D.Transparency

As has been stated in Chapter II, an important issue regarding the implementation of codes of conduct is their transparency, or the extent to which foreign contractors and subcontractors, workers, the public, NGOs and governments are aware of their existence and meaning.

Information gathered by Department of Labor officials during field visits regarding transparency of U.S. corporate codes of conduct is reported in this section, grouped around the following issues:

• Is the foreign supplier aware of codes of conduct developed by U.S. garment importers? Is the supplier familiar with the code of conduct of the U.S. garment importer for which it is producing?
• Does the U.S. company that originated the code of conduct hold training sessions with foreign suppliers (contractors, subcontractors, buying agents) to explain the code? Does the U.S. garment importer require a signed statement/certificate of compliance from the foreign supplier indicating that the code has been received and understood?
• Are codes posted in the factory in places accessible to workers? If the code is posted, is it in English or in the native language of the workers?
• Is there a requirement to inform workers about the code? If so, do workers have to be informed in writing, orally, or both?
• How well has information about the codes of conduct been disseminated to foreign government officials, NGOs and the public in general? Have there been efforts to inform the public about the codes of conduct?

1. Foreign Suppliers' Awareness About Codes of Conduct

The voluntary survey of U.S. retailers and garment manufacturers indicated that most U.S. corporations with policies regarding labor standards and child labor had distributed them to their suppliers. A smaller set of respondents indicated that they had actively engaged in communicating their policies to contractors, plant managers, employees, and workers.

In the six countries, Department of Labor officials visited 70 producers of garments currently exporting - or producing for contractors who are exporting - to the United States to learn their degree of awareness about codes of conduct. The majority of the suppliers interviewed produced for one or more U.S. importers identified - either from the survey described in Chapter II or from other public information - as having codes of conduct.

Managers of two-thirds (47 out of 70) of the plants visited that currently export to the United States indicated that they were aware of codes of conduct prohibiting the use of child labor, particularly of the codes issued by their U.S. customers. Based on the company visits, awareness among managers about codes of conduct was highest in El Salvador (all 8 companies visited knew about the codes) and Guatemala (6 out of 9 companies knew); in three other countries visited - the Dominican Republic, Honduras, and the Philippines - managers interviewed were more evenly divided between those who were aware and those who were not; in India, only 2 out of 7 producers visited were aware of U.S. codes of conduct. However, only 34 of the 47 companies that indicated they were aware of codes of conduct had available a copy of the code of conduct (or contractual provision) that they could show and discuss with the visiting Department of Labor official. Thus, managers at less than half of the plants visited were able to produce a code of conduct upon request.

• An observation from Guatemala - which seems to be applicable to other countries as well - is that a contractor's specific awareness of codes of conduct seemed to be a function of the U.S. company for which they produced.
  • Contractors and some subcontractors producing for JCPenney and Phillips-Van Heusen had knowledge of the U.S. companies' codes of conduct or policies on child labor and some of them had copies available.
  • Meanwhile, the manager of Don Sang, a Korean-owned maquila that produces mostly for Paul Solary and Marcraft Apparel Group in New York stated that he had never heard of the concept of U.S. company codes of conduct or policies.

• In El Salvador, managers of all eight plants visited by the Department of Labor were aware of U.S. codes of conduct and were able either to show a copy of the code of conduct to the Department of Labor officials or had copies of the document posted in public places at the factory.

• In Honduras, managers of plants producing under contract for JCPenney, Sears, The Gap, Macy's, Rothschilds and Oxford Industries were aware of the codes of conduct of these corporations and had copies of those commitments.
  • Managers of plants wholly owned by Fruit of the Loom and Warnaco were similarly aware of those companies' codes of conduct; the manager of two Fruit of the Loom factories (Confecciones Dos Caminos I and II) had a copy of the U.S. corporation's "Contractor Code of Conduct" and the Warnaco subsidiary posted their internal regulations in the cafeteria and three workplace areas. The internal regulations contained the Warnaco code of conduct.
  • In contrast, Cosmo and Fnix, two Korean-owned plants producing for Target (Dayton-Hudson), Kmart, Wal-Mart, and Montgomery Ward stated that they did not know about the codes of conduct of their customers.
  • Two other plants visited in Honduras, OshKosh B'Gosh and Exportadores Textiles, stated that they were not aware of codes of conduct or whether their U.S. customers have codes of conduct.

• In the Dominican Republic, contractors for Levi Strauss (RK Fashions, Interamericana Products, D'Clase Corporation, and Grupo M), Sara Lee Corporation (BRATEX Dominicana), and JCPenney (Polanco Fashion International) were aware of the codes of conduct of their U.S. customers and had copies of the codes available.
  • In contrast, Toscana Corporation and Pons San Pedro, two U.S.-owned companies in Zona Franca San Pedro de Macorµs which subcontract for Kmart, Wal-Mart and Target (Dayton-Hudson), did not know whether their U.S. customers had codes of conduct and were not able to provide any documents that set out the operating policies of the U.S. garment importing companies.
  • Finally, Bonahan Apparel and Hingshing Textiles, Korean-owned corporations producing garments for the U.S. market - under the labels Chaus, Smooth, B&B, Tuxedo Junction, Harmony Clothes, Neema Clothing, Luscasini, First Nighter, and Jacob Sigel - were not aware of codes of conduct at all.¹¹

• In the Philippines, managers' knowledge about codes of conduct was mixed.
  • The manager of a plant wholly owned by Levi Strauss was familiar with that company's code of conduct and had copies of the document available.
  • Several plants that contract all or a large portion of their production to Liz Claiborne (U.S. Fashion Image, All Asia Fashions, Woo Chang, and L&T International) were also familiar with the codes of conduct of the U.S. importer and had copies available.
  • Two Nike suppliers, Go-Thong and Mactan Apparel Incorporated, both located in Cebu, were aware of Nike's code of conduct and had copies of it.
  • Management of Castleberry, a contractor to JCPenney, became familiar with that company's code of conduct only recently and had a copy available; three of Castleberry's subcontractors, also visited by the Department of Labor, were not aware of JCPenney's code of conduct, however.
  • Similarly, A La Mode Garments, a subcontractor to The Gap, was not aware of The Gap's code of conduct for suppliers.

• In India, Department of Labor officials found only two companies - Ambattur Clothing Company and Orient Craft - that were aware of the codes of conduct of U.S. apparel importers, and both had copies. These companies produced for large U.S. apparel suppliers Liz Claiborne, The Gap, Ralph Lauren, Sears, and JCPenney.
  • The five other Indian plants that were visited which produced for the U.S. market were not aware of U.S. codes of conduct.¹²

2.Training and Supplier Certification

Several U.S. corporations responding to the survey said that they held training sessions with suppliers about their codes of conduct. Others - particularly retailers - said they inform foreign contractors about their policies/codes of conduct and require each foreign producer to sign a document stating that it has been informed about the code of conduct and its meaning.

Department of Labor officials found that formal training of plant managers and supervisors about the codes of conduct was not common in the six countries visited. Only 14 out of the 47 companies visited where managers indicated awareness about codes of conduct stated that they had received some formal training regarding the U.S. companies' codes of conduct, although it was evident that the intensity of the training varied widely from company to company.¹³

• The clearest example of a formal training program was in the Dominican Republic, where contractors stated that Levi Strauss had conducted training on codes of conduct for managers and supervisors of plants throughout the country and had provided the information in both English and Spanish.
  • For example, RK Fashion is a Dominican-owned plant located in Zona Franca La Vega that produces only for Levi Strauss; different levels of managers/supervisors received - and continue to receive - periodic training from Levi Strauss on the implementation of that company's code of conduct.
• In India, Triburg Consultants, an Indian agent, administers Liz Claiborne's human rights guidelines. Triburg conveys the guidelines to the supplying company and discusses them with management. Some of Triburg's staff have gone to New York for orientation sessions and total quality management programs conducted by Liz Claiborne. Upon their return, they communicate the information to the Liz Claiborne contractors.

Some suppliers indicated that they had to certify in writing to their U.S. clients that they had received and understood the codes and agreed to abide by them.¹⁴ For example:

• In the Philippines, several Liz Claiborne contractors interviewed in Manila stated that they had signed certificates of compliance with Liz Claiborne's Standards of Engagement which, among other things, prohibit child labor. These contractors also supply Ralph Lauren, Eddie Bauer (Spiegel), May Department Stores, Tommy Hilfiger, and The Gap.

• In India, Triburg Consultants, an agent for Liz Claiborne and others, stated that they receive human rights guidelines and mission statements from Liz Claiborne. Agents discuss the guidelines with the suppliers and a common understanding is reached. Suppliers then agree on the guidelines and each signs a document stating that it understands them.
  • Associated Indian Exports, an agent for Sears and other U.S. companies, followed similar procedures regarding the implementation of Sears' Vendor Certification.

3.Posting of Codes of Conduct

A concrete example of transparency of codes of conduct is the voluntary posting of codes of conduct at the workplace, preferably in the native language of the workers. In two of the countries visited - El Salvador¹⁵ and Honduras - there is a legal requirement that companies post their internal regulations, including starting and ending time, rest periods, and disciplinary rules. These internal regulations tend to be very detailed and instruct workers on a range of issues such as rest periods, talking, use of bathroom facilities, and penalties for offenses such as tardiness, absences, or not meeting their production quotas. Thus, workers perceive internal regulations as rules to which they are bound in the workplace.

The plant visits by Department of Labor officials suggest that while posting of a U.S. garment importer's codes of conduct seems to be common practice in El Salvador, it is not the norm in the garment industries of the other 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, 7.¹⁶

• As noted above, posting of codes of conduct was common in El Salvador. Department of Labor officials viewed codes of conduct - in Spanish - in the following plants:
  • Lindotex, a Korean-owned company, produces under contract for Hampton, Capitol Mercury, Wal-Mart, The Gap, JCPenney, and Sears. JCPenney, Hampton, and Capitol Mercury each account for approximately 25 percent of production. Wal-Mart, The Gap, JCPenney, and Sears have codes of conduct, which Lindotex orally explains to the workers. Hampton's code of conduct is posted at the entrances.
  • Mandarin, a Taiwanese owned and financed factory supplies garments to Eddie Bauer (Spiegel), The Limited, Liz Claiborne, JCPenney, Casual Corner, and The Gap,¹⁷ among others. The Gap, JCPenney and Eddie Bauer account for 70 percent of production. The Gap's code of conduct is posted at the entrances to the plant.
  • Textiles Lourdes Limitadas, a subsidiary of Fruit of the Loom, exports all of its production to the United States. Fruit of the Loom's code of conduct is posted at the plant.
  • Hilasal, located in the Export Salva Free Trade Zone, Santa Ana, is a joint venture (50-50) between U.S. and Salvadoran investors. The plant manufactures for Sears, Liz Claiborne, and Hampton Industries; Hampton accounts for 80 percent of the plant's production. Hampton's code of conduct - in Spanish - is posted at the entrances.
  • Codes of conduct were also posted at Industrias Caribbean Apparel, S.A. (JCPenney's code of conduct), C.M.T. Industries (Lily of France's and VF Corporation's codes of conduct), and Primo Industries (Liz Claiborne's code of conduct).
  • The only plant of eight visited in this country where a code of conduct was not posted was Confecciones El Pedregal, a subsidiary of Sara Lee.

• In Guatemala, two of the companies visited by the Department of Labor had codes of conduct posted in the plant:
  • Maquila Cardiz, S.A., a contractor to Phillips-Van Heusen, had that company's code of conduct posted on the factory wall - both in English and Spanish.
  • Camisas Modernas, another Phillips-Van Heusen contractor, followed the same practice.
  • Meanwhile, the manager of a Korean-owned maquila (Lindotex) located in Chimaltenango that produces for JCPenney and Wal-Mart said that he normally had his customers' codes of conduct (both JCPenney and Wal-Mart) posted at the plant, but they had been recently taken down while the walls were being repainted.

• In Honduras, KIMI, a Korean-owned contractor to The Gap, located in the Continental Park, La Lima, was the only company visited by the Department of Labor that posted a code of conduct. KIMI posted The Gap's code of conduct - in Spanish - in two plant locations.
  • Certified Apparel Services, located in San Pedro Sula, produces for Wal-Mart, Sears, Mervyn's (Dayton-Hudson), JCPenney, Target (Dayton-Hudson), Kmart, William Carter, Bradlees and Meijer. While Wal-Mart, Sears and JCPenney have codes of conduct, copies were not available at Certified Apparel Services in San Pedro Sula. According to the manager, signed copies of the codes of conduct are available in corporate headquarters in Florida (Certified Apparel Services is a subsidiary of Kleinerts, based in Tampa, Florida). He also stated that workers and union leaders have been advised of the corporate codes of conduct, but copies of the documents were not available and they were not posted on factory walls.

• In India, only two of the plants visited by Department of Labor officials posted a code of conduct:
  • Ambattur Clothing Company, located in Madras, which used to produce garments for The Limited and currently does so for The Gap, Banana Republic (The Gap), Eddie Bauer (Spiegel), J. Crew, and Liz Claiborne, posted Liz Claiborne's code of conduct - in Hindi - at the factory.
  • Orient Craft, located near New Delhi, which produces garments for Liz Claiborne and Ralph Lauren also posted Liz Claiborne's code of conduct in Hindi outside the factory lunchroom.

• In the Philippines, seven plants visited by the Department of Labor had posted a code of conduct.
  • The Liz Claiborne Human Rights Statement, in Tagalog, was posted at the worksites of the four contractors of that company visited.
  • At the wholly owned Levi Strauss subsidiary in Makati, the company's Statement of Aspirations was prominently posted in Tagalog and English.
  • Mactan Apparel and Globalwear, two contractors for Nike in Cebu, posted copies of the Nike code of conduct.

• In the Dominican Republic, Hanes Caribe, a U.S.-owned corporation producing for Sara Lee, and Grupo M, a Dominican-owned corporation producing for Levi Strauss, Liz Claiborne, Fruit of the Loom, Kellwood, Tommy Hilfiger, Polo, and Oxford, both had posted codes of conduct in Spanish and English at their plants; Hanes Caribe posted the Sara Lee code of conduct, while Grupo M displayed the Levi Strauss code of conduct.
  • Two other companies visited, Manufactura Borinque-a (Zona Franca San Pedro de Macorµs) and Woo Chang Dominican Industry (Zona Franca Bonao), stated that they used to post their companies' internal policies (not codes of conducts per se, but statements to the effect that they complied with domestic laws) but they had stopped this practice a number of years ago because "the companies had been in operation for a long time and workers already knew the rules." These two companies supply garments to U.S. corporations New Age Intimates, Sears, Kmart, and Wal-Mart, among others.

Some foreign producers with multiple U.S. clients each with different codes of conduct stated that the proliferation of codes of conduct - often with different definitions of standards and monitoring requirements - created confusion with regard to implementation. This view was expressed most clearly in the Dominican Republic:

• D'Clase Corporation, a Dominican-owned company located in Zona Franca Santiago, which assembles garments for Levi Strauss, Eddie Bauer (Spiegel), Oxford Industries, Haggar Clothing, JCPenney, Lee (VF Corporation), Wrangler (VF Corporation), and Ralph Lauren-Polo, took elements from different U.S. corporate codes of conduct and developed a code of conduct for D'Clase Corporation. D'Clase posts its own code of conduct rather than the codes of its U.S. clients. (D'Clase Corporation's code of conduct includes provisions on working conditions and employment practices and a prohibition on the use of child labor and forced labor.)

• Undergarment Fashions, a U.S.-owned contractor for JCPenney, Victoria's Secret (The Limited), Sears, Wal-Mart, and Kmart, located in the Zona Franca San Pedro de Macorµs, did not have knowledge of the codes of conduct of its clients, but had developed - and posted - its own code of conduct ("Best Form Foundation"), which includes provisions prohibiting child labor.

4.Workers' Awareness of Codes of Conduct

Although a significant number of suppliers knew about the U.S. corporate codes of conduct, meetings with workers and their representatives in the six countries suggested that relatively few workers are aware of the existence of codes of conduct, and even fewer understand their implications.

The lack of awareness on the part of workers about codes of conduct may be in part attributable to the relatively low level of effort on the part of producers to inform their workers about the codes. Management regards codes of conduct - and compliance with labor law - to be a management problem, and approaches monitoring and supervision of these matters as management responsibilities. Workers are not seen by management as having a role in these activities.

Department of Labor officials were told by management of 22 of the companies visited that they informed their workers about codes of conduct; 13 of the companies indicated that they inform their workers about codes of conduct orally, while only 9 stated that they do so both orally and in writing.

Out of all of the plants that were visited in the six countries, there was only one example of a producer that had an explicit policy of informing workers about the code of conduct of its U.S. customer:

• As part of a strategy to keep workers informed about company policies and developments, in the Dominican Republic, Mr. Vµctor Polanco, the manager of Hanes Caribe, a subsidiary of Sara Lee, stated that Hanes Caribe had provided copies of Sara Lee's code of conduct - in Spanish - to each worker; held several meetings to discuss the contents and implications of the code; and required that workers attending the meetings sign an attendance sheet acknowledging receipt of the code of conduct.
  • This was confirmed by Mrs. Yokalty Malmolejos Uribe, a former worker at Hanes Caribe, who stated that in addition to providing information on Sara Lee's code of conduct, Hanes Caribe's personnel specialists also made available to workers copies of the Dominican Labor Code and referred to these materials during discussions with workers.

The following examples illustrate the general lack of awareness about the codes of conduct among workers in the six countries visited:

• In El Salvador, representatives of major labor organizations [National Federation of Salvadoran Workers (FENASTRAS), Federation of Labor Unions of El Salvador (FESTRAES), National Unity of Salvadoran Workers (UNTS), and Union of Textiles and Related Industry Workers of El Salvador (STITAS)] stated that most workers - and even some labor leaders - do not know about codes of conduct. In addition:
  • Representatives of CENTRA (Centro de Estudios del Trabajo), an organization that conducts research on labor issues in El Salvador, stated that a survey of one thousand 16-17 year old workers conducted in June-July 1995 found that not a single person had ever heard of a code of conduct.¹⁸
  • Interviews of workers conducted by the Department of Labor officials confirmed the workers' lack of knowledge about codes of conduct. For example, of a dozen workers interviewed outside of the San Marcos Free Trade Zone, only one said she knew about codes of conduct. In three interviews of maquila workers held in a small neighborhood near a free trade zone, two of the workers had never heard of a code of conduct, and one had heard about it from a friend who worked in the free trade zone. The worker interviewed "knew" that only women over 18 years of age were hired in the zone.¹⁹

• In the Dominican Republic, workers had very little knowledge about the codes of conduct of U.S. companies whose garments they produced.
  • Most workers appeared to be surprised that such policies exist at all, and had never seen or heard of codes of conduct prior to being interviewed. Some workers expressed frustration at the disregard for their right to have access to information which may improve the general environment in which they worked.
  • The workers best informed about codes of conducts were those participating or involved in labor union organizing. Labor unions, such as the National Federation of Free Trade Zones Workers (FENATRAZONA), provided workers with general information on codes of conduct and worker rights.

• In Honduras, workers of the KIMI plant, a Korean-owned company that contracts with The Gap, are aware of The Gap's code of conduct. A representative from The Gap explained its code of conduct to KIMI's workers, but no specific training was provided. As was discussed in the previous section, KIMI was the only one out of twelve plants visited in Honduras that posted the code of conduct of a U.S. customer.
  • The national leadership of two major union organizations interviewed [Central General of Workers (CGT) and Confederation of Workers of Honduras (CTH)] was aware of The Gap's code of conduct, but not of the fact that other U.S. importers had similar codes.

• In Guatemala, representatives of UNSITRAGUA (Union of Labor Organizations of Guatemala), the main confederation of workers in the country, had limited knowledge and understanding of the codes of conduct of U.S. companies due to information received from U.S. labor unions, and believed that Guatemalan workers are completely unaware of them.
  • Mr. Juan Francisco Alfaro, Secretary General of the Guatemalan Confederation of Labor Unity (CUSG), seemed somewhat knowledgeable that corporate codes of conduct existed in the United States, but stated that they are not known in Guatemala; if some maquilas know of them, he does not believe they are effectively implemented and he believes that the workers are not informed.
  • Representatives of the Central General of Guatemalan Workers (CGTG) were not aware of any U.S. corporate codes of conduct.
  • Meetings with garment workers conducted outside of plants in Guatemala City, Chimaltenango and San Pedro de Sacatepequez demonstrated that these workers are unaware of any U.S. company code of conduct or policy on child labor, although they are aware of the maquila industry's move not to hire under-age workers.
  • A representative of the garment industry stated that some maquila managers are aware of U.S. corporate codes of conduct; even if workers in these plants do not know about the codes of conduct, the codes are playing a positive role as they are being implemented and companies are conducting audits to monitor behavior.
  • The manager of a maquila plant (Confecciones Caribe, S.A.) stated that there was no need to inform the workers about the codes because they should already know the Guatemalan labor code and the corporate codes do not add anything new to the country's labor law.

• In India, trade union representatives in Tirupur (from the Janatha Dal Labor Federation) were not aware of any U.S. corporate code of conduct or terms of engagement for garment exporting companies.

• In the Philippines, some workers at subsidiaries of U.S. corporations or large contractors for major U.S. corporations were aware of codes of conduct through posting at the worksites.

The alleged low literacy level of garment workers is sometimes used to justify the non-posting of codes of conduct within factories. In the case of the Dominican Republic, Mr. Eddy Martµnez, Executive Director, Dominican Association of Free Trade Zones (ADOZONA), stated that since the literacy level of free trade zone workers is low, communication is often conducted orally. This sentiment is obviously held by many free trade zone employers; seven out of 10 companies (70 percent) visited in the Dominican Republic that informed workers about codes of conduct did so orally. In contrast with these statements, employers also stated that they prefer to hire workers who are able to read and write, as they are better equipped to follow directions.

In fact, all workers interviewed by the Department of Labor official in the Dominican Republic were shown copies of a sample code of conduct and their reading skills were sufficient to understand its contents. Although the argument of illiteracy as a reason for not making copies of codes of conduct available to workers has been raised in the case of the Dominican Republic, it is clear that it is a pervasive one and probably applies to the garment industries of most developing countries. Whether it has merit, however, is doubtful.

As was discussed in the previous section, codes of conduct are sometimes posted in factories. Yet discussions with workers and their representatives revealed a lack of awareness of codes of conduct and their implications for workers. Possible explanations for this apparent contradiction may be that:

• the posting of the codes is a very recent phenomenon, and workers have not had time to learn about their existence and absorb their contents;

• workers put in long hours - particularly when transportation time to and from their jobs is taken into account - and have very little unstructured time while they are within the plants to read materials posted on bulletin boards; and

• workers generally read bulletin boards for the rules they must follow - and disciplinary consequences if they fail to do so - and equate materials posted by management with work rules. They may not have grasped that corporate codes of conduct refer to the behavior of employers rather than their own.

It is quite clear from the field visits that posting of codes of conduct alone has not had the desirable effect of making workers aware of their existence, and active steps to educate workers about the codes of conduct is required.

5.Dissemination of Codes of Conduct

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 - can also be helpful in enhancing their effectiveness. Department of Labor officials found a mixed record regarding the extent to which these entities were familiar with codes of conduct and their implications.

• In the Dominican Republic, Secretary of Labor Rafael Alburquerque was knowledgeable about codes of conduct and their use as a tool to improve working conditions. As the author of the Dominican Labor Code of 1992, Secretary Alburquerque was also very familiar with the current provisions regulating the employment of minors in the Dominican Republic. He stated that the Ministry of Labor had engaged in a public awareness campaign to disseminate information on labor standards; the Ministry published and distributed copies of the new labor code to employers, labor unions, and many NGOs.
  • Most NGOs interviewed were knowledgeable about the existence and content of codes of conduct in the garment industry. The American Institute for Free Labor Development (AIFLD) representatives in the Dominican Republic work closely with local labor unions and NGOs in providing information on codes of conduct and international labor standards.
  • Other NGOs, such as the Research Center for Female Action (CIPAF) and OXFAM-UK, have also taken active roles by developing a public awareness campaign to call attention to working conditions in the FTZs and the use of codes of conduct to improve the well-being of these workers. A joint publication by CIPAF and OXFAM, entitled En el Paraµso/In Paradise, established as one of its goals the need: "to make local entrepreneurs and large international corporations aware of the need to formulate and enforce codes of conduct that proclaim the companies' sense of responsibility towards their workers."
  • In contrast, the American Chamber of Commerce in the Dominican Republic was unaware of the existence of codes of conduct for the garment industry or how these codes were being implemented in the FTZs. Mr. Arthur E. Valdez, Executive Vice President, stated that his member companies have not provided the Chamber with copies of U.S. companies' codes of conduct and requested such information from the visiting Department of Labor official.

• In the Philippines, government officials and political leaders who met with Department of Labor officials were somewhat aware of corporate codes of conduct. When informed further, they thought that the codes could have a positive impact.
  • NGOs which met with Department of Labor officials seemed vaguely aware of corporate codes of conduct.
  • Most of the union leaders interviewed were not familiar with corporate codes of conduct.
  • However, the Chairman of the American Chamber of Commerce Garment Industry Committee, Mr. Robert Robbins, and representatives of Levi Strauss, Liz Claiborne, Gelmart (which produces for Playtex) and two contractors that produce for Renzo, a U.S. importer for JCPenney and other U.S. retailers and name brands, stated that the Chamber takes the issue of codes of conduct seriously and tries to keep its members informed.

• In El Salvador, the Minister of Labor indicated familiarity with codes of conduct, emphasizing that they were strictly private agreements between the U.S. apparel importers and their manufacturers. The Minister of Labor expressed no objection to codes of conduct, but stated that since they were not national law, they were not enforced by his Ministry.
  • Several NGOs interviewed [FOES (Salvadoran Worker/Management Foundation), PROCIPOTES (Project to Integrate Children into Work, Education and Health), and Olof Palme Foundation] indicated a lack of knowledge about codes of conduct.
  • Representatives from CODYDES (Organization of Fired and Unemployed Workers of El Salvador), a maquila worker rights organization, indicated that they had first learned about codes of conduct in February 1995 but had actually never seen one.

• In India, Mr. Bajpai, Executive Director, American Business Council in New Delhi, who represents the interests of U.S. companies in India, indicated that he was not aware of buyers' codes of conduct, and requested more information on them.
  • Mr. Anand, Federation of Indian Chambers of Commerce and Industry (FICCI) in New Delhi, said codes of conduct are not shared at the Chamber of Commerce level. However, at the factory level, companies are trying to comply and implement the codes.
  • In the Punjab, all people interviewed - including government officials, factory owners and managers, union officials and workers - did not know anything about U.S. companies' codes of conduct, policies or guidelines.

• In Honduras, the Vice President of the Honduras American Chamber of Commerce (HAMCHAM), Mr. Raymond Maalouf, was not aware of U.S. corporate codes of conduct. HAMCHAM, however, leaves all matters related to the apparel industry to the Honduran Association of Maquilas.
  • The National Commission on Human Rights (CNDH) was aware of The Gap's code of conduct and had a meeting with officials of Liz Claiborne to discuss child labor and codes of conduct. According to Lic. Rolando Arturo Milla of CNDH, Liz Claiborne representatives stated that it was their intention to name a representative in Honduras to monitor its code of conduct.
  • The Committee for the Defense of Human Rights of Honduras (CODEH) was aware of The Gap's code of conduct and was disappointed that CODEH had not been requested by any company to monitor a code of conduct.

• In Guatemala, government officials were aware of a code of conduct being developed in the country by the domestic apparel export industry,²¹ but had little awareness of U.S. corporate codes of conduct. Most NGOs had little knowledge about U.S. corporate codes of conduct, but opined that they would be beneficial if properly implemented and monitored.