September 2025
Do any existing sustainability initiatives, from grievance mechanisms to organic certification, result in protections for workers?
This article reviews 23 different schemes and pieces of legislation that claim to support workers’ rights in Spain, and assesses their strengths and weaknesses.
By Shanta Bhavnani, Edward Lander, and Jasmine Owens.
Supermarkets across Europe and the UK source fruit and vegetables from southern Spain, where workers’ rights abuses are endemic.
In this article we have created a list of the different mechanisms that claim to support workers’ rights in Spain, and assessed their strengths and weaknesses.
When supermarkets or agricultural producers are accused of being linked to labour exploitation in Spain they typically respond by highlighting the protections that are in place: for example, involvement in grievance mechanisms, certification schemes, or policies which are designed to safeguard workers’ rights.
However, these protections vary drastically in terms of scope and impact. While some can make a real difference for workers (such as Fairtrade International certification), others are just greenwash and don’t make any difference to workers’ lives.
Click on the scheme name, or the arrow on the right, to find out more about that initiative.
What is it and who runs it? The French government (its Ministry of Agriculture and Food Sovereignty) owns and manages Agriculture Biologique, which certifies that products are made in accordance with EU organic regulations.
Stated aims and activities: The logo is used to promote organic farming to citizens.
Strengths: This logo has no strengths in relation to ensuring workers’ rights.
Weaknesses: The Agriculture Biologique label does not include workers rights in its requirements.
What is it and who runs it: Appellando is a private company established in Germany in 2024. It’s a subsidiary of the EHI Retail Institute, a German trade and retail research group which includes Lidl and Aldi amongst its business members. The EHI Retail Institute is also a shareholder of FoodPLUS GmbH, the owner of the GLOBALG.A.P. standard (see above).
Stated aims and activities: Appellando was established to help companies meet the requirements of the new German Supply Chain Due Diligence Act and the EU Corporate Sustainability Due Diligence Directive (see respective entries). Those laws require companies to establish grievance mechanisms that workers in their supply chains can use to alert companies to abuses and seek remedy. Appellando’s stated objective is to explore and evaluate industry-wide complaints mechanisms (as opposed to individual companies setting up their own mechanisms) and to develop and implement “an effective and easily accessible single industry-wide solution”.
Strengths: The project has quickly gained the support of retailers and food producers. According to the EHI website, in 2024 Appellando began operating two hotlines in Spain which producers can sign up to. These are independently operated and give employees “the opportunity to express any complaints in a protected space without fear of reprisals. Both systems comprise more than ten production plants and groups with a total of more than 10,000 workers.” Appellando has developed training specifically for workers with writing and reading difficulties to help them understand labour law. It has begun to deliver this to migrant workers in the berry farms of Huelva.
Weaknesses: As the project is relatively new, it’s difficult to evaluate its scope, impact or effectiveness. However, the organisation’s ownership and membership may indicate potential weaknesses. The EHI Retail Institute is also the ultimate owner of the Global GAP standard (see entry for Global GAP) which has been condemned by the trade union SOC-SAT as whitewashing worker exploitation. Appellando itself lists its supporters and members on its website. These are mainly large food retailers and producers and include the company BioSabor which grows organic tomatoes in Almeria and has been criticised for abuses of workers’ rights.
In a Facebook post dated 6th September 2024, the union SAT Almeria stated that it decided to work with Appellando to see whether it could improve the situation for workers. SAT informed Appellando about its existing labour conflict with BioSabor and met with Appellando’s director. Workers from the BioSabor group provided testimonies of their experiences and SOC-SAT requested mediation with the company via Appellando. According to SAT “Months later, the APPELLANDO formula has been useless, and the workers continue to suffer injustices.”
In response to this, Appellando told Ethical Consumer that after some delay they had tried to respond to SAT but had not been able to make contact with the union.
Appellando also said that it had investigated several complaints in Spain. Appellando said that it was unable to provide any details of these complaints or the affected regions and companies due to ‘data protection regulations.’
What is it and who runs it? Bio-siegel is a logo used to show a product has been produced in accordance with the EU organic regulation. It’s owned by the German government’s Federal Ministry of Food and Agriculture.
Stated aims and activities: To guarantee compliance with “high, uniform standards by organic companies”.
Strengths: This logo has no strengths in relation to ensuring workers’ rights.
Weaknesses: Its standards only relate to organic production, ensuring adherence to EU organic regulation, which contains no clauses regarding workers’ rights or social aspects of production.
What is it and who runs it? BioSuisse Organic is a certification scheme for organic produce that is imported to Switzerland. Producers with supply chains that meet the scheme’s environmental and workers’ rights standards can use BIOSUISSE ORGANIC (BSO) label on their products. The certification scheme is run by the Association of Swiss Organic Agriculture Organisations (BioSuisse).
Stated aims and activities: Workers' rights are covered under the social responsibility standard of the certification. An annual or biannual Bio Suisse social audit is mandatory for BSO operations in Spain and Italy unless these supply chains have any of the following certifications: Fairtrade Standard for Hired Labour (other Fairtrade standards are not recognised); Fair for Life; FairWild; For Life; Naturland; SA8000.
According to BioSuisse, the social responsibility standards “are based around the internationally recognised labour standards set out by the ILO (International Labour Organisation), a specialised agency of the United Nations.”
“In addition to ensuring fundamental labour rights such as free choice of employment, equal treatment and freedom of assembly and association, this duty also makes mandatory regulated employment relationships, the payment of minimum wages, compliance with maximum working time regulations and the provision of social benefits.”
Strengths: It recognises the increased risk of supply chains in Spain and Italy. Its requirements are based on international labour standards. Bio Suisse has outlined a clear process to address non-compliance: measures include corrective actions, and the suspension or revocation of certificates.
Weaknesses: Compliance is monitored through auditing – Human Rights Watch and Partners for Dignity & Rights have warned that social audit processes are ineffective at addressing workers rights issues. No information about how frequently non compliance regarding workers’ rights is identified was found, nor examples of companies implementing corrective actions, or having their relationship with Bio Suisse terminated if corrective steps were inadequately implemented.
What is it and who runs it? Demeter is a certification for biodynamically farmed products (all products with the Demeter logo are also organic). It is owned by the Biodynamic Federation Demeter International (BFDI).
Stated aims and activities: The BFDI describes biodynamic farming as “a holistic, ecological and ethical approach to farming and gardening… . Going beyond the organic standard, through holistic management practices biodynamic farming focuses on reinforcing the interaction between soil, plants, animals, and humans in an environmentally friendly and regenerative way.”
Strengths: As a holistic approach to farming, biodynamics not only focuses on farming methods but also seeks to “create living contexts and communities in which we can all thrive.”
As well as having a standard covering the production, processing and labelling of food, Demeter has a social responsibility standard which is a compulsory part of certification. This standard states, “Demeter operations should strive for working conditions, which are above the average, as well as a positive and fair social relationship with the surrounding community.”
The standard includes strong workers’ rights protections such as the right to free association and collective bargaining, requirements on working time and vacations, and protections for temporary workers.
Farms are inspected annually for compliance with the standard in addition to the organic inspection.
Weaknesses: There was no information on the BFDI website about how failures to meet the Demeter Social Responsibility standard are dealt with. In relation to the certification process as a whole the website states, “The results of your inspection are reviewed, and you are contacted with the results of the review. If improvements are needed then we let you know.” No evidence could be found of certification having been removed in the event of failures to meet the standard.
What is it and who runs it: Ethical Trading Initiative is a multi-stakeholder initiative (MSI) – an alliance of companies predominantly, but also some trade unions and NGOs. ETI has company members in countries including the UK, Australia, Germany, Spain, Sweden and USA. Union members include the Trades Union Congress and international union federations such as the International Trade Union Confederation and International Transport Workers’ Federation. NGO members include Oxfam and CAFOD. ETI is governed by a board of directors which represents its tripartite membership (companies, NGOs and unions) in equal numbers. ETI's income is generated through membership fees, delivering training, and donor funding.
Stated aims and activities: ETI aims to address “human rights impacts in supply chains”. It states “We support businesses to identify and reduce human rights risks in supply chains, through support, guidance, and collaboration across our membership.”
Membership of the ETI is intended to demonstrate a company’s commitment to driving responsible business practices in its supply chain. It also commits companies to follow the ETI Base Code, founded on the Conventions of the International Labour Organisation (ILO), as an internationally recognised code of labour practice.
Where major violations are found, a complaint can be filed with the ETI, which will convene its business members to try and resolve the issue. Only ETI members can file a complaint but non-members can ask members to support their complaint.
Strengths: The ETI’s Base Code contains significantly higher standards than the legal requirements for workers in many countries.
ETI can convene a broad range of companies to discuss and respond to an issue in which they’re all involved. Sometimes this results in companies responding collectively to an issue in their supply chains when a single company wouldn’t do so (for example for fear of inviting increased media scrutiny of its future performance). ETI’s collective approach can also theoretically result in companies pooling resources and being able to implement more thorough solutions than would be possible if they acted independently.
ETI creates opportunities for NGOs, unions and companies to communicate and collaborate and provides a platform for discussions to begin.
Weaknesses: The ETI lacks a binding mechanism to ensure companies comply with its Base Code. The code is routinely violated, as Ethical Consumer’s Produce of Exploitation report demonstrated.
While ETI can recommend that companies implement changes, and provide space for unions and NGOs to discuss breaches of the Base Code with companies, it cannot force and does not request companies to implement changes. For example, the ETI organised an online meeting in which Ethical Consumer presented the recommendations made in the Produce of Exploitation report to all major UK supermarkets, but the ETI did not require or expect companies to adopt the recommendations, which to date remain unimplemented. In response to this criticism ETI told Ethical Consumer it “cannot compel members to implement third-party recommendations... In this case, ETI provided access and visibility to concerns raised by civil society, but decisions on implementation ultimately rest with companies.”
The one sanction available to ETI to use when a brand violates its code appears to be expulsion. ETI says that in the last 10 years around 15 members have been expelled or had membership terminated due to breaching member commitments. Ethical Consumer could only find information about one of these cases of expulsion on the ETI website (which related to the banana brand Fyffes).
ETI therefore has limited leverage with companies. It also relies heavily on funding from its corporate members, therefore expulsion, or a corporate member choosing to leave the scheme, results in a loss of income for ETI.
Multi-stakeholder initiatives (MSIs) more broadly have also faced criticism for lack of effectiveness in terms of improving conditions for workers. According to the organisation MSI-Integrity, “While MSIs can play important roles in building trust and generating dialogue, they are not fit-for-purpose to reliably detect abuses, hold corporations to account for harm, or provide access to remedy.”
In Ethical Consumer’s experience, meeting with the supermarkets alongside NGO partners, and sharing a video from workers in Spain, made it possible to guarantee that all supermarkets were aware of the abuses in their supply chains and the recommendations. But supermarkets chose not to implement the recommendations, and ETI did not encourage them to, so Ethical Consumer did not consider further dialogue through ETI mechanisms to be of use.
In response to this criticism ETI stated: “As with other MSIs, ETI’s influence is shaped by its mandate: to facilitate responsible business practice by enabling tripartite dialogue, setting shared expectations, and supporting members to address human rights risks through collaboration and continuous improvement - not enforcement.”
What is it and who runs it: ETI Grievance mechanisms in agriculture project was a research and pilot project led by the Ethical Trading Initiative (see above). The work was funded by the UK Government Modern Slavery Innovation Fund. The project had a work group of 20 members from ETI, other ethical trade groups, and UK retailers and suppliers who provided “oversight to the initiative” and facilitated “access to growers and suppliers in the countries of production”. It concluded in early 2025.
Stated aims and activities: This two-year research and pilot project aimed to improve the evidence base for effective grievance mechanisms for migrant workers; increase access, awareness, and understanding of grievance processes among migrant workers at pilot sites; and promote innovation in preventing modern slavery and improving working conditions through cross-national, multi-stakeholder collaboration.
Strengths: The project completed its research phase in 2024, during which it interviewed workers in Spanish and Italian supply chains. It published a report which concluded that workers, particularly migrant workers, are highly vulnerable to modern slavery and that existing grievance mechanisms do not meet their needs. It made recommendations to businesses and producers to improve grievance mechanisms and to construct them around the needs of workers: “Workers must be at the centre of the design and implementation of mechanisms, as they are the ones who best understand their conditions and have the strongest interest in ensuring that their rights are respected”.
In summer 2024, the project began a grievance mechanism pilot in several sites in Spain and Italy (including one in Almeria which is a key vegetable sourcing region for UK and European supermarkets). The project engaged Oxfam Business Advisory Service and the Spanish Ethical Trade Forum to develop pilot grievance mechanisms which involved workers in its assessment and design. ETI stated that the pilots “were co-designed and executed at the site level in collaboration with workers and management through dedicated taskforces” and that “efforts were made to ensure these mechanisms were accessible to all workers, with a focus on language and literacy needs”.
In May 2025, ETI stated: “Final learnings and tools developed through the pilot - such as approaches to taskforce training and methods for inclusive design - are now being shared with the UK Government, ETI members, and other relevant stakeholders. A final summary report and case studies developed from this work will be shared publicly in the coming months.”
Weaknesses: It is unclear what outcomes will emerge from this project, and if workers will experience any benefits.
The project does not discuss any binding mechanism to guarantee worker safety in reporting, or penalties that must be implemented if a farm is found to violate labour standards.
It is worth noting that the project partnered with the Spanish Ethical Trade Forums (see below) which has been operating in the Spanish fruit and vegetable sector for nearly ten years, and faces criticism for failing to improve conditions for workers.
What is it and who runs it: The Corporate Sustainability Due Diligence Directive is a new law approved by the EU in 2024 but not yet implemented. EU member states are therefore responsible for its transposition into domestic law and application.
Stated aims and activities: The CSDDD aims to foster sustainable corporate behaviour and provide increased protection of human rights, labour rights and the environment. For companies, the law provides a uniform legal framework across the EU single market rather than having to comply with different laws and standards in different countries.
Strengths: The Directive requires companies to identify and address potential and actual adverse human rights and environmental impacts in their own operations, their subsidiaries’ operations, and those of their business partners where related to most of their value chain. It also requires companies to provide remedies to those who have been harmed. This includes restoring people and the environment to their original situation before the harm occurred, or paying financial compensation. During the process, companies must meaningfully engage with stakeholders such as workers and communities affected by their operations.
Weaknesses: In February 2025, following corporate lobbying, the European Commission published a proposal that, if adopted, would significantly weaken the requirements of the Directive. In the Commission’s proposal, for example, companies would only be required to investigate and address human rights abuses taking place at tier 1 suppliers (direct suppliers) and not throughout the whole supply chain. Human rights abuses are much more likely to take place further up the supply chain, for example on farms, and these new proposals mean that companies such as supermarkets would not be obliged to investigate or remedy those abuses.
Currently, the Directive only applies to very large companies: EU companies (or the parent company of a group) with more than 1000 employees and a net worldwide turnover of more than EUR 450 million per year, and non-EU companies (or the parent company of a group) that generate a net turnover of more than EUR 450 million in the EU per year. One NGO estimated that this means that it will apply to only 5,421 companies.
Under the Directive, companies must establish a fair, publicly available, accessible, predictable and transparent procedure for dealing with complaints. However, there is no obligation to involve workers in the design of such procedures and there is therefore a risk that they will not address the power imbalance between employers and workers. Companies are likely to use their existing grievance mechanisms, which in general do not involve workers in their design and are largely ineffective (See entry on the ETI Grievance Mechanism project above).
What is it and who runs it: The Forced Labour Regulation is a law approved by the EU in 2024 that will be implemented in late 2027. The European Commission and EU member states will be responsible for its enforcement.
Stated aims and activities: To prevent products made with forced labour being sold in or exported from the EU.
Strengths: Where forced labour is suspected in supply chains of products meant to circulate on the EU market, the law gives investigatory and enforcement powers to the European Commission and member states. If forced labour is found they can order the withdrawal of goods from the EU market and their confiscation at borders. If companies don’t comply with these orders they will face penalties.
Strawberries from Huelva in Spain have previously been associated with forced labour and could therefore be excluded from all EU markets. This may mean that supermarkets in EU countries stop buying them and find an alternative source. As the law covers exports from the EU, UK supermarkets are also covered by the law and may also choose an alternative source for their strawberries. However, campaigners hope that rather than seeking alternative sources, companies will instead address the issue of forced labour in their existing supply chains and improve working conditions so that they can continue buying from Huelva.
The law applies to all sectors, all products and all companies (regardless of their size).
Weaknesses: As the UK is no longer an EU member, the law doesn’t apply here. While it will cover products made in the EU and exported to the UK, there’s no law in place to stop products from the rest of the world made using forced labour from coming here.
The law won’t come into force until late 2027.
Read more about the law in our separate article on the legislation.
What is it and who runs it? The European organic leaf logo is used on products to show they are organic, and is run by the European Commission.
Stated aims and activities: “The European Union organic logo gives a coherent visual identity to organic products produced in the EU. This makes it easier for consumers to identify organic products and helps farmers to market them across the entire EU.”
Strengths: This logo has no strengths in relation to ensuring workers’ rights.
Weaknesses: Its standards only relate to organic production, and contain no clauses regarding workers’ rights or social aspects of production.
What is it and who runs it: Fair trade is the collective term for product certifications that aim to improve the lives of food producers and protect the environment. Fair trade isn’t a protected term with a specific definition. This means that companies can use it without meeting any particular standard. However, there are a number of fair trade certifying bodies that do require certain standards to be met:
Fairtrade International (FTI), a non-profit, multi-stakeholder association of 22 member organisations – three producer networks and 19 national Fairtrade organisations. Fairtrade Ibérica is the local branch of the organisation for Spain.
Other ‘fair trade’ certifications for food include Fair Trade Certified and Fair Trade Federation for example.
Stated aims and activities: Fairtrade International says it “works to share the benefits of trade more equally – through standards, certification, producer support, programmes and advocacy.”
Strengths: Fairtrade International guarantees a minimum price for producers – significantly reducing the likelihood that a farm is unable to pay workers a fair rate. It also lists the following benefits for farmers and workers: “Better prices and the Fairtrade Premium to invest in their businesses and communities; An equal say in how Fairtrade is run; Decent working conditions and a ban on discrimination, forced labour and child labour.”
The Fairtrade Premium is an extra sum of money that is paid to farmers on top of the income they receive for their produce or labour. The Fairtrade Foundation said that this premium is aimed at enabling farmers to “invest in improving the quality of their lives.”
Weaknesses: There are currently no fair trade certification schemes covering fruit and vegetables from southern Spain.
What is it and who runs it: These are websites owned by farms and agricultural companies in Spain.
Stated aims and activities: It’s common for agricultural companies in Spain to make claims on their websites about their sustainable or ethical practices. These might be brief statements, or full sustainability web pages or reports. These may suggest that the company is committed to providing fair conditions for workers.
Strengths: These statements may provide some information about what steps the company is taking to guarantee good working conditions.
Weaknesses: Claims that stem entirely from the company’s perspective are not independent and can be very biased. On several occasions Ethical Consumer has spoken with workers who say that conditions at farms are far worse than the farm owners claim, and that the websites present a false image.
The claims made by farms often lack detail and don’t provide information about specific measures the company is taking. This makes it harder for workers or campaigners to hold the companies to account for their claims.
The steps they do list might not be meaningful, or may not be being implemented. For example, the organic company Biosabor has a webpage promoting its positive treatment of workers. However, Biosabor workers told Ethical Consumer in 2022 that serious workers’ rights abuses were occurring at the farm, including falsified timesheets, denying workers paid breaks and underpayment. Biosabor says these allegations were false.
What is it and who runs it: GLOBALG.A.P. is a voluntary certification scheme under which producers are assessed for compliance against a series of food safety, environmental impact and worker wellbeing standards. Audits are conducted on an annual basis by an independent and accredited auditor.
The standards are developed through a public consultation and “collaboration with representative stakeholder groups, including technical committees, focus groups, and others,” the GLOBALG.A.P. website said.
The scheme addresses workers’ rights through the GLOBALG.A.P. Risk Assessment on Social Practice (GRASP), a voluntary add-on for producers.
According to a response from GLOBALG.A.P. to Ethical Consumer’s Produce of Exploitation report, the add-on is not a certificate but an evaluation. It covers: “self-declaration on good social practices regarding human rights, working, contracts and hours, wages, no employment of minors.”
These annual assessments are conducted through document reviews, farm visits and worker interviews.
GLOBALG.A.P. is the operating brand of the company FoodPLUS GmbH, which was established in 2001 by a group of European retailers. FoodPLUS GmbH is now owned by the EHI Retail Institute, a German research, training and consultancy institute for the retail industry. The international EHI network includes Lidl and Aldi amongst its business members. The EHI Retail Institute also owns Appellando (see below).
Stated aims and activities: GLOBALG.A.P is a certification scheme, with a number of standards, including some covering plant production processes (fruit and vegetables and crops). Producers can choose to extend the scope of this certification with add-ons including around worker wellbeing.
The company said of its workers’ rights audits “The purpose of a GRASP evaluation [see above] is to record valid information on indicators of workers’ rights on farms so that operators can use this information to identify risks.”
“Implementation of GRASP requirements is checked through document reviews, farm visits and especially worker interviews.”
“The compliance with the ILO core labour conventions together with the policy on human rights complete the framework required from each GRASP assessed producer.”
Strengths: One of its aims is to help companies to “strengthen workers’ rights and develop a positive working environment in accordance with the International Labour Organization’s convention”.
The standards are developed in collaboration with a range of stakeholders including producers, and assessments are conducted by independent auditors.
Information from the audits can theoretically then be used by companies to address workers’ rights risks.
The most widespread certification solution is the GLOBALG.A.P. Integrated Farm Assurance (IFA) standard for fruit and vegetables. The IFA standard, which includes workers’ health, safety, and welfare topics, is adopted by nearly 200,000 producers worldwide. In Spain, almost 50,000 producers hold a GLOBALG.A.P. IFA certification.
Weaknesses: Compliance is monitored through auditing – Human Rights Watch and Partners for Dignity & Rights have warned that social audit processes are ineffective at addressing workers' rights issues. Self-evaluations and standard social audits have long been criticised as ineffective methods for addressing workers’ rights abuses (see SMETA entry for more on weaknesses of audits).
A key weakness of this scheme is its lack of binding enforcement mechanisms. Farms found to be breaching standards face a warning, followed by suspension of certification if they fail to address identified issues within 28 days. Suppliers that have not resolved identified issues after the suspension period will have their certification cancelled for at least 12 months.
The scheme is not fully independent of farms and supermarkets – it is run by a commercial enterprise that was established by a group of European retailers. According to the Spanish union SAT Almeria, abuses of workers’ rights have taken place on farms with GLOBALG.A.P. certification. In 2019, it told Ethical Consumer that farms provide auditors with “false information showing the payment of national insurance for workers and, in this way, avoid paying the minimum wage”.
GLOBALG.A.P. says, "compliance with the standards is independently reviewed by an integrity program…The GLOBALG.A.P. Secretariat strongly condemns any abuse of workers' rights and any social abuse. At the same time, we must emphasize the observation described is a criminal act that is outside the scope of all certification systems. Criminal acts fall under the jurisdiction of the law enforcement authorities.”
What it is and who runs it: Human Rights Impact Assessments (HRIAs) are carried out voluntarily by corporations in order to assess human rights standards across their supply chains. According to a report by Oxfam, Aldi, Lidl, Morrisons, Sainsbury’s and Tesco have all published HRIA reports. For example, Lidl conducted an HRIA of one of its berry supply chains from Huelva in 2020 which resulted in an action plan, and M&S did a rapid risk assessment for produce from Almeria.
Stated aims and activities: Oxfam describes the human rights impact assessment as an “in-depth analysis diving into a high-risk chain to understand the human rights impacts, from the perspective of rightsholders, and to formulate actions to stop abuses.”
Strengths: According to the Danish Institute for Human Rights, HRIAs can improve corporate accountability by identifying adverse human rights impacts from the workers’ perspective and determining measures to address these issues through prevention, mitigation and remediation.
Weaknesses: There are no agreed standards or methods for conducting HRIAs. This means that they can vary in quality. The report by Oxfam identified the following weaknesses in the way supermarkets conduct HRIAs. These included:
The report also criticised supermarkets for failing to take action to tackle the human rights abuses that they find and in particular not discussing price and power, despite these being root causes of human rights issues in food production.
What is it and who runs it? Naturland is an organic association founded in Germany.
Stated aims and activities: It aims to promote organic farming, environmental protection, fair trading, animal welfare and more. Its activities include issuing certifications and labelling, and a range of other activities such as training farmers, publishing research, and developing the organic food market.
Strengths: Naturland certification includes social standards as well as organic. Its standards say companies must abide by UN Conventions and ILO recommendations. It says, “A product created under conditions violating basic human rights, under gross violation of social justice or infringing indigenous land and water rights can not be traded as a product certified by Naturland.” It prohibits for example forced labour, retaining salaries or documents in order to force workers to stay, union busting, discrimination, health and safety abuses, and paying below minimum wage, etc. It has a whistleblowing mechanism for ‘violations of human rights’ and many other issues such as fraud, discrimination, corruption etc.
It audits farms once per year, plus unannounced spot checks for higher risk ones. It conducts interviews, documentation audits and farm tours, looking at social compliance. This makes it the most stringent organic certification in relation to workers’ rights, because it does contain detailed requirements within its standards while many organic certifications do not discuss social issues.
Weaknesses: It is primarily an organic certification scheme, with workers’ rights only one small component. Naturland appears to rely on auditing to monitor compliance with its standards — an approach which has been widely criticised as ineffective. There is no information on the Naturland website detailing how it addresses issues of non-compliance with its social standards audits, and no evidence has been found demonstrating that Naturland has ever taken action in relation to social issues found within supplier farms.
What is it and who runs it: There are a range of regulators which can certify businesses and products as organic (the Soil Association is one example). It is a legal requirement in some countries, including the UK, for food labelled as organic to be certified.
Stated aims and activities: Organic certification means that the food must, among other requirements, not be produced using chemical pesticides and weedkillers, artificial fertilisers, or GMOs.
Strengths: Organic certification is positive for the environment and animals. Occasionally, some organic standards mention workers’ rights (see for example entry for Demeter).
Weaknesses: Organic requirements are not designed to address working conditions. If they address workers’ rights at all, it is typically briefly, and for those which are more detailed, enforcement mechanisms are not clear and no evidence of implementation of sanctions for violations has been found.
According to local union SAT Almeria, organic farms are among the worst offenders on workers’ rights in southern Spain’s agricultural sector. French newspaper Le Monde reported in 2019, “Everyone draws the same conclusion: working conditions in organic farming are “no better” than in so-called conventional farms”.
What is it and who runs it: PRELSI is run by InterFresa, the Andalucian association of berry producers (which helps berry producers in the region cooperate and have a collective voice, among other aims). It’s composed of “1,300 businesses and over 150,000 workers” however no information was found to explain what involvement workers had in management of Interfresa or PRELSI or its activities. It appears to be corporate-led.
Stated aims and activities: PRELSI is a voluntary ethics plan for employers, created and launched in 2018 “to respond to the need for understanding, assistance and promotion of good practices to promote the socio-labour welfare of all the agents involved” in soft fruit production. One of its activities is a system for monitoring standards in migrant workers’ accommodation, including through auditing.
Strengths: PRELSI has been broadly adopted by the soft fruit sector, showing large-scale participation. PRELSI consultants visit the facilities of member companies, including inspecting housing.
Weaknesses: PRELSI’s consultants are usually satisfied with their inspections, and PRELSI told Ethical Consumer in 2023 that since PRELSI’s implementation it was “not aware of any inappropriate practices by member companies”.
Poor working and living conditions have been widely reported across the region, suggesting that PRELSI’s audits may be failing to adequately assess conditions. Its website currently states that accommodation for workers on “contracts in origin” is inspected prior to their arrival, and if incidents are logged they are “normally” resolved before the workers’ arrival, and a new inspection is carried out.
PRELSI audit findings are used by companies as evidence that they are operating satisfactorily. Compliance is monitored through auditing – Human Rights Watch and Partners for Dignity & Rights have warned that social audit processes are ineffective at addressing workers rights issues.
Overall, this is an industry-led scheme and has no robust independent enforcement mechanism. OpenDemocracy reported in 2021 that the scheme is “managed by the same companies that violate labour laws.”
Retailer supply chain policies / codes of conduct / general statements on website
What is it and who runs it: Retailers write policies and codes of conduct to govern the behaviour of their suppliers. These contain obligations relating to workers’ rights. Retailers may also make statements on their websites about the rights of workers in their supply chains. These policies and codes therefore are designed by, and implementation is monitored by, the retailers.
Stated aims and activities: In the last decade supermarkets have made increasingly strong claims and promises about ensuring their supply chains are managed responsibly. Supermarkets generally use these statements to demonstrate respect for human rights and workers' rights, and have a system for monitoring these standards in their supply chains.
Strengths: These policies and statements provide a means for NGOs and ethical ratings organisations like Ethical Consumer to assess a company’s overall policies on workers’ rights, and compare these policies with other corporations in the sector.
Supermarkets can be held to account for these policies and commitments when a supply chain breach is identified. Workers and their representatives in corporate supply chains can use these policies to ensure that employers uphold company standards. And they might be able to use the statements to make sure any breaches are addressed.
The fact that supermarkets have these standards can mean that where there is a high risk of breach – as in Spain – they develop initiatives to improve the situation. For example, the Co-op recognises modern slavery and vulnerable workers in Spain as one of its top eight identified high risk areas. Measures to address the situation include: working with Stronger Together and other retailers (which include M&S and Waitrose) on a toolkit for suppliers in Spain to reduce the risk of modern slavery; and supporting the ETI human rights due diligence pilot project on agricultural supply chains in Spain. Aldi also recognises Spanish produce as a high-risk, priority area, which may lead to enhanced supply chain monitoring.
Weaknesses: Supermarkets’ claims of high standards within their supply chains are often not reflected in the lived reality of workers in southern Spain. Supply chain codes of conduct for most supermarkets focus on direct suppliers but supermarkets are most likely to buy produce indirectly from southern Spain from an intermediary company. Some retailers that state that their policy covers the entire supply chain, say that enforcement of the requirements is the responsibility of the intermediary suppliers. When researching the Produce of Exploitation report in 2023, Ethical Consumer looked in detail at supermarket policies. Tesco was the only company clearly found to be committing to audit companies beyond direct suppliers.
What is it and who runs it: SEDEX is a private British company that provides services to other companies to help them demonstrate and improve sustainability. One service it offers is to map companies’ supply chains and identify where the risks lie. SEDEX provides an information-sharing platform, auditing (see SMETA below), consultancy and training.
Stated aims and activities: SEDES aims “to supply data-driven insights, tools, and services to help companies continuously improve environmental, social, and governance (ESG) outcomes.”
Strengths: SEDEX is a membership organisation for businesses. Membership gives access to the SEDEX platform where businesses can share information about their suppliers. This could be audit results from any type of audit including SEDEX’s own audit tool, SMETA (see below). This sharing of information avoids duplication of audits for suppliers which could be costly and time-consuming. In theory it allows companies to co-operate to improve their suppliers’ sustainability practices.
Weaknesses: SEDEX membership is not a form of certification, nor does it require companies to meet any specific standards, but companies sometimes refer to it as if it does which could be considered misleading. There do not appear to be any requirements for membership, and SEDEX membership cannot be withdrawn. SEDEX membership in itself, therefore, has no relevance to discussion of working conditions.
What is it and who runs it: SMETA is an audit methodology that is owned and run by SEDEX (see above). It is a way of assessing businesses to see whether they comply with a range of workplace standards. SMETA is used by companies to check the performance of their suppliers in areas including labour and health and safety.
Stated aims and activities: SEDEX says: “The SMETA audit is designed to help protect workers from unsafe conditions, overwork, discrimination, low pay, and forced labour.” It is used by many large suppliers and in many sectors including food and agriculture. SEDEX does not conduct the audits itself but contracts external auditing bodies to do so. Audits involve self-assessment by the suppliers followed by a site visit by an auditor. This results in an audit report which may include corrective actions for the supplier.
Strengths: The audit provides some oversight of the activities of suppliers. The audit standard is based on International Labour Organisation conventions. The results of the audit can be shared via the SEDEX platform with other companies who buy from the same suppliers. This means suppliers do not have to undergo multiple audits.
Weaknesses: SMETA is a type of “social audit”. Social audits were originally developed by companies in response to public pressure to demonstrate that their suppliers were not involved in human rights abuses or environmental harm. They are now widely used and there are many different ones available. However, they have faced significant criticisms from workers’ rights organisations and NGOs for ineffectiveness, and failure to address exploitative and harmful practices. For example, Malaysian company Top Glove, has been accused of multiple human rights abuses and yet has undergone many social audits, including SMETA.
A particular weakness of social audits is their inability to effectively evaluate working conditions and to hear from workers in a way that allows them to talk freely and without fear of retribution. They have also been criticised for lack of transparency (see reports by Human Rights Watch and Partners for Dignity & Rights for more). SMETA audits are a case in point as they are only available to SEDEX members and not the wider public.
SMETA certification has been found on the website of a farm company in Spain that workers have accused of violating their rights and it is likely that other suppliers in Spain are relying on SMETA audits.
What is it and who runs it: SETF is a grower-led multi-stakeholder initiative. Its corporate members, which make up the majority of its membership, include many of the largest fruit and vegetable producers in the region, and international supermarkets including Aldi, Asda, Co-op, Lidl, M&S, Morrisons, Sainsbury’s, Tesco and Waitrose. It has a small advisory committee consisting of, for example, NGOs like Oxfam and WWF, and large Spanish unions like UGT and CCOO. Its work is sponsored by retailers, and coordinated by SETF employees in Spain.
Stated aims and activities: It aims to “improve understanding of human rights abuses and to raise standards”. It holds meetings in Almeria every year which are attended by the Forum’s members, including retailers and importers, and they exchange information on agricultural supply chains, including clarifying challenges, requirements and progress made throughout the year. It also coordinates seminars and working groups, to share challenges facing the sector and best practice responses. Topics covered by working groups include health and safety and grievance mechanisms.
Strengths: Involvement with SETF may mean that companies are more likely to acknowledge workers’ rights abuses do exist, and that they are willing to discuss them. When responding to the findings of Ethical Consumer’s Produce of Exploitation report in 2023, SETF stated, “working conditions at companies participating at the Forums are not better or worse than others. Our participants are just companies that have the commitment to improve and this does not mean that everything is done correctly at their sites, but at least that they commit to work for it.”
Weaknesses: SETF is a voluntary initiative. Its members are Spanish agricultural companies and, although it does have an advisory committee made up of NGOS and unions, it is unclear what role these play on an ongoing basis within the forum’s work and how extensive this is. Whilst it may provide a forum for discussing options to create change and share training and best practice, members do not have any obligation to act on best practice guidance shared.
SETF is frequently referred to by retailers and Spanish growers as a valuable initiative in the region, but it holds the same structural weaknesses as other multi-stakeholder initiatives (see ETI’s entry above) for example being funded by corporations. It is also unclear how significant worker or NGO input is into the forum’s operations and how meaningful and impactful this is.
What is it and who runs it: Spain has various laws covering workers’ rights and migration that potentially apply to southern Spain’s migrant workers. They are made and enforced by the Spanish government.
Stated aims and activities: One such law is the Estatuto de los Trabajadores (Workers’ Law) which regulates employment and includes provisions on employment rights and working conditions. As well as this, agricultural workers in Almería and Huelva are covered by specific collective agreements which contain provisions on a range of matters such as pay, overtime, trade union membership and maternity. Many migrant workers are recruited under an arrangement between the Spanish and Moroccan government that allows for the recruitment of workers directly from Morocco. Such contracts are called “contracts in origin”.
Strengths: On paper Spanish laws protecting workers’ rights are robust and accord with international laws. They apply to migrant workers as they do to Spanish nationals. There is a Labour Inspectorate which has powers to enforce labour legislation and collective agreements. On many occasions, unions have successfully used these laws to challenge companies and gained compensation and reinstatement for workers who were unfairly treated.
Weaknesses: In reality, migrant workers receive very little legal protection from Spanish laws. Firstly, many workers speak limited or no Spanish and are not aware of what their legal rights are or how to enforce them. It is therefore very difficult for them to make any kind of legal claim. Furthermore, the Labour Inspectorate does not reliably enforce the law when shown evidence of breaches by companies.
According to the SOC-SAT union of Almería, it files many hundreds of legal complaints every year on behalf of its workers, often successfully. That one small union brings so many cases indicates systemic failure because it demonstrates that the laws are being regularly violated, and that current legal mechanisms aren’t working to ensure the law is routinely respected.
There are also issues with the nature of existing legal arrangements which make it difficult for some workers to receive permanent contracts. For example, some collective agreements define permanent workers as those who have worked at the same business for a year, without a break of longer than 15 consecutive days. However, in Huelva the majority of workers are employed under contracts in origin, which can only be offered to agricultural workers for a maximum duration of 9 months in a period of 12 consecutive months. More generally, the seasonal nature of the work in the agricultural sector, means that workers are unlikely to work for 9 months of the year at a single company. This means that workers are de facto excluded from access to permanent contracts and therefore the security associated with having such a contract.
These examples demonstrate that Spanish law and local government legislation can be difficult to enforce and can at times work to the detriment of workers.
What is it and who runs it: Worker-driven social responsibility (WSR) is a model in which workers develop and run schemes tailored to their own conditions to protect and enforce their own rights.
It was first developed in the 2000s by farm workers in Florida and schemes have now been developed in the garment sector and other agricultural sectors.
Stated aims and activities: WSR is a way of protecting the rights of workers’ in supply chains. Unlike corporate social responsibility mechanisms that are designed by companies, it is developed and monitored by workers themselves. It uses legally-binding agreements between workers and companies at the top of supply chains that require those companies to ensure their suppliers respect workers’ rights. Most importantly, the agreements require that companies stop doing business with suppliers that do not respect workers’ rights. The Workers’ Rights Consortium explains, “Under WSR programs, it is workers who determine the labor standards under which they work and who design the systems necessary to enforce those standards, including genuinely independent investigations and mechanisms to resolve complaints.”
Retailers in turn make a legally-binding commitment to source from companies respecting the code, and pay for the costs of the monitoring and enforcement mechanisms.
Strengths: The Worker-Driven Social Responsibility Network says that the mechanism transforms traditional approaches to corporate responsibility by:
i) centering the experiences and knowledge of those on the ground;
ii) ensuring enforcement is truly independent of both retailers and producers;
iii) and defining legally binding processes to ensure that retailers take an active role in remedying violations in their supply chains.
As a result, WSR models have already seen enormous success around the world. They’ve been shown to address issues such as sexual harassment and assault, employer intimidation and retaliation, and health and safety failings. They’ve also raised wages and improved housing.
Weaknesses: WSR programmes can take a long time to develop. A WSR programme is in the initial stages of development in southern Spain but is likely to take a number of years to fully implement. If it goes ahead, farm workers will need to create and agree on a code of conduct that meets their needs. After that they will need to convince supermarkets and farms to commit to a legally-binding agreement to uphold the code of conduct.
This index is designed to provide an overview of existing mechanisms that aim to improve working conditions in southern Spain’s agricultural sector.
For more information on workers’ rights abuses in this sector, read the full report (Produce of Exploitation).