We, the undersigned organizations [ICAR, ALSTEAN-Burma, Center for Intl. Environmental Law, Coalition of Immokalee Workers, Intl. Labor Rights Forum, Investors Against Genocide, PODER, and Shift], write to strongly oppose a proposal by the Swedish Standards Institute to set up a Technical Committee (“TC”) on Social Responsibility by the International Organization for Standardization (“ISO"). The proposed TC on Social Responsibility and creating potential standards for human rights and labor practices based on a compliance and audit based management systems approach. We do not believe that such areas can or should be standardized in such a reductive approach...

Business and State responsibilities with respect to human rights are already determined by international human rights law, frameworks, and treaties. ISO standards are not appropriate to address business respect for human rights... [B]y engaging in efforts to interpret universally agreed standards and norms, the ISO risks generating a compliance approach to human rights, creating unnecessary work for businesses in order to demonstrate compliance with the proposed standard, and distracting from the role of governments in ensuring adherence with these universal norms...

[Lastly, there is evidence that a] compliance and audit based management system fails to improve the lives of workers and communities...