Together for Sustainability
Together with Employees?

        The administration and the members of
        Together for Sustainability AISBL (TfS)
        Avenue Edmond van Nieuwenhuyse 4
        1160 Auderghem

Dear Ladies and Gentlemen

The TfS members use the services of EcoVadis. The employees of your companies are key stakeholders in the CSR management of your company. Do you, as members of TfS and EcoVadis, disclose the EcoVadis Premium Reports to your employees?

Corporate Social Responsibility for Irresponsibility (2012):

The B.E. Journal of Economic Analysis & Policy: Vol. 12: Iss. 1 (Contributions), Article 55. DOI: 10.1515/1935-1682.3308

Corporate Social Responsibility for Irresponsibility

Matthew Kotchen and Jon J. Moon

This paper provides an empirical investigation of the hypothesis that companies engage in corporate social responsibility (CSR) in order to offset corporate social irresponsibility (CSI). We find general support for the relationship that when companies do more “harm,” they also do more “good.” The empirical analysis is based on an extensive 15-year panel dataset that covers nearly 3,000 publicly traded companies. In addition to the overall finding that more CSI results in more CSR, we find evidence of heterogeneity among industries, where the effect is stronger in industries where CSI tends to be the subject of greater public scrutiny. We also investigate the degree of substitutability between different categories of CSR and CSI. Within the categories of community relations, environment, and human rights—arguably among those dimensions of social responsibility that are most salient—there is a strong within-category relationship. In contrast, the within-category relationship for corporate governance is weak, but CSI related to corporate governance appears to increase CSR in most other categories. Thus, when CSI concerns arise about corporate governance, companies seemingly choose to offset with CSR in other dimensions, rather than reform governance itself.

EcoVadis wants to dominate
the US Market

[…] Terra Nova developed a robust financial tool, known as the Variable EcoVadis Scenario Projection Analysis (VESPA) model, in order to ensure that all of its strategic recommendations were underpinned by thorough financial forecasting and robust data analysis. This rigorous and methodological approach resulted in a suite of three strategies, all supported by actionable tactics that, if employed, would allow EcoVadis the greatest chance at success in achieving its goal of dominating the US market.

 One objective of is to make you aware of problems which may be caused by allowing EcoVadis to dominate the CSR assessment business.

How does the DFGE support Employees as CSR Stakeholders?

Dear Dr. Thomas Fleissner

Coming from the Technical University Munich, you founded the DFGE. That company helps suppliers to present their CSR management to EcoVadis.

Do you think that the employees of suppliers assessed by EcoVadis should be provided with a EcoVadis Premium Report in case their employer subscribed to an EcoVadis Premium plan and received “Silver” or “Gold” from EcoVadis?

Employees are key stakeholders in the CSR management of their employer. Is there any link to your web site where I find an explanation on how you support these stakeholders?

Mit besten Grüßen,
Götz Kluge


 No doubt, Huawei is a renown leader in protecting human rights. In China these are human rights in “Chinese coloration”: 中国特色的 = zhōngguó tèsè de. I lived and worked in China long enough to know well, what I am talking about.

 EcoVadis grows aggressively. They tweet: “How Sustainability Is Becoming A Competitive Advantage In China”. I guess that EcoVadis sees outstanding chances for its business to grow significantly in China and needs success stories from Chinese big players. EcoVadis is an independent company, but it surely is not independent from its business interests.

–> Questions to suppliers

EcoVadis should not blindly rely on OHSAS 18001 Certificates

This is about certificates for OH&S (Occupational Health & Safety) management systems. EcoVadis accepts them as evidence.

In Germany, a well known CAB (accredited Compliance Assessment Body) of OH&S management systems tolerated for several years a very obvious non compliance of his client with OHSAS 18001:2007. Seemingly the client certified by that CAB did not like the terms in OHSAS 18001:2007 and therefore kept using the terms of OHSAS 18001:1999, which are less demanding. After some years an employee discovered that. The accreditation body DAkkS initiated a re-audit.

In Germany, at least the big CABs protect employers, not employees. The best OHSAS 18001 audits in Europe probably are run in the Netherlands, where the SCCM auditing scheme is applied.

 Bad audits of OH&S managements systems by CABs and by the authorities are a problem for companies like EcoVadis. Certificates provided by accredited CABs simplify their efficiency optimized document audits (remote audits in most cases). But even with well known suppliers and CABs those assessment providers like EcoVadis cannot rely on OHSAS 18001 audits. One way to verify the quality of OHSAS 18001 implementation could be to check, whether assessed suppliers really register and evaluate all incidents defined in clause 3.9 (and clause 3.8) in OHSAS 18001:2007.

OHSAS 18001 Incident Reporting

 Regrettably, EcoVadis tolerates incomplete incident reporting. As for occupational health and safety, EcoVadis only expects reporting on the accident severity rate and the accident frequency rate. That kind of reporting is not the state of the art anymore. EcoVadis allows OHSAS 18001 certified suppliers to get away with incomplete reporting (many of them still keep doing that) although “accident” in OHSAS 18001:1999 for a good reason has been replaced by “incident” in OHSAS 18001:2007. Since 2007, according to clause 3.8 (ill health) and 3.9 (incident) there are twelve kinds of incidents:

12 Incidents in Occupational Health & Safety

In words:
Incidents which …

          … have caused physical ill health
          … have worsened physical ill health
          … could have caused physical ill health
          … could have worsened physical ill health
          … have caused mental ill health
          … have worsened mental ill health
          … could have caused mental ill health
          … could have worsened mental ill health
          … have caused injury
          … could have caused injury
          … have caused fatality
          … could have caused fatality

    Or in other words (strictly following clause 3.8 and clause 3.9 of OHSAS 18001:2007):
    Incidents in which …
          … physical ill health occurred
          … physical ill health worsened
          … physical ill health could have occurred
          … physical ill health could have worsened
          … mental ill health occurred
          … mental ill health worsened
          … mental ill health could have occurred
          … mental ill health could have worsened
          … injury occurred
          … injury could have occurred
          … fatality occurred
          … fatality could have occurred

    “Incident” and “ill health” according to OHSAS 18001:

    • Incident: Work-related event(s) in which
      • an injury
      • or ill health (regardless of severity)
      • or fatality

      occurred, or could have occurred.

    • Ill health: Identifiable, adverse physical or mental condition arising from and/or made worse by a work activity and/or work-related situation.