NORMAPME Draft Comment On ISO/FDIS 26000 July 2010

Template for comments and secretariat observations Date: July 2010 Document: ISO/FDIS 26000:2010(E)
NORMAPME Comment
ISO/TMB/WG SR
1 2 (3) 4 5 (6) (7)
MB1 Clause No./ Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Secretariat observations
Subclause No./ Figure/Table/ of on each comment submitted
Annex Note com-
(e.g. 3.1) (e.g. Table 1) ment2
NO Whole ge NORMAPME is dedicated to looking after the

RM document interests of European small and medium
AP enterprises in standardization. We appreciate
ME the intensive work of ISO/TMB/WG SR over the
last five years but have to recognize that
- NORMAPME is the only true
representation of SMO interests in this
ISO 26000 project
- SMO stand for more than 95% of all
possible ISO 26000 users, and that
- their main concerns and proposals have
not been sufficiently taken into account
when drafting the FDIS.
More details offered the following comments.
We remain convinced that the entire wisdom on

SR guidance contained in the FDIS could easily
be expressed in half the number of words and
that such a shorter document would be much
easier to use.
NORMAPME is ready to contribute to the further
improvement of the guidance standard, on the
basis of our comments. We recommend for any
further work that SMO interests are properly
represented, on a global scale. In particular, we
believe that, in order to establish balanced
representation of stakeholders, SMOs should be
represented by an additional category of
stakeholders; hence, SMOs should constitute an
independent stakeholder group in the process.
Within the FDIS vote (deadline 12 September
1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by **)
2 Type of comment: ge = general te = technical ed = editorial
NOTE Columns 1, 2, 4, 5 are compulsory.
page 1 of 23
ISO electronic balloting commenting template/version 2001-10
NORMAPME Comment
ISO/TMB/WG SR
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Annex Note com-
2010) ISO is seeking “full and formal backing”

from the D-Liaison organizations.
NORMAPME is not in a position to express this

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

NO Whole ge NWIP requirement: “limiting proliferation of SR Although criteria for better social behavior of
RM document sector standards …” is not met. organizations is increasingly discussed, and
AP According to N049 Design Specification and its we see more sector or branch standards
ME annex “New Work Item Proposal”, see NWIP’s are published, often in the form of a sector’s
Annex B, little c), this requirement should be met: code of conduct; the FDIS does not offer
options to stop this trend. To the contrary: by
“…limiting the proliferation of SR sector standards;” lines 164 and 165 (This International
Standard is not intended to prevent the
We have not seen WGSR addressing this development of national standards that are
requirement. more specific, more demanding, or of a
different type.) the FDIS explicitly denies this
requirement!
Proposal: start work on this NWIP
requirement by e.g. identifying the criteria for
emerging SR sector standards, analyzing the
substance of SR sector standards and the
deltas to the FDIS, and amend the FDIS
accordingly.
NO Whole ge NWIP requirement: “easy to understand…” is At many instances the document is not
RM document not fulfilled. considered as easy to understand: The level
AP of detail has lead to far too many
In N049 Design Specification, lines 63 and 64, this
ME recommendations, making it impossible for
requirement reads:
the user to distinguish between what is
“The language must be clear, understandable and important and what is not.
objective throughout the guidance standard. “ This will provoke a considerably expensive
consulting business. This is contradictory to
The purpose and intent of this NWIP requirement, the goal of “promotion of a more social
as agreed by the ISO/TMB/SAG Special Advisory responsibility behavior.
Group was to make an involvement of external Proposal:
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Annex Note com-
advisors, consultants etc. unnecessary. 1) prioritize the different recommendations or

suggest a system of criteria for an
organization to prioritize them
2) conduct a user survey to identify all
instances of lacking comprehensibility and
revise the document accordingly.
NO Whole ge Volume; self-containing document vs. The document should not extend beyond 40
RM document referencing other sources; non-applicability, pages.
AP particularly to SMOs
An 80 pages volume could only be justified if
ME
Particularly SMOs will not study some 80 pages in 50% of it offers practical guidance in form of
order to find guidance eventually valuable for them. good practical examples.
The immense volume was articulated in CD Proposal: a 40 page volume can be
comments by various ISO member bodies and D- achieved without loss of substance by
Liaison organizations. We don’t understand the WG
SR Secretariat’s “observation” (reply in column 7 of - Deleting redundancies and broader
the comment template), in preparing for the Quebec explanations in the document itself
meeting: “This issue has been considered in some - Referencing other valuable sources
detail during earlier WG SR meetings where a instead of developing own guidance
previous decision was taken, often on the basis of a proposals;
careful compromise. It is thus strongly advised
that we do not reopen discussion on this issue.” e.g. the core subject Human Rights
can be dealt with by referencing the
In this context please note that the statement United Nations’ declaration UNDHR
sentence in line 437/438 in the SMO box is and briefly describing how best to
proposed to be rephrased. “For the purpose of apply it.
this International Standard, SMOs include those
very small organizations referred to as “micro” E.g. guidance on the Environment
organizations.” can be dealt with by referencing the
. ISO 14000 series and briefly
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describing how to apply these

standards.
NO Introduction, Lines ge Relevance of all core subjects to every Proposal: Change lines 49 onwards by
RM scope and 49/50; organization; inconsistency of statements replacing “are relevant” with “may be
AP other sub- 454/456; relevant” so that it reads:
ME clauses 714; 2957; The term “relevant” calls for action. The document
needs consistency in this regard to be applicable: “While not all parts of this International
Standard will be of equal use to all types of
1 relevance of all ... to every… organizations, all core subjects are may be
“While not all parts of this International Standard will relevant to every organization”.
be of equal use to all types of organizations, all core
subjects are relevant to every organization. It is the Additionally: include a sentence like
individual organization's responsibility to identify “It is at the organization’s discretion to
what is relevant and significant for the organization decide, according to the concerns expressed
to address, through its own considerations and by its stakeholders, whether a core subject is
through dialogue with stakeholders.” relevant to it or not or to what degree.”
Comment: this statement can be read in many Further: delete the repetitive statements on
ways; firstly, that all core subjects are relevant (i.e. this relevance from the other indicated lines.
have to be taken into account), and then that the
organization has to decide itself what is relevant to
address. This is a contradiction in itself.
2 relevance of all … to every…

“….be aware that when reviewing all seven core
subjects and identifying the relevant issues, the
organization’s own context, conditions, resources
and stakeholder interests should be taken into
account, recognizing that all core subjects, but not
all issues [will be relevant] for every
organization;”
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Comment: depending on the kind of activity of an

SMO, it will not be considered acceptable that all
core subjects should always be relevant.
3 relevance of all ... to … every…

“…responsibility. Every core subject, but not
necessarily each issue, has some relevance for
every organization.”
and in clause
7.3.2.1 Determining relevance
“All the core subjects, but not all issues, have
relevance for every organization. The degree of
relevance of the…”
Comment: if all core subjects are supposed to be

relevant to an organization and the organization
decides about the degree of relevance, this degree
can be zero, in other words: it can be decided
that a core subject is not relevant.
NO 2 Terms and Various ge Various definitions don't meet the requirement Proposal: rework the definitions so that they
RM Definitions definitions of the ISO/IEC Directives all meet the requirements of the ISO/IEC
AP Directives
ME Definitions are not in line with the ISO/IEC
Directives Part 2 which says on page 48:
C.1.5 Drafting of definitions
• C.1.5.1 Rules for the drafting of definitions
are given in ISO 10241.
• C.1.5.2 A definition shall not take the form
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of, or contain, a requirement.

• C.1.5.3 The form of a definition shall be
such that it can replace the term in
context.
Additional information shall be given only in
the form of examples or notes (see C.3.9).
C.1.5.4 A definition given without an
indication of its applicability may be taken as
representing the general meaning of the
term. Special meanings in particular
contexts shall be indicated by designating
the subject field (see C.3.6).
The requirements of C.1.5.2 and C.1.5.3 are not

met by a number of definitions, in particular those
on “social responsibility” itself and on “sphere of
influence”.
During the commenting phases this deficiency was
repeatedly mentioned and one can only wonder
that it had been ignored in spite of ISO
representatives taking part in the process.
NO 2 Terms and Line 180 te Definition due diligence Proposal: Add a note that reads
RM Definitions NOTE To act accordingly does not require a
This definition assumes that an organization has a
AP formal process.
formal process in place to identify risks.
ME
Micro and small organizations generally operate this
way without having a formal process in place.
NO 2 Terms and Line 212 Definition international norms of behavior Proposal:
RM Definitions this definition reads “2.11 Reword this definition to:
international norms of behaviour
page 7 of 23
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Annex Note com-
AP expectations of socially responsible organizational 2.1.10 international norms of behaviour

ME behaviour derived from customary international law, Customary international law, generally
generally accepted principles of international law, or accepted principles of international law, or
intergovernmental agreements that are universally intergovernmental agreements (such as
or nearly universally recognized. treaties and conventions) that are universally
or nearly universally recognized.
This definition is not a definition because it contains
undefined terms like NOTE 1 (as it stands)
- expectations
- customary international law add NOTE 2 In any case of doubt about, or
- generally accepted principles of potential conflict with, international norms
international law of behaviour, national law prevails.
- universally recognized, and
- nearly universally recognized. add NOTE 3: give 5 examples for customary
international law and expectations expressed
The notes don't remedy this deficiency therein
add NOTE 4: give 5 examples for generally

accepted principles of international law and
expectations expressed therein
add NOTE 5: give 5 examples for

intergovernmental agreements that are
universally recognized and expectations
expressed therein
add NOTE 6: give 5 examples for

intergovernmental agreements that are
nearly universally recognized and
expectations expressed therein
page 8 of 23
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To make this part “easy to understand”, make

sure that selected expectations don’t overlap
and are not in conflict with each other.
NO 2 Terms and Line 248 ge Definition social responsibility Proposal: Change text into a shorter and
RM Definitions to 256 easier to understand definition that reads:
AP The current definition is not in line with the
ME requirements of the ISO/IEC Directives because
a. it contains requirements and the bullet 2.1.18 social responsibility
points and
b. it cannot replace the term “social responsibility of an organization for the
responsibility” where it occurs in the text impacts of its decisions and activities on
society and the environment
The explanations and requirements currently NOTE 1 Such a behaviour
contained in the definition itself should go into
notes. - contributes to sustainable
development;
- takes into account the expectations
of stakeholders;
- is in compliance with applicable law;
- is an integral part of the organization;
and
- is practiced in its relationships.
NOTE 2 Activities include products, services
and processes.
NOTE 3 Relationships refer to an
organization’s activities within its sphere of
influence.
page 9 of 23
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NO 2 Terms and Line 222 ge Definition organization Proposal: Use this practice-proven definition:
RM Definitions onwards The current definition reads “Social unit of people systematically arranged
AP 2.12 organization and managed to meet a need or to pursue
ME entity or group of people and facilities with an collective goals on a continuing basis.
arrangement of responsibilities, authorities and
relationships and identifiable objectives NOTE1 Organizations have a management
- structure that determines relationships
between functions and positions, and
This wording contradicts the scope and seems subdivides and delegates roles,
particularly unrealistic when reading the sentence responsibilities, and authority to carry out
from line 437: “For the purpose of this defined tasks.”
International Standard, SMOs include those very
small organizations referred to as “micro” Based on:
organizations.” http://www.businessdictionary.com/definition/
Please note that this statement is proposed to be organization.html (November 2009)
deleted.
Proposal: add to the definition further notes
The definition 2.1 on accountability explains that an
organization has its governing bodies. This reads
as if every organization has one or more levels and NOTE2 An SMO which does not have the
governing bodies. This is not realistic for SMO. formal management structures referred to in
the definition of an organisation above may
Key words like governing bodies, management consider the standard inapplicable to it.
structure, functions, positions, authority for and
delegation of responsibility are missing in the
current definition.
NO 2 Terms and Line 265 ge Definition stakeholder Proposal:

page 10 of 23
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Annex Note com-
RM Definitions onwards The draft definition reads Use the ICC proposed definition that reads
AP 2.20 stakeholder
ME individual or group that has an interest in any “Individual or group significantly affected by
decisions or activities of an organization an organization’s activities.”
This definition has the potential to disqualify the And add a NOTE that reads
whole document because “an interest” and “any “It is up to an organization to determine
decisions or activities” are undefined terms. whom to consider a stakeholder.”
By this definition everyone/anyone simply

declaring “an interest” would be a
“stakeholder”. This is not in line with the general
understanding of “stakeholder” as “affected parties”,
which is correctly explained in lines 768-769
(“Stakeholders are organizations or individuals that
have one or more interests in any decision and
activity of an organization. Because these interests
can be affected by an organization…”)
Also lines 778/805/3218 reference to “stakeholders

being affected”.
2.1.19 Line 257 Definition sphere of influence: Proposal: Rephrase lines 437 and 438 as
the current definition “sphere of influence proposed in order to clarify that micro-
NO onward
range/extent of political, contractual, economic or organizations are excluded from the scope of
RM
other relationships through which an organization this standard.
AP
ME (2.12) has the ability to affect the decisions or
activities of individuals or organizations”
is not applicable to micro-organizations and smaller
organizations. They will argue that they don't have
page 11 of 23
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the sphere of influence.
NO 3.3.4 437/438 te “For the purpose of this International Standard, The statement sentence in line 437/438 in
RM SMOs include those very small organizations the SMO box is proposed to be rephrased.
AP referred to as “micro” organizations.”
ME
NO 6.3.2.2 : 995 -1427 te We consider human rights as an integral part Proposal: to eliminate those
RM of social responsibility and, therefore, agree on recommendations from the text of the
6.3.6.2
AP an extensive chapter concerning human rights sub-chapters concerned. However, it
ME 6.3.7.2 within the ISO 26000. could be useful to add a general remark
on these issues in chapter 6.3.2.2.
Different sub-chapters urge organizations to (Considerations) that could run as
6.3.9.2 promote human rights in the public, to raise follows: “Organizations should in general
human rights issues with authorities, to seek to promote human rights also in the
facilitate access to education etc. We think that public whenever deemed feasible.”
actively promoting human rights at
governmental institutions and political work in
this field is not the primary duty or
responsibility of (non-governmental)
organization.
In consequence, the following sentences

should be eliminated:
1077, 1078 (this only concerns human rights

education and should be replaced by the
general phrase mentioned above);
1234-1235;
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1238, 1239;
1250;
1274, 1275;
1279 1280 (2nd part of the sentence);
1336, 1337
NO 3.3.4 Lines te This sentence “Social responsibility should be an Proposal: Solve the contradiction between
RM 394/396 integral part of core organizational strategy with this sentence and the definition of
AP assigned responsibilities and accountability at all “organization” by adapting the latter one.
ME appropriate levels of the organization.” clarifies that
an organization has various levels and shared
responsibilities, which generally is not the case for
SMOs.
NO Box 3 on Line 436 to te Expressions like Change this language based on interviews
RM SMOs 472 with several SMOs of different but sample-
- top management
AP representative sizes.
ME - integrated approach to managing an
Avoid negative language, as if SMOs
organization’s activities and impacts
generally take decisions and undertake
- …to remedy immediately all negative actions that will have negative
consequences of its decisions consequences.
- …that appropriate levels of transparency
are preserved
…are not supposed to be SMO language and will
rather be detrimental to the acceptance of the
guidance standard.
NO Box 3 on Lines 460 - The following statement may be wrongly interpreted Proposal: if the FDIS maintains stating that
RM SMOs 463 to infer that SMOs should produce the guides “… SMO should seek assistance… in
AP themselves. This would be unrealistic. It should be developing practical guides and programs for
page 13 of 23
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ME reiterated that an SMO has neither the resources using this international standard.” it admits
nor the know how to develop guides on the implicitly that it is not practicable to all types
standard of applicability to a range of SMOs. This and sizes of organizations as required by its
activity should be performed by the sectoral scope. In consequence either the scope
associations who may have the resources, should be clarified or the sentence in lines
experience and the broader familiarity with the 460-2463 should be clarified.
needs of the various sectors.
‘SMOs should seek assistance from relevant Proposal: The text to read, ‘Practical guides
government agencies, collective organizations should be produced by the government
(such as sector associations and umbrella or peer agencies, collective organizations (such as
organizations) and perhaps national standards sector associations and umbrella or peer
bodies in developing practical guides and organizations) and perhaps national
programmes for using this International Standard. standards bodies for the provision of
Such guides and programmes should be tailored to assistance to SMOs in their interpretation of
the specific nature and needs of SMOs and their the standard and its relevance to them.
stakeholders
NO 4 Principles Lines 519 ge Redundancies Proposal: Combine the principles of clause 4
RM to 669 with the core subjects’ clause 6 in order to
Respecting the good intent of clause 4, it seems
AP shorten the text and avoid any overlaps.
evident that it addresses primarily larger
ME
organizations with transnational operations so that If this merger of clauses 4 and 6 seems not
SMOs will not find it applicable. feasible, the bullet points (“an organization
should…”) should be deleted in all sections
Further, parts like 4.8 on Human Rights overlap with
4.x to help reduce the mentioned confusion.
the Human Rights section of clause 6. Other parts
4.x are redundant with similar statements in clauses
3, 5, 6 and 7.
This is confusing and will be judged as not easy to
understand.
NO 4.3 Lines 550 ge As written this requires detailed information that is Clarify that this guidance is meant for larger
RM Transparenc to 572 not available in smaller organizations. organizations and that SMO may use it only
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AP y This section is another indicator that the whole as they feel fit.
ME document addresses larger organizations and does
not fulfill the NWIP requirement of being applicable
to all organizations.
NO 4.7 645 - 658 Te Complicity: It is quite comprehensible that Proposal: A serious definition could contain
RM complicity has both legal and non-legal meanings. It the following wording:
AP is also true that this issue has been subject to
Unless the law expressly provides for criminal
ME lengthy discussion in WG SR. However, in terms of
liability based on negligence, only intentional
legal meanings the definition is lacking a clear
conduct shall attract criminal liability
reference to an “intentional” element in its attempt
to find a legal definition in line 649. The use of the term “complicity” which is a
legal term in many national legal systems
leads to different interpretations in the context
As regards the reference to “omission” as to these legal systems.
equivalent to an illegal act further explanation
ge Consequently, it might be useful to use terms
appears to be necessary.
which are used in a more general context.
As a general remark it is clear that the more
we use abstract definitions the more we have
to explain what is meant by it. Moreover, the
more we define the more we lose the aim to
develop a guideline for practical use. In the
end, it would seem to be worthwhile to
develop a short SMO-friendly guideline and a
further developed separate document
providing more practical information including
definitions.
NO 5.2 Line 682 to te SMOs won't feel any appeal for this section if Proposal: Shorten the text of this abstract
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RM Recognizing 763 addressed to them; they will miss more practical presentation and add some practical
AP social guidance. examples and guidance that make the
ME responsibility section easier to understand.
NO 5.3 Lines 764 ge This chapter seems to be a theoretical deduction or Proposal: Shorten the text of this abstract
RM stakeholder to 868 abstract presentation of the topic. presentation and add some practical
AP identification examples and guidance that makes the
SMOs generally (like the violin manufacturer in
ME and section easier to understand.
Northern Bavaria) know their stakeholders quite
engagement
well and don’t have the capacity to investigate the
details of a stakeholder identification and
engagement process. They rather invest all energy
into their survival.
NO 6.2 Lines 971 ge There is confusion over the statements Proposal: Clarify that section 6.2 is
RM Organization to 994 applicable for small and micro
- “create a system of economic and non-
AP al organizations only in some parts.
economic incentives
ME governance,
related - promote fair representation of under-
expectations represented groups
and actions
- encourage effective participation of all
levels of employees in the organization’s
decision making on issues of social
responsibility
- balance the level of authority, responsibility
and capacity of people who make decisions
on behalf of the organization
- keep track of the implementation of
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decisions to ensure that these decisions are

followed through and to determine
accountability for the results of the
organization’s decisions and activities
- periodically review and evaluate the
governance processes of the organization”
clearly indicate that FDIS is written for larger
organizations, not for small (less than 50 persons),
and not at all for micro organizations (less than 10
persons): it is not realistic to believe that SMO have
the mentioned “structures and procedures” in place,
as asserted in line 967 to 970.
NO 6.3.7 Human Lines 1217 ge, te The text reads: Proposal: Change text to
RM rights issue to 1220 “Discrimination can also be indirect. This occurs
when an apparently neutral provision, criterion or “Discrimination can include also particular
AP 5:
practice would put persons with a particular attribute attributes like religion or belief, disability, age,
ME Discriminatio
at a disadvantage compared with other persons, race or sexual orientation.”
n and
vulnerable unless that provision, criterion or practice is Screen whole clause 6 accordingly.
groups objectively justified by a legitimate aim and the
means of achieving that aim are appropriate and
necessary.”
Its content is theoretically correct but not easy to

understand, particularly not for SMOs.
This text serves only as an example for offering

shorter and easier understandable texts in clause 6.
NO 6.3 whole Lines 1079 ge Human rights issues Proposal: To avoid users’ confusion, rewrite
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RM clause to 1427 Respecting the content, at instances its description this section and use the UNDHR and ILO
AP is rather theoretical, written in a pedagogical style, documents as basis, select the most
ME and creating confusion in relation to other important rights and give more practical
“instruments”. The issues guidance on how best to follow them.
1: Due diligence To avoid users feeling misled, include the
statement that
2: Human rights risk situations
“in case of doubt national law prevails”.
3: Avoidance of complicity
It can’t be the role of ISO or of an ISO
4: Resolving grievances standard to try introducing rights the
practicing of which may lead to conflicts with
5: Discrimination and vulnerable groups issued national law.
6: Civil and political rights Delete issue 8 because it overlaps in a
7: Economic, social and cultural rights confusing way with section
6.4 on Labour Practices.
8: Fundamental principles and rights at work
.
…are not relevant where regulated by law. In
countries where all 8 issues are covered by
regulation, the whole core subject “human
rights” will not be considered relevant, while the
document says in various lines that all core
subjects are relevant to all organizations.
NO 6.4 Labour Lines 1428 ge With all due respect for the good intent of this Proposal: focus this clause on fewer issues
RM Practices to 1737 clause, it is written in the spirit of (see line 1611) and explain better HOW organizations could
AP “Trade unions… have a particularly important role to readily practice them.
ME play…”
Good and easy-to-understand examples,
This clause is industry biased and clearly written
derived from good practices, should be
for larger organizations and particularly for those
added.
acting internationally.
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It can easily be understood as if the recurrent theme

were “Sharing benefits, not sharing risks with an
organization owner”.
Thus, owners of SMOs, most of them private
persons and family oriented, will feel very uneasy
and may chose to disregard the whole document
because of this clause, particularly micro
organizations.
Much of the text is covered by its handbook
character and educational style; some motivating
and convincing practical examples would be more
helpful, particularly for SMOs.
A rewrite without industry bias is necessary.
NO 6.5 Lines 1738 ge Recognizing its good intent and content, this Proposal: Restructure this clause by
RM Environment to 2035 clause seems to be written for larger organizations - referencing other tools like the series
AP and particularly for those acting internationally. ISO 14000,
ME - providing priorities of problems and
Its applicability to organizations like doctors, natural kind of actions, and
healers, offices, homeopaths, schools, religious - underlining them with practicable
organizations, not-for-profit organizations like examples.
“Medecins sans frontiers”, architects, engineering
offices, lawyers and many others is basically limited Proposal: Provide tools with which
to the responsible use of water. particularly SMOs can readily demonstrate
how they manage environmental problems,
Addressing the issues by referencing other tools so that there is no need to involve external
like the series ISO 14000, providing priorities of parties like consultants, auditors or certifiers.
problems and kind of actions, and underlining them
with practicable examples would be more helpful for
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users.
NO 6.6 Fair Lines 2036 ge The actions on this core subject as proposed for Proposal: Mention at the beginning of 6.6
RM Operating to 2172 these issues, that the degree of applicability of this core
AP Practices subject “Fair Operating Practices” varies for
1. Anti–corruption
ME organizations according to their size and
2. Responsible political involvement type.
Lines 3. Fair competition
49/50 4. Promoting social responsibility in the sphere
of influence
5. Respect for property rights
can be relevant for larger industry organizations but
won't be considered relevant for SMO like
pharmacies, doctors , natural healers offices,

homeopaths, schools, religious organizations,
not-for-profit organizations like “Medecins sans
frontiers”, architects, small engineering offices,
lawyers, retailers, craftsmen of all kinds, gardeners,
hair cutters, bakeries, car repair shops,
Nachbarschaftshilfen (associations of neighbours
providing help with shopping, cleaning, gardening,
etc. to those less able in the neighbourhood),
Kindergartens, Homes for senior citizens and other
“social institutions”, Hospitals,
while the scope claims that all core subjects are
relevant to all organizations.
page 20 of 23
NORMAPME Comment
ISO/TMB/WG SR
1 2 (3) 4 5 (6) (7)
Annex Note com-
NO 6.6.3 Anti- Line 2080 Ge, The bullet point “establish and maintain an effective Change this bullet to
RM corruption te system of internal controls to counter corruption”
“as appropriate to the size of the organization
AP indicates that the whole document is written for
establish and maintain effective means of
ME larger organizations.
internal controls to counter corruption”
NO 6.6.4 Line Ge,te This issue is addressed to larger organizations only; Make the applicability dependent on the size
RM Responsible 2090/2091 SMO will feel overtaxed and micro organizations will of organization by adding to 2089 the
AP political see this issue totally irrelevant for them. underscored words
ME involvement
“According to their possibilities organizations
may support public political processes…
NO 6.7 Lines 2173 ge While respecting its good intent, this section is Proposal: Focus this clause on genuine
RM Consumer to 2540 excessively large (consumer issues are but a consumer issues
AP issues small part of society related issues) and causes
- Issue 2: Protecting consumers’ health
ME problems because it addresses items just from
and safety
a consumer perspective while the same item is
dealt with at other places, like - Issue 4: Consumer service, support,
and dispute resolution
- “sustainable consumption” in 6.7 and
sustainable resource use in 6.5 - Issue 6: Access to essential services
- Fair marketing in 6.7 and fair competition in - Issue 7: Education and awareness
6.6 are too similar to be dealt with
and refrain from the explanatory style, thus
separately.
shortening clause 6.7 from now 16,3% of the
Such content-related overlaps lengthen the whole clause 6 to some 7%;
document unnecessarily and confuse users.
integrate the other issues into the other
Since consumer goods/services are regularly relevant sections:
manufactured/offered by larger organizations (a
- 6.7 Issue 1: Fair marketing…, into 6.6
typical good is household equipment), the entire set
Issue 3: Fair competition
of consumer issues will not be seen relevant by the
page 21 of 23
NORMAPME Comment
ISO/TMB/WG SR
1 2 (3) 4 5 (6) (7)
Annex Note com-
vast majority of SMOs so that they may deny the - 6.7 Issue 3: Sustainable consumption
relevance of the whole core subject. into 6.5 Issue 2: Sustainable
resource use
- 6.7 Issue 5: Consumer data
protection and privacy into 6.6 Issue
5: Respect for property rights
NO 6.8 Lines 2541 While lines 2549/2550 describe the flexibility of Proposal: Delete 6.8 as a core issue and
RM to 2889 relevance to an organization (“The area and the integrate its content into clause 3
AP whole community members affected by an organisations Understanding social responsibility
ME clause impacts will depend upon the context and especially
upon the size and nature of the organization’s This way, redundancies are avoided and the
impacts.”) the details further down in lines benefits of “society involvement and
2635/2636 demonstrate that the spirit of this clause development” are presented in a more
is directed to larger organizations: “When motivating way at the beginning of the
developing plans for community involvement and document.
development, an organization should seek
opportunities to engage with a broad range of
stakeholders (see 4.5, 5.3 and Clause 7).” Such a
general recommendation realistically is not directed
to SMOs and particularly not to micro organizations.
“Community” versus “society”: at almost each

instance in this clause the term community can be
replaced by society. It would make a lot of sense to
integrate clause 6.8 into clause 3 Understanding
social responsibility so that redundancies are
avoided and that the benefits of “society
involvement and development” are presented in a
motivating way at the beginning of the document.
page 22 of 23
NORMAPME Comment
ISO/TMB/WG SR
1 2 (3) 4 5 (6) (7)
Annex Note com-
This would also contribute to considerably reducing

the volume of the document.
NO 7.4.2 Setting Line 3112 Ge,te The phrase reads: Proposal: Change sentence to
RM the direction to 3114 “Detailed plans for achieving the objectives,
“According to the organization’s size, more
AP of an including responsibilities, timelines, budgets and the
detailed plans for achieving the objectives,
ME organization effect on other activities of the organization, should
timelines, budgets etc. can be helpful.”
for social be an important element in establishing the
responsibility objectives and the strategies for their achievement.”
Again, this is a clear indicator that clause 7 and the
whole document is written for larger organizations,
not for SMOs, because SMOs regularly don’t need
such detailed plans to behave in a socially
responsible manner.
page 23 of 23

NORMAPME Draft Comment On ISO/FDIS 26000 July 2010

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Template for comments and secretariat observations Date: July 2010 Document: ISO/FDIS 26000:2010(E)

1 2 (3) 4 5 (6) (7)

NO Whole ge NORMAPME is dedicated to looking after the

We remain convinced that the entire wisdom on

1 2 (3) 4 5 (6) (7)

2010) ISO is seeking “full and formal backing”

NORMAPME is not in a position to express this

1 2 (3) 4 5 (6) (7)

recommendations to their activities.

1 2 (3) 4 5 (6) (7)

advisors, consultants etc. unnecessary. 1) prioritize the different recommendations or

1 2 (3) 4 5 (6) (7)

describing how to apply these

2 relevance of all … to every…

1 2 (3) 4 5 (6) (7)

Comment: depending on the kind of activity of an

3 relevance of all ... to … every…

Comment: if all core subjects are supposed to be

1 2 (3) 4 5 (6) (7)

of, or contain, a requirement.

The requirements of C.1.5.2 and C.1.5.3 are not

1 2 (3) 4 5 (6) (7)

AP expectations of socially responsible organizational 2.1.10 international norms of behaviour

add NOTE 4: give 5 examples for generally

add NOTE 5: give 5 examples for

add NOTE 6: give 5 examples for

1 2 (3) 4 5 (6) (7)

To make this part “easy to understand”, make

1 2 (3) 4 5 (6) (7)

NO 2 Terms and Line 265 ge Definition stakeholder Proposal:

1 2 (3) 4 5 (6) (7)

By this definition everyone/anyone simply

Also lines 778/805/3218 reference to “stakeholders

1 2 (3) 4 5 (6) (7)

the sphere of influence.

In consequence, the following sentences

1077, 1078 (this only concerns human rights

1 2 (3) 4 5 (6) (7)

1 2 (3) 4 5 (6) (7)

1 2 (3) 4 5 (6) (7)

1 2 (3) 4 5 (6) (7)

1 2 (3) 4 5 (6) (7)

decisions to ensure that these decisions are

Its content is theoretically correct but not easy to

This text serves only as an example for offering

1 2 (3) 4 5 (6) (7)

1 2 (3) 4 5 (6) (7)

It can easily be understood as if the recurrent theme

1 2 (3) 4 5 (6) (7)

pharmacies, doctors , natural healers offices,

1 2 (3) 4 5 (6) (7)

1 2 (3) 4 5 (6) (7)

“Community” versus “society”: at almost each

1 2 (3) 4 5 (6) (7)

This would also contribute to considerably reducing

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