Recommendations

Based upon the information collected from the voluntary survey of 48 U.S. apparel importers and site visits to six countries producing garments for the U.S. market, the Department of Labor found that codes of conduct can be a positive factor in solving the global child labor problem. Consistent with the important efforts already undertaken by many U.S. apparel importers, the Department of Labor recommends that U.S. companies consider whether some additional voluntary steps might be appropriate:

1. All actors in the apparel industry, including manufacturers, retailers, buying agents and merchandisers, should consider the adoption of a code of conduct.

If all elements of the apparel industry have a similar commitment to eliminating child labor, this would have a reinforcing impact on the efforts that the leaders in the industry have made. Trade associations should consider whether they could increase their technical assistance to help assure that the smaller companies in the industry can achieve this objective.

2. All parties should consider whether there would be any additional benefits to adopting more standardized codes of conduct.

There is a proliferation of codes of conduct. Some foreign companies and producer associations are even drafting their own codes. The definition of child labor differs from code to code, thereby creating some uncertainty for business partners and workers as to what standard is applicable.

3. U.S. apparel importers should implement further measures to monitor subcontractors and homeworkers.

Since most of the violations of labor standards, including child labor, occur in small subcontracting facilities or homework, U.S. apparel importers should consider further measures to monitor subcontractors more closely.

4. U.S. garment importers - particularly retailers - should consider taking a more active role in the monitoring/implementation of their codes of conduct.

The implementation of codes of conduct is a complex matter, and a relatively recent endeavor. Implementation seems best - and most credible - when U.S. companies get directly involved in the monitoring. There is little incentive for foreign companies to comply with a U.S. importer's code of conduct if there is no verification of actual behavior.

5. All parties, particularly workers, should be adequately informed about codes of conduct so that the codes can fully serve their purpose.

In the supplying countries, managers of enterprises are generally familiar with the codes of their clients. Workers, however, are seldom aware of codes of conduct of the U.S. corporations for which they make garments. NGOs and foreign governments are also not fully informed about codes of conduct.