the management of the procurement process and for the delivery of sustainability objectives. To ensure accountability and management involvement in procurement planning, the procurement process and delivery of sustainability objectives.

Organization-wide governance is covered in section 1.It is important to embed sustainability into existing governance arrangements and not to develop a new governance programme. There should be a clear connection between how procurement is governed and the core subjects and impacts described earlier in this chapter.

Lack of governance of SP policies and practices might generate important risks such as:

Risk of inaction by internal stakeholders Lack of contribution from external stakeholders and especially suppliers

No involvement of purchasing management No taking into account of suppliers CSR awareness

No acknowledgement of CSR committed SMOs

No involvement of financial management No control over the end-phases of the purchasing process

Insufficiently honoured payment deadlines

No involvement of commercial department No enhancement of the SP approach in the commercial offering

No joint commercial offering

No involvement of general management No trust, in some cases Etc,

� An SP approach’s success requires internal stakeholders – and preferably external ones as well – to be associated with SP governance

Governance groups

Typically organizations will have a group of senior people to provide governance over such issues as approving procurement strategies, gateways and commitments, monitoring savings and other functional KPIs. This group (or groups) should incorporate governance of sustainability issues in accordance with this standard.

Global cost and value creation method

Whenever important decisions have to be made, there is a need, at each step of the procurement process, to refer to an appropriate economic analysis through detailed costing and revenue items covering life cycle of products/services as well as costs of risks and value creation, such as the following map invites to do it (source Obsar- France- august 2014):

2–Whatsortof

Accountability

Clear accountabilities for sustainable procurement should be established. The accountability at a senior management level usually resides with the head of procurement. This plus embedding sustainability into the teams’ objectives and job descriptions may be sufficient. However, as most sustainable procurement programmes involve a degree of change management, it may be necessary to allocate accountability to implement this standard. Typically this may be a single “champion” for sustainable procurement in a full time or part time role, or a network of champions, possibly embedded into category teams or within procurement teams embedded in the business.

Procedures and systems

Governance requires a set of rules that people need to follow. For most organizations, this will typically comprise a set of documents: policies, systems, procedures, standards and templates, etc. These documents need to be aligned with the organization’s sustainability and procurement objectives. Some organizations use systems (e.g. e-tendering, contract management system, ERP systems etc.) to support their workflow and procedures. These systems should be aligned with the organization’s sustainability objectives where necessary.

Search for best practices

As ISO 26000 encourages a dynamic view of recognized recommendations, it is particularly important on such a subject to organize a “watch function” which will allow the organization to take into account issues, recommendations and good practices that are fast moving. Where it is possible joining and being involved in SP or CSR associations, thinktanks, communities or even workgroups can greatly help such a function and cope with fast moving initiatives worldwide, in order to increase one’s capacity and relevance for action. Alternatives ways are gathering documentation, studying complex issue in workgroups including various organizations….lack of implication in such a function might result in discrepancies between internal guides and up to date best practices and recommendations.

Guides

‘Soft’ documents such as tools and guidelines can be provided to enable procurement professionals to achieve sustainability objectives. For example:

• Sustainability guides per category • Guides on ecolabels, management systems, etc. • Evaluation tools, such as whole life cost models • Case studies

Assurance

Existing assurance processes should be modified to embed sustainability. Typically this would include audits, gateway reviews, management reviews and external verification.

Exercising influence on supply chain

The exercise of an organization’s influence should always be guided by ethical behavior and other principles and practices of social responsibility. When exerting its influence, an organization should first consider engaging in dialogue aimed at improving awareness of social responsibility and encouraging socially responsible behavior. If dialogue is not effective, alternative actions should be considered.

When capacity of influence is high with a supplier , methods of exercising influence include:

• engaging with stakeholders (through open dialogue, workshops, symposium, etc.); • publish a sustainable procurement charter; • sharing knowledge and information; • conducting joint projects; • setting contractual provisions or incentives; • making investment/procurement decisions; • undertaking responsible lobbying and using media relations; • promoting good practices; and • forming partnerships with sector associations, suppliers and others. • If these efforts prove unsuccessful, the organization will either need to take steps to end the relationship, or it

will need to be able to demonstrate that it has done everything reasonably possible to improve performance, and it also needs to be prepared to face any consequences for its decision to maintain the relationship.

Where the supply chain entity is crucial to the organization but it lacks leverage to influence performance , its priority should be to seek ways to increase its leverage to enable mitigation. This could take a number of forms, for example:

• offering capacity-building support to the supply chain entity to help it address the problems; • working collaboratively with other organizations that have relationships with the entity to incentivise

improvements; • working with other organizations on a broader regional or sectoral basis to incentivise improvements; • working with local or central government to the same ends.

A procurement organization should be conscious of the effect of its decisions and activities on the interests and needs of its suppliers. It should have due regard for its suppliers as well as their varying capacities and needs to engage with the organization .

Supplier engagement is more likely to be meaningful when the following elements are present: a clear purpose for the engagement is understood; the suppliers’ interests have been identified; the relationship that these interests establish between the organization and the supplier is direct or important; the interests of suppliers are relevant and significant to sustainable development; and the suppliers have the necessary information and understanding to make their decisions.

A procurement organization should encourage suppliers to identify their core issues and act accordingly. Mutual analysis will lead to appropriate dialogue related to the priority heat map between the procurement organization and supplier.

According to John Henke study, august 2014, when capacity of influence is high through strong partnership beneficial as well to the supplier, benefits for the organization are high and feed value creation as defined in “global cost and value creation” concept:

Annex D

5.5 Engagement

A basic principle of social responsibility is that an organization should respect and consider the interests of its stakeholders that will be affected by its decisions and activities (ISO 26000). As a consequencechange management towards sustainable procurement practices requires public or contractual engagement of key players such as internal stakeholders and suppliers. Few outcomes can be delivered without their full contribution. What recommendations can be made do design engagements based on an organization SP stakes and policy that has been established accordingly? 1 – reciprocity : Each one should continuously invest in a balanced partnership (or collaborative relationship) with its stakeholders, primarily its suppliers, according to ethical principles, actions and behaviour, in search of a relationship of trust and reciprocal interest. This principle should lead the principal at a willingness of exemplary. 2 – relevance : priority commitments should target the organization and stakeholders’ CSR stakes. The relevance the explicit nature of these commitments is likely to reduce risks of misinterpretation, of “greenwashing” and to contribute to a responsible communication 3 – responsible communication : internal and external communication must be favoured in order to encourage the SP approach’s transparency and to generate trust, taking into consideration efforts requested from the various stakeholders. 4 – encouraging the actors towards progress through mot ivation It should be made sure that commitments made by the ordering party can - when other recipients such as suppliers respect them - create a value for suppliers and not only be considered as a source of overcost. One of the most effective means to reach this result is to make it possible for the supplier to better access the ordering party’s market and to develop his business. Reversely, an insufficient level of expected commitments left unachieved by the ordering party should not result in an abrupt ceasure of businesss, but rather initially should be dealt with action plans for progress.

Annex E 5.6 Measuring and improving performance

The procurement function and different functions in charge with sustainable procurement issues, as any other key function, should measure and monitor the process in order to:

• measure improvement and take corrective action if necessary,

• show results to decision makers and internal stakeholders,

• benchmark the organisation against competitors and sustainability leaders,

• communicate to external stakeholders, e.g. through annual reports.

The procurement function should define key performance indicators, put in place systems to collect and analyse the data and use them to support its sustainable procurement approach.

What recommendations can be made do design measuring and monitoring tools based on an organization SP stakes and policy that has been established accordingly?

1. to primarily allow an assessment of the organization’s maturity degree in its SP performance and this in order to encourage it to continue its efforts when first sta ges are reached

A large organization can be very complex and reference frames such as the ISO 26000 and its transposition in responsible purchasing are themselves broad. To deploy such reference frames in organizations sometimes very complex can somewhat take time. One of the objectives of the reporting is thus to provide a honest account of progress made, to contribute to the organization’s valuation reflecting its true results by limiting risks linked to an irresponsible communication (“greenwashing-style”). This kind of measurement is likely to increase internal, and also external, stakeholders’ confidence and to encourage them to continue their efforts to reach a higher level of SP maturity in the organization, on a sustainable basis.

This maturity assessment can be made with the help of dedicated assessment tools well in line with this standard’s recommendations and which should advisably be updated because of rapid changes in reference frames (example given in line with recent OECD recommendations stemming from the textile industry, following the RANA PLAZA accident in april 2013):

Have you identified « risky »

suppliers and subcontractors?

“risky” = organizations

that could potentially violate ILO

fundamental conventions and the most basic

HSE requirements

Have you identified suppliers and subcontractors which may present non-compliance risks with fundamental ILO conventions and/or with hygiene and security conditions and/or with environmental regulations? Do you have a fair knowledge of potentially risky subcontractor chains, beyond your level 1 suppliers? Are you being provided with transparent and up to date information regarding the number and nature of subcontractors working for them? Is this information reliable and regularly updated? Are you aware of the social and environmental risks linked to your suppliers and subcontractors? Have they undergone a detailed analysis (by purchase category and by production country)?

Yes, in a traversal mode. Through a comprehensive risky suppliers and subcontractors mapping, undertaken in close collaboration with the Risk Department and/or with other support functions involved in the SP approach and complemented with field studies. Yes, through a risky suppliers mapping (on a complete scope integrating qualitative and quantitative criteria, such as geographical location, sector linked CSR type of risk, labour intensity, etc)….but too “laboratory” style – with little contribution from other departments or subsidiaries involved, or with no field visit Yes, partially, through a risky suppliers mapping, but its scope is limited to some categories. No

2. Primarily, base reporting and indicator choice o n accepted reference frames, taking into account th eir international legitimacy (as a priority), but also their domestic one

GRI/ global reporting initiative can be recommended for KPI’S relevant with supply chain activity:

Relevant indicator (1/2) Relevant indicator (2/2)

G4-DMA

G4-EC9 proportion of spending on local

suppliers at significant locations of operation

G4-EN15 direct greenhouse gas (ghg) emissions

(scope 1)

G4-EN16 energy indirect greenhouse gas (ghg)

emissions (scope 2)

G4-EN32 percentage of new suppliers that were

screened using environmental criteria G4-EN33 significant actual and potential

negative environmental impacts in the supply

chain and actions taken G4-LA14 percentage of new suppliers that were

screened using labor practices criteria

G4-LA15 significant actual and potential

negative impacts for labor practices in the

G4- DMA management approach description

G4-EC9 proportion of spending on local suppliers at significant locations of operation

G4-EN15 direct greenhouse gas (ghg) emissions (scope1)

G4-EN16 energy indirect greenhouse gas (ghg) emissions (scope 2)

G4-EN32 percentage of new suppliers that were screened using environmental criteria

G4-EN33 significant actual and potential negative environmental impacts in the supply

chain and actions taken

G4-LA14 percentage of new suppliers that were screened using environmental criteria

G4-LA15 significant actual and potential negative environmental impacts in the supply


G4-HR10 percentage of new suppliers that were screened using human rights criteria

G4-HR11 significant actual and potential negative human rights impacts in the supply


G4-SO3 total number and pêrcentage of sites which underwent an assessment of

identified corruption risks

SP issue Key questions Assessment of maturity

supply chain and actions taken

G4-HR10 percentage of new suppliers that were

screened using human rights criteria

G4-SO4 communication and training on policies and procedures in anti-corruption

matters

G4-SO5 Reported cases of corruption and actions taken

G4-SO9 percentage of new suppliers that were screened using social impact criteria

G4-SO10 significant actual and potential negative impacts for society in the supply


Other international or collective initiatives might be useful to go beyond GRI KPI’S:

• Dow Jones Sustainability Index is very relevant for the top 2500 largest corporations in the world • OECD recommends specific KPI’S for anti-corruption issue • ObsAR in France has published a specialized list of KPI’S consistent with the French standard on

sustainable procurement • professions gathering a large number of enterprises generate recommendations on KPI’S well suited to

their business and SP stakes • governments might recommend standards for reporting from public purchasers based on sustainable

procurement policies

The reliance on fully recognized reference frames will per se generate three kinds of benefits for the organization and its stakeholders:

• it leads the organization to comply with professional good practices recommended by these organizations: transparency, auditability via a third party audit, a structured coverage of stakeholders’ points of view,…

• the resulting seriousness thereby induced contributes to increase the feeling of confidence with the market (customers, consumers), with NGOs, financial and non-financial rating organizations, public sector users and can provide new business development opportunities for the organization

• it simplifies and reduces the expected work of many internal and external stakeholders – that of SMOs in particular – by avoiding the generation of hidden costs

3. insure relevancy and credibility with regard to the organization’s businesses, its SP policy and commitments made Reporting must be an additional pledge, to remain in the spirit of responsible communication, respect of ISO 26000 recommendations and of the principle of materiality in particular. It is thus essential – in the KPI' S, the form of the reporting and more generally in the overall related internal/external communication policy – to ensure proper coherence with SP issues prioritized in the mapping, the SP policy, and commitments made.

This necessary coherence can result in broadening the reliance on more business customed KPIs, which will validly go beyond the reliance on only recognized reference frames (see second recommendation).

As a consequence, measurement might have both qualitative and quantitative dimensions and may be applied to both procurement practices(organizational indicators such as % of number of purchasers trained in an organization) and outcomes(such as % of reduction of greenhouse gaz emission).

Also use, when relevant to key priorities, macro-economic indicators. These are not typically used at the supply chain level. However, some organizations might use such indicators to inform overall strategy. An example would be social return on investment (CSRI) which may, in turn impact on objectives for the supply chain and the criteria for making procurement decisions.

4. To feed the KPIs by favouring information sources providing quality and reliability and providing also contribution mutually beneficial relations principles on which ISO 26000 is based.

Organizations may start building KPI’S based on declarative informations provided most often by key internal stakeholders . Whereas this approach is pragmatic and can be recommended at key steps of deployment of SP policy, it also has its limitations which produces risks in reliability of reporting, auditability, acceptance from external stakeholders and as a consequence reliability of internal and external communication.

We therefore recommend progressive feeding of KPI’S based on more reliable or relevant data source:

• One important priority is to challenge internal evaluation of SP performance against external perception from relevant stakeholders. We therefore recommend to regularly conduct surveys with key external stakeholders such as suppliers . Given the nature of recommendations made by this standard (SP issues regarding strategic and non strategic suppliers) as well as the high number of suppliers, we recommend to conduct regularly supplier surveys based on representative samples including strategic as well as non strategic suppliers.

• An important driver for convincing senior management to provide additional means for deploying SP policy is benchmarking , allowing performance comparison with similar organizations.For that reason, an organization might choose to benchmark itself against peer organizations. There are a number of robust corporate responsibility measurement indexes available. These are not limited to supply-chain activities but take into account all aspects of an organization’s business practices including supply-chain. The main indexes are: Business in the Community Corporate Responsibility Index, Dow Jones Sustainability Indexes and FTSE4Good. Alternatively, public reporting initiatives such as GRI or national initiatives focused on SP performance may be used to provide transparency and might be very effective benchmarking opportunities.

Examples of benchmarking tools used in France

Annual barometer of sustainable procurement practices in all sectors (public and private) – edited by ObsAR since 2010

Annual study on the French SMEs’ perception of the 60 largest French ordering parties purchasing practices – edited by Médiation inter-entreprises (Ombudsman for the French government), in partnership with Challenge magazine, since 2013

• IT support can be very useful to industrialize the production of KPI’S improving reliability with minimum effort from internal and –as much as possib le- external stakeholders - in order to avoid administrative overload in particular for SMO’S. This effort also contributes to reduce hidden costs related with procurement. We therefore recommend best of the art use of IT technologies such as:

� Adequate use of ERP or SRM implying correct setup, correct use of functions and reporting provided. Note that some ERP and SRM editors make particular efforts to help their customers comply with CSR and help monitor CSP/SP performance. Adequate use of IT existing data collected for other purposes to prevent duplication. In the example above, it is necessary to collect information about people working on site for health and safety purposes, the same information can be used to provide data about employment.

� Best of the art decision tools being able to aggregate heterogeneous and voluminous data originating from different information systems. This can greatly accelerate the ability to produce KPI’S at reasonable cost

� Alternative IT platforms allowing easier access and information sharing with small external stakeholders such as SMO’S increase the capacity of collecting usefull data:

• Acceptance and processing of supplier information “as it is” can prove efficient for very small SMO’S

• online tools can enable efficient collection and aggregation of performance data,

• …

o generally speaking, avoid collecting unnecessary data that will not be used in a meaningful way, failure to do this will add cost for no benefit, generic questionnaires are an example of this and should be considered only if the information is to be used to inform procurement decisions; and in particular when constructing or updating a SP policy with key stakeholders