World Development 139 (2021) 105314

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World Development
journal homepage: www.elsevier.com/locate/worlddev

Regular Research Article

Private sustainability governance, the Global South and COVID-19: Are

changes to audit policies in light of the pandemic exacerbating existing
inequalities?
Graeme Auld a,⇑, Stefan Renckens b
a
School of Public Policy and Administration, Carleton University, Canada
b
Department of Political Science, University of Toronto, Canada

a r t i c l e i n f o a b s t r a c t

Article history: The COVID-19 pandemic has disrupted global economic relations. Transnational private regulatory pro-
Available online 17 December 2020 grams, such as sustainability certification and eco-labeling schemes that set standards for responsible
production practices in global markets, have had to react. Private regulation’s market credibility is par-
Keywords: tially built on audits, which include field visits used to assess whether participating operators conform
Private regulation with a program’s standard. But COVID-19-related health and business restrictions have forced adjust-
COVID-19 ments to field-audit policies. Literature on private governance has identified several barriers to participa-
Crisis
tion of Global South operators, including the costs of certification, the availability of qualified auditors,
Inequalities
Sustainability
and uncertain socio-economic benefits. Are audit policy changes made because of the COVID-19 pan-
Certification demic exacerbating these barriers? We examine this question through a dataset constructed between
April and November 2020 that contains information on COVID-19-related audit policy responses of 98
transnational private sustainability regulators. We describe the mixed transparency of these adjustments
to date and five ways in which the adjustments create explicit and implicit barriers to operators from
Global South countries. The changes create barriers through (1) the conditions set on when and how
adjustments to audits are permitted, (2) the limited flexibility of substantive standards, (3) the potential
costs of shifting to remote audits, (4) the focus on accommodating existing participants over new appli-
cants, and (5) the potential challenges of accessing auditors to conduct assessments. We conclude with
implications for research on private regulation post-COVID-19.
Ó 2020 Elsevier Ltd. All rights reserved.

1. Introduction observe. Well-known examples are programs like Fairtrade Inter-

The transnationalization of supply chains and economic net-
works has generated considerable concerns about the sustainabil-
ity implications of these global connections. Non-state actors, such
as non-governmental organizations, firms and industry associa-
tions, have taken up an important role in providing regulatory gov-
ernance instruments to verify the sustainability of global economic
activities, most notably in the form of sustainability certification
and labeling schemes (e.g., Rueda & Lambin, 2013; Tolentino-
Zondervan et al., 2016). This type of private regulatory governance
aims to uncover features of products, services and organizations—
such as the sustainability of production processes, or a firm’s car-
bon footprint—that consumers and service users cannot readily
national, which has certified over 12 percent of the global coffee
production area; Rainforest Alliance, which certifies over 16 per-
cent of global tea production and 33 percent of global cocoa pro-
duction; and the Marine Stewardship Council (MSC), which has
certified 15 percent of global marine catch (International Trade
Center, 2017; MSC, 2019).1
The COVID-19 pandemic, however, is posing challenges to the
globalized economy. Early on, food and consumer product supply
chains were disrupted. Disruptions remain for business activities
and the personal freedom of mobility that many individuals, in
particular in the Global North, had been accustomed to, while
the underlying free market or neoliberal ideology is being chal-
lenged too (e.g., Clapp, 2020; Oi & Hoskins, 2020; Financial

⇑ Corresponding author. 1
The figures for Rainforest Alliance are combined figures of the certification
E-mail addresses: Graeme_auld@carleton.ca (G. Auld), stefan.renckens@utoron- programs of Rainforest Alliance and UTZ Certified, which announced the merger of
to.ca (S. Renckens). their programs in 2018.

https://doi.org/10.1016/j.worlddev.2020.105314
0305-750X/Ó 2020 Elsevier Ltd. All rights reserved.
G. Auld and S. Renckens
Times, 2020). Private regulatory programs have not been immune
to these disruptions. As countries imposed increasingly wide-
reaching restrictions on business activity and travel, private regu-
lators have needed to adjust their ways of operating, including
moving to remote operations in their head office and regional
offices. Participants in these programs have also faced tremendous
upheaval and financial strain. Markets for their products have van-
ished or dramatically declined. The international cut flower mar-
ket, as an example, saw prices and trade flows plummet causing
considerable problems for producing countries, such as Kenya that
exports a $1 billion worth of cut flowers a year (Faux, Herbling, &
Munsterman, 2020) and has 30 percent of its flower workers
employed on farms certified by Fairtrade International
(Frederburgh, 2019). Concerns over food shortages, moreover,
sparked a wave of trade restrictions that the United Nations Food
and Agriculture Organization (FAO), the World Health Organiza-
tion (WHO), and the World Trade Organization warned would dis-
proportionately harm low-income, food-deficit countries (FAO,
2020).
How do these global disruptions affect sustainability gover-
nance and operators in the Global South? This question is impor-
tant, since existing research shows that operators in Global South
countries face specific barriers to participation in private regula-
tory programs (Neilson, 2008; Ponte, 2002; Renckens & Auld,
2019). These barriers include the costs of certification, such as
audit fees, data requirements and changes to practices to comply
with private standards. In addition, scholars have found that smal-
ler producers are disadvantaged, and that a relative lack of avail-
able auditors and uncertain socio-economic benefits of
certification are obstacles to participation for producers in Global
South countries. Inequalities resulting from these barriers may be
exacerbated, and new barriers developed, by the programs’
responses to the COVID-19 pandemic, making the situation during
the pandemic even more precarious for producers in the Global
South.
In this paper, we assess how transnational private regulatory
programs have adjusted to the COVID-19 crisis by changing their
audit policies and how these changes may affect operators in the
Global South. While rule making is a core function of private regu-
latory programs, audits are crucial as efforts to verify whether
firms and operators meet a particular level of performance mea-
sured against the certification and labeling rules. Audits provide
assurances to buyers and consumers that sustainability claims
are credible; audits are essential for facilitating governing at a dis-
tance in a globalized market (Loconto & Busch, 2010). In many
instances, audits include in-person or on-the-ground, physical vis-
its to the firms, farms, production sites, and organizations that
apply to be certified.
Thousands of these visits occur under the auspice of private reg-
ulatory programs in a given year, in the form of initial certification
audits, annual surveillance audits, recertification audits (usually
every three to five years), or unannounced control audits. For
example, FLOCERT, the independent organization that conducts
audits for Fairtrade International, carried out 2,760 audits in
2017 and 3,001 audits in 2018 (FLOCERT, 2020a). The 26 member
companies of the Together for Sustainability initiative were
involved in 14,000 supplier evaluations in 2019 (Together for
Sustainability, 2020). The Program for the Endorsement of Forest
Certification (PEFC) has certified (through its accredited auditors)
individually or collectively 750,000 forest owners in 53 countries,
with 12,000 companies certified against the program’s chain-of-
custody standards (PEFC, 2019, 2020b). Through group and indi-
vidual assessments, these forest owners and supply chain compa-
nies must be assessed via an annual surveillance audit as well as
a full recertification audit after five years. Yet, the COVID-19 pan-
demic has made in-person, field audits nigh impossible for the near
2
World Development 139 (2021) 105314
future. What adjustments have private rule-makers made to their
auditing policies? And what are the implications for operators in
the Global South?
We assess these questions by examining the audit policy
changes of 98 private regulatory programs. Disclosure is partial
at best. Fifty-one programs have made these policy changes pub-
licly available, with the earliest policies announced in late January
but the bulk coming into effect in March around the time the WHO
classified COVID-19 as a global pandemic. Policy adjustments vary
in their scope and types of permitted modifications to normal in-
person audits. The dominant modifications focus on the three typ-
ical audit processes – initial audits, surveillance audits, and recer-
tification audits – with programs focusing on postponements,
extensions or remote audits as acceptable temporary measures in
light of COVID-19. Very few programs made any modifications to
their standards’ substantive requirements. The policy changes also
included conditions specifying when modifications would be per-
mitted and reporting requirements on the application of the policy
by auditors and certificate holders.
Five facets of these changes create explicit and implicit (or
unintentional) barriers for operators from countries in the Global
South. First, barriers are created by the conditions for when mod-
ifications to existing audit practices are allowed, which in some
cases explicitly excludes operators from Global South countries
or small producers in these countries. Second, the limited flexibil-
ity regarding private programs’ substantive requirements means
no leniency will be in place in spite of the potentially dropping
market interest in certification in the short and potentially med-
ium term. Third, costs to be certified may increase as a result of
shifts to new types of audits, such as remote audits, that require
different infrastructure and competencies. Fourth, programs show
a greater concern for operators that are already participating in a
program, rather than those that are trying to get access – a prefer-
ence that exacerbates existing biases toward high-capacity and
well-resourced operators. Finally, access to auditors to conduct
assessments may be more challenging for operators in the Global
South, due to the varying timing of country restrictions, audit pol-
icy changes, and the organizational policies of individual auditors.
Our analysis proceeds as follows. In the next section, we discuss
the importance of audits in private regulatory programs and the
impact that the COVID-19 pandemic may have based on the liter-
ature’s discussion of barriers to Global South operators. After out-
lining the data gathering process, the article discusses the variation
in the audit policy changes and highlights five potential barriers for
operators from Global South countries. We conclude with limits
and implications of the current analysis.
2. Credibility of private regulatory governance amidst
disruption
Credibility is a key concern for private regulatory programs. Pri-
vate regulators aim to provide marketplace assurances that opera-
tors, certified against a program’s standards, can make
environmental and ethical claims. Examples include a fishery that
is not using harvesting techniques that harm aquatic ecosystems;
or a cattle farm that is allowing cows to pasture graze. The pro-
grams we examine regulate practices that can create environmen-
tal and social harms – practices that are invisible to the buyer or
user, even when they use the good or service. In the absence of
some mechanism to create trust (Shapiro, 1987), these credence
attributes (Darby & Karni, 1973) – like pasture grazing or benign
fish harvesting techniques – will be under produced (Akerlof,
1970). Audits are one mechanism devised to foster the kind of trust
needed in these situations. The credibility of private regulation is
partly defined by the efficacy of these audits, although many other
G. Auld and S. Renckens
institutional, political, and sociological processes will also matter
for how the legitimacy, credibility and authority of a private regu-
lator is viewed by outside audiences (Bernstein & Cashore, 2007;
Black, 2008; McDermott, 2012).
Audits have become increasingly separated from standard set-
ting. This separation happens to varying degrees (Loconto, 2017).
In most instances, a private regulatory program sets a standard,
often with expert and stakeholder input. Audit organizations then
seek the opportunity to certify operators against this standard by
being accredited by the regulatory program or via a separate
accreditation organization (e.g. Assurance Services International
performs accreditation for programs like the Forest Stewardship
Council (FSC) and the Global Sustainable Tourism Council (GSTC)).
Audit organizations sometimes hire inspectors on a one-time or
recurring basis, or they use their own employees, to perform the
audit assessments. Stakeholders and outside experts are typically
engaged in the audit processes. In other instances, the private reg-
ulator will control and oversee the audits, using an appointed
expert panel or committee. Like the auditors, the private regulator
may hire inspectors that report directly to it or its appointed expert
panel or committee. Finally, external audits may be a voluntary
component of a program, which applicants may consider undertak-
ing if they have reason to seek greater assurances that they are in
compliance with a program’s standard.
Regardless of the actors doing the audits, all audits provide an
external evaluation of practices against some pre-determined stan-
dard to provide assurances in the market and to other evaluative
audiences like environmental groups or local communities. Most
private regulators include three types of audits. An initial audit
checks to ensure a new applicant to a program meets some thresh-
old of performance as measured against the standard. Once certi-
fied, periodic surveillance audits check for non-conformances and
to ensure corrective action requests are being addressed on agreed
timelines. Recertification audits usually occur after five years. Vari-
ants on this three-part model exist. Carbon offset programs include
additional steps such as a preliminary requirement that project
developers engage a stakeholder consultation process before
beginning the program that they are then required to submit to
the program for review (e.g. Gold Standard asks for this and has
preliminary documents reviewed by SustainCERT, the program’s
internal auditor). External audit organizations then play a role in
validating and verifying (in the language of offset programs) the
design and performance of a carbon offset project. Product-
focused standards usually add laboratory testing.
All of these audit modalities include in-person and remote
forms of assessment, sometimes termed desk reviews or desk
audits. In-person audits, however, are seen as central to the rigour
of compliance checks and thus feature prominently, particularly in
the initial certification and recertification processes. This is impor-
tant given the standards’ focus on credence attributes. In-person
audits seek to obtain objective information – by observing an oper-
ator in situ – about the production of credence attributes to ensure
they can be credibly marketed through on-product claims.
2.1. Impacts on the Global South
Previous research highlights an inherent bias in private regula-
tion, in that operators from Global South countries face additional
barriers to participate in private regulatory programs and enter the
market for sustainably produced goods and services. The barriers
relate, among other things, to the fact that certification costs can
be high for operators as a result of the costs involved in adjusting
practices to adhere to private programs’ standards and the require-
ment to have to pay for audits to verify compliance (Carter, Scott, &
Mahallati, 2018). Research has shown that larger and vertically
integrated firms can generate economies of scale in ways that
3
World Development 139 (2021) 105314
smaller producers cannot and hence reduce the certification costs
per unit (Cashore, Auld, & Newsom, 2004; Ebeling & Yasué, 2009;
Ponte, 2008). Relative cost may further increase for operators in
the Global South since accredited auditors are not as widely avail-
able in Global South countries, while Global North governments at
times have offered financial assistance to their domestic operators
to be certified, which gives them a competitive advantage (Jacquet
et al., 2010; Morris & Dunne, 2004; Pattberg, 2006; Renckens &
Auld, 2019). Global South participation in private regulatory pro-
grams has also been hindered by the use of western science stan-
dards in developing sustainability rules and data requirements for
audits (Ponte, 2008; Stratoudakis et al., 2016), the uneven and
uncertain expected socio-economic impacts of certification on
local communities in the longer term (Cashore, Gale, Meidinger,
& Newsom, 2006; Grabs, 2020; Mohan, 2016; Naegele, 2020;
Neilson, 2008), and local resistance to what are perceived to be
Northern-dominated programs, both in terms of their stakeholder
engagement and substantive requirements (Hospes, 2014;
Schouten & Bitzer, 2015; Sun & van der Ven, 2020). Rather than
empower producers in the Global South, private governance pro-
grams are also viewed increasingly as mechanisms that reinforce
and strengthen the power of lead firms – particularly retailers
and brand owners – in global value chains, allowing these firms
to define the terms of sustainability according to their interests
(Levy, Reinecke, & Manning, 2016; Marques, 2019).
The global COVID-19 pandemic presents evident challenges for
in-person audits, which may exacerbate and come on top of these
existing barriers for operators in countries of the Global South. Due
to restrictions on travel and business activities for personal health
and safety reasons, private regulators have had to consider adjust-
ments to their auditing practices. Shifts to new types of audits,
such as remote or virtual audits, may partly compensate for some
of these challenges. Yet, they may also create new requirements in
terms of data provisions, including risk assessments, and technolo-
gies to perform the audit. Allowing more time for the audit process
will likely be necessary. Delaying in-person audits until the pan-
demic is over, or until audits can be safely performed, may impede
Southern operators more than others. These countries initially
lagged behind Northern countries in terms of the spread of the
virus, which implies they may also be lagging behind in terms of
when authorities deem it safe to allow business activities to return.
More limited governmental capacities to effectively respond to the
virus—both in terms of health care provisions and financial assis-
tance to citizens and businesses—may create additional delays.
With vaccines now available, the global distribution and vaccina-
tion may also be uneven, which again may create delays that are
more pronounced in some (poorer) countries. Thus, inequalities
created by the response of private regulators to COVID-19 may
(unintentionally) exacerbate existing barriers for producers in Glo-
bal South countries.
3. Data collection
We explore these issues building from our previous work which
identified 98 private regulators, derived from existing datasets and
listings as well as our own research (Abbott, Green, & Keohane,
2016; Bulkeley et al., 2012; Fransen, Schalk, & Auld, 2016; Hale &
Roger, 2014; Hoffmann, 2011; Perez, Cohen, & Schreiber, 2019;
van der Ven, 2015; Big Room Inc., 2017; International Trade
Center, 2018; MSI Integrity, 2017; United Nations Climate
Initiatives Platform, 2017). Private regulators are defined as inde-
pendent organizations that have a regulatory (or standard-
setting) function addressing sustainability issues; are private (i.e.,
not administered or created solely by state actors); and are
transnational (i.e., operate in more than one country). Importantly,
G. Auld and S. Renckens
this definition excludes programs that are operated or managed by
organizations that predominantly have other functions than rule-
making (e.g., an industry association that also has developed a
standard-setting scheme). Ours is not an exhaustive list of private
regulators. However, the 98 in our dataset should give us a reason-
able picture of what these organizations are doing in response to
the COVID-19 pandemic. For each program, we have information
from previous work on their headquarters location, sector of work,
and certification procedures. We use these as correlates to identify
patterns in the timing and nature of responses to COVID-19.
Our COVID-19 data collection occurred from April to November
of 2020. We collected the url addresses for each program and
searched these for references to COVID-19 and related terms. These
searches focused on identifying any public statement about
changes to the program’s audit policies. But we also collected infor-
mation on other references to the pandemic. Furthermore, we
coded the policy announcements in several ways, including
whether one was noted before the end of October 2020 (a feasibility
cut-off for this rapid analysis) and how much information was
made available and to whom. For programs that disclosed their pol-
icy (51 instances out of 98), we coded the policies to report on when
they first came into force, how long they were to last (if an end date
was set), what the scope was, and what types of changes to audit
practices were permitted and in what circumstances.
4. Adjusting audits to account for COVID-19
A total of 51 private regulators (or 52 percent of our sample)
announced changes to their audit policies before the end of Octo-
ber 2020 (Fig. 1). Consistent with the literature, transparency has
been incomplete (Schleifer, Fiorini, & Auld, 2019). Forty-one of
these policies were made fully public. The other 10 were made
available to key stakeholders, such as the audit organizations and
the certificate holders.
The effective start dates of announced policy changes began in
January. Two programs (the FSC and Social Accountability Interna-
tional (SAI)) announced policies that entered into force on January
30, 2020. This was just 17 days after the first COVID-19 case out-
side of China was announced (namely in Thailand on January
13). But the biggest growth period came in March. Six programs
had announced policy changes by the end of February; 34
announced policies by the end of March.
Transparency was also partial on the key issue of the time per-
iod a policy change would be in place: 51 programs provided a
clear start date, and only 20 noted a specific end date. Those that
did not mention an end date usually referenced ongoing review
of the situation and future announcements about when the policy
would sunset. A little over five months was the average duration of
the policies with clear end dates. The longest duration was around
11 months, and the shortest was two and a half months. By the end
of our data collection period (November 2020), six programs had
extended their end dates given the continuation of the pandemic;
one program (the Alliance for Water Stewardship) had added an
end date when the program had updated its policy in June 2020.
Since some of the programs in our dataset are specific to geo-
graphic areas outside of the Global South (14 in total), we excluded
these for the remainder of the analysis. Of the remaining 84 pro-
grams, 47 (or 56 percent) announced audit policy changes. Of the
four programs in our dataset that have headquarters in the Global
South, the Roundtable on Sustainable Palm Oil (RSPO) was the only
program to publicly announce a policy change.2 Yet, when we focus
2
RSPO has its headquarters in Malaysia. The other programs are Fair Trade Tourism
(FTT), with headquarters in South Africa; LIFE Certification, with headquarters in
Brazil; and Small Producers Symbol (SPP), which is based in Mexico.
4
World Development 139 (2021) 105314
on programs operating in sectors that are relevant for Global South
countries, we see that 74 percent of them announced changes: 73
percent of programs in agriculture and food; 86 percent of fisheries
and aquaculture programs; 68 percent of forestry/wood products
programs; and 69 percent of metals/mining programs.
4.1. Audit policy scope
Forty programs provided information on the scope of their audit
policy changes. These generally focused on the three features of
audits typical to private regulators – initial audits (22 mentions),
surveillance audits (21 mentions), and recertification audits (25
mentions). In 15 cases, all three were noted, and the combinations
of recertification, surveillance audits, and/or initial audits were
also frequent. RSPO, for example, mentioned all three types of
audits. Very few programs mentioned just one of these forms of
audits, without mentioning any others. One such program is B
Lab (which certifies companies for their overall environmental
and social performance) that only mentioned recertification;
another is MPS (which certifies companies in the horticultural sec-
tor) that only mentioned surveillance audits.
Several programs included issues beyond these three typical
audit processes. Two programs (SAI and Better Cotton Initiative)
made specific reference to provinces in China where the policy
would apply, in light of the early outbreaks of the coronavirus in
the regions. Other programs typically treated geography as one
condition along with others (see further discussion below) that
might affect the policy’s application. Other atypical scope consider-
ations dealt with the specific nature of a program’s processes –
such as verification and validation for carbon offset programs or
lab testing for certain product standards. There were also explicit
exclusions. For instance, the Marine Stewardship Council’s (MSC)
policy covered initial audits, surveillance audits, and recertification
audits, but it excluded objection procedures to certification deci-
sions that are overseen by an external adjudicator (for discussion
of this process, see Gulbrandsen & Auld, 2016; MSC, 2020).
4.2. Audit modifications
Thirty-nine programs noted the types of modifications they
would permit. Postponements, extensions and remote audits were
the most frequent options: 31 programs offered postponements or
extensions and 29 programs offered remote audits. Twenty-four
programs offered both these options, with five offering just remote
audits, and seven offering just postponements or extensions. Post-
ponements and extensions are the simplest solution to the pan-
demic disruption. The Alliance for Water Stewardship (AWS), for
instance, posted a note on their website on April 22, 2020 explain-
ing that all surveillance and recertification audits would receive a
two-month extension; no information was provided on procedures
for new applicants (Alliance for Water Stewardship, 2020). B Lab
took a similar approach, giving participants a six-month grace per-
iod for recertification (B Lab, 2020). The IFFO Global Standard for
Responsible Supply (IFFO RS, now MarinTrust) had more specific
rules, combining remote audits and postponements or extensions:
initial and recertification audits were eligible for an extension of
six months (or until restrictions are lifted), and surveillance audits
were permitted four months, after which a remote audit would be
required (MarinTrust, 2020).
Remote audits are a catchall. They encompass a wide range of
practices, some of which are very poorly explained in the public
documents we reviewed. Green Seal, for instance, provided the fol-
lowing on their website: ‘‘Green Seal will conduct virtual audits
instead of in-person audits where necessary. This will allow any
companies that have submitted for a new certification evaluation
to achieve conditional Green Seal certification in a timely manner”
G. Auld and S. Renckens World Development 139 (2021) 105314

Fig. 1. Date of announced changes to audit policies. Legend: ASC = Aquaculture Stewardship Council; ASI = Aluminium Stewardship Initiative; AWS = Alliance for Water
Stewardship; BCI = Better Cotton Initiative; EITI = Extractive Industries Transparency Initiative; EP = Equator Principles; FLO = Fairtrade International; FoS = Friend of the Sea;
FSC = Forest Stewardship Council; GAA = Global Aquaculture Alliance; GAP = GlobalG.A.P.; GOTS = Global Organic Textile Standard; GS = Gold Standard; GSTC = Global
Sustainable Tourism Council; IFFO RS = IFFO Global Standard for Responsible Supply; ISCC = International Sustainability and Carbon Certification; ISSF = International Seafood
Sustainability Foundation; LEAF = Linking Environment and Farming; MSC = Marine Stewardship Council; PEFC = Program for the Endorsement of Forest Certification;
RA = Rainforest Alliance; RBA = Responsible Business Alliance; REC Std = International REC Standard Foundation; RJC = Responsible Jewellery Council; RSB = Roundtable on
Sustainable Biomaterials; RSPO = Roundtable on Sustainable Palm Oil; RTRS = Round Table on Responsible Soy; SAI = Social Accountability International; SBP = Sustainable
Biomass Program; SFI = Sustainable Forestry Initiative; SGPP = Sustainable Green Printing Partnership; TE = Textile Exchange; UEB = Union for Ethical Biotrade;
WHC = Wildlife Habitat Council; WRAP = Worldwide Responsible Accredited Production.

(Green Seal, 2020). Friend of the Sea noted that they will use the
pandemic as an impetus to move to sustainable augmented reality
audits, which they opined ‘‘will become the future global audit pro-
cedure. . . [allowing] the qualified auditor to carry [out] the onsite
inspection from a control panel commanding remote ‘eyes’ and
recording a complete video of the audit, following strict inspection
procedures.” Blockchain technologies would also be used to ensure
the integrity of the audit report and video recordings (Friend of the
Sea, 2020). In these cases, the specifics of the virtual, augmented
reality, or remote audit were left under specified.
Other programs took greater care to detail the nature of their
remote audits. These were not all made publicly available, how-
ever. Some programs indicated that careful guidelines were being
developed, and that these would be made available to the auditors
(GOTS, 2020). Other programs disclosed detailed explanations of
the nature and expectations around remote audits. Six programs
– FSC, PEFC, Aluminum Stewardship Initiative, MarinTrust, and
Aquaculture Stewardship Council (ASC) – that discussed remote
audits made specific reference to the International Accreditation
Forum’s (IAF) Mandatory Document for the Use of Information
and Communication Technology (ICT) for Auditing/Assessment
Purposes (IAF, 2018). This document sets out a number of
provisions – that are mandatory for IAF members – including pro-
visions concerning security and data protection, the needed ICT
infrastructure on the part of the applicant and the auditor, compe-
tencies for conducting remote audits, and knowledge of the risks
and limits of ICT-based information for the validity, effectiveness
and efficiency of audits. As another example, Fairtrade Interna-
tional, and its certifier FLOCERT, had a helpful FAQ document that
answered a range of questions about the application of remote
audits, including concerns about necessary technology and Inter-
net connections (FLOCERT, 2020c). In these cases, programs
appeared to have understood the implications of remote audits
and determined ways to prepare to address the potential limits
and downsides of this audit technique.
A much rarer type of modification to the audits was a change to
the program’s substantive standards. Seven programs offered this
form of accommodation. The Wildlife Habitat Council noted that
during the pandemic applicants could submit incomplete informa-
tion and their eligibility would be determined on the basis of par-
tial data (Wildlife Habitat Council, 2020). Extractive Industries
Transparency Initiative allowed similar flexibility on reporting
requirements (EITI, 2020), while Equator Principles noted flexibil-
ity on the environmental and social due diligence process based
on a risk analysis (Equator Principles, 2020). Worldwide Responsi-
ble Accredited Production (WRAP) offered some flexibility on rules

5
G. Auld and S. Renckens
about working hours, conditional on transparent reporting and
careful documentation (WRAP, 2020). For the International Sea-
food Sustainability Foundation (ISSF), participating companies
and vessels that were unable to provide audit-related evidence
due to COVID-19-related disruptions in record-keeping (such as
on forbidden transactions with vessels engaged in illegal, unre-
ported and unregulated fishing, or those involved with shark fin-
ning) would not be penalized with a non-conformance (ISSF,
2020). The Better Cotton Initiative allowed granting producers
engaged in a reassessment ‘‘COVID-19 Compliance Exemptions”
when a core indicator of the standard could not be complied with,
which would give producers additional time for implementing cor-
rective actions (Better Cotton Initiative, 2020). Textile Exchange,
finally, was requesting brands show flexibility when suppliers
were not able to show compliance with certain parts of the stan-
dard due to COVID-19 disruptions (Textile Exchange, 2020).
Programs also detailed conditions under which the modified
auditing practices could be used and the kinds of reporting that
would be necessary. Roughly half of the programs with publicly
available policy changes detailed conditions for when audit prac-
tices could be modified. Implicit and explicit references to risk
analysis were apparent in these conditions. For instance, programs
advised auditors to consider past non-conformities and unresolved
corrective action requests, potential supply chain integrity issues,
and stakeholder complaints as factors that might limit the applica-
tion of remote audits (FSC, 2020; Gold Standard, 2020). Others
mentioned the need for risk assessments, but specified little of
what this should involve (GOTS, 2020). Certain programs included
explicit risk-based tools, such as ASC that developed a country-
level risk index to establish whether aquaculture farms would be
eligible for remote audits (ASC, 2020a; see also, RSB, 2020).
Auditors were often empowered to determine the nature of the
responses on a case-by-case basis. Bonsucro, for instance,
explained that desk audits and postponing would be options for
certificate holders with audits due between March and June
2020, but that certificate holders would need to discuss these with
their audit organization that would then confer with Bonsucro
(Bonsucro, 2020). The Rainforest Alliance provided a template for
auditors to fill out that details the kinds of exceptions they were
seeking approval for (Rainforest Alliance, 2020a). Auditors were
also expected to report on the performance of audits during
COVID-19. Some were simple requirements, such as retaining a list
of all the instances where the modified audit policy had been used
that could be accessed by the private regulator (MSC, 2020).
Others, for instance the Roundtable on Sustainable Biomaterials
(RSB), spelled out lengthy reporting requirements for the applicant
and the auditor, including details on the scope of the audit, the
kinds of documents to be provided, the systems the auditor would
be able to access remotely, and a completed risk analysis (RSB,
2020). The frequency of reports was also sometimes noted; FSC,
for instance, required quarterly reports from auditors on the appli-
cation on the policy (FSC, 2020).
By late October 2020, 25 programs had published updated poli-
cies. Several programs changed the scope and the types of modifi-
cations of their policies, for example by including surveillance
audits in their policy scope, and by limiting postponements to
audits and allowing more remote audits. Most of the updated poli-
cies offered more details on how remote audits were to be exe-
cuted, with several mentioning specifically that on-site audits
would be required once travel restrictions are lifted.
5. Consequences for inequalities in global markets
A first feature of the changes that may exacerbate inequalities
comes with the conditions placed on when the private regulators
6
World Development 139 (2021) 105314
and auditors are willing to accept modifications to existing audit
practices and the reporting requirements auditors must follow.
Conditions limit the application of these policies. In certain cases,
they explicitly target operators in the Global South. The ASC, as
we mentioned above, referenced a risk-tool for determining the
countries eligible for remote audits for initial and recertification
audits. The risk-tool – called the ASC Country Social Profile – builds
a country-level risk score using the World Governance Indicators,
Trafficking in Person, Transparency International, and the Global
Slavery Index along with non-conformances identified on social
indicators during ASC farm audits. Of the Global South countries
that were explicitly mentioned by ASC, 16 were indicated as high
risk, seven as medium risk, and none as low risk, while all of the
Global North countries that were mentioned were indicated as
low risk, except for three that were considered medium risk. The
tool helped determine eligibility for modified audits. For instance,
farms in high risk countries, according to this tool (e.g. Bangladesh,
Belize, China, Colombia, Ecuador, and others), would not face addi-
tional barriers to using remote initial audits, which farms in low
and medium risk countries would not face (ASC, 2020a).3 Other
programs were less explicit about the nature of the risk assessment,
but the implied logic was that remote audits would present a risk to
the credibility of audits in certain cases more than others. Auditors
needed to document their assessment of these risks and justify their
decisions (PEFC, 2020a, 2020c).
Certain policies contained implicit or unintentional barriers.
ASC, for instance, did not permit group certification to be con-
ducted by remote audits. The group certification methodology
was introduced in April 2019 with the explicit purpose of helping
small producers get access to the ASC. In a news release about the
methodology, the Head of ASC Programme Assurance noted that:
‘‘We are delighted to have launched this in Vietnam, where there
are so many smaller producers who can benefit from the opportu-
nity to implement ASC’s requirements” (ASC, 2019). The ASC does
stand out as having more Global South country farms involved in
the program (six of the top ten producing countries are from the
Global South, with Chile being the largest ASC producer of all)
(ASC, 2020b). Still, the restrictions on the group certification
methodology do implicitly work against the intention of expanding
opportunities for the program among Global South producers,
especially small-scale farmers.
A second barrier-creating feature of the audit policy changes is
the limited flexibility of private regulators on their substantive
requirements. Recall that only seven programs noted they would
adjust their performance rules in light of the COVID-19 pandemic.
The most explicit of these came from WRAP that offered some flex-
ibility on rules about working hours and Bonsucro’s ‘‘COVID-19
Compliance Exemptions”. The lack of flexibility is particularly
striking given the hardship being experienced by producers
involved in these programs. Travel restrictions, border closures
and other measures have disrupted supply chains, creating finan-
cial hardship for the participants in private regulatory programs
that, in theory, are meant to provide market opportunities. The
cut flower market has suffered, and other export crops, such as
tea and coffee, have faced similar challenges, leaving farmers and
producers, in particular smallholders, in potentially precarious sit-
uations (Committee for the Coordination of Statistical Activities,
2020; Fairtrade International, 2020b; Guido, Knudson, & Rhiney,
2020; Morton, 2020).
3
There is some ambiguity about the extent to which additional barriers are placed
on farms in high risk countries given different potential readings of how restrictions
on remote audits for assessing social indicators (point 6.2.1. in the policy) are meant
to condition the options for using remote initial audits (set out in table 1 of the
policy).
G. Auld and S. Renckens
Programs do recognize the hardship that the pandemic has cre-
ated. The Rainforest Alliance, for instance, provided a list of almost-
daily updates on the impacts being experienced by farmers work-
ing with the program (Rainforest Alliance, 2020b), and it offered an
opportunity to donate to support its participants. Other programs
have set up similar funds; for instance, Goodweave established
the COVID-19 Child and Worker Protection Fund to help the pro-
ducers it works with in Nepal, India, and Afghanistan
(Goodweave, 2020). But there is still a sense that the programs
view their credibility and the need for certification as essential.
MPS (a horticultural certification program that includes a standard
for cut flowers) notes the serious challenges and hardships facing
the sector, but suggests that certification remains important and
will be demanded again when things return to normal (MPS, 2020).
A third implication of the audit policy changes is the cost of the
proposed new audit practices. Remote and virtual audits require
technologies to which operators may not have access. Even the
availability of a stable and sufficiently fast Internet connection
for the transfer of documents cannot be taken for granted. If it is
assumed that operators have to carry the costs of acquiring the
technologies—and several audit policies mention the availability
of these technologies as a prerequisite for remote audits—this
places an additional burden on poorer operators seeking (re)certi-
fication. As mentioned, some programs, such as Fairtrade Interna-
tional, are attentive to these additional costs. Possible remediation
can come from financial assistance that is made available, like
through the funds we noted above. Fairtrade International, for its
part, launched in early May a ‘‘Fairtrade Producer Relief Fund”
and a ‘‘Fairtrade Producer Resilience Fund,” which could be used,
among other things, to cover short term ‘‘business continuity
costs” or longer term ‘‘technology-based capacity building”
(Fairtrade International, 2020a). Nonetheless, even this program
did not see an alternative solution than postponing the audit if
such technological hurdles could not be overcome (FLOCERT,
2020b).
Fourth, and related, the audit policy changes tend to favor oper-
ators that are already in the program, not those that might be try-
ing to get access. We know that there are considerable barriers to
operators in the Global South, including the cost of certification.
But the initial entry into a program is also highly consequential
for operators: it provides them access to the market for sustainable
goods and services for which the private programs to a degree act
as gatekeepers. Not having the ability to acquire this access due to
the COVID-19 pandemic increases the costs to operators in terms
of lost revenue and operating costs to maintain the likelihood of
access later on when in-person audits are possible again. The
ASC, for instance, limits the application of remote and remote
assisted audits (which are audits that involve some in-person
assistance). Applicants that are seeking to certify new sites (that
have not been operational for a full production cycle), are not eli-
gible for remote audits. Instead, they need to wait to complete a
full audit following the standard rules and procedures (ASC,
2020a).
Finally, another consideration is the policies of the audit organi-
zations themselves. The COVID-19 outbreak has affected countries
in different ways and at different times. The operating location of
the private regulator and auditors thus is likely to also matter for
how accessible audits have been for operators in certain countries,
particularly those in the Global South that did not experience
COVID-19 outbreaks as early as countries in the Global North.
Our previous work has identified that auditors and assessors are
often not from producing countries in the Global South
(Renckens & Auld, 2019). At the same time, the modified audit poli-
cies put in place by private regulators in light of COVID-19 often
exclude operators that are not in affected areas. Thus, there might
be situations where operators cannot benefit from the policies, but
7
World Development 139 (2021) 105314
have no access to auditors due to travel restrictions and other mea-
sures the auditors and assessors are facing due to the location of
their operations or headquarters.
6. Conclusions
Responses to COVID-19 have been fast moving. We have offered
an initial analysis of these rapid adjustments from one type of gov-
ernance organization. We found relevant variation across the pri-
vate regulatory programs in terms of which programs announce
audit policy changes and the types of changes they proposed.
Transparency of the adjustments to audit policies is incomplete
at best. Of those programs making their adjustments public, the
vast majority did so around the time or within a month after the
World Health Organization declared a global pandemic on March
11, 2020. Most programs opted for postponing audits and/or intro-
ducing remote and virtual audits. Very few, in contrast, allowed
modifications or exemptions to their substantive standards.
Our assessment of the implications of these changes for opera-
tors in the Global South showed that they may exacerbate existing
barriers to participation and can create new barriers, at least tem-
porarily. The technologies necessary to engage in remote and vir-
tual audits may impose additional costs on operators. Conditions
on when the new audit policies can take effect, including the avail-
ability of these technologies and acceptable levels of compliance
risks, implicitly and in some cases explicitly target Global South
operators. The limited flexibility on compliance with substantive
requirements of the private programs, and the focus on existing
rather than new program participants, may also disadvantage
Southern operators. These barriers are additionally troubling given
producers in these countries face the direct challenges presented
by the COVID-19 pandemic.
Our analysis has several limits. We are unable to capture policy
and practice changes that programs did not announce on their
websites. In time, we may be able to determine if this is the case,
by examining audits performed during the COVID-19 pandemic
to determine if practices shifted with or without formal policy
changes. Our analysis was also unable to trace the small adjust-
ments programs made to their policies as the pandemic unfolded.
The documents we collected noted earlier versions of standards.
We noted the earliest start date as the beginning of a policy adjust-
ment, but we were not able to trace all the modifications and
updates certain programs made. For instance, by the beginning of
May, SAI had developed a sixth edition of its policy; on May
15th, GlobalG.A.P. announced a new remote audit policy that was
developed through extensive stakeholder engagement. It offered
a more elaborate explanation of remote audits as an alternative
to merely postponing audits for six months (GlobalG.A.P, 2020).
According to our data, 25 programs had announced revised policies
in the late summer and early fall, which often extended the time-
frames of their original policy changes and clarified when remote
audits and on-site audits would be needed. Further work ought
to track these changes carefully to determine if such adjustments
are improving or worsening the opportunities for producers in Glo-
bal South countries.
Broader implications of the COVID-19 pandemic for private reg-
ulatory governance emerge from our work and require future
attention. For a couple of months in the second quarter of 2020,
the global economy was brought to a virtual standstill, with signif-
icant impacts on global trade. The economic downturn that follows
will put additional stress on global supply and demand at a time
that public finances are stretched. How will these short- and
medium-term economic conditions impact private sustainability
governance? Will firms and consumers still be willing and able
to spend resources on certification? Will only certain programs
G. Auld and S. Renckens
survive as funding sources change priorities or certification and
licensing fees decline?
Our preliminary analysis suggests that capacity is highly varied
across the programs. Indeed, there is a strong correlation between
membership in the ISEAL Alliance (a member organization focused
on advancing credible social and environmental certification and
labeling initiatives) and disclosure of an audit policy that accounts
for COVID-19; all but one of ISEAL’s relevant full members dis-
closed their audit policy changes, while for non-ISEAL members
around 60% did not disclose these changes. Declining resources
for and support of private regulation as an organizational form
may lead to greater program attrition, as expected by theories of
organizational ecology (Abbott, Green, & Keohane, 2016). At the
same time, we also observe high variability in the capacity of the
auditors doing work for private regulators, with certain large audit
firms from the testing, inspection and certification industry or the
financial accounting industry investing heavily in COVID-19-
related programs and operational shifts, including remote audits.
A permanent shift to more remote audits, in other words, may fur-
ther heighten the power and influence of auditors located in the
Global North.
More broadly, what do the global disruptions resulting from the
pandemic mean for private governance in the medium to long
term? Regulatory scholarship notes the key importance of the
macro-political-economic context for the operation and logic of
regulatory efforts, creating conditions that support or undermine
particular regulatory projects (Bernstein & Cashore, 2007;
Braithwaite, 2005, 2008; Büthe & Mattli, 2011). Will transnational
private governance diminish in prominence to be replaced by other
forms of eco-social transformation (see e.g., Pye, 2019)? Existing
research already notes alternative models and a move beyond cer-
tification as the organizing logic for the work of the private regula-
tors we examine (Fransen, 2018). The pandemic may accelerate a
trend that was already ongoing, increasing the importance of other
work done by the private regulatory organizations that does not
involve standards and audits, such as consultancy, capacity build-
ing, information sharing, and advocacy (Renckens, 2020).
Another possibility is a return to local roots, as supply chains
shorten. Will private governance programs that currently operate
globally become more localized (a return to the origins of certain
programs like organic agriculture (Auld, 2014) when the pandemic
pushes the transition to an economy that is based on more local-
ized production and shorter supply chains? There has been a rise
in programs with origins in the Global South. But the logic of these
programs often centred on providing alternatives to programs with
perceived Northern bias or assisting local producers in getting
access to a global market. As trade is impacted by the pandemic
and perhaps does not return to its former levels in the medium
term, will these programs cease to have a purpose? Existing
research suggests that shifting markets can rapidly change the
interest in private governance (Schleifer, 2017), a finding that
might suggest private regulatory programs face harder times to
come. Our work, we hope, is a foundation for advancing answers
to these important questions in work on private regulatory gover-
nance that emerges in a post-COVID-19 world.
Declaration of Competing Interest
The authors declare that they have no known competing finan-
cial interests or personal relationships that could have appeared
to influence the work reported in this paper.
Acknowledgements
The authors thank Lindsay Wong, Amy Janzwood, and Kristen
Pue for their excellent research assistance. An early version of this
8
World Development 139 (2021) 105314
work was presented to a virtual speaker series on International
Affairs in the Time of COVID-19 hosted by the University of Ottawa,
Graduate School of Public and International Affairs on May 20,
2020. We thank Gina Bateson, Mike Beale, Jennifer Clapp, Janina
Grabs, Andrea Khan, Jochen Markard, and Yixian Sun for helpful
comments on our initial thinking and drafts. Financial support
was provided by Carleton University’s Faculty of Public Affairs
Research Excellence Chair, the Connaught New Researcher Fund
of the University of Toronto Scarborough, and the Social Sciences
and Humanities Research Council of Canada (SSHRC IDG 507273
and SSHRC Insight Grant 435-2013-2072).
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