A Comparison of Stakeholder Engagement Practices in Voluntary Sustainability Standards

Voluntary sustainability standards (VSS) play an important role in moderating the environmental impacts of production, protecting human rights, and ensuring the well-being of workers. Most standards are created, enforced, and maintained by non-governmental organizations that derive their legitimacy and authority from engaging with their stakeholders. New or revised standards are routinely submitted to public comment periods where any stakeholder can offer edits or changes. Stakeholder engagement is considered essential to crafting standards that are widely used and socially or environmentally impactful, but practices of stakeholder engagement vary widely across voluntary sustainability standard setters.

In a recent paper in Regulation & Governance, I compare the stakeholder engagement practices of six voluntary sustainability standard setters through an original dataset of 7945 stakeholder comments submitted during public comment periods. I use this data to answer two research questions: first, are some standard setters better at balancing stakeholder representation than others? And second, does stakeholder influence vary across standard setters?

This paper intervenes in an ongoing debate about the difference between industry-sponsored and multistakeholder VSS. Most VSS fall into one of these two categories. Multistakeholder VSS are those that are founded and funded through a collaboration of multiple parties, principally industry and NGOs. By contrast, industry-sponsored VSS are those that were founded and initially funded primarily by businesses or industry associations. Whereas some scholars contend that industry-sponsored VSS are less likely to have diverse participation and may be biased towards accepting a disproportionate amount of industry input, others argue that sponsorship is largely irrelevant. The latter camp argue that the industry's technical expertise and structural advantages in participation vis-à-vis other stakeholders create a bias towards industry interests regardless of VSS sponsorship.

My findings suggest a middle ground in this debate. On one hand, industry-sponsored VSS do appear to get more industry input than multistakeholder VSS. Across the six VSS in my study, the industry-sponsored schemes averaged between 16-31% more industry comments than their multistakeholder counterparts. This finding lends credence to past research suggesting that industry may be more willing to participate in industry-sponsored VSS while NGOs and other non-industry stakeholders may prefer to stay away.

However, multistakeholder VSS also face challenges in balancing stakeholder representation. Across all types of VSS, there was a tendency to over-represent groups that were involved in the early design and development of a standard system. What might be termed ‘legacy stakeholders’ submitted a disproportionate number of comments, suggesting that the pool of people shaping the content of VSS is actually quite narrow.

On the second research question, I find no evidence to support the idea that industry comments will be more influential in industry-sponsored VSS. The provenance of a comment appears to have little relationship to whether it changes the final standard. Rather, the content of the comment appears far more important. All else being equal, stakeholder comments intended to weaken the stringency of a standard or clarify its intent were significantly more likely to be accepted than other types of comments in both industry-sponsored and multistakeholder VSS. Often these comments focused on removing or modifying criteria that were viewed as too costly or time-consuming. Thus, a key implication is that stakeholder engagement may actually be lowering the bar for stringency in VSS, not raising it. 

Taken together, these findings present a troubling picture of stakeholder engagement in VSS. The existing way in which stakeholder input is solicited tends to lead to standards that are weaker and dominated by a handful of interest groups.

There are a number of ways in which inequalities in stakeholder representation could be reduced in VSS. A simple first step would be to increase the requirements of meta-governance (eg, the ISEAL Codes). Currently, VSS are not required to balance participation between stakeholder groups in order to gain or maintain ISEAL membership. However, the ISEAL Codes could easily be modified to make this a requirement. Secondly, greater transparency over who provides input into standards would provide a medium for accountability. Knowing who comments on VSS and which group they represent would enable watchdogs and academics to call out standards with poor representation practices. Finally, the medium for stakeholder engagement needs to be more varied. In addition to technocratic, top-down, document reviews, standard setters should also host more open-ended discussions centered around their sustainability goals. Doing so would afford more opportunities to hear from actors who lack the background knowledge or resources to engage in the existing stakeholder engagement exercises.

Hamish van der Ven is Assistant Professor of Sustainable Business Management of Natural Resources at the Faculty of Forestry of the University of British Columbia.