A. Introduction

There have been numerous recent reports of children working in the leather and footwear industries of various countries. ¹ Public concern and consumer interest about such exploitative child labor practices appears to be growing, and consequently, pressure for change has increased. ² Since 1994, an increasing number of importers and producers of leather footwear have taken steps to assure consumers that their products are not made by children.

This chapter focuses on several private sector initiatives to prevent the em- ployment of children in the leather footwear industry. Section B provides a brief overview of the structure of the industry and the U. S. market for leather footwear. Section C discusses evidence of the role child laborers play in this industry based on various published reports as well as information collected during U. S. Department of Labor site visits to Brazil, China, India, Mexico and Pakistan. Section D discusses consumer labeling initiatives, looking specifically at two currently in operation in Brazil: the Child-Friendly Company Program of the Abrinq Foundation and the labeling program of the Pro-Child Institute. Their goals, structure and implementation procedures are outlined based on information provided by the programs' administrators and observations of Department officials on their site visit to Brazil. Finally, Section E discusses the corporate codes of conduct of several large U. S. importers and retailers of leather footwear, based on information they provided in a voluntary survey. Where Department of Labor site visits provide additional perspective on the implementation of these codes, this information is also provided. (Appendix D contains country-specific lists of the individuals and
organizations visited for this report.)

B. Industry Profile

The term leather footwear refers to any footwear with an upper portion (known simply as the "upper") constructed of leather. In 1995, an estimated 4.5 billion pairs of footwear, or about 43 percent of the world's footwear production, met this criterion. ³ Despite recent technological innovations in footwear manufacturing, production remains a highly labor- intensive activity. Hence, producers have continued to relocate across national boundaries in pursuit of lower wages and inexpensive raw materials. ⁴ Today 42 percent of the world's leather footwear originates in Asia and the Middle East (principally China, India, Thailand, Indonesia, Pakistan, Iran, and Turkey). Another 27 percent of production originates in Europe (particularly Italy), 18 percent in the Americas (particularly Brazil), and the remainder in other regions. ⁵ Production within the United States is now rather limited. Less than 10 percent of the nonrubber footwear purchased in this country in 1996 was produced domestically. ⁶

On average, every man, woman, and child in the United States purchases more than four pairs of shoes each year, a level of consumption that establishes this country as the world's largest importer of footwear. ⁷ In 1996, the United States imported 602 million pairs of leather footwear at a value of $8.2 billion. ⁸ Figure III- 1 shows the top 25 suppliers of leather footwear to the United States in 1996. As Figure III- 1 illustrates, two- thirds of U. S. leather footwear imports came from China and Brazil. China alone accounted for about 53 percent of all leather footwear imports by quantity (317 million pairs) and 42 percent by value ($ 3.4 billion). Brazil accounted for another 14 percent on both measures (86 million pairs of shoes at a value of $1.2 billion). Table III- 1 lists U. S. imports of leather footwear by country and value.

A wide variety of leather footwear is offered for sale in a myriad of U. S. retail establishments. In terms of dollar value, athletic shoes make up the largest component of U. S. sales, followed by dress shoes, casual shoes, work shoes, sandals, sport/ hiking boots, and western/ casual boots. ⁹ Family shoe stores are the retail outlets with the largest volume of sales, followed by shoe specialty stores, department stores, discount stores, national catalog chains, sporting goods stores/pro shops, mail order, factory outlets, and apparel specialty stores. ¹⁰

Figure III- 2 illustrates the chain of production within the international foot- wear industry. This schematic also highlights relationships among the various entities responsible for production. The key actors can be described as follows:

• Retailers typically sell products obtained from U. S. footwear manufacturers and design and marketing firms. Some, however, function as their own design and marketing firm, often with the assistance of overseas buying agents. A large share of the footwear sold in the United States is sourced directly from abroad through the retailer's overseas buying offices and/ or buying agents, for sale under the retailer's own brand name( s).
• Design and Marketing Firms design footwear, brands and trademarks for which they then develop marketing, promotion, and advertising programs. These firms do not generally own their own factories and include firms such as Nike, Reebok, and Brown Group. Instead, they contract out all production activities, mostly to foreign manufacturers. Design and marketing firms' communications with foreign producers occur via their own buying offices and/ or buying agents abroad. These firms typically sell their products wholesale (to retail distributors) or directly to consumers through their own chain of stores. U. S. manufacturers that source abroad, such as Nine West, Wolverine, and Florsheim, follow similar practices.
• Buying Agents are often used by U. S. companies that do not have a large presence abroad; they can also be part of the U. S. company's own buying staff. Buying agents locate, inspect, qualify, and negotiate with foreign producers on behalf of the company in question. Their role may also include communication of quality standards and/ or corporate codes of conduct as well as monitoring for quality control and compliance with other standards.
  In the footwear industry, buying agents typically consult on design and fashion issues. Often, especially in children's footwear, they have trademark licenses which they sub-license to retail customers.

TABLE III-I
U.S. Leather Footwear Imports, 1989-1996,
Top 25 Suppliers in 1996
(in millions of U.S. dollars)

Source: Official Statistics of the U.S. Department of Commerce

• Overseas Buying Offices are similar to, and perform many of the same functions as, buying agents. However, they work directly for U. S. retailers, manufacturers or design and marketing firms.
• Contractors, also known as "producers" or "manufacturers," are usually independently owned businesses that are responsible for the actual manufacturing of footwear for sale in the United States. These contractors typically own and operate their own factories, but many also delegate certain parts of the manufacturing process to subcontractors (smaller, more specialized factories or workshops).

Because of the number of actors involved in the footwear production chain, rarely is a single entity responsible for the design, production and sale of a pair of shoes. Moreover, this multi-layered system of production tends to isolate the final consumer from the manufacturer and often affects the dissemination of information among the relevant parties.

C. Child Labor in the Leather Footwear Industry

Leather, a natural material, has certain properties that makes automation difficult in some stages of footwear production. ¹¹ Thus, certain aspects of production have traditionally been performed manually. For instance, to produce leather uppers, each hide must be inspected for imperfections and quality variation; some leather must also be cut one layer at a time. ¹² Prefitting operations, e. g., stitch marking, seam rubbing and taping, cementing (or gluing), folding, and eyeletting, are also labor intensive. ¹³ An upper can involve as many as 60 separate stitching operations, depending on its design. Some can be done by machine; others are done by hand, particularly decorative moccasin seams. ¹⁴ Soles and heels are attached to the upper: by cementing, molding, or sewing, processes which can be labor-intensive.

Evidence suggests that in some countries many of these labor-intensive operations are often performed by children. Many reports indicate that child labor occurs most frequently in the informal sector of the industry, where government regulations either do not apply or are not enforced. ¹⁵ Children are found cutting, hammering, folding, gluing, marking, hand-sewing, hammering studs, and sanding the soles of shoes. ¹⁶ They often work in home- based or small workshops that frequently supply shoe parts for larger, exporting firms. ¹⁷ Working conditions are often unhealthy and dangerous. In many workshops, children are exposed to toxic fumes, solvents, and other dangerous chemicals, ¹⁸ which may cause skin and respiratory diseases. ¹⁹ Children are also exposed to work hazards such as knives and cutters or scrapers, and are rarely provided with protective clothing (e. g., gloves, masks or boots). ²⁰ Child labor has also been observed in the leather tanning industry, which supplies raw materials to footwear producers. ²¹

The actual number of underage workers in the leather footwear industry is difficult to determine. ²² Data on child workers for the export-oriented portion of the industry are likewise difficult to isolate since subcontracting arrangements often involve small-scale factories, workshops, and home production. ²³

Brazil

Child labor has been documented in home-based and subcontracting operations in Brazil's two major footwear producing regions. ²⁴ A recent ILO- sponsored study of child labor in two cities of the Vale dos Sinos, in the State of Rio Grande do Sul, documents the existence of child labor and describes some characteristics of 7-14 year old child workers. ²⁵ In Franca, located in the State of Sao Paulo, local union representatives conducted a UNICEF and ILO- sponsored study of children who worked in the footwear industry while simultaneously attending school. ²⁶

The Vale dos Sinos study reveals that children are employed primarily in small workshops and in household production of goods and services supplied to many medium and large-sized leather footwear firms. The children usually work between 4 and 7 hours daily; most give part or all of their salary to their parents. ²⁷ In these workshops, children perform manual functions such as hand sewing, stitching, gluing, attaching buckles, poking holes in leather, pounding tacks in heels, and sanding and buffing footwear. ²⁸ Because much of this work takes place in clandestine, informal workshops, conditions tend to be much worse than those in larger firms. ²⁹ The greatest hazard in these workshops is exposure to glue and other solvents that have been demonstrated to cause respiratory ailments, nausea, lethargy, and sometimes irreversible damage to the functioning of the immune system, nervous system, and the liver. ³⁰ Dangerous working instruments contribute to injuries such as cuts, bruises and punctures.
Injuries sometimes result in amputations. ³¹

Brazil's half- day public educational system also may contribute to the em- ployment of children. ³² Because most parents in the informal workshops cannot afford child care, their children often spend the rest of the day helping them at work. The ILO Vale dos Sinos report indicates that 27 percent of children surveyed worked before or after school because they had "no other place to go." ³³ Some municipal governments and NGOs have responded to this dilemma by establishing complementary activities for children during non-school hours. ³⁴

A 1994 report on child labor in Franca found that 73 percent of 7-14 year olds who worked and studied were employed in the footwear industry; most of these children worked in home production. ³⁵ Visits by U. S. Department of Labor officials to small workshops and production facilities in Franca confirm that child labor may still be a problem in footwear production. ³⁶ However, it appears that the number of child laborers has decreased from just a few years ago when Franca was dubbed Brazil's "capital of child labor." ³⁷ This reduction is reportedly the result of a variety of economic, social, and political developments. Among these are plant closings in the footwear industry, which have reduced labor demand and created a pool of skilled, unemployed adult workers. ³⁸ To the extent that some firms are attempting to raise quality and productivity through increased investment in automation and in-plant production, this has also reduced the opportunities for child labor. ³⁹ Finally, it appears that, especially in the city of Franca, partnerships between government, industry, union, and NGO representatives to combat child labor have been instrumental in increasing awareness of the problem and reducing its incidence. ⁴⁰

However, the reports mentioned above and U. S. Department of Labor interviews with numerous representatives from NGOs, unions, government, and industry, confirm that children continue to work in Brazil's footwear industry. According to the Ministry of Labor, the multi-layered structure of production, the high mobility of small suppliers, and the existence of household producers has made it difficult for Ministry of Labor inspectors to locate children working in this sector. ⁴¹ These same factors have complicated efforts to determine the number of children working in footwear production and overall trends in child labor. Further study is required to assess the scale of the child labor problem and the impact of both public and private efforts to combat it. ⁴²

China

The closed nature of the Chinese political system and a lack of statistical data make it very difficult to obtain reliable information about the incidence of child labor in China as a whole, or the leather footwear industry in particular. A recent report by the ILO International Program on the Elimination of Child Labor (IPEC) states that "although child labour is certainly not yet that much entrenched in China as in many other countries in the region, it is a growing problem." ⁴³ According to IPEC, the problem seems to be more prevalent in the southern coastal cities, mainly because that region has been developing rapidly. ⁴⁴ Because there are virtually no available data on child labor in China, most reports are based on anecdotal information. ⁴⁵ In some cases, estimates of the incidence of child labor are based on other indicators such as school attendance. ⁴⁶ Information received by Department of Labor officials visiting China indicates that child labor may not be very prevalent in the foreign-invested enterprises of the special economic zones (SEZs) where most of the production of exported footwear takes place. ⁴⁷ The reportedly low incidence of child labor in the Chinese leather footwear industry may be attributed to a significant number of adult workers seeking these jobs, the one-child-per-family policy, and the societal importance placed on education and mandatory schooling. Child labor, however, may be more common in family enterprises in rural areas or in private enterprises or township and village enterprises. ⁴⁸

Generally, child labor in the Chinese leather footwear industry has not been among the labor concerns raised by NGOs and international organizations, but there have been reports of forced overtime, minimum wage violations, corporal punishment, and safety and health hazards. ⁴⁹ A recent study of the footwear industry in China by the Asia Monitoring Resource Centre and the Hong Kong Christian Industrial Committee, non-governmental monitoring groups, concludes that "compared with our research on the shoe factories in 1995, conditions today are even worse... . All categories of [Nike and Reebok's] Code of Conduct health and safety, freedom of association, wages and benefits, hours of work, overtime compensation, nondis- crimination, harassment and child labor are being violated." ⁵⁰ While the report made no allegations of use of child labor in Reebok factories, Nike and Reebok have both challenged the veracity of this report and have each issued point by point rebuttals to several of its claims, including those regarding child labor.

India

In recent years, a number of reports have noted the use of child labor in India's leather footwear and tanning industries. For instance, a 1995 study estimated that children under 15 make up a significant portion of the leather workforce in the towns of Agra, Kanpur, Durg and Tonk. ⁵¹ These children reportedly make up 40 percent of flayers, 34 percent of tanners, 39 percent of manufacturers and repairers, and 36 percent of wage earners. ⁵² Recent reports from Mumbai [Bombay] indicate that children can be found assembling shoe components in subcontracting shops — particularly in Dharavi, a slum area notorious for using children in its leather and shoe-making units. ⁵³ Many of the persons visited by a U. S. Department of Labor official in June 1997 acknowledged that children can be found in the cottage workshops of India's leather footwear industry.

Human Rights Watch/ Asia (HRW) reported in 1996 that the use of child labor in India's footwear industry may be growing. HRW reports that between 2,000 and 20,000 bonded child laborers — some as young as 6 or 7— are currently working in footwear production in the slums of Mumbai [Bombay]; these children are trafficked from the rural villages of Rajasthan. The HRW report describes the employment of children in footwear production as follows:

The slum . . . was a place of appalling squalor. The amount of footwear garbage — leather, plastic, and rubber — indicated a sizeable amount of production. The children do not make complete shoes, but their components. We saw children tracing heels on wooden two by fours and cutting them out with motorized saws; cutting women's leather uppers out of leather sheets; stamping brand names on the insoles of shoes and sandals; making the straps and uppers together; sewing uppers to insoles on sewing machines; stamping insoles out of sheets; stamping out soles (leather, rubber, wood); and transporting finished products to wholesalers. Every process involved in the manufacture of this footwear was done by children. Their work days begin at 5: 00 or 6: 00 a. m. and continue until 10: 00 or 11: 00 p. m. The children receive no wages; instead, their parents receive a [small] payment at the time the child is taken away. ⁵⁴

There are also reports of children working in India's leather tanning industry — particularly in Rajasthan, Madhya Pradesh, ⁵⁵ Andhra Pradesh ⁵⁶ and Tamil Nadu. Evidence suggests that thousands of children may be employed in leather tanneries in Tamil Nadu — some estimate that in the town of Dindigul alone, 30 percent of the tannery labor force is children, many of whom work with dangerous chemicals without any protective clothing. ⁵⁷ The numbers may be greater in Andhra Pradesh. ⁵⁸ One report of children working in tanneries that supply products for the export market describes children cleaning chemical drums and placing hides inside the drums. In one such case, a child fell asleep while cleaning a drum and was killed when the drum was subsequently reemployed and refilled with chemicals. ⁵⁹

Mexico

Child labor in the Mexican footwear industry has been reported for a number of years. In 1994, a Wall Street Journal reporter found children as young as 10 working 8 hour days gluing soles to shoes in small factories in the state of Guanajuato. ⁶⁰ A report by Defense for Children International also noted that the athletic and casual shoe industry of León, in the State of Guanajuato, employed numerous children who worked with hazardous materials without protective wear. ⁶¹

Statistics on the incidence of child labor in the Mexican leather footwear industry are not available. However, interviews with NGOs, industry representatives, and labor unions in June 1997 indicate that there is an extensive child labor problem in the household production of leather footwear. ⁶² In the states of Guanajuato and Jalisco, it is a practice of the footwear industry to subcontract the stitching of uppers (for moccasin style shoes) to household production. ⁶³ Some factory managers indicated that the children usually help with the work only after school, but that there were no instructions or subcontract provisions on the use of child labor.

Pakistan

A number of allegations have been made about child and bonded labor in the Pakistani leather and footwear industries which are concentrated in the cities of Lahore and Karachi. In 1994, the International Textile, Garment & Leather Workers Federation reported that children 10 and 11 years old were sick and deformed from years of sniffing glue while working in a shoe factory. ⁶⁴ A recent study of leather tanneries in Kasur found children as young as six working for 10 hours a day in filthy and dangerous conditions:

Children yanked out hair from salted hides and skins with bare hands; they loaded and unloaded raw and semi- finished hides into and from large rotating drums; some of them had to disappear into the drums to retrieve semi-finished hides which stuck to the walls of drums reeking of poisonous gases; some of them transported filthy hides within the tannery from one process to the other; elder children peeled off waste from raw hides; and mixed dangerous fuming chemicals into buckets, simply pouring them into drums and small ponds; on the roof tops many small children spray painted leather pieces, inhaling formaldehyde and depositing layers of spray in their hair; their clothes coated in several shiny layers of black and brown. ⁶⁵

Employment of children in the leather and footwear industries is prevalent in small, family-owned workshops. About 1,500 children are estimated to be working in family owned leather tanneries in Kasur (near Lahore). ⁶⁶ The use of protective clothing is not widespread among the children (or adults) working in these tanneries. ⁶⁷

According to interviews with government, business, labor and NGO representatives, one of the major factors contributing to the incidence of child labor in Pakistan is the lack of compulsory education. Some of the major problems relate to access, quality, affordability and rigidity of the formal education system. ⁶⁸ In a survey conducted in Kasur, children who work in tanneries had a school dropout rate of 63 percent, while the average time spent in school was one year. ⁶⁹ These children gave a number of reasons for leaving school: physical abuse by teachers; teachers forcing students to do domestic chores at their homes; boring classes, and parents pulling children out of school for economic reasons.

Subcontracting (or outsourcing) seems to be prevalent in footwear production and leather tanning. A number of footwear manufacturers acknowledged that children may be found working in footwear production on a contract basis. ⁷⁰ A 1995 report by the Human Rights Commission of Pakistan found that while most children worked in the smaller tanneries (usually in groups of 5 to 15), larger tanneries also employed children. ⁷¹ These children, who were almost entirely employed on a contract basis, earned $7.50 to $15 per month. As in India, it appears that in Pakistan subcontracting shoe production and leather processing services to small, family owned enterprises is used to avoid prosecution under child labor laws. ⁷² Currently, production of leather goods and footwear in Pakistan is mostly for domestic consumption although some of the production is exported. A number of exporters stated that they plan to expand exports to the United States, particularly of leather garments.

D. Consumer Labeling Programs in the Leather Footwear Industry

1. Introduction

Although private-sector initiatives to reduce child labor in the leather foot- wear industry exist in many countries, partnerships to eliminate child labor are notable in Brazil and Italy. In Brazil, government, industry, labor union, and NGO efforts have helped to reduce the number of children working in the footwear industry. In particular, programs of the Abrinq Foundation for Children's Rights and the Pro-Child Institute have raised awareness among Brazilian footwear producers about child labor and encouraged the development of educational and rehabilitation programs to address child labor issues. The labeling programs of the Abrinq Foundation and Pro-Child Institute are described below.

In March 1997, the Italian Association of Leather Manufacturers and the textile and leather working unions of the three major labor confederations signed an agreement to develop a certification process to guarantee consumers that leather products were manufactured without the use of child labor. The agreement also includes provisions on establishing some type of "mark" to signify that a product was manufactured without any child labor. ⁷³

The Italian agreement calls for the establishment of an independent auditing agent to certify the conditions under which products bearing the mark are made. Companies which are members of the Italian Association of Leather Manufacturers will be inspected and clauses will be inserted into any subcontracts that the companies have providing for the termination of services if child labor violations are found. ⁷⁴ Strategies for promoting the mark in Italy and other parts of Europe are now being evaluated. In addition, a study is underway to determine whether the mark should be placed on the products themselves or used as a certification for products being distributed through authorized outlets. Sponsors of the agreement see it as a follow- up on their commitment under the Italian National Agreement Against Child Labor of 1996 to eradicate child labor and as a way of cutting down sales of counterfeit or competing products made in the underground economy, where labor standards are low. ⁷⁵

2. Abrinq Foundation for Children's Rights

a. Program Overview

The Abrinq Foundation for Children's Rights (Abrinq) is a non- profit organization established in 1990 in São Paulo by members of Brazil's Association of Toy Manufacturers. Abrinq's mission is to "move and mobilize society regarding childhood matters, promoting social and entrepreneurial engagement to address child welfare issues through political actions in defense of children's rights and through exemplary actions which may be disseminated and multiplied." ⁷⁶

The Abrinq Foundation is comprised primarily of Brazilian entrepreneurs, political and social scientists, academics, and other professionals who provide financial support and/ or technical advice to the Foundation. Abrinq receives funding and in kind contributions from a number of sources, including Brazilian companies, in- ternational organizations, and individuals. ⁷⁷ Many of the contributions are project-specific and involve the participation of the contributing entity. Abrinq's strategies include: political action, publicity, project development, and fundraising for programs which benefit children. The Foundation focuses on a number of child welfare issues, including health and nutrition, education, child labor, family and community, and rights advocacy.

In April 1995, the Abrinq Foundation created the Child-Friendly Company Program ( Programa Empresa Amiga da Criança ) aimed at eradicating child labor and promoting child- friendly policies in a number of Brazilian industries. This program, which includes a labeling component, encourages companies to eliminate child labor and invest in projects which improve the quality of children's lives.

Some of the sectors participating in this program include services (restaurants, parking garages, photo developing establishments), finance (credit card companies and banks), and manufacturing (toys, shoes, automobiles). Companies that are certified as "child-friendly" are allowed to use the Child- Friendly Company label, which reads: " Child-Friendly Company – An Initiative of the Abrinq Foundation for Children's Rights. " The label signifies that no child labor was used in the production of the company's goods or services and that the company has developed or is contributing to a project that benefits children. Child-Friendly Companies use the label at their own discretion. For example, the label may be placed on products, packaging, or a company's advertisement and promotional materials. Although a number of companies in the program export goods to the United States, there are currently no products being exported to the United States with a Child- Friendly Company label. ⁷⁸

b. Program Structure

The Abrinq Foundation is responsible for overseeing the implementation of the Child- Friendly Company certification and labeling program. The Foundation has very specific eligibility criteria that companies must meet prior to joining the labeling program. These include: ⁷⁹

• making a formal commitment not to use child labor, as defined by Brazilian law;
• promoting this commitment to their network of suppliers and clients; and
• creating or supporting programs to educate and train children.

The process by which companies are certified is as follows: ⁸⁰

• interested companies sign a commitment letter and provide the Abrinq Foundation with documentation demonstrating that they meet the eligibility criteria;
• the Abrinq Foundation reviews this information and, in the case of companies in industries with a high incidence of child labor (e. g., sugar and footwear production), consults with its network of partners, which includes labor unions, employers associations, NGOs, and public officials; ⁸¹
• the findings of the initial review undergo an internal review process conducted by Foundation representatives and business persons on the Foundation's Administrative Council; and
• companies that successfully complete the review process are provided with a certification letter and a copy of the artwork for the label during a public ceremony certifying them as a Child-Friendly Company. ⁸²

The certification and label are valid for one year. The company may be re-certified by reiterating its commitments and undergoing a new investigation by Abrinq along the lines of the above-mentioned review procedures. A decertification process has also been established through which reports of child labor violations are investigated by the Foundation. Companies are given 30 days to correct violations, and if unsuccessful, are removed from the program and denied use of the label.

Child-Friendly companies do not pay fees or dues to the Abrinq Foundation in order to participate in the labeling program. The Child-Friendly Company program is financed through a grant provided in 1995 by Yakult S. A., a Japanese company which produces dairy products in Brazil. ⁸³ This grant allowed Abrinq to establish and finance the operation of the certification and labeling program. This unique funding structure gives the Child-Friendly Company program a significant amount of independence. However, because the funds provided by the initial grant are limited, Abrinq is currently searching for new sources of funding for the program.

c. Program Implementation

Currently, the Abrinq Foundation cooperates with about 1,700 firms on specific projects. The Child-Friendly Company program has about 380 participating companies. Approximately 40 of these companies are manufacturers of leather footwear, nearly all located in the city of Franca. ⁸⁴

One of the main components of the Child-Friendly Company program is a label indicating that the participating company has not used child labor in the production of its goods or the provision of its services. In the case of Abrinq, the label is part of a certification program for the company and not for a specific product. Child-Friendly companies are also expected to promote the non-utilization of child labor to their network of suppliers. The certified companies, however, are not required to include a "child labor-free" clause in contracts with their suppliers or to verify that services that have been subcontracted were performed without illegal child labor.

Another aspect of the Child-Friendly Company program is the development or financing of educational and training programs for children. The Abrinq Foundation provides information to interested companies on the types of projects previously established by other companies. These social programs are not necessarily targeted to former child workers. Many Child-Friendly companies provide child care services and sports/ recreational facilities for after- school programs and fund professional and technical training projects. ⁸⁵

The Abrinq Foundation raises awareness about child labor issues through newspaper advertisements, television and radio commercials, publications, and mass mailings. Companies are educated about the Child-Friendly program's requirements through training workshops conducted by the Abrinq Foundation staff as well as informational materials aimed at marketing the Child-Friendly Company label.

As discussed above, the Abrinq Foundation has an extensive pre- screening system to certify Child- Friendly companies. However, once the companies join the program, there are no formal monitoring procedures to ensure adherence to the certification and labeling program's requirements. The Child-Friendly Company program was designed to be "self- monitoring" and, in essence, relies on Abrinq's network of partners (e. g., labor unions, NGOs, workers, public attorneys, etc.) to notify the Foundation of possible child labor law violations. To date, Abrinq has not received any allegations of child labor law violations by a Child-Friendly company.

d. Findings from Site Visits

It is difficult to determine the level of public awareness about the certification and labeling program. Abrinq is currently developing an educational campaign to inform consumers about the Child- Friendly Company program and encourage consumers to buy products and use services that contain the label. The Foundation would like to have a larger number of participating companies prior to launching this campaign. Interviews with government, labor union, and NGO representatives indicate that those who were familiar with Abrinq's labeling program appear to have a positive perception of the Foundation's efforts to help children.

Although information about the program's goals and requirements is pro- vided to the companies, it appears that this information is not communicated to the workers of some of the participating companies. Interviews with workers and labor union representatives in June 1997 indicate that some of Abrinq's "network of partners" ⁸⁶ may not be aware of the certification and labeling program or the role they can play in monitoring the implementation of this program. For instance, some labor leaders in Franca were not familiar with Abrinq's labeling program or which footwear companies were participating in the program. Similarly, some workers for Calçados Samello did not know that this company was a Child-Friendly company. Overall public awareness seems essential to the labeling program since the effectiveness of Abrinq's self-monitoring policy depends on how well-informed all interested parties are about the Child-Friendly companies and the commitments they have made.

While Abrinq emphasizes the importance of examining the chain of production when addressing child labor issues, the agreement between Abrinq and its Child-Friendly companies only requires a commitment to work with suppliers and not an obligation to cease doing business with suppliers or subcontractors who use child labor. Abrinq officials acknowledge it is possible that suppliers of Child-Friendly companies may be using child labor. Some of the subcontracting arrangements U. S. Department of Labor officials observed in Franca and Novo Hamburgo could easily lead to this type of situation. For example, one government official in the city of Franca noted that child labor is not found in the larger firms which directly export to the United States, but children can still be found working in the small workshops that supply products and services to many of the large firms. ⁸⁷ Nevertheless, Abrinq works with companies to maintain their commitment to promote the elimination of child labor throughout the production chain. For example, when Abrinq learned that a supplier for one of its Child-Friendly companies was to be sued by a local district attorney for child labor violations, the Foundation provided guidance to its member company and helped to get the supplier to agree to eliminate the use of child labor. ⁸⁸

Because Abrinq's labeling program is relatively new, it is difficult to assess the impact of the program in reducing child labor in the footwear industry. However, the Abrinq Foundation has been instrumental in raising awareness among footwear producers and encouraging them to create educational and recreational projects which benefit children. Abrinq also has strived to encourage industry associations and other NGOs to develop similar programs aimed at eradicating child labor. Abrinq assisted the Pro Child Institute in the creation of a footwear labeling program in Franca and is currently providing technical assistance to the industry association of Novo Hamburgo in its effort to create a footwear industry code of conduct.

3. Pro- Child Institute

a. Program Overview

The Pro-Child Institute ( Instituto Empresarial de Apoio a Formação da Criança e do Adolescente "Pro- Criança" ) is a non-profit organization founded in November 1995 by business persons in the city of Franca, Brazil. The Institute was founded by the Footwear Industry Association of Franca, the Trade and Industry Association of Franca, and the Regional Delegation of CIESP ( Centro das Indústrias do Estado de São Paulo ), a statewide industry association. In October 1996, the Pro-Child Institute launched the "Program for the Prevention and Eradication of Child Labor in the Footwear Industry," which has as its main objectives the development of actions to: (1) prevent and eradicate child labor; (2) encourage and support children to stay in school, while raising awareness among the general public about the importance of formal education; and (3) encourage and support the professional and technical training of adolescents. ⁸⁹

One of the components of this program was the development of a Pro-Child label which is placed on footwear products to indicate a company's adherence to the program's objectives. The label, which has been reproduced in Portuguese, English and Spanish, reads: " Pro-Child Institute – No Child Labor was Used in the Manufacture of this Product." Footwear manufacturers may place the label on the packaging, boxes, and tags of footwear products after obtaining authorization from the Pro-Child Institute. Companies participating in the program must:

• make a formal commitment not to use child labor;
• not subcontract services with suppliers who use child labor;
• encourage a no- child labor policy throughout its chain of production;
• be a contributing member of the Pro- Child Institute;
• adhere to the Institute's regulations regarding the use of the label; and
• place a no- child labor clause in contracts with other manufacturers and encourage them to also become members of the Pro-Child Institute.

In the context of the Pro-Child Institute labeling program, child labor is defined in accordance with Brazilian law, which prohibits the employment of children under the age of 14. Child labor is the only labor standard covered by the labeling program, and it applies to the production of both the finished product and chain of production inputs.

Currently, the Pro-Child Institute's labeling program is only operating in Brazil. Footwear manufacturers have initiated discussions with importers in the United States and other countries to start exporting footwear that contains the Pro-Child Institute label. ⁹⁰

b. Program Structure

The Pro-Child Institute, which has seven staff members, oversees the implementation of the labeling program. The program operates as follows:

(1) Companies interested in joining the Institute sign a letter of commitment to participate in the Program to Prevent and Eradicate Child Labor in the Footwear Industry;

(2) The Pro-Child Institute provides each company with a certificate which outlines its commitment not to use child labor in the manufacture of its products, to develop programs which benefit children and adolescents, and to be a contributing member of the Institute;

(3) The companies also sign a number of documents regarding the appropriate use of the label.

The Institute has established procedures for de- certification if a company is found to have violated any of the requirements listed above. The procedures involve a written warning and a notice to rectify the situation within 30 days. If the alleged violation is not resolved within the allowed period of time, the company is then de-certified and the use of the label is prohibited. To date, no company has been investigated or de-certified for an alleged violation of the program's requirements.

The operational cost of the Pro- Child Institute is approximately $30,000 monthly. ⁹¹ The Institute's operational costs, as well as the labeling program, are financed through private- sector contributions to the Pro-Child Institute. ⁹² Most of the contributions are made by members of the Institute who may also participate in the labeling program. The contributions are made monthly and range from $50-$200, depending on the size of the company. These funds also cover staff salaries and some children's projects sponsored by the Institute. There is no direct government involvement in the operation of the labeling program. However, the Institute receives technical assistance from a number of governmental organizations including: the Office of the Mayor of Franca, the Federal Department of Commerce and Industry, and the Federal Department of Education, Culture and Sports. International organizations such as the ILO and UNICEF also provide technical assistance.

c. Program Implementation

As of January 1997, the Pro-Child Institute had certified 67 companies, with 59 of these companies currently participating in the labeling program. ⁹³ According to the Industry Association of Footwear Manufacturers of Franca, about 70 percent of its members are contributing members of the Institute, although not all of them participate in the labeling program. ⁹⁴ The Institute and the manufacturers interviewed indicated that the cost of participating in the labeling program (including contributions to the Institute and the cost of placing the label in the packaging or boxes of footwear products) is so insignificant that producers absorb the expense without passing it along to consumers in the form of increased prices.

The implementation and monitoring of the labeling program is carried out by the Institute's staff which includes a six-member executive directorate and a managing director. As part of its pre-screening procedures, the Pro-Child Institute conducts site visits to companies that have applied for membership in the labeling program. The Institute's monitoring procedures include announced and unannounced visits to the certified companies, regular meetings with the companies, and periodic reports on the labeling program provided to the Municipal Councils for the Defense of Children and Adolescents Rights, ILO/ IPEC, UNICEF, the U. S. Consulate General in São Paulo, and the Abrinq Foundation. ⁹⁵

The Institute conducts periodic workshops and meetings to educate partici- pating companies about the labeling program. During these meetings, manuals and other informational materials are distributed to certified companies. The manuals contain general information about the labeling program's requirements, suggestions on how to use the label, and updates on the educational/social projects being sponsored by the Institute on behalf of children and adolescents. The Pro-Child Institute has developed a series of educational and social projects for children and adolescents. These projects include: a health center for adolescents, resource centers for children between the ages of 7 to 12, vocational training centers, and recreational programs. Many of these projects serve as complementary activities to Brazil's four-hour school day.

d. Findings from Site Visits

Although it is difficult to assess the impact of the labeling program in reducing child labor, the Pro-Child Institute seems to have been effective in raising aware- ness among the larger footwear manufacturers in Franca. ⁹⁶ In addition, the rehabilitation programs sponsored by the Institute are reaching some of the target population – children between the ages of 7 to 14. The Pro-Child Institute has also been very active in sharing its experiences with other footwear producing regions. The Institute is currently working with the Abrinq Foundation and the local footwear industry association in Novo Hamburgo to develop other initiatives that address child labor in footwear production.

According to the managing director of the Pro-Child Institute, the Institute uses a "natural inspection" process which is based on the concept of self-monitoring. The Institute may conduct unannounced visits to production facilities, but it primarily relies on various inspection and monitoring mechanisms already in existence, including "denuncias" or complaints of child labor made by labor inspectors and unions. Representatives of companies who visit suppliers on a regular basis are also asked to monitor the use of child labor.

Through interviews conducted in Franca, it appears that neither the Institute nor the participating companies have developed procedures to inform workers about the labeling program's guidelines and objectives. Of the three companies visited in Franca, only one, Samello, indicated that workers were informed about the company's code of conduct and membership in the Pro-Child Institute. Workers interviewed had seen a Pro- Child Institute poster at the Samello plant; however, they were not aware of the labeling program's details. Some of the workers confused a "Made in Franca" label with the Pro-Child Institute label. Even though Samello has been certified as a Child-Friendly company and is a member of the Pro-Child Institute, the company does not currently place either label on its footwear products.

The Pro- Child Institute requires that member companies encourage a no-child labor policy throughout the chain of production. Multiple layers of suppliers and the use of intermediaries ( gatos ) make dissemination of information and monitoring of companies' policies very difficult in the footwear industry. It appears that information about the labeling program may not be reaching the smaller firms and workshops (suppliers and subcontractors) that appear to be the main employers of children. To address this situation, the Pro- Child Institute is planning an initiative to increase awareness about child labor issues among footwear subcontractors in Franca. ⁹⁷

E. Codes of Conduct in the Leather Footwear Industry

Voluntary codes of conduct have been in existence in the footwear industry for a number of years and are increasingly common among footwear manufacturers and retailers. In 1992, Reebok International was one of the first companies to initiate a formal, worldwide code of conduct concerning the treatment of workers who are employed by foreign suppliers. In August 1993, the Athletic Footwear Association (AFA) developed a statement of guidelines on practices of business partners. ⁹⁸ The statement includes a number of voluntary guidelines — environmental, ethical, health and safety, legal and employment. One provision of these guidelines states that AFA members will not do business with contractors or suppliers who use child labor. ⁹⁹ Similarly, in March 1995, a Charter on Child Labour for the footwear industry was adopted in Europe. ¹⁰⁰ In April 1997, leaders from the U. S. footwear and apparel industries, labor unions, and consumer, human rights, and religious groups also agreed on a workplace code of conduct. ¹⁰¹

In the last few years, a number of footwear companies have included provisions in their corporate policies that govern the production of footwear imported into the United States. Some of these companies have publicly  available, well-defined codes of conduct describing the companies' policies regarding child labor and other labor standards. Other companies do not have formal codes but include child labor provisions on their purchase orders and other contractual documents. This section discusses the implementation of these policies by examining three basic elements: transparency, monitoring and enforcement. ¹⁰² Transparency refers to the awareness and understanding of the policies by foreign contractors, subcontractors, and workers. Monitoring refers to how companies oversee the implementation of their policies. Finally, enforcement refers to how companies deal with violations of their policies.

In order to gather information on the extent and implementation of codes of conduct and labeling programs regarding child labor in the U. S. footwear industry, the U. S. Department of Labor conducted a voluntary survey of 20 U. S. producers, design/marketing firms, and retailers of leather footwear products. ( See Box III-1 for a list of the companies surveyed and Appendix B for the Company Questionnaire). These companies were chosen using information from Kurt Salmon Associates. ¹⁰³ The survey instrument was also discussed with the Footwear Industries of America and the Footwear Distributors and Retailers of America. The selection criteria included total sales, overseas production facilities or suppliers, and known codes of conduct. Information obtained from the survey and from Department of Labor site visits to production facilities in Brazil, China, India, Pakistan and Mexico is reported below. Sixteen companies responded to the survey: Adidas, Brown Group, Edison Brothers, Fila, Footstar, Genesco, JCPenney, May Department Stores, Nine West Group, Nike, Payless, Reebok, Stride Rite, Timberland, WalMart, and Wolverine.

1. Survey Results and Information from Site Visits

All of the respondents indicated that they import footwear directly from foreign footwear manufacturers. Twelve of these respondents stated that they also use buying agents or overseas buying offices to purchase footwear. Only one of the respondents, Timberland, indicated that it owns footwear manufacturing facilities abroad.

None of the survey respondents participate in a labeling program or import labeled footwear which claims to be child labor-free. Although codes of conduct have been in existence for a number of years in the footwear industry, labeling is a relatively new concept that has not been embraced by U. S. importers and retailers of leather footwear, and in fact, has been generally opposed. For example, the Foot- wear Distributors and Retailers of America recently stated that "the use of labels may create a variety of problems which will greatly outweigh their utility, and that other means of communicating with customers about [child labor] and other issues are far preferable." ¹⁰⁴ However, many Brazilian companies whose principal U. S. importers include JCPenney, Cole Haan [Nike], Nine West, Fila, Brown Group, Edison Brothers, Sears, and Genesco ¹⁰⁵ are already producing footwear for Brazilian consumption under one of the two child labor-free labeling programs discussed earlier in this chapter. Representatives of the Footwear Industry Association of Franca, who have been promoting one of the labeling initiatives in Brazil, noted that many U. S. importers have not wanted to import labeled footwear into the United States. ¹⁰⁶

Nevertheless, all of the companies that responded to the survey have developed and implemented some type of corporate policy prohibiting the use of child labor in the manufacture of their products. ¹⁰⁷ ( See Appendix C for copies of these policies). These policies are usually articulated in the form of codes of conduct, vendor standards, or statement of principles. Table III-2 illustrates the type of policies that are being used by respondents to prohibit child labor in the manufacturing of leather footwear.

TABLE III-2
Type of Policy Prohibiting Child Labor
(Based on Responses to Department of Labor Questionnaire)

^a Company has a formal code of conduct, statement of principles or compliance certificate

^b Company has a purchase order, letter of credit, or buying agent agreement, ehich contains a specific prohibition on child labor in overseas production.

Codes of conduct differ with respect to how child labor is defined. Respondents use a variety of methods to define child labor including "national law" and "international standards." Most of the respondents defined child labor as employment under the age of 14 or in accordance with domestic law. Only one of the respondents (Wolverine) defined it as employment under the age of 16.

a. Transparency

Foreign manufacturers' awareness of U. S. importers' corporate policies vary from country to country.

• In Brazil, there was only limited awareness about U. S. importers' codes of conduct. Calçados Agabê officials stated that they had received a copy of  JCPenney's code but were not able to provide a copy. ¹⁰⁸ The Nine West buyer in Brazil stated that the company does not currently have a code of conduct or written statement regarding child labor in the manufacture of its product. ¹⁰⁹ Another Brazilian company, Calçados Paquetá, producing for JCPenney and Nine West, was not aware of any written policies from these companies regarding child labor or general working conditions. ¹¹⁰ Most of the large companies interviewed, however, were participating in one of the two child labor-free labeling programs currently operating in the footwear industry.
• In China, Nority, Ltd., which produces for Reebok, Fila and Nortica, was very familiar with Reebok's Human Rights Production Standards but was not aware whether Fila or Nortica had a code of conduct. ¹¹¹
• In India, one of the companies visited, India Shoes, producing Nunn Bush brand footwear, indicated that it had received a code of conduct from its U. S. importer but was unable to provide a copy of the code. ¹¹² FlorInd, an Indian subsidiary of Florsheim, noted that it operates under a "standing order" from headquarters not to use child labor in the production of footwear. ¹¹³  Another company, Chevro Shoes producing for Wolverine, indicated that it was not aware of Wolverine's code of conduct but it had a "gentlemen's agreement" not to employ children. ¹¹⁴ According to Chevro representatives, the use of child labor was one of the first issues raised by Wolverine representatives before subcontracting with the company. K. H. Group, producing Hanover, Wolverine, and Cole Haan (Nike) shoes, did not appear to be aware of the codes of conduct of its U. S. footwear importers but had received a code from Sara Lee for the manufacture of Coach leather bags. ¹¹⁵ One of WalMart's subcontractors in India, Tej Shoe, was not aware of the WalMart code of conduct. ¹¹⁶
• In Mexico, nearly all of the footwear producers interviewed were unfamiliar with the codes of conduct of their U. S. importers including WalMart, Timberland, and H. H. Brown. ¹¹⁷ Only one company, Calzados Celis, producing for Stride Rite, was able to provide a copy of a Stride Rite/ Footwear Distributors and Retailers of America Manufacturers Certificate ¹¹⁸ which included a statement on child labor.

A number of the respondents (Nike, Payless, Reebok and WalMart) indicated that their policies are required to be posted in the production facilities of their suppliers. In addition to requiring its vendors to post the code in a visible area for all employees, WalMart also provides a telephone number for reporting allegations of code violations.

• In Brazil, only one of the companies interviewed by U. S. Department of Labor officials, Calçados Samello, stated that its child labor policy is communicated through posted signs and during periodic meetings with workers. ¹¹⁹
• Two other companies, Calçados Agabê (producing for JCPenney) and Calçados Paquetá (producing for JCPenney and Nine West), do not post or inform their workers about U. S. importers' codes of conduct.
• In China, U. S. Department of Labor officials observed that Nike's code of conduct was posted both in English and Chinese in the Pegasus factory that produced for Nike. Nority, Ltd., which produces for Reebok and Fila, only had the Reebok code of conduct posted.
• In India, K. H. Group, producing for Hanover, Wolverine and Cole Haan (Nike), was not aware of any of its U. S. footwear importers' codes and therefore did not post them. Similarly, Tej Shoe, a WalMart subcontractor, was not aware of and did not post WalMart's code of conduct.

A number of the respondents' policies address child labor in the chain of production (subcontracting operations), including Adidas, Edison Brothers, Fila, May Department Stores, Reebok, Stride Rite, WalMart, and Wolverine. For example, Wolverine prohibits use of child labor by its partners or sources and their sources or vendors. Edison Brothers and Stride Rite do not accept goods from partners that use child labor in any manner. Adidas also states it requires manufacturers to ensure that subcontractors comply with all applicable laws, including those prohibiting child labor.

• The Adidas representative in Brazil, however, stated that Adidas' child labor policy is not communicated to its subcontractor because child labor is not a problem and adult labor is readily available. ¹²⁰
• In India, Chevro Shoes, producing for Wolverine, and K. H. Group, producing for Hanover, Wolverine and Cole Haan (Nike), sometimes subcontract the manufacture of footwear to household producers who are often company employees, and where children may help out in production.
• In Mexico, Calzados Celis, producing for a number of companies including Stride Rite, subcontracts the stitching of uppers, moccasin style shoes to household production and acknowledges that child labor may be a problem in home production. ¹²¹
• Firhaj Footwear, a Wolverine subcontractor in Pakistan, stated that the company had been asked to certify that child labor is not used in the production process; the certification was requested in letters of credit issued by the banks of European importers. Firhaj Footwear also provided a copy of a letter from its corporate headquarters stressing the importance of complying with child labor laws and ordering strict compliance.

b. Monitoring

Monitoring procedures used to oversee the implementation of the codes of conduct differ among the survey respondents. Some of the respondents (Nike, May Department Stores, Reebok, and WalMart) indicated that they conduct pre-screening inspections to ensure that foreign suppliers have the capacity to implement their codes of conduct. The monitoring strategies used by the companies surveyed include contractual monitoring (self-certification by foreign manufacturers), internal monitoring (e. g., in-country site visits and inspections by the company's employees or representatives), external monitoring (site visits and inspections by external par- ties, such as NGOs and auditing firms) or a combination of these strategies. Table III- 3 illustrates the different monitoring strategies used by U.S. importers and retailers of leather footwear surveyed.

All of the survey respondents indicated that they monitor overseas facilities for compliance with their corporate policies. The type and frequency of the monitor- ing differs among companies. The companies use their quality control personnel (in some cases buying agents or company representatives) to also oversee compliance with labor standards; this is a form of internal monitoring. In addition, three of the companies (Nike, Reebok and WalMart) use external monitors. Visits to overseas production facilities are conducted at least once a year and may be unannounced. One of the respondents, May Department Stores, indicated that visits by buying agents are conducted as often as six times per year; two of these visits are unannounced.

• In Brazil, the Nine West buyer relies on the Ministry of Labor inspectors to oversee compliance with labor laws while JCPenney reportedly makes unannounced visits to Calçados Agabê at least once a year to verify code compliance. ¹²²
• In China, Pegasus International indicated that Nike regularly inspects its facility but that its other buyer, Dr. Scholl's (Brown), has clauses in its contracts but never checks for compliance with those conditions. ¹²³
• Chevro Shoes, the Wolverine subcontractor in India, indicated that Wolverine conducts regular inspections of the production facilities. ¹²⁴ Similarly, Tej Shoe, producing for WalMart, noted that it receives frequent visits from WalMart representatives. ¹²⁵ K. H. Group, producing for Hanover, Wolverine, and Cole Haan (Nike), also indicated that it receives frequent inspections but did not specify by which of the U. S. importers. ¹²⁶

TABLE III-3
Monitoring Strategies for Compliance with
International Child Labor  Policies
(Based on Responses to Department of Labor Questionnaire)

^a Company relies on guarantees made by suppliers through contractual documents or certificates that they are adhering to the company's policies.

^b Company uses site visits and inspections by company staff, buyer agents, or other parties to verify that suppliers are actually implementing the codes of conduct.

^c Company uses external accounting, auditing, testing or consulting firms, NGOs or international organizations to monitor labor practices

¹ Company reported that an internal monitoring program is currently being developed.

² Company reported that its plans to start using external monitors in the near future.

Contractual monitoring (manufacturer's certification or purchase order re- quirements not to use child labor), in conjunction with site visits and inspections, is used by 14 of the respondents. 

• In Brazil, the Nine West buyer stated that there are no written agreements with subcontractors, except for purchase orders, and that business arrangements are based on well- established personal relationships with manufacturers. ¹²⁷
• In Pakistan, Service Industries stated that their European wholesale purchasers have asked them to certify that Service's products do not include child labor in the production process.

c. Enforcement

Enforcement refers to how companies deal with violations of their corporate policies. Most of the survey respondents indicated that willful non-compliance with the companies' policies may result in canceled orders or termination of the business relationship. ¹²⁸ Many of the survey respondents have included enforcement provisions in their codes of conduct. Edison Brothers' code of conduct, for example, states that if a violation of any provision of the code is discovered, an investigation into the alleged violation may be conducted and corrective measures imposed. Corrective measures could range from termination of the order, merchandise rejection or return, and/ or termination of the business relationship. Similarly, Stride Rite indicated that any partner which fails or refuses to comply with its standards is subject to immediate cancellation of all outstanding orders as well as refusal to continue to do business in any manner with that partner.

Only a few of the respondents (Brown Group, Nike and Reebok) acknowl- edged they had found violations of their codes of conduct. In some cases, violations included the use of child labor as well as violations of other labor standards, including minimum wage and safety and health provisions. The companies addressed these violations in different ways. Brown Group indicated that counterfeit or false age documentation may result in the employment of minors. In these cases, the aid of local government officials is immediately secured to verify the authenticity of the employee's identification card; employees with false documentation are dismissed. Nike and Reebok have handled some child labor problems by changing their method of production to reduce or completely eliminate outsourcing or subcontracting

F. Conclusion

There are still many reports of child labor in the leather footwear industry, although reliable data on the actual number of children working in this industry are difficult to obtain. Children reportedly work in small workshops and households that supply larger firms on a subcontracting basis. Many footwear manufacturing processes are manual and fairly simple, leading to the use of children for certain production tasks, such as gluing and stitching leather uppers to soles. Children usually work long hours in dangerous and unhealthy conditions and earn very little. Lack of access to quality education appears to contribute to the incidence of child labor in many of the countries visited by Department of Labor officials.

The incidence and attitudes towards child labor in the footwear industry differ among countries. For instance, child labor in household production of foot- wear seems to be widely acknowledged in Mexico. In India and Pakistan, where the footwear industry has experienced some growth and codes of conduct are not widely implemented, there are reports that the use of child labor may be increasing. In Brazil, where child labor in the footwear industry was reported to be rampant a few years ago, there appears to be a reduction in the incidence of child labor. The Brazilian government has established the eradication of child labor as a priority; there are a number of partnerships between industry, trade unions, government and NGO representatives aimed at eliminating child labor, and two industry- sponsored labeling programs on child labor are currently operational in the footwear industry.

Although it is too early to assess the impact of these labeling programs in reducing the incidence of child labor in Brazil, anecdotal information suggests that the programs have been effective in increasing awareness about child labor issues among footwear manufacturers and establishing educational and rehabilitation programs for children. However, the effectiveness of both of the labeling programs discussed in this chapter — the Abrinq Foundation's Child-Friendly Company and the Pro-Child Institute seal — depends on the establishment and implementation of monitoring strategies. In addition, increasing public awareness of the programs and labels appears to be essential to the success of these programs given their reliance on external parties to monitor compliance with program requirements.

There is significant use of codes of conduct or other policies prohibiting child labor among U. S. importers of leather footwear. All of the sixteen respondents to the Department of Labor survey indicated they have a corporate policy regarding the use of child labor in the manufacture of their products; fourteen of these companies have well-defined codes of conduct which are publicly available. These policies usually prohibit the use of child labor, and often establish guidelines for the monitoring of foreign manufacturers and disciplinary actions for violations. The actual implementation of these policies, however, varies from company to company and from country to country. Awareness of the policies among foreign manufacturers, workers, and trade unions seems to be limited at best. Similarly, monitoring by U. S. importers is not consistent, even within the same country.

Labeling programs and codes of conduct are more effective if they are implemented in a transparent manner in which all interested parties, including plant managers, workers and trade unions, are well- informed about these policies. Labeling programs and codes of conduct, in combination with efforts by government officials, trade unions and NGOs, can be important tools for reducing child labor in the leather footwear industry.

This report was produced by the staff of the International Child Labor Program and is published by the U.S. Department of Labor, Bureau of International Labor Affairs.

Acknowledgements