Part IV - Truth

10 Transparency and Truth in Organic Certification

A question I am often asked when sharing my research on certified organic agriculture undertaken by smallholder farmers in northern India, goes along the following lines: “So, were these farmers really organic?”¹ For a long time, I was inclined to treat questions like this as peripheral to my research. They often puzzled and even troubled me, for the purpose of my work is not to assess and evaluate farmers but to better understand how the quality of becoming, and being, organic is assembled in the first place. Over time, the frequency with which such questions have been posed pushed me to pay more attention – instead of tuning them out, I reflected on why such a question could be ethnographically significant in its own right. As I have discussed elsewhere, a question like this needs to be located in histories of racialized suspicion and mistrust (see Galvin 2022). But to ask whether farmers are “really organic” also assumes that there is something that organic really is. And so, unraveling this question can help us understand how transparency projects like those associated with organic certification come to constitute truth regimes.

In what follows, I work to develop a different stance toward the question “Is it really organic?” by thinking more carefully about some of the assumptions and implications latent in it – particularly the assumption that organic has an objective and verifiable truth status. I aim to show not only how transparency works in certification, but what transparency does; I do this by exploring how transparency instruments and aspirations work as semiotic technologies (Hull 2003; 2008; 2012b) and practices that actively produce – rather than merely reveal – a quality called “organic.” In this regard, my work is inspired by research that attends to the importance of semiotic technologies and infrastructures in bureaucratic processes (Hull 2003; 2008; 2012b; Weichselbraun 2019). In his study of Pakistan’s Capital Development Authority, Hull (2003; 2008; 2012b) demonstrates the importance of what he terms graphic artifacts – files, lists, maps, stamps, and signatures, among other things – for understanding meaning-making and signification within bureaucratic and governmental processes. Hull’s effort to advance understandings of “governance as material practice” (2008: 501) is pushed further by Weichselbraun, who examines how the material semiotic characteristics of metal seals used by the International Atomic Energy Agency (IAEA) in Iran’s uranium conversion facilities function as “the semiotic infrastructure of nuclear governance that materializes international law and geopolitical relations between states through the IAEA’s supposedly neutral techno-epistemic devices and practices of interpretation” (Weichselbraun 2019: 505, emphasis in the original). For these scholars, conceptualizing particular material artifacts as semiotic technologies or infrastructures has yielded important insights around questions of agency and intentionality.

Building on this, I suggest that, in the case of organic certification, semiotic technologies that range from certification documents to tags affixed to sacks of rice bring organic quality into being as something endowed with a particular reality or truth. Pushing on what the editors of this volume characterize as the paradox of transparency – a process of mediation that presents itself as one of disintermediation – I argue that this process is a fundamentally productive and political one, in which institutionally anchored semiotic technologies are essential not simply for mediating between an object (say, organic quality) and an observing subject (in this case inspectors responsible for organic certification), but for producing the object itself.

Transparency Beyond Opacity

Transparency, understood as discourse (West and Sanders 2003) as well as a “political technology [and] form of intervention” (Ballestero 2012: 160), has been most closely associated with the late twentieth-century turn to voluntary regulation, accountability, and public management. Without question, transparency projects have profoundly shaped “political and legal landscapes” (Ballestero 2012: 160), but they are informed and legitimated by, and seek also to produce, ethical and normative ideas, practices, and dispositions. Transparency is promoted as an indispensable element of good governance, conveying “trust, openness, fairness” (West and Sanders 2003). In this regard, the rise and expansion of audit as an instrument of new public management in the late twentieth century is especially illustrative of the power of transparency as a global social and economic value; as Power observes, audits “promise external visibility of internal processes” (1996: 21).

Such notions of transparency resonate powerfully in India. Secrecy has long been enshrined in the practice of government and linked with the legacies of colonial power. In the late twentieth century, transparency impulses in India not only reflected global discourses, but also moved in step with domestic political reforms harboring democratizing and participatory objectives as well as with processes of economic liberalization. At this time, Mazzarella observes, transparency was “much beloved by the NGO business and other transnational growers of civil society, [as] the term ostensibly suggested public accountability in political processes” (2006: 489). Transparency has also been taken as an expression of a more enduring form of what Bornstein and Sharma call “technomoral politics,” the “complex, strategic integration of technical and moral vocabularies as political tactics” (2016: 77).

The ascendance of transparency as a technomoral value with global currency has necessarily drawn anthropological attention toward its tensions and contradictions, in particular with varying forms of concealment, secrecy, opacity, and ignorance (Mathews 2008). Comaroff and Comaroff historicize the contemporary fascination with transparency, placing it within the enduring relation of “the manifest and the inscrutable,” as an indelible facet of power (2003: 288). West and Sanders likewise posit that “ideas that power operates in hidden ways make necessary claims that it operates in the open” (2003: 12).

Yet the emphasis on transparency as affording (or not) a kind of technomanagerial visibility or legibility (Scott 1998) risks overlooking the particular kind of revelatory, purportedly truth-telling work that projects, such as audit, undertaken in the name of transparency do. Dunn writes:

[T]he self-representations contained in auditable documents are supposed to create “transparency.” That is, they purport to have a one-to-one correspondence with what actually goes on in a firm or an organization, thereby granting the auditors (and, by proxy, those who trust the auditors) the ability to look into the firm and see what actually happens there.

(Dunn 2007: 42, emphasis added)

The truth-telling powers ascribed to audit, and what the editors of this volume signal in their Introduction as disintermediation, have been taken up within public policy in the context of welfare delivery, democratization, and anti-corruption. A number of scholars have critically engaged with such processes, querying what the revelatory potentialities of audit and other transparency projects in fact produce. In India, the Rural Employment Guarantee Scheme (NREGA) built in considerable documentary infrastructure to ensure transparency and avert corruption, but ultimately led to “an enhanced focus on the production of what my informants described as the sarkari zindagi (state life) of NREGA, a life that, more often than not, does not readily map onto its asli zindagi (real life)” (Mathur 2016: 7). This distinction that transparency produces between the “state life” and “real life” of the state bears affinity with Hansen’s (2001) distinction between the profane and sublime dimensions of state power. For Mazzarella, the “game of revelation” in which the Indian state engages through its various transparency projects “reinstates the constitutive mystique of the state” (2006: 494). In the fields and offices of Uttarakhand’s organic program, the “game of revelation,” undertaken at various moments and through diverse practices of certification, is in fact crucial to producing organic quality as something real and true in the first place.

Transparently Organic?

Unlike the fertile Indo-Gangetic plain in which India’s Green Revolution took root, or the districts of southern and western India where horticulture and GM cotton have taken hold, Uttarakhand is a region that many people claim has always been organic. Bypassed by agrarian transformations that swept through other regions of the subcontinent – on account of a mountainous terrain, rain-fed agriculture, and sparse road and transport networks – for much of the nineteenth and twentieth centuries, Uttarakhand was rendered politically and economically peripheral (Berreman 1985; Mawdsley 1998; 1999). Yet, in 2003, shortly after Uttarakhand was hived off from the plains of Uttar Pradesh and created as a state, the new state government established the Uttarakhand Organic Commodity Board, the first commodity board of its kind in India focused on the development and promotion of organic agriculture.² In the years that followed, the Organic Commodity Board facilitated the development of contract farming between aspiring organic farmers and a major India rice retailer that would procure organic basmati rice from the Doon Valley, a fertile region surrounding the state capital of Dehradun.

My research in Uttarakhand explores the tensions of being “organic by default” and becoming “organic by design,” through, among other things, the adoption of certification schemes and contract farming in the twenty-first century (Galvin 2014). As I have described elsewhere, certification, paradoxically, often generates uncertainty and does not always succeed in enlisting farmers as faithful subjects of its audit and inspections regimes (Galvin 2018; 2021). In the Doon Valley, the kind of transparency and legibility that certification systems seek (and often claim) to achieve proved elusive as documents were invariably incomplete and on-site inspection interviews produced conflicting accounts of agricultural practices.

Organic certification often manifests as a commitment to transparency, requiring farmers, producers, and processors to make their work visible and legible through documentation, inspections, and sometimes also residue testing of their crops and land to check for the presence of prohibited inputs. Yet, as a characteristic or property of comestibles, organic does not manifest in any readily knowable way, in a material or physical sense. Organic, therefore, remains a quality largely intangible for everyone other than those who labor to produce it. Paradoxically, it is precisely this difficulty of discerning organic quality that impels the work of transparency, assembling a multitude of practices, documents, and sociotechnical objects to make visible something which cannot be readily seen, and to make more perceptible and traceable the production processes that bring organic, as a quality of comestibles, into being.

From Paper Work to Digital Transparency

Organic certification is accompanied by copious practices of documentation. Upon registering with the Organic Commodity Board, farmers are given a farmers’ diary in which they are to record virtually every facet of their agricultural activities. Through the Board, farmers were also assigned a “master trainer,” an extension worker who advised farmers on issues related to cultivation, certification, contract farming, and marketing and who completed booklets called “farm files.” These contained the same information as the farmers’ diaries and even more, documenting every plot of land cultivated by a farmer (most farmers would cultivate multiple plots of land) and such things as the history of cultivation, irrigation sources, and future cropping plans. The Board, moreover, employed a cadre of internal inspectors whose task was to review these documents and conduct inspections of every farm registered with the Board.

During the four years when I conducted most of my fieldwork, from 2005 to 2008, internal inspectors produced internal inspection reports and spreadsheets (called actual farmers’ lists) which were forwarded to a third-party certification agency. There, third-party inspectors reviewed documents in order to prepare formal risk assessments, an exercise that helped them identify subsets of farmers to follow up with for further inspection. For example, if internal inspections yielded questions and concerns about whether farmers maintained adequate buffer zones between conventional and organic plots, or about the source of their seeds, third-party inspectors would note these as “risky farmers” whom they needed to contact. Third-party inspections therefore focused on a narrower set of farmers who had been signaled in internal reports and spreadsheets as “riskier.”

Third-party inspections also produced further sets of documents, among them observation sheets, which recorded any issues or problems arising from the inspection, and finally led to the preparation of an inspection report. This report was then evaluated by a certification committee, which made recommendations for actions to be taken for subsequent years; the committee also conducted its own inspections of a subset of farmers registered with the Organic Commodity Board (especially those whose risk assessments had identified them as being at greater risk of noncompliance).

This system of linking internal control systems to third-party certification agencies through the manual preparation of documents changed in 2010 with the development of TraceNet, a web-based platform for managing the certification process which claims to be the “world’s first online system for organic traceability.” Promising to offer its users the ability to “track the trail” across an entire food supply chain and thereby to afford “transparency across the system,” TraceNet has digitized many aspects of the certification process. Since its introduction, the Board’s internal inspectors no longer forward their inspection reports and actual farmers’ lists to the third-party certification agency but instead enter details into TraceNet, which then algorithmically generates lists of farmers identified for further inspection by third-party certification inspectors. Third-party certification agencies similarly use TraceNet to enter data gathered from their review of documentation and field inspections. Scope certificates, issued to producers, and transaction certificates, issued to buyers and exporters, are issued via the TraceNet platform by these certification agencies.

The introduction of TraceNet was hailed by the Organic Commodity Board’s certification manager as an enhancement of transparency. “Now there is no bias,” he told me in 2016, as he described the changes TraceNet had brought about in carrying out the everyday work of certification. This sentiment intimates the kind of “fantasy of immediation, of frictionless social mechanisms” that Mazzarella (2006: 499) describes in relation to the rise of e-governance in India. It is a fantasy that appears to be especially associated with digitization, but Hull reminds us that documents, too, have been “overlooked because it is easy to see them as simply giving immediate access to what they document” (2012a: 253). The rise of digital platforms and technologies such as TraceNet similarly seem to afford such access, bestowing transparency with a seemingly frictionless form. A promotional video for TraceNet, produced by the Delhi-based software company that developed it, lauds its “in-built checks and balances [that] enable instant reference of previous steps in the supply chain … GPS system to trace farmers … real time information of producers, processors, traders, and their trading activities, anytime, anywhere, 365 by 24 by 7.”³ In appearing to make the fantasy of immediation a reality, TraceNet also obscures the ways in which it has itself become a crucial mediator of the certification process. While seemingly providing a transparent and “frictionless” platform for recording and generating information about certification, it centralizes the collection of data from inspection reports at the national level by the Agricultural and Processed Food Products Export Development Authority within the Ministry of Commerce.

Tag and Trace

As the introduction of TraceNet exemplifies, traceability is taken to be integral to the kind of transparency sought in many supply chains, including one that organic certification processes also seek to establish. Because organic is not a quality inherent in any product, but one that is conferred on basmati through the land on and practices through which it was cultivated, along with the methods of storing, transporting, and processing it after harvest, it is necessary to trace or follow the products of the land as they are harvested, stored, transported, processed, and packaged. In the Doon Valley, the procurement of basmati by a large Indian rice retailer which I refer to as Hira Foods, the company with which farmers had formed a contract arrangement, marked an important moment when grains of rice themselves were made traceable. Procurement occurred, shortly after basmati was harvested, when farmers brought their unmilled basmati paddy to a collection point to be evaluated by quality and technical inspectors from Hira Foods. At this stage, quality inspectors were evaluating unmilled basmati not primarily for its compliance with organic standards (this had happened during certification inspections), but instead in relation to government of India standards for export-quality basmati rice. At this stage, transparency efforts were directed less at making visible the organic or agricultural practices of farmers; instead, since rice was collected from hundreds of farmers across the valley, the tagging of bags ensured that it would be possible to trace an individual grain back to the sack and farm from which it originated. As bags of paddy were unloaded and weighed by daily laborers, Hira Foods’ technical adviser, Dr. Sharma, kept detailed records in a document called “Procurement of Organic Basmati, Kharīf 2007.” These details included the variety, the stage of conversion and/or organic status, the precise weight of each bag, the total number of bags brought by the farmer, and the total price per quintal.

While the bags were sewn closed, Dr. Sharma filled out tags to be affixed to each sack. The tags included information on the administrative block, the date, the farmer’s name and a unique code number, the variety of rice, the year of organic conversion, the number of bags brought by the farmer, the total weight, and the pre-agreed price named in the contract (and dependent on the stage of conversion). In addition to these written details, the tags were also color coded, with different colors indexing different stages of conversion (zero, first, and second year, and fully organic). Dr. Sharma explained to me that the color coding was intended to ensure that illiterate laborers who handled the paddy as it was transported and processed at the rice mill would be able to separate paddy at different stages of organic conversion. As material semiotic objects, these tags, through the detailed information they relayed through both their form (color) and the written script, brought the paddy into a larger regime of traceability. They ensured that appropriate measures could be taken to separate paddy at different stages of conversion and certification, and made it possible to know, even as rice was aggregated and processed in batches at the rice mill, from which farmer, and which place, the paddy originated.

The tagging of bags, and the tags themselves, not only distinguished organic from conventional rice, but also indexed distinctions within the category of organic according to the stage of conversion. Marking distinctions in this way mattered, because the stage of conversion could determine in which international markets basmati might be sold as organic. In particular, basmati rice that had been certified organic for a period of two years (marked as second year on the tags) could be sold as certified organic in Indian domestic as well as European markets, but not in the US, which required producers to undergo a three-year conversion period before their products could be certified organic according to United States Department of Agriculture organic standards. Tags attached to sacks of unmilled basmati paddy served crucially as what Latour has called immutable mobiles – material and semiotic objects that produce transformations as they travel, without being themselves transformed (Latour 1987; 2005; see also Dun 2005). These tags are intended to reflect, and to inscribe, on mobile and mutable grains, an organic status acquired through place and methods of production and to render these grains traceable as they move through the supply chain. Linking national and international standards regimes with sacks of rice, these innocuous objects do crucial semiotic work – making organic something that is materially meaningful and discernible.

Organic Truths

The revelatory work that transparency projects claim to do connects them with practices of truth-telling and, more potently, of truth-making. In this regard, transparency projects such as organic certification might be seen to be emblematic of what Foucault described as “the will to truth” (1980). Truth, he writes, is a “thing of this world … Each society has its regime of truth, its ‘general politics’ of truth” (1980: 131–132).

Truth regimes, indeed, operate in a range of ways that themselves shift over time in step with transparency’s shifting forms. For example, as asylum claims in Europe are made subject to ever greater scrutiny, Fassin and D’Halluin (2005) recount how, in France, medical certificates documenting evidence of torture through physical bodily harm and injury are increasingly necessary forms of evidence. While in the past the truth of asylum claims was adjudicated on the basis of asylum seekers’ testimony, these authors describe how in recent decades it has been increasingly mediated through medical expertise and the production of medical certificates that authorize such truths. These authors argue that, “whether it reproduces the account or attests to the consequences, the scriptural trace envelopes the fragile words and invisible wounds of the asylum seeker in its legitimacy … In the context of generalized skepticism, the written testimony is the highest form of truth-telling” (Fassin and D’Halluin 2005: 606). Similar kinds of processes are evident in other settings: for example, criminal trials, where DNA samples are seen to work as a “truth machine.” Lynch observes that, within the space of a few years:

[The] statistical procedures and correction factors, which had seemed so obscure when compared with the tidy declarations of fingerprint examiners, now stood as emblems of transparency, only now transparency did not mean intuitively apparent; instead it referred to calculations of probative value that were logically traceable through formulae accepted by experts.

(Lynch 2008: 65)

Organic agriculture and its certification may be a far cry from such settings, but parallels nonetheless exist insofar as documents and now the forensic testing of grains for prohibited residues are regarded as indispensable “proof” of organic status. This revelatory power of transparency and the insertion of transparency instruments in proliferating regimes of truth built around audit and other forms of inspection and surveillance are what sustain and explain transparency’s power as a value and a form of action. This chapter began by reflecting on a question that often arises in relation to products that are marked as certified organic: “Is it really organic?” Revealing of the ways in which racialized suspicion mingles with the normative and ideological power of transparency, it is a question that in fact urges us to query how it is that certification produces organic (or anything else) as a truth in the first place.

11 Discreet Transparency Dealing in Plural Veridictions in Swiss Gold Refineries

In 2015, a coalition of 114 Swiss organizations including NGOs, trade unions, political parties, churches, and business associations launched a federal popular initiative to amend the Swiss constitution by adding a new article (Article 101a) on corporate accountability. The text, which was finally rejected in November 2020 by the majority of Swiss cantons despite being accepted by 50.7 percent of voters,¹ established that Swiss companies and those they control outside the country would be required to respect human rights and international environmental standards. The innovation of this text was that it introduces civil liability for the parent company in case of violation of these standards by the companies it controls elsewhere in the world. Between the launch of the initiative and the popular vote, the coalition embarked on a long campaign to raise awareness about the deleterious impacts abroad of several large companies based in Switzerland. The coalition’s strategy was multifaceted, but one of its most visible aspects was an intensive and systematic examination of the procurement practices of certain companies active in the “riskiest sectors” – namely, the extraction, processing, and trading of raw materials. During the campaign, several organizations, mostly new to this type of “guerrilla auditing” (Hetherington 2011), published numerous reports pointing to acts of “misconduct” (human rights abuses, environmental damage, corruption, money laundering, tax evasion) and, by the same token, to the inability of the Swiss legal framework to prevent the harmful impacts abroad of companies established in its jurisdiction.

Among the various sectors considered to be “at risk,” the gold-refining industry quickly came under the spotlight of the coalition, and by extension the media. Although the refiners cultivate a certain discretion, it is estimated that 70 percent of the world’s mined gold transits through this industry (WWF 2021: 20), which has a strong presence in Switzerland due to its historical links with the banking, watchmaking, and jewelry sectors. Because of its fungible nature, once the material has been aggregated, melted down, and refined according to international standards, the different origins of the gold disappear mechanically. Echoing the classic issue of commodity fetishism, the social life of gold and the traces of its potentially contentious past prior to refining are literally erased in favor of a standardized and commensurable licit product that can be bought and sold in licit international markets.

As a response to growing concerns among consumers about the possibly harmful origins of gold (e.g., Bloomfield 2018), the refining industry adopted responsible sourcing standards deemed to guarantee compliance with international norms of sustainability and human rights, yet without disclosing the provenance of the metal. In this chapter I examine the industry struggles and the legal processes through which the “responsible sourcing” claims of refining companies are established, made visible, and verified. I suggest that that Swiss refineries operate under a register of discreet transparency, through which this industry aligns with the contemporary trope of transparency while preserving discretion as a core business value. Refiners’ practices, I suggest, are both discreet in their efforts to preserve secrecy in their business operations, and discrete in the legal processes through which they separate normative orders to establish different veridictions on the “true” provenance and ownership of gold. The chapter suggests that the various legal entanglements of gold and transparency establish specific “veridictions” (Latour 2004: 298), or different ways of defining what is true or false by textually linking and dissociating facts, persons, and objects in the construct of a situation. Based on the premise that corporate disclosure does not necessarily reveal undisclosed truths but rather produces new truths, I further argue that such work of legal entangling mediates the “responsible” status of gold as a veridiction project essentially aiming at establishing new truths.

I draw on ethnographic fieldwork in Switzerland and London with political activists, policymakers, and gold-refining industry actors within their respective epistemic communities and events, as well as on longstanding research among gold producers and traders in West Africa.² The chapter interrogates how growing expectations of transparency about the provenance of gold – largely at odds with the technical process of purification and the norms of business secrecy – are negotiated by gold-refining industry actors, coalition activists, and the Swiss government. I start with a brief genealogy of the “public secret” (Taussig 1999) about the provenance of gold refined in Switzerland – that is, the shared but hardly articulable knowledge (Taussig 1999: 5–6) that gold from ethically contentious sources transits through Switzerland. By sketching the controversies surrounding the elusive notion of provenance as applied to a fungible, and potentially indefinitely recycled, substance, I propose an examination of three competing approaches to corporate responsibility. For each, I pay attention to the different roles, conceptualizations, and legal entanglements of transparency and secrecy, broadly understood as the disclosure and access – or the lack of them – of singular elements mobilized to claim so-called responsible business relationships.

Responsible Gold: The Legal Entanglements of Transparency

Guarantees of ethical responsibility for gold refined into bullion and semifinished products are based on industry self-regulation through compliance with the standards of the London Bullion Market Association (LBMA), the umbrella organization of refiners that issues accreditations for over-the-counter trade. In addition to technical and financial criteria such as a minimum refining volume capacity or compliance with the standard to reach at least 99.5 percent purity of gold, LBMA-accredited refiners have been required since 2011 to comply with the Responsible Sourcing Programme (RSP). This standard embodies the principles set out in the Due Diligence Guidance for Responsible Supply Chains of Minerals from the Organisation for Economic Co-operation and Development (OECD 2016).³ Refiners are expected to prove their capacity to have a transparent view of the “upstream” supply chain through a cascading system of due diligence self-reporting across the chain, allowing them to assess the social, environmental, and commercial practices of their suppliers. The notion of transparency is thus not only at the forefront of the LBMA’s framework objectives – “ensuring integrity and transparency for the gold market.” It is also in the implementation guide of its responsible standard, which is deemed to establish a “robust system of vigilance, control and transparency of the supply chains” (LBMA 2019: 7), yet without this calling into question the confidentiality of refiners’ business relationships. The paradoxical promise of an assessment of the degree of “responsibility” of suppliers, yet invisible to the public, practically questions how unstable boundaries of secrecy and transparency are constituted and respectively valued in the trade and the import of natural commodities, including gold, in Switzerland.

In the context of the federal initiative campaign, the focus on gold refining by different members of the coalition was arguably strategic, since this market is regularly characterized as particularly “opaque” (Mariani 2012; Pieth 2019). It acted as a mirror to a certain national imaginary in which both watchmaking and banking – the main gold-consuming sectors – represent flagships of the Swiss economy, associated with values of precision and discretion respectively. As I was told by members of one advocacy group, by focusing on the main refineries, the coalition’s limited resources could be judiciously allocated within a defined perimeter. The aim was to illustrate, synecdochically, the broader issue of accountability for wrongs in globalized supply chains, and the closely related issue of disclosure regimes that do or do not identify and attribute accountability. In particular, the judicial component of the initiative was considered the main shift toward a possible transformation of the accountability regime, adding the possibility of sanctions to the self-regulation model. Indeed, the violations that the coalition and its allies had made visible (see, e.g., EPER 2016; Global Witness 2020; STP 2018; TRIAL 2016; Ummel 2020) had had little effect so far other than to lead the targeted companies to either deny these allegations once they were made public, or to blame the suppliers under the pretext that reasonable due diligence had been carried out in accordance with industry standards. Following Pistor (2019: 6), the rhetoric at work thus oscillates between “but it’s not our responsibility” and “it is our responsibility, but it’s legal.”

In other words, mandatory due diligence, or “the production of narratives that make visible certain actors, relationships and processes of the past” (Hansen and Flyverbom 2015: 878), as already imposed by the codes of conduct of most companies, relies on a largely circular mode of verifiability as it is based on self-narration. Provocatively challenging the dominant paradigm of self-regulation and corporate social responsibility (CSR), the coalition’s main question was quite simple: How can the misbehavior of certain companies be mitigated if it is assumed that only the same companies whose business practices might be objectionable are able to identify these failures? From this perspective, corporate claims of responsibility cannot be credible through the transparency apparatus of due diligence and CSR reporting alone, which are essentially “second-order descriptions” (Strathern 2000: 312) of the company by the company itself, then verified by audit firms paid by the same company. Against this circular system of verification of transparency claims, the members of the coalition insisted that only by disclosing the sources of the raw materials they trade, process, and transform would companies be able to make their claims potentially verifiable and credible.

According to the text of the proposed constitutional article, corporate accountability should therefore be dissociated from the scope of corporate codes of conduct only in order to be re-embedded into the broader framework of public transparency of the country that ultimately makes companies’ operations not only possible but lawful. This proposition illustrates in its own way the shift in claims of industrial irresponsibility described by Julia Eckert (2021: 407), “from local officials to transnational facilitators.” The attribution of responsibility for possible wrongs to different entities – operator, parent company, host state – and through different jurisdictions thus necessarily involves a plurality of legal orders, whose embeddings, by textually linking facts, persons, and things, give rise to what might be described after Latour as different types of “veridiction” (2004: 298).

This suggests paying attention to the “discursive entanglement, [or] the universe of statements that connect different bodies of norms to each other” (Krisch 2021: 6). I thus consider law – in various forms, including the “soft” (or non-binding) law of voluntary codes of conduct – as acting as a mediator in Latour’s formulation. Indeed, Latour sees law as a “mode of enunciation” (2004: 298), whereby what is considered true or false in a situation is legally defined in a way that is neither strictly scientific, nor technical, nor political, but rather depends on the dominant criteria used to define a certain object in a certain situation. In the processing and trading of gold, shifting veridictions notably manifest in its material transformations, and in the displacement of the limits of transparency (and secrecy) regarding its provenance.

The Plural Modes of the Existence of Gold

The unstable materiality of resources extracted and circulated on a global scale informs their inscription in different ontologies (Richardson and Wetzkalnys 2014), or in different modes of existence carrying their own registers of veridiction (Latour 2004; 2012). By way of examples that I document elsewhere (Bolay 2021; 2022), artisanal gold mining in Guinea requires the approval of ancestors’ spirits to be separated from the earth. Once smuggled to Mali, smelted and exported by officially registered comptoirs in Bamako, the gold acquires a status of good and a Malian geographic provenance. The same gold, when aggregated from other sources, most often in Dubai, and possibly smelted and made into jewelry, will no longer be “mined gold” but “recycled gold.” Qualified by its presumed use rather than by its mode of circulation, it ends up legally free of any mining origin. Once remelted and refined into ingots to industry standards, it is considered by Swiss customs as a monetary item and not as a commodity. As a medium of exchange rather than an object of exchange, it is legally exempt from import taxes and declaration of origin. Thus, new social and normative inscriptions are conflated in the successive episodes of gold’s transformation through the processes of smelting and purification of the substance from both its physicochemical and its social impurities.

With gold, the translations of a mined substance into an accredited product, tradeable on the main markets, are reminiscent of what Weeks (2020) calls “off-shore ontologies.” Those are dematerialized, detached from anchorage, rely on simulation, and are, by the same token, flexible in their personification – gold being possibly considered as natural substance, as raw ore, as currency, as financial product, as jewel, or, more recently, as digital token. Such personifications act as ontological truths once their “mode of existence” is inscribed (by Guinean earth priests, for instance, by Malian-registered buying houses, by the LBMA’s RSP, by Swiss customs, or by the Swiss Financial Market Supervisory Authority) in a register of veridiction, “far from epistemological definitions of true and false, but deserving of the qualifiers true and false” (Latour 2012: 66).

As the form of gold changes, so does its legal status, whether it is semi-purified gold from mines, also known as doré, jewelry, industry scrap, or refined bullion. In this respect, gold refineries have played a key role in maintaining the public secret about the potentially contentious origins of gold by “knowing precisely what not to know,” to use Taussig’s formulation (1999: 5–6). The roots of this industrial policy of strategic ignorance, reminiscent of other regulatory bureaucracies,⁴ lie in the ambiguous status of gold as both money and commodity. Indeed, until the beginning of the twentieth century, gold refining was not yet an industry in its own right, but rather a sub-branch of the banking sector. The refining industry was institutionalized by the demand of central banks to calibrate the value of gold against chemical purity standards in order to serve as a benchmark for the issuance of paper money (Schenk 2013: 19). The artisan works of smelting, purifying, and hallmarking gradually merged into a single entity – the gold refinery – which delivered to the banks standardized and certified bars in terms of weight, shape, and purity. In this process, the refineries became the mediators of political considerations regarding the establishment of central banks and, later, of commercial banks and finance, with the transformation of a natural substance into an object of univocal interpretation, a standardized financial artifact, cleansed of its previous modes of existence.

Thus, through chemical purification to at least 99.95 percent, as defined by the LBMA Good Delivery Standard, gold is also purified of traces of its past. As Field (2019: 176) reminds us, gold’s role in Western histories of money was accompanied by the erasure of other histories and ontologies of gold during colonialism. The golden adornments systematically stolen during European conquests were melted down in order to be reused as “money-commodity,” in Marx’s phrasing (1976 [1867]: 188). It is precisely this ambiguous status as a monetary asset and a fungible material that has contributed to making gold a specificity of the Western economy, in which it has historically played the role of a more durable and malleable fetish than paper money for transporting value while hiding the conditions of wealth extraction attached to a specific “origin.”

Through its strategy of guerrilla auditing, the coalition intended to “unveil” what can be considered one of the public secrets of Swiss history. In this sense, it was an extension of previous episodes of unveiling which had made public certain contentious modes of existence of gold before its requalification in the refineries. These include the role of Swiss banks in the refining and requalification of gold stolen by the Nazis during World War II (Ziegler 1997), the way Swiss neutrality was used to circumvent the UN embargo on apartheid South Africa to turn illegitimate South African gold into legitimate Swiss gold (Bott et al. 2005), and, more recently, gold’s central role in various money-laundering schemes (Pieth 2019). Pressured by the political context of the upcoming vote and growing publicity about the role of refineries in processing gold from “illegitimate” sources,⁵ the Swiss government commissioned an expert study of the gold sector and the associated risks of human rights abuses. The report unambiguously concluded that there is a compelling need “to increase transparency regarding the provenance of gold, [as] it is difficult [for the Swiss government] to decide on any policy measures without having access to primary sources of information” (Tratschin et al. 2017: 107). Against this backdrop, three types of veridiction define distinct configurations of visibility and responsibility with reference to the situation of importing gold. Rather than opposing notions of transparency and secrecy through clear-cut boundaries, as often assumed at least since Simmel’s work on secrecy (1906), these veridictions instead seek to assemble the values associated with both terms. These veridictions result in being both discretely and discreetly transparent – that is, separated from legal responsibilities and accessible in loosely intelligible terms only to those actively seeking visibility.

Veridiction 1: Monetary Gold and Institutional Discretion

The Swiss government’s recognition of its own regulatory impotence is certainly ironic. In Switzerland, opacity regarding the provenance of gold has been institutionalized since the beginning of the twentieth century. By then, the legal frameworks to regulate its circulation and trade were established by adapting the rules of the banking sector – then configured around the principle of banking secrecy – rather than those of customs regulations on the import and export of goods. Still today, the Swiss government considers that “the circulation of precious metals [is] more closely linked to payment transfers as a substitute for paper money than to the circulation of goods to be processed or used” (Swiss Confederation 2013: 5).

Gold thus exists physically as a substance to be mined, transported, and processed through technical and financial logistics, partly concentrated in Switzerland. However, its legal existence is that of an immaterial “liquidity” in circulation. As the former CEO of one of the leading refineries stated in the local economic press, “We are regulated by the Swiss Financial Market Supervisory Authority and we are considered a bank.”⁶ In this legal logic, the risks identified are those of money laundering, meaning those that may occur after the gold has been refined into bullion or once it is used as “currency,” rather than those that may occur beforehand in the trade of illicit goods. As a result, the Swiss government admits that it leaves the monitoring of money-laundering risks to the indirect control of the banks that finance the commodity sector under the Money Laundering Act. This illustrates a “legal circularity” (Couture 2014) whereby one thing – here a natural commodity – is turned into another – a monetary asset – in a self-fulfilling and legally incontestable logic. By textually linking gold to a monetary mode of existence instead of a commodity mode of existence, such veridiction articulates the field of transparency outside of the circulation and material transformation of gold.

One of the main reasons for this is that Swiss refineries established their dominant position through their integration into the banking sector during the interwar period. Whereas in the early days of the industry in eighteenth-century London, refineries had to be accredited by the Bank of England in order to trade their bullion (Green and Murray 2011), Switzerland took this integration a step further by completely recharacterizing the commodity as money. Indeed, the boundary that separated the banking and refining sectors temporarily disappeared as the three main refineries were owned by the three major Swiss banks until the early 2000s. The fourth major refiner entered this market later as a subsidiary of a commodity-trading firm, thereby making the reverse journey from gold as a commodity to be sold on spot markets and bullion exchanges to gold as money used as forward and financial swaps and as liquid and convertible currency.

This later, industrial trajectory illustrates another key aspect of the Swiss business environment. In addition to the banking sector, Switzerland has become a major hub for commodity trade, which has led some authors to speak of “Swiss extractivism” to highlight its central role in the “servicification” of global value chains (Dobler and Kesselring 2019). As these authors point out, Switzerland competitively provides all the necessary infrastructure for global commodity trade: “Fast and secure access to finance and insurance, excellent virtual and physical global connections, a dynamic freight industry, trader-friendly regulations, proximity to international standard-setting bodies and the plethora of international lobbying groups in Geneva” (Dobler and Kesselring 2019: 229). As with banks, Switzerland’s reputation for business discretion is also mentioned as a comparative advantage of its business environment model for commodity trading.

The ramifications of gold refining in the banking and trading industries – the two main sectors contributing to Swiss GDP (Lannen et al. 2016) – help explain Switzerland’s central position as a gold-refining hub, as well as the political cultivation of “discretion” in its business environment. Discretion has been institutionalized by bank secrecy laws since the 1930s; these laws offer a mirror to the public secret of gold provenance. As Genier (2014) explains, the legal entanglements underlying bank secrecy created exceptions that cannot be easily dismantled. This is the case because of the laws themselves, such as the 1934 Banking Act, which made the disclosure of Swiss bank clients a criminal offense. But more insidiously, a plethora of informal rules recommend that industry remains discreet about these very practices of discretion: for example, a note circulated by the Swiss banking association in 1962 urged its “members to avoid any promotion or publicity concerning the tax advantages offered by our country, or the qualities of banking secrecy” (Perrenoud 2003: 39).

Discretion is now often portrayed as part of “Swiss culture.” Even the national tourist office promotes this narrative on its website, stating that “discretion is part of the Swiss character.” In Swiss embassies, the promotional book Swiss Made: The Untold Story Behind Switzerland’s Success (Breiding 2012) also describes the country as “the ultimate in discretion.” Essentializing and turning discretion into a national marketing device is a continuation of political calculations from the beginning of the twentieth century to “position banking in an international environment as safe and discreet” (Swiss Federal Council 1934; cited by Leins 2018: 36). Beyond the banking sector, Swiss companies overall have “considerable discretion in reporting and the level of mandatory disclosure is low,” according to Hail (2002: 742). To paraphrase Taussig, what these legal entanglements may veil – namely, the potentially contentious origin of material gold or of financial flows (it does not matter which, since the two are treated interchangeably) – is “known but difficult to articulate” (Taussig 1999: 6).

This was frequently experienced by my interlocutors from the coalition when they were confronted with rejections of their requests for information on potentially illegitimate gold in the flows of certain refineries. These refusals were justified by the fact that – like banks in terms of the assets they hold – refiners do not always own the gold they process, and therefore do not consider themselves to be in a “supply” relationship but in a “customer” relationship with their sources. The central role of trade secrecy in gold procurement was made very clear at a meeting organized by the Secretariat for Economic Affairs to which refiners, NGOs, accreditation bodies, lawyers, and scientists like myself were invited. In response to the call by one of the coalition members for greater transparency in procurement, a refinery representative stated vehemently: “What you want is to simply destroy our industry. If we disclose our customers [i.e., our sources of supply], others will be quick to attack our market. You don’t ask insurance companies or doctors to reveal who their customers are. It’s the same with us!” Certainly, none of the members present in this meeting would think that a shipment of gold, a health insurance contract, or a relationship with a patient were ontologically “the same” – especially in the context of a policy meeting on responsible sourcing. However, even though several organizations were able to trace the path of illicit gold in Switzerland, its entanglement through contract law, customs categories, trade secrecy rules, and banking regulations underpins a mode of veridiction in which this equivalence is true. The legal entanglements on which the mode of existence of monetary gold is based make it impossible to formally link a refined product, which nevertheless satisfies the LBMA’s criteria of responsibility, to its provenance. Even when this link is known, as in the various reports published during the campaign, it cannot be legally articulated as such in this mode of veridiction.

Veridiction 2: Livelihood Gold and the Utopia of a Discrete Industrial Panopticon

In the face of mounting public pressure, neither refiners nor the Swiss government have remained impassive. Aligning with the trend toward supply chain governance through CSR and the ethical auditing regime, the Swiss government has been promoting a responsible sourcing program for gold from artisanal and small-scale mines since 2013. CSR commitments within the industry already existed, as well as Fairtrade-certified channels such as Max Havelaar’s Fairtrade gold and the Association for Responsible Mining’s Fairmined gold. However, the Swiss Better Gold Initiative for artisanal and small-scale mining is unique in that it is nationally coordinated at the industry level by the Swiss Better Gold Association, an ad hoc grouping of banks, jewelers, watchmakers, and the four major refineries. And, most importantly, it was publicly funded to the tune of CHF 8 million over four years, with a further CHF 6 million for an additional four years in 2021 (SECO 2021). The stated aim of the program is to increase transparency, accountability, and profitability in the gold value chain. It targets small-scale operations, especially those using artisanal methods, which are “high risk” according to OECD guidance and constitute 20 percent of global mining production.

Initially, the program was conceived as a support to small producers wishing to move toward fair trade certification, and introduced a premium on the market price in exchange for a monopoly on the certified mines. In order to meet the high requirements of traceability and the segregation of flows imposed by Fairmined or Fairtrade certifying bodies, the approach developed essentially consists of formalizing small producers and integrating them into a fully controlled supply chain. As with industrial mines, the main objective is to reduce the number of commercial intermediaries in order to reduce costs, and by the same token facilitate the work of traceability. Locally, however, initiatives of this type are not without ambiguity with regard to the exclusion mechanisms they inevitably establish (see, e.g., Fisher 2018), or even the new forms of control and dependence that the Fairtrade regime may imply (Besky 2013). From this point of view, Fairtrade certification manifests the opposite of the regime of discretion outlined above by seeking to realize the utopia of an integral top-down, panoptic view of a separate segment of the supply chain.

This is what its promoters emphasize. The secretary general of the association insists, for instance, on the technical challenges that the traceability of artisanal gold represents in the face of the permanent danger of “contamination” by other sources of gold. At the same time, such concerns largely evade the unspoken issue regarding the expansion of the few pilot projects to a larger scale. In our discussions, the partners who implement the program regularly mentioned the difficulty of recruiting new miners, who are hampered by the administrative and technical-legal burden of compliance, as well as by their reduced leeway within the informal sector. As a result, the few certified mines, located exclusively in South America, supply less than 1 percent of the total amount of mined gold imported into Switzerland from that region, and much less when compared to global gold imports from all sources. In commercial terms, the program is therefore marginal, to say the least, on a national scale and negligible on an international one. On the other hand, the initiative does not lack visibility at industry conventions, multi-stakeholder conferences, and other public events, where it illustrates the efforts of Swiss refiners to support the livelihoods of small-scale miners in the Global South. It thus paradigmatically illustrates common strategies in the “audit society” to decouple normative goals from operational ones (Power 1999), between discretionary CSR ethics of philanthropy for reputational purposes and the maintenance of core business operations.

While the decoupling of ethics and business in the CSR movement is frequently questioned as a mechanism for preserving the status quo, it nevertheless informs the separate social and material inscriptions of gold in plural normative frameworks. Strategic decoupling extends materially and legally, one might say, toward the establishment of an alternative mode of veridiction. While monetary gold is associated with an indefinitely fungible and provenance-free liquidity, certified “fair” gold is staged as a material good indexed to a supposedly inalienable local provenance. By preserving such gold from any “contaminating” interaction with other sources, fair trade certification establishes with the consumer the fiction of a relationship with the lives and livelihoods of the people who live and work in mining areas. Such gold is physically identical in every respect to gold that is not certified by the program. However, the gold differs by the content of the voluntary compliance and auditing standards to which it is subject, and by the extension of these standards along the supply chain to make its interpretation unambiguous. The program guards against the anxieties of “social pollution” (Douglas 2000 [1966]) that the artisanal sector represents due to its association with illegality, irrationality, and environmental irresponsibility in government and NGO discourses (Childs 2014). It does so by establishing a decoupled mode of veridiction articulated around the utopia of a dis-intermediated relationship between producers and consumers, which, paradoxically, multiplies the intermediaries – not in the production chain in this case, but in the verification chain.

Veridiction 3: Offshore Gold and Civic Rights to Information

One of the obstacles the coalition members encountered in their attempts to expose illegitimate commercial practices related to the administrative categories under which gold is registered with Swiss customs. While a commodity such as cocoa can be registered with Swiss customs under forty-five different categories depending on its form, use, and qualities, gold has only three subcategories: jewelry, raw (mined) gold, and recycled gold (already processed and refined). As customs bureaucrats unambiguously explained, as gold is considered a currency rather than a commodity, raw and recycled gold are treated indistinguishably as nontaxable assets. Due to the absence of tax requirements, customs officials do not need to distinguish whether the provenance is that of the last importer or the place of extraction. Once qualified by customs and tax regulations, this de facto conflation of terms renders the released data unreadable and useless for identifying jurisdictions of origin that might be considered more or less “at risk.” The recent accessibility of customs statistics on gold, which were kept secret until 2014,⁷ only performs the ideal of government transparency. As Birchall (2011: 14) argues, “the release of incomprehensible data” in turn helps to “keep certain practices opaque.” In contexts where quantification is purposely unintelligible to outsiders – for example, in the global culture of finance studied by Maurer (2005) – the evaluation of offshore risks is subject to the ethical judgment of peers and the public, provided that situations can be contextualized in a “community of regard” (Maurer 2005: 476). This is what the coalition intended to do.

Some coalition members had indeed managed to circumvent the unintelligibility of Swiss customs’ data by accessing detailed trade statistics directly from producing and transiting countries. The presence among the main exporters of jurisdictions known to be hubs for both trade and money laundering, such as the Dubai Multi Commodities Centre (DMCC) free zone in the United Arab Emirates, regularly aroused suspicion. In the name of companies’ own claims to being responsible businesses, Jürg, one of the coalition’s activists, took the initiative to write to the main Swiss refineries to ask them to clarify their commercial relations with Dubai. In his letter, he asked them, on behalf of his organization, to confirm that they were receiving gold from Dubai, to disclose the quantities and names of their Emirati suppliers, and to illustrate the due diligence measures taken to ensure that no gold from “high-risk or conflict-affected areas” – in line with the OECD wording – was traded in Dubai. He justified his request by pointing out that, in the previous year, import statistics showed that over 160 tons of gold had been imported into Switzerland from Dubai.

The responses he received followed a similar script. Each of the companies listed their commitments to “responsible sourcing,” starting with their compliance program to meet the LBMA requirements – the first type of veridiction. In addition, they referred to their own codes of conduct and CSR programs in which they were engaged, including the Swiss Better Gold Initiative – the second type of veridiction. Finally, the replies consistently concluded that it was in any case legally not possible to disclose quantities or names of business partners for “obvious” reasons of confidentiality, thus referring to the protection of trade secrets.

Faced with this response, Jürg repeated the same undertaking, but this time he wrote as a Swiss citizen to the customs administration in the name of the federal law on the principle of transparency in administration. The subject of the request – Excel tables showing all gold purchases by each refinery between 2014 and 2018 – resulted, to his surprise, in a positive response from the customs administration under the application of the transparency law. As with most freedom of information laws in other jurisdictions, citizens in principle have a civic and political right to access “information that the state collects and holds on [their] behalf” (Calland and Bentley 2013: 71). The unexpected trajectory of Jürg’s request thus suggests the possibility of a third mode of veridiction operating through the detachment of transparency claims to a specific product in favor of their attachment to a civic right. The dissociation of gold from its modes of existence as either a currency or a commodity also disentangles it from a producer–consumer relationship and from the main normative frameworks – industry norms and private contract law – that regulate such a relationship. Instead, it inscribes imported gold as a mere piece of information detained by the state on behalf of the sovereign, thereby enabling a reconfiguration of what ought to be made visible, by whom, and to whom.

Yet, the decision to disclose detailed trade data was immediately objected in an appeal brought to the highest court by the four main refineries acting together through the same law firm. The appeal brought before the Swiss Federal Court sought to challenge the entanglement of Jürg’s claim with the protection of citizens’ rights to information, by re-entangling it instead with the rights of companies to protect their business secrets. As summarized in the appeal, the name of the clients and the imported quantities are to be considered “business secrets, i.e. strategic economic data of great importance to four of the most important players in the economic sector concerned.”

In law, for information to be considered a business secret worthy of legal protection, it must meet a series of conditions, including an “objectively founded interest in keeping the information secret” (Article 162 of the Swiss Criminal Code), meaning that the information itself has commercial value in that it provides a comparative advantage over competitors. Yet, as Levine (2011: 414) rightly points out, “the definition of commercial value as a prerequisite for trade secret protection has expanded dramatically over the past 75 years, with the result that more and more information falls under the protection of the trade secret doctrine.” This expansion, which often strategically plays out in offshore outsourcing, together with the increasingly blurred boundaries between private and public entities in government, recreates barriers of access to information supposedly made accessible through freedom of information laws.

To several interlocutors, the question of whether details of provenance and quantities had any commercial value was questionable.⁸ However, not having to disclose such information – concomitant of the ideal of Swiss discretion – was perceived as having value in itself. Thus, while claiming transparency as a core value of the industry, as in the two earlier veridictions, companies simultaneously sought to preserve secrecy in the third. What activists and a large share of the public might consider ethically and practically irreconcilable truths could therefore apparently cohabitate coherently, through strategically operating legal “cuts” (Strathern 1996) in the network of facts, persons, and things that define the situation.

One major element that enables such cuts lies in the ambiguities surrounding the notion of ownership. Ownership suggests responsibility toward the thing or situation owned, and for demands for accountability such as those made by the coalition. One recurring argument that surfaced again in the appeal was that refineries supposedly did not own the gold they processed: So why should they be responsible for it? Shifting definitions of ownership appeared clearly in the presentation of the facts provided to the high court by the refineries’ consortium.

As argued in the appeal, if gold is considered a commodity “shipped from overseas by exporters,” then the refineries in turn affirmed that they do not own the gold. They are merely providing a service to a “customer” – the true owner of the gold – and therefore are not responsible for its provenance or conditions of production. Yet refineries admit that they also import gold as buyers themselves. But in this case, gold would not be considered an imported commodity, but money to be transferred to financial markets, including banks and central banks. Despite the refinery being the de facto owner of the gold destined for the banking sector, the protection of confidentiality of business relations in the banking sector prevents the disclosure of any information. Terms such as “exporter” or “customer” thus operate as “shifters” (Silverstein 1976) that enable legal separations, and thereby the passage from the register of the right to information to that of the protection of trade secrets, all while the refineries claim transparency through separate veridiction registers.

The transparency struggles that occupied much of the Swiss vote on corporate accountability that I chronicled in this chapter illustrate that the conditions of veridiction of so-called responsible gold are never stabilized. Plural veridictions emerge in the weighing of hierarchies and relationships between various normative frameworks that define a situation. Such legal entanglements determine what, in a given situation, may or may not be seen, may or may not be evaluated, and by whom. They enable an industry, such as the Swiss gold-refining industry, to simultaneously tap into apparently opposite fields of value – transparency and discretion – by isolating contradictory claims within what could be termed after Krisch bounded “universes of statements” (2021: 6).

Conclusion

Despite the plurality of veridictions they encompass, responsibility claims – whether by Fairtrade certifiers, CSR officers in refineries, LBMA-accredited auditors, customs officers, or legal activists – are necessarily linked to the ideals of making visible and accessible both ownership (who is responsible for what at what point in time) and provenance (how responsibilities relate to the social life of gold along its journey from mine to market). The etymology of “discretion” both as a disposition for secrecy and as an act of separation helps make sense of the way in which “supply chain transparency” is differently fabricated through distinct legal framings of gold imports into Switzerland. Assuming that the different veridictions discussed in this chapter result from socio-legal mediations in a triangular relationship between an object, a provider of visibility, and an observer (see also the Introduction to this volume), we can finally distinguish the ways in which ownership and provenance are differently conceptualized and made “transparent.”

In the first type of veridiction, notions of ownership and provenance are relatively autonomous and vaguely defined. Through self-narrated due diligence, retrospective views on the ownership and provenance of gold are provided by industry actors for industry actors themselves. This circularity is supposed to result from the technical and legal impossibility of tracing monetary gold, which is continually purified of traces of its past by discarding its commodity mode of existence and the set of regulations associated with it.

In contrast, the second type of veridiction intimately links the notions of ownership and provenance. Provenance is assumed to be made traceable to the mine and verifiable by identifying all the links in the “chain of custody.” The underlying assumption is that of gold as an “inalienable commodity” (Ferry 2002) tied to the livelihoods of impoverished artisanal miners in the Global South. To exist as such, private systems of gold certification are given priority over national regulations and corporate codes of conduct governing monetary gold. Although negligible in terms of volume and, in their current form, unsuited to significant changes in scale even from the point of view of their promoters, they essentially consist in the company making visible a marginal form of production that meets the ethical expectations of certain consumers and investors for whom it is intended.

The third type of veridiction, finally, challenges both the discrete (separative) and discreet (secretive) dimensions of transparency promoted in the industry. By disentangling gold from its materiality and legal status either as money or as a commodity, coalition activists moved away from an ontology of individuals-as-consumers to an ontology of individuals-as-citizens. In the third type of veridiction, gold is no longer conceived in terms of its material or legal relation to a consumer, but as part of a stream of information ultimately owned by the sovereign. This approach potentially reconfigures the triad of the visibility provider, the object observed, and the observer through an alternative socio-legal mediation. This veridiction differs mainly because it places the firm as the object of scrutiny, rather than as the provider of visibility, in between the state giving sight and the citizen as observer. In so doing, it bridges two forms of transparency project that so far have relatively separate trajectories: the politics of transparency in government that emerged in the early 2000; and the more recent, and widely discussed in this volume, politics of transparency in international trade.

12 How to Count Vanilla Transparency Trade-Offs in Organic Certification

The main feature of the international vanilla market is its total opacity.

Odoux 2003: 4

Introduction

International development groups and humanitarian programs have long called for increased transparency in the places where they work – whether this be clearer election policies or better accountability for the government use of development funds.¹ Increasingly, calls for transparency resonate within global supply chains, to bring attention to severe problems including child labor, worker abuse, sub-par food safety standards, and environmental violations. For many commodities it is not only development and government groups calling for transparency, but also consumers, who seek assurances that their purchases are not facilitating abusive social, economic, and environmental relationships (Guthman 2014; Raynolds 2000). Often, commodity transparency is operationalized through the rubric of “traceability” and certifications, which theoretically guarantee that certain environmental, social, safety, and economic standards are being met from the point of production to the point of consumption for a given product (Besky 2008; Tracy 2016).

Developing commodity relationships that are environmentally sustainable, socially just, and with the capacity to track health or safety concerns is an important goal. Yet, the discursive rhetoric that circulates around calls for transparent, certifiable, and traceable supply chains often equates these attributes with fundamentally more moral and ethical systems (Busch 2000; Moberg 2014; Mutersbaugh 2002). Organizations promoting organic and fair trade certifications frame them as “win–win” enterprises: farmers get better prices, development groups accomplish sustainability goals, consumers have better products, and everything is funded by the free market (Arsel and Büscher 2012; Galvin 2011).

Framing these projects through a moralizing lens, however, obscures the significant political, epistemological, and economic work that they do in the places where they work. In this chapter, I focus on a vanilla organic certification project in Madagascar to ethnographically examine what the project accomplishes, or not, and for whom. The case study involves a partnership between an association of vanilla bean farmers in the Mananara Nord region of northeastern Madagascar and an international certification agency. I conducted fieldwork during the pilot phase of the certification project in 2007, and then again in 2016 after the project had been in place for nine years. I observed the interactions between smallholder vanilla farmers and certifying agents, including vanilla field inventories and farmer training meetings.

The organic vanilla project reveals how organic certification processes privilege certain forms of transparency and traceability, while ignoring or undermining others. For vanilla organic certification, what may seem opaque from the vantage point of certifiers and others outside of local systems supports alternative forms of transparency and ethical accountability, especially from farmer perspectives. The processes that make particular aspects of supply chains more transparent for certain groups (including exporters, certifiers, and consumers) replace or undermine local forms of transparency. At the same time, globalized certification systems produce their own forms of non-transparency, especially for the vanilla farmers who take part in these initiatives. Smallholder vanilla producers are often not fully informed about the pricing structures, certifier responsibilities, and decision-making processes of organic certification (Galvin 2018; Moberg 2014; Tracy 2016).

Transparency is not an either/or state, but rather a spectrum of negotiations and strategic positionings (Ballestero 2012; Duffy 2005). Making some aspects of production and trade more transparent undermines transparency in other ways: beans may be counted, but other things are then not counted. Some economic costs are recorded, while others are obscured. It is the people and organizations with more economic, social, and political power that can most successfully advocate for the forms of transparency that best serve their own interests, even if they have the intention of supporting smallholder farmers. Given the established literature in agrarian studies and environmental anthropology, this dynamic is not surprising. This work notes how systematic attempts of outsiders to write down, make known, codify, and circulate renderings of local livelihoods tend to favor those in power (Ferguson 1990; Goldman 2003; Hanson 2007; Scott 1998; West 2005; 2006). Looking forward, certification programs could better support smallholder farmers by adopting more inclusive definitions of transparency that account for multiple forms of knowledge production, relationships of social and economic capital, and moral accountability.

Contexts of Vanilla Production and Trade

Smallholder Vanilla Production

The Mananara Nord region of northeastern Madagascar is situated along the Bay of Antongil, looking outward toward the Indian Ocean. The bay has long been a site of global trade. The Dutch East India Trading Company established trading posts in the region during the early 1600s, and the area was a pirate hub throughout the seventeenth and eighteenth centuries (Ellis 2007; Pearson 1997). Throughout its history, the region has produced a variety of goods for international markets, including timber, honey, sugar cane, black pepper, and cacao. Today, the three main cash crops in the area are cloves, vanilla, and coffee. Cloves and vanilla have been in the region for nearly 100 years and gained prominence as an export commodity during the French colonial era. During colonial times, the French tightly controlled the vanilla market, forcefully restricting smallholder farmers in Mananara from cultivating vanilla beans in favor of supporting plantation production systems further north (Osterhoudt 2017).

Today, the commercial center of the region is the town of Mananara Nord, which is surrounded by many smaller rural districts and villages. One of these villages is Behazo – the site of the following case study on vanilla organic certification.² As with other villages in the region, the majority of Behazo households engage in both subsistence and cash-crop agriculture, organized into diversified and well-tended agroforestry fields. The region is known for producing high-quality vanilla beans – an identity that farmers are understandably quite proud of, given the difficulty of cultivating and curing vanilla.³ In Behazo, the scale of vanilla cultivation varies considerably from person to person, ranging from a few kilograms of harvest to several tons. In this area, vanilla cultivation is not primarily a wage-labor enterprise, as famers tend to their own fields (although larger-scale farmers may hire help at certain points in the vanilla harvest cycle).

In Behazo, and across many regions of Madagascar, farmers often form local associations called fikambananas, usually comprised of between twelve and fifteen men and women. In the Mananara region, many of these associations focus on vanilla cultivation, with members sharing labor, equipment, and information on vanilla markets and cultivation techniques. Fikambananas also play a social function within communities, organizing events and workshops. For a fikambanana to be officially recognized by the Malagasy government, members must register paperwork both with the administrative offices in Mananara and in the provincial capital city of Toamasina. Beyond associations, the next level of farmer organization is a farmer cooperative, comprised of a group of twenty or so farmer associations. While cooperatives today are increasing in number and strength in the Mananara region, this is a relatively new development within the past ten to fifteen years.

Vanilla Trade in the Global Market

The average vanilla bean travels a long and highly mediated path from Behazo farmers to American and European kitchens. After harvest, some producers sell their “raw” (uncured) green vanilla beans to other families or associations for curing. Other farmers will cure their own vanilla beans – a months-long process that involves carefully blanching, sweating, sun-drying, and sorting the beans. Households then sell these “finished” beans to small-scale collectors who travel to villages to buy vanilla to resell to larger collectors based in the town of Mananara.⁴ Mananara operators then sell this vanilla to export societies, often based in the larger port cities, which then export vanilla to international import and wholesale companies, which then sell to distributors in Europe and the United States. Distributors sell vanilla within domestic markets, including to retail outlets and food manufacturers.

Madagascar produces about two-thirds of the world’s vanilla exports, over half of which are sold to the United States (Odoux 2003). The primary region of vanilla production is the Sambava region in northeastern Madagascar, known as the “vanilla triangle,” to the north of Mananara (Andriamparany et al. 2021). Insiders within the international vanilla market describe Madagascar’s vanilla market as “in no way standard” and “highly speculative and very sensitive to rumors” (Odoux 2003: 4). The volatility of the vanilla market has been especially pronounced since the 1990s, when the Madagascar vanilla market was deregulated in response to pressure from international trade organizations (Salas 2007). The uncertainty within Madagascar’s market reverberates throughout the international vanilla industry, as other vanilla-producing countries adjust their vanilla prices in response to Madagascar’s prices.

Market deregulation, combined with a cyclone that destroyed much of Madagascar’s vanilla crop, contributed to a dramatic price spike in 2003, with export prices climbing from approximately $70 per kilogram to $500 per kilogram (Salas 2007). This dramatic boom was followed by an equally dramatic crash in 2004; by 2006, international vanilla prices had lost about 75 percent of their 2003 value (Salas 2007). The market downturn hit rural Mananara farmers particularly hard. With such low prices, many vanilla collectors simply stopped coming to Mananara. The collectors who did continue to work in Mananara offered growers extremely low prices for their gourmet vanilla. The depressed vanilla market stretched on for more than a decade, finally recovering around 2016.⁵

During the prolonged years of the vanilla bust, farmers struggled to earn enough income to support their basic needs; many families dedicated less time to their vanilla crops, concentrating on the clove market instead. Other farmers became curious about new forms of trade relationships including organic certification, which in 2004 was beginning to gain momentum in international markets. In Behazo, one such group was the local fikambanana VOKATRA, whose members contacted the Peace Corps Madagascar office to request a volunteer to help them pursue new market opportunities. Peace Corps agreed to the request, and, in 2005, at the lowest point in the vanilla market, my partner and I arrived at the village of Behazo as Peace Corps volunteers charged with the task of helping to develop an organic certification program in partnership with local vanilla farmers.

Cultures of Transparency

Fast forward two years, as I stand behind a table that was set up in front of a farmer’s home. In front of me, dozens of scattered papers are pinned under rocks to prevent them flying away, but they fly away regardless. A representative of the organic certification group ECOFIN stands next to me; she is weary and grumpy after enduring a two-day pickup truck ride to the village to certify vanilla fields. As I struggle with papers, two farmers from VOKATRA are yelling at one another, as other farmers chime in from the side. As I watch, tensions continue to rise, along with the volume of voices. In other words, things are a mess.

This scene developed after many months of trying to organize an organic certification project for the twelve farmers of VOKATRA – an organization that had been together for many years, and which included some of the most skilled and successful vanilla farmers in the region. To lead up to the visit from ECOFIN, the farmers had attended informational meetings and workshops on organic certification. Together, we had filled out multiple inventory forms for each farmer, for each of their fields. These forms detailed, among other things, field locations and histories, as well as which crops farmers cultivated and the specific agricultural techniques they used to care for their land. The ECOFIN agent was in Behazo for several days to ground-truth this paperwork and to inspect the practices of participating farmers.

The fight unfolding in front of everyone occurred after one member of the association accused another member of using fanafody – or pesticides – to ward off pests on his vanilla flowers.⁶ The accuser worried that this action would ruin the certification for all farmers, as the inspector emphasized that certification would be an all or nothing affair: if one farmer breeched protocol, the whole association would be rejected for certification. The accused farmer shouted back angrily and then stormed off, declaring that he was quitting VOKATRA. Others followed. The project, and the very organization that was meant to be empowered by the certification, was disintegrating. It was later formed again, but, on that day, things looked bleak.

Trade Agreements: The Written and the Spoken

The dramatic altercation between farmer association members had been foreshadowed since the beginning of the certification project, which had consistently encountered a range of suspicions, misunderstandings, and frustrations. These stemmed in part from the fact that the ECOFIN project, as with most projects of organic certification, primarily equated traceable knowledge with written knowledge. For ECOFIN, legible, transparent traces were written traces, as exemplified by the requirements for voluminous paperwork, numbered harvest batches, and written contracts (Hetherington 2012; Mutersbaugh 2002; Randrianarivelo et al. 2013; Skaria 1996). A written trail theoretically allows knowledge to cross scales between vanilla farmers, trade intermediaries, and consumers, allowing actors separated by space to keep track of the movement of materials through supply chains. Such legible paperwork is assumed to support more ethical relationships of trade and to eliminate dishonest practices.

Privileging written forms of knowledge, however, overrides the oral forms of traceability that Malagasy farmers carefully establish within their own trade relationships. In many regions, spoken agreements are a component of speech-making and public pledges, and bind together people and ancestors in social contracts (Bloch 1998). In many of the fikambanana certification meetings I observed, for example, one person would present information and ideas in an oral format, then another member would repeat back the information to confirm what was said. Often, the person responding would elaborate on key points or raise follow-up questions. These interactions followed familiar oral templates for public rhetoric common in this region of Madagascar (Osterhoudt 2017). This format leaves space for people to raise questions, confirm plans, and establish leadership. Such spoken interactions, done before a group, also create a community of listeners who can hold parties accountable for promises made.

The certification programs, however, largely ignored such spoken and dialogic methods for establishing transparency. As such, they overlooked the important social, economic, and cultural weight given to verbal contracts and oral performance to cement relationships, including relationships of trade. Instead, the certification organization insisted that, to be transparent, agreements must be written down; including a spoken component to trade agreements was not regarded as necessary to the process.

Yet written agreements between certification agencies and farmer associations are often written in a language and in terms that farmers are not familiar with. Farmers are not given space to negotiate the terms of these contracts, which are drawn up by certification agents in consultation with the private sector partners who plan to buy the certified products. Written agreements are therefore usually negotiated, written, and safeguarded by individuals considered to fall outside of local networks of trust (Skaria 1996).⁷ This produces trade agreements that are more transparent for certification agencies and other extra-local actors, but less transparent for farmers.

The exclusive reliance on written knowledge also has implications for accountability – an essential component of transparency projects. In the case of any potential dispute within certification projects, the written contracts will carry much weight in the resolution process. For many Malagasy farmers, however, written contracts are more difficult to enforce than their oral counterparts (Bloch 1998; Osterhoudt 2017). For example, if farmers feel that a written contract has been broken, they will likely be required to find recourse through the courts – a system highly skewed against smallholder farmers. The formal court system contrasts with more local ways to settle grievances – for example, through a council of elders or analogous community governance structures such as dina agreements for local natural resource management (Rakotondrabe and Girard 2021). A council of elders, however, would likely not feel confident to comment on the intricacies of an international trade contract drawn up in French or English if it came into dispute, nor would the nonlocal partners in the contract be likely to agree to settle any claims in this way.

Written contracts therefore set up processes of accountability that favor certification agencies and vanilla buyers, who can more easily enforce contracts if the farmers are seen to break agreements. Farmers, on the other hand, do not have the same available resources to enforce written contracts if the certifiers do not follow through on the agreed terms, or if they engage in corrupt or dishonest practices. This protection from accountability confers much power on certification agencies (see also Moberg 2014).

Of course, many local processes of accountability are also skewed in favor of farmers with more political influence and economic resources. Yet, while both processes have their strengths and weaknesses, one is more fully situated at the local level, which brings transparency in its own right: farmers better understand what is stacked against them within more local systems, and have established strategies for navigating them.

Field Inventories: How to Count Vanilla

The emphasis on written records privileges knowing things through counting and inventories – popular tools of many development and conservation initiatives (Li 2007; Muehlmann 2012; West 2006). Yet, counting is not without cultural nuance and political maneuvering. For example, organic certification programs require farmers to carefully estimate their anticipated vanilla harvest for the season. These estimates are recorded in individual field inventory sheets and then compiled across all farmers in the association. Harvest estimates are used to determine the quantity of vanilla that becomes organically certified; this number also helps to determine the cost of annual organic certification.

Most often, organic certifying agents are worried that farmers overestimate their production for the year. If the group is certified for an anticipated ten tons but produces only seven tons, farmers could potentially bring in three tons of “counterfeit” vanilla and claim it as part of the ten tons under certification. Thus, the certifier who came to the village for Behazo’s pilot project was keenly interested in verifying that the estimates farmers gave for their vanilla production matched what she saw in the fields. To accomplish this task, we visited several sample fields to ground-truth data on the farmers’ projected yields.

Once in the fields, however, the certifier noticed the opposite trend to what she had anticipated: instead of exaggerating the extent of their vanilla vines under cultivation, the farmers had consistently underestimated the number of vines – often to a significant degree. Observing this trend, the certifier remarked dismissively that the farmers did not seem to know what was growing in their own fields. Calling an impromptu meeting, she then took time to explain to farmers how to count their own vanilla vines. I was surprised by her conclusion that farmers lacked skills to estimate their own vanilla production – in my experience, vanilla farmers had a good knowledge of how many vines they had under cultivation.

When I spoke with farmers about this discrepancy a few weeks after the inspection, they explained to me that people did not miscount their vines; rather, they deliberately underestimated their harvest numbers. They gave several reasons for this decision. One was that the younger farmers did not want to publicly announce that they had more vines than the elder farmers, which would be a sign of disrespect that could disrupt social relationships within the fikambanana. People with a potentially large vanilla harvest did not want to become a target for theft, nor for people asking them for money or favors. Many vanilla farmers did not want to commit to specific production numbers, knowing the many challenges that could prevent a good harvest, including cyclones, pests, or diseases. Finally, being a new project, farmers were hesitant to pledge all of their vanilla to certification, preferring to follow the risk-hedging strategy of diversifying their trade relationships across various buyers and markets (Osterhoudt 2017).

Thus, it was not that the farmers needed to be educated on how to count their vines, but rather that they had specific reasons for miscounting them in the first place. In the end, it was the “numerically correct” counting desired by certification agents, and not the “socially correct” forms of counting useful to farmers, that prevailed. Before ECOFIN agreed to certify the vanilla as organic, farmers were required to go back and “correct” the anticipated yield numbers on their inspection sheets.

Representing Transparency: The Spreadsheet

The organic certification project not only privileged certain forms of writing and counting, but also how this information was represented (see also Galvin 2018). Most notably, the process encouraged mastering the Excel sheet format, as became evident during a follow-up visit I made to the organic certification project in 2016. Nine years after the first disastrous attempt at organic certification, I again sat in on a meeting between Behazo farmers and an ECOFIN agent. This time, the farmers were part of a large cooperative, with professional leadership and a membership of hundreds of farmers. The meeting was not held outside a village home, but in a fancy hotel in Mananara. Instead of scattered papers pinned under rocks, the cooperative representatives worked on laptops, with the field inventory data neatly presented in the form of Excel spreadsheets. The data were beautifully legible, arranged in neat columns. Looking at the screen, the ECOFIN agent complimented the group on its work. There was a cursory visit to a few vanilla fields, but the spreadsheet inspired trust, and the ground-truthing of reported harvest numbers no longer played as much of a role in the proceedings.

I left the meeting impressed by how well the farmers had figured out what the murky system of transparency was supposed to look like, through the eyes of the certifier. They realized the connection that certification programs make between the quality of information presented and the presumed quality of the thing that the information represents (Galvin 2018; Hetherington 2012; Tracy 2016). With the presentation of an Excel spreadsheet that inspired trust, the materiality of the vanilla vines faded into the background.

Economic Transparency, to a Point

A common goal of transparency projects is to bring to view problematic economic relationships, such as corruption, predatory lending, paying workers nonliving wages, and extreme profit capture. Organic and fair trade programs, for example, often circulate narratives that criticize “middlemen” involvement in commodity trade networks, connecting the activity of trade intermediaries to decreased profits for farmers. Certification agencies promote their projects as an alternative to this model, noting that participating farmers receive higher prices for their products, in part by forging more direct linkages between farmers and consumers (Osterhoudt et al. 2020).

This baseline narrative, however, does not disclose how certification agencies themselves act as “middlemen” in the trade process. These organizations charge significant costs for certifications. Although farmers and businesses may receive welcome price premiums for organically certified vanilla, these premiums must be balanced against the considerable direct and indirect costs to farmers and businesses to obtain certification. Organic certification in Madagascar is conducted by accredited for-profit entities, and they charge a good deal for their services – services that must be performed each year. For businesses engaged in certification programs, they must often hire teams of people to manage certification paperwork and reporting requirements, representing another significant expense.

In addition to the direct costs of certification fees, the organic certification process includes significant indirect costs (Randrianarivelo et al. 2013). For farmers, there are the indirect costs of lost work time and the need to purchase new materials required to pass certification, such as vanilla bean drying racks, wooden storage boxes, or forms of organic fertilizer. There are also the indirect costs for both farmers and businesses that come from hosting certifying agents during their site visits. These agents stay in villages for several days, and often expect to be shown a “good time” by farmers. After nine years of hosting ECOFIN project representatives, for example, farmers noted that they feel pressured to buy the agent lavish food and drinks and put them up at the most expensive hotel in the region. A happy agent, they say, is more apt to give them a better inspection.

In their project narratives, however, certification agencies do not make readily visible the direct and indirect costs they charge to farmer associations and vanilla buyers. Organic certification agencies often present their work as purely a social mission, instead of as a socially minded business, and many consumers do not realize that they rely on extracting profits from the commodity chains they certify. Overall, while making some forms of economic costs transparent, certification programs obscure their own role as economic actors within the vanilla commodity chain.

Ultimately, certification agencies act in a role analogous to the “middlemen” they criticize, as they capture significant profit and value from agricultural supply chains. These outside agencies often replace local Malagasy individuals involved in the vanilla supply network – usually younger Malagasy men and women from local villages who transport vanilla from place to place, connecting farmers with buyers. Organic certification projects, instead of empowering local Malagasy individuals to perform the paid work of certification, bring in people from outside the region to profit from the vanilla trade. Certification projects also open up space for people like me – an American with no experience in vanilla farming – to capture forms of value within the vanilla supply chain (Corson 2016; Guthman 1998). In the end, certification programs do not eliminate trade intermediaries as much as they replace local intermediaries with extra-local ones (Osterhoudt et al. 2020).

Discussion: Transparency, Knowledge, Power

During the public argument between VOKATRA members, the farmer accused of wrongdoing at one point angrily shouted: “If you don’t trust me, just test my vanilla beans for pesticides!” Indeed, this statement raises a key point about the process of organic certification. If organic certifications were only about keeping chemicals out of the ground, all that would be needed for a successful certification would be to randomly test products for contamination. Instead, organic certification comes with a suite of auxiliary complications: paperwork, field visits, trainings, and audits. This raises the question: If these requirements are not necessary to make a vanilla bean organic, what types of work are they doing? Which forms of knowledge, profit, and power do certification programs enable, and which do they obstruct? And who tends to ultimately benefit from organic certifications?

Certification organizations often present their work as driven by social concerns, as they claim to promote more transparent – and morally desirable – relationships of trade. Yet, as we have seen with the Behazo case study, framing traceability and transparency as exclusively morally driven projects obscures the underlying forms of economic, social, and political work that these projects do. Through the ECOFIN organic certification programs, local forms of knowledge, accountability, and economic profit are gradually replaced by extra-local forms (cf. Corson 2016; Jaffee 2012; Webb 2012). As a result, while organic certification projects may increase transparency for certain groups, they decrease transparency for others.

As the opening quote of this chapter notes, the global vanilla supply chain, like many global commodity chains, is a highly opaque system. This murkiness has negative consequences for smallholder farmers, who often lack the power or resources to navigate the market to their advantage. Making the power structures, economic interests, forms of patronage, and deep historical roots of exploitation in the vanilla industry more transparent unquestionably holds much potential to empower farmers in Madagascar and in other vanilla-producing regions of the world. Transparency programs with this goal could focus their attention “up” the chain, examining the role of export groups, state-led regulatory policies, multinational food corporations, and the organic certifying agencies themselves in the vanilla commodity network. Yet, vanilla certification programs do not focus transparency efforts on systems at these levels. Instead, they focus on smallholder vanilla growers and their fields. This approach repeats the oft-critiqued tendency for development groups to focus on local symptoms, instead of extra-local drivers, of challenges such as economic exploitation, political insecurity, and environmental degradation (Andriamahery and Zhou 2018; Blaikie 1985).

Moving forward, certification projects can adopt a more nuanced and equitable approach to transparency that recognizes the trade-offs inherent in projects of visibility. As commodity chain projects cannot achieve perfect transparency, they can mindfully select which forms of economic, political, and environmental relationships to bring to the fore. They can continuously ask which types of transparency are important to whom, and how alternative forms of transparency can be included within project designs. Such an orientation would underscore that transparency is not as much a question of which groups have better ethics, but of which groups have more power to define what becomes seen and what remains hidden.