What was the starting point?
An SME well run on food safety, but with no formal CSR approach. This is a composite case study: it brings together situations our teams encounter at Moroccan food exporters, without describing a client.
The company, a family-owned limited liability company (SARL) in the Kenitra area, freezes vegetables and red fruit for export. It has about 140 permanent employees and hires seasonal workers during the harvest campaign. It is certified to IFS Food Version 8, is a member of the CGEM, the General Confederation of Moroccan Enterprises, and has been operating for more than ten years. Its customers are in Spain, France and the Netherlands.
In 2026, three requests arrive within six months:
- a European manufacturer subject to the CSRD asks it for value-chain data: energy, emissions, workforce, health and safety, at a level of detail beyond what the plant tracks;
- a retailer opens an account for it on its supplier rating platform, with an environmental, social and ethics questionnaire;
- another retailer proposes a contract amendment on respect for human rights in the supply chain, down to the farmers who grow the produce.
The quality manager starts filling in the three questionnaires in parallel, with figures that do not match from one document to the next. General management stops the exercise and decides to build a single approach, assessed by a third party: the CGEM CSR label, the Label RSE de la CGEM.
How did the SME sort its customers’ requests?
By writing down, for each request, its basis, its content and the answer chosen. This matrix took two weeks; it saved months of re-keying.
Request | Basis invoked | Answer chosen |
|---|---|---|
The manufacturer’s value-chain data | The customer’s CSRD reporting | Answer aligned with the EU voluntary standard; questions beyond it flagged to the customer |
The retailer’s platform questionnaire | The retailer’s responsible purchasing policy | Full answer from the evidence base, with supporting documents |
Human rights amendment | The retailer’s supplier policy, anticipating EU due diligence | Accepted after legal review, and growers brought into the CSR approach |
For the first request, the SME relied on the value-chain cap. According to the European Commission staff working document of 3 July 2026, a company with 1,000 employees or fewer in the value chain of a company subject to the CSRD may decline, for sustainability reporting purposes, to provide information beyond the voluntary standard, whose Annex II lists the data covered. The SME did not simply refuse: it provided the core data of the standard, then explained to the customer what it did not yet track and when it would. It first checked with the customer that the cap applied to a supplier established outside the EU, a point we have not yet confirmed in the text of Directive (EU) 2026/470.
For the third, the context was different: according to the Commission, EU due diligence will only apply from 26 July 2029, and to very large groups. The retailer was anticipating. The SME accepted the amendment because it already matched areas 1 and 8 of the CGEM CSR charter (charte RSE).
What did the diagnosis across the nine areas of the charter reveal?
Strengths where a system existed, and evidence gaps where nobody was responsible. The self-assessment was carried out objective by objective, with interviews with a sample of permanent and seasonal workers, and with staff representatives.
Area of the charter | Finding | Treatment |
|---|---|---|
1. Human rights | No discrimination found; many women on the lines, few in management | Gender indicators and an internal promotion target in the action plan |
2. Working conditions | Payroll reconciled with CNSS social security slips once a year; start dates out of step for some seasonal workers | Monthly reconciliation and regularisation before the assessment |
3. Environment | Water and electricity tracked monthly for the cold chain; no greenhouse gas emissions inventory | First inventory added to the action plan |
4. Corruption | No written rules; end-of-year gifts received from suppliers | Code of ethics, gifts rule, awareness for buyers |
6. Corporate governance | Certified accounts; no risk map | Risk map presented to the managing director |
7. Customers and consumers | Traceability, complaints and product safety covered by the IFS system | Evidence reused as it stood |
8. Suppliers and subcontractors | Payments to small growers sometimes later than the contractual terms; no social purchasing criterion | Tracking of the average payment period, purchasing criteria, CGEM “good payer” charter (charte du bon payeur) signed |
9. Community engagement | Local hiring and transport of seasonal workers, never documented | Written policy and indicators |
Area 5, fair competition, raised no difficulty. Two points were treated as absolute priorities, because they touched on the legal compliance that the assessor would check against documents: the declarations of seasonal workers and payment terms. The ISO 26000 grid was used to rank the rest, starting from the stakeholders: seasonal workers, growers, customers, the plant’s neighbours.
How did the assessment and the decision go?
As the CGEM rules provide, with one point of attention on the period chosen. After the meeting with the CSR and Diversity Commission and the CGEM’s written approval, the SME consulted two accredited bodies and selected one.
The date was discussed. According to the CGEM’s guidance, seasonal staff present at the time of the assessment count in actual headcount, which sets the indicative duration: 7 to 9 person-days between 50 and 150 employees, 9 to 12 between 150 and 400. Management chose the start of the campaign, a representative period when the assessor could meet seasonal workers. The proposed duration fell within the 150 to 400 employee band, adjusted to take account of the existing IFS system, since the reduction cannot exceed 30%.
The report, delivered within 15 days, raised no blocking criterion, but two reservations: the anti-corruption policy, still recent, and the tracking of payment terms, in place for only three months. The file was submitted within six months, with the commitments and action plan signed by the managing director.
Before the award committee, the managing director attended with the appointed CSR manager. The committee awarded the label subject to two conditions, lifted in less than six months after a half-day verification assessment. In this case study, as in reality, the decision belongs to the committee; no support can guarantee it.
How did the label serve the ESG questionnaires?
As an evidence base, not a ready-made answer. Each customer question was linked to an area of the charter and to evidence already gathered for the assessment.
Questionnaire topic | Charter area | Evidence reused |
|---|---|---|
Energy and emissions | 3 | Monthly readings, emissions inventory under way |
Water and waste | 3 | Meters, waste tracking slips |
Workforce and contracts | 2 | Reconciled CNSS slips, staff register |
Health and safety | 2 | Accident register, minutes of the health and safety committee |
Human rights at growers | 1 and 8 | Purchasing criteria, amendments, visits to growers |
Ethics and corruption | 4 | Code of ethics, gifts register, awareness sessions |
Product safety and complaints | 7 | IFS Food Version 8 system |
Two communication rules were respected. The SME mentioned its label in its answers without altering the assessor’s opinions or the committee’s views, as the award rules require. And it asked for the CGEM’s written authorisation before using the logo in its sales documents.
For the European buyers, the benefit was symmetrical: one consistent set of figures, each tied to a piece of evidence.
What lessons for other exporters?
The main one: an assessed CSR approach is worth more than three questionnaires filled in under pressure. A fish cannery in Agadir or a packaging maker in Tangier will find the same logic, with other risks.
The general framework is in our guide to the CGEM CSR label and ISO 26000, the method in our CGEM CSR label application checklist. If your European customer mainly asks for an environmental management system, read the ISO 14001 case study of an exporter with an EU customer. Requirements specific to the industry are on our food and beverage sector page.