III. Implementation Experiences of Codes of Conduct in the U.S. Apparel Industry

B. Field Visits

For a two-week period in September 1996,¹ Department of Labor officials traveled to six countries - the Dominican Republic, El Salvador, Guatemala, Honduras, India, and the Philippines - that produce garments for the U.S. market. The objective of the visits was to learn about the approaches of foreign garment suppliers to the implementation of the established child labor policies of U.S. importers. Interviews were held with as many relevant persons or organizations as possible associated with the apparel industry, i.e., labor ministry officials, manufacturers, plant managers, buyers, trade associations, unions, workers, community activists, human rights groups, organizations concerned with children's issues, and other non-governmental organizations (NGOs).

1. Planning of Field Visits

In planning the field visits, Department of Labor officials met in Washington with a variety of organizations and individuals. Where meetings were not practical, consultations were held by telephone. Among others, the Department of Labor consulted with representatives of U.S. garment importers, labor organizations, the Department of State, and Washington-based diplomatic representatives of the countries being visited.

a. U.S. Apparel Importers

Department of Labor officials met with representatives of the International Mass Retailers Association (IMRA), the National Retail Federation (NRF) and the American Apparel Manufacturers' Association (AAMA) to discuss the objectives of the field visits. The Department of Labor sought input from the three business organizations on specific individuals and companies in each of the foreign countries who should be contacted. All three organizations indicated that they would inform their members about the mission and, where appropriate, suggested specific individuals and corporations that should be contacted in each country.

b. Labor Organizations

Department of Labor officials consulted with representatives of organized labor in the United States in preparation for the foreign visits.

• Department of Labor officials met with representatives of the American Institute for Free Labor Development (AIFLD) and the Asian-American Free Labor Institute (AAFLI), the entities within the AFL-CIO responsible for Latin American and Asian affairs, respectively. These entities provided advice on individuals/organizations that Department of Labor officials should visit in each country and informed their overseas contacts about the mission.

• Department of Labor officials also consulted with the Union of Needletrades, Industrial and Textile Employees (UNITE), the main U.S. labor union in the garment industry, for the same purpose.

c. Department of State

The U.S. Embassy in the capital of each country was requested to assist in the identification of all relevant individuals and organizations with whom the Department of Labor officials should meet and, where possible, make appointments for such visits.

d. Foreign Governments

The Department of Labor requested from U.S. Embassies in the six foreign countries that an appointment be made with high-level officials of the Department of Labor (or appropriate department) in each country to discuss the objectives and methodology of the mission.

2. Conduct of Field Visits

Organizations and persons interviewed by the Department of Labor officials in each of the six countries are listed in Appendix D. The categories of individuals interviewed were: government officials (including legislators), employers, workers, and NGOs. U.S. Embassy personnel in each of the countries generally accompanied the Department of Labor officials. At the beginning of each interview, Department of Labor officials indicated the purpose of the interview was to gather information for a public report, and any information collected could be used for that purpose.

3. Plant Visits

The central element of the field visits was the opportunity to discuss matters related to the existence and implementation of codes of conduct with managers and workers of plants producing apparel for the U.S. market.

Information is not publicly available on the universe of foreign subsidiaries, contractors, and subcontractors of U.S. garment importers. Information which is available (e.g., membership lists of apparel manufacturers associations) may not cover the entire industry. Moreover, publicly available information may be out of date, thereby not reflecting the current structure of supplier networks of U.S. garment importers.

For these reasons, Department of Labor officials in each country developed a sample of garment plants to be visited using information obtained from garment manufacturers or exporters associations in each of the countries, U.S. Embassy officials familiar with the garment industry of the given country, and recommendations from U.S. labor union representatives and NGOs. U.S. business organizations - particularly the AAMA - also assisted in this task.

Department of Labor officials sought to visit a representative sample of the following types of garment plants producing for the U.S. market:

• U.S.-owned subsidiaries of the 48 companies surveyed;
• U.S. or host country-owned contractors or subcontractors; and
• Third party-owned (e.g., Korea, Taiwan) contractors or subcontractors.

Boxes III-1 through III-6 list plants, trade associations, and other garment industry representatives visited by the Department of Labor in each country:

• In the Dominican Republic, the Department of Labor visited eighteen garment plants in seven Export Processing Zones (EPZs) and met with representatives of the Dominican Association of Free Trade Zones, the American Chamber of Commerce of the Dominican Republic, the Free Trade Zones Association in Santiago and San Pedro de Macorµs, and other organizations connected to the apparel export industry (Box III-1).

• In El Salvador, eight plants in five EPZs were visited, and meetings were held with the Salvadoran Association for the Garment Industry and other garment industry representatives (Box III-2).

• In Guatemala, visits were made to nine plants in Guatemala City, Chimaltenango, and San Pedro de Sacatepequez, and meetings were held with representatives of the Apparel Manufacturers Exporters Committee, the Non Traditional Products Exporters Association, the Commission for Coordination of Agricultural, Industrial, Commercial, and Financial Associations, and other garment industry representatives (Box III-3).

• In Honduras, visits were made to twelve plants, ten in five EPZs and two outside of the zones; meetings were held with the Foundation for Investment and Development of Exports, the Honduran American Chamber of Commerce, and the Honduran Association of Maquilas as well as with other organizations connected with the apparel export industry (Box III-4).

• In India, Department of Labor officials visited nine plants and met with the American Business Council, the Federation of Indian Chambers of Commerce and Industry, the Apparel Export Promotion Council, and other garment industry representatives in New Delhi, Bombay, Madras, Calcutta, Chandigarh and Tirupur (Box III-5).

• In the Philippines, visits were made to eighteen plants and three EPZs, and meetings were held with the Garment Industry Subcommittee of the American Chamber of Commerce and several other apparel industry representatives (Box III-6).

In all, Department of Labor officials visited 74 apparel-producing plants and 20 export processing zones. They also met with key officials of the garment industry - and more particularly of the garment export industry - in all six countries.

Four of the 74 plants visited by Department of Labor officials were found not to be exporting at the present time to the U.S. market and were determined to be outside of the scope of the present study.² The observations made in this chapter with regard to the implementation experiences of foreign suppliers with codes of conduct of U.S. importers that address child labor are therefore based on the 70 plant visits that fell within the scope of the study. Nine of the 74 plants visited, or 12 percent of the total, were subcontractors to foreign companies that exported garments to the United States.³