Transparency of Codes of Conduct in the Apparel Industry

Most survey respondents who have child labor policies indicated that they have distributed copies of their policies to all suppliers, including contractors and subcontractors. A few said they also communicate the policy to a wider audience. On the other hand, many respondents said they were not certain whether workers know about their codes of conduct.

Field visits conducted in six countries revealed that:

• Managers at two-thirds of the export-oriented plants visited indicated they were aware of codes of conduct prohibiting child labor, particularly codes issued by U.S. customers.
  
  
• Formal training about codes of conduct was not common. Approximately 30 percent of the facilities visited where managers knew about codes reported that they received formal training from the U.S. corporation issuing the code. However, more than half of these facilities produced for just two corporations.
  
  
• Meetings with workers and their representatives suggested that relatively few workers making garments for U.S. companies are aware of the existence of codes of conduct and even fewer understand their implications.
  
  
  • This confirms information received from U.S. companies through responses to the survey and follow-up telephone interviews that they were not aware how - or if - their policy is communicated to workers making their products.
  
  
  
• The lack of awareness among workers about codes of conduct may be in part attributable to the relatively low level of effort by producers to inform their workers about the codes. Only 22 of the plants visited informed their workers about codes of conduct; 13 of the companies indicated that they informed their workers about codes of conduct orally, while only nine stated that they did so both orally and in writing.
  
  
  • In many cases where plant managers told Department of Labor officials that they had informed workers orally about company policies, workers denied having ever been so informed.
    
    
• Posting of the codes of conduct at the workplace for the benefit of the workers -preferably in their own language - was not the rule in the garment industries of most of the countries visited. In all, 21 of the 70 plants visited by the Department of Labor officials had posted a code of conduct of a U.S. customer; 7 of such plants (out of 8 visited in that country) were in El Salvador. The number of plants visited in each of the other countries where codes of conduct were posted was: Dominican Republic, 2; Honduras, 1; Guatemala, 2; India, 2; and the Philippines, 7.
  
  
  • Some managers stated that they do not post codes because all they do is repeat domestic law. However, not all codes define child labor by existing domestic law.
    
    
  • Others have also used as an excuse the illiteracy of workers, even though managers contradict this by stating that they are seeking to employ better-educated workers. Many workers had no trouble reading codes of conduct shown to them by Department of Labor officials.
  
  
  
• While it is most critical that overseas contractors, subcontractors and their workers be familiar with corporate codes of conduct, knowledge about their existence and implications by others - host governments, NGOs, business organizations - also can be helpful in enhancing their effectiveness. The record was mixed with respect to the extent to which these entities were familiar with codes of conduct and their implications.