The Ethical Trading Initiative 1 is a tripartite alliance between companies, trade unions and NGOs aiming to promote respect for workers’ rights around the globe. As of 2021, there are almost 100 member companies 2 , which must:

  • Adopt the ETI Base Code in full 3 , which draws from ILO Conventions and includes provisions on freely chosen employment, freedom of association and the right to collective bargaining, safe and hygienic working conditions, prohibition of child labour, payment of living wages, non-excessive working hours, non-discrimination, regular employment and prohibition of harsh and inhumane treatment.
  • Sign up to ETI’s Principles of Implementation 4 , to progressively implement the code. These require companies to: “demonstrate a clear commitment to ethical trade; integrate ethical trade into their core business practices; drive year-on-year improvements to working conditions; support suppliers to improve working conditions, for example through advice and training; and report openly and accurately about their activities.”
  • Submit biennial reports to the ETI Board on measures taken to improve working conditions in their supply chains: Company annual reports are reviewed by the ETI Board, the Secretariat provides detailed feedback to each company, identifying where progress has been made and where further action is required. If member companies do not make sufficient progress, or fail to honour their membership obligations, the ETI tripartite Board may terminate their membership.

Complaints Mechanism

The EIT set up the ETI Code Violation Procedure in order to provide a formal avenue for raising and addressing breaches of the ETI Base Code in the supply chains of ETI Member companies. 5 These guidelines, which draw on the UN Guiding Principles on Business and Human Rights were reviewed in November 2014. The procedure was last revised in February 2017.

Who can file a complaint?

ETI members. However, an organisation which is not an ETI member may approach an ETI member to secure its support to take a complaint forward. A worker, or workers, wishing to file a complaint can do so with the assistance of the relevant Global Union Federation,other trade union organisation, or NGO member. 6

Process and outcome

This complaint procedure has four distinct stages.

  1. A complaint is filed and the company responds. 7 Where the parties agree, the complaint then progresses to stage 2; Where the parties are not in agreement ETI will attempt to develop agreement through a process of mediation, stage 3.
  2. A remediation plan is developed and implemented.
  3. Mediation seeks to place the parties in a position where they can agree on developing a remediation plan.
  4. Where mediation fails, either party can request an ETI recommendation on the complaint. Any of the parties can request that such a recommendation be reviewed by a tripartite sub-Committee of the ETI Board.

At any stage, under this procedure, the parties can agree to conduct an investigation into the issue, with a view to determining the facts raised by the complaint. A mediator or ETI can also commission an independent investigation where mediation is unable to resolve disagreements between the parties.

In order to avoid the victimisation of workers, the complainant can withhold their names, and the ETI member must warn its supplier under allegation that there is a “no victimisation” policy in relation to workers who may be named in the complaint. All information received from each party will be provided to the other parties to the complaint, and in the case of a mediation procedure, parties can agree to keep the contents confidential. Progress on complaints heard under this process will be routinely reported to the ETI Board. At the conclusion of a complaint, the ETI will publish a statement agreed by the parties or a short summary of the complaint and the outcome. There is limited information on ETI’s website on complaints and outcomes regarding cases of violations of workers’ rights in members’ supply chains, but the secretariat can easily be contacted (see below). 8