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Leather Footwear - Footnotes

1 See Globalization of the Footwear, Textiles, and Clothing Industries (Geneva: International Labor Organization, 1996) [hereinafter Globalization of the Footwear, Textiles, and Clothing Industries]; The Small Hands of Slavery: Bonded Child Labor in India (New York: Human Rights Watch, 1996) 90- 92 [hereinafter The Small Hands of Slavery]; Shad Islam, "Children: Use of Child Labor Called 'Out of Control, '" Inter Press Service (June 26, 1996); Crianças que Estudam e Trabalham na Ciudad de Franca (Franca: Sindicato do Trabalhadores na Indústria de Calçados e do Vestuário de Franca e Reigião, July 1994) [hereinafter Crianças que Estudam e Trabalham]; Diagnóstico do Trabalho Infantil em Novo Hamburgo e Dois Irmãos (Draft) , Rio Grande do Sul, Porto Alegre, 1997 [hereinafter Diagnostico do Trabalho Infantil]; Fawad Usman Khan, "An Innovative Approach to Non- formal Education," (Lahore: International Workshop on Gender and Development, February 1996) [hereinafter An Innovative Approach to Non- Formal Education] [on file].

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2 See Jean- Paul Sajhau, Business Ethics in the Textile, Clothing and Footwear (TCF) Industries: Codes of Conduct (Geneva: International Labor Office, 1997) 4; Janet Hilowitz , Labelling Child Labour Products, a Preliminary Study (Geneva: International Labour Organization, 1997) v; Child Labour: Targeting the Intolerable (Geneva: International Labor Organization, 1996) 5; Practical Action to Eliminate Child Labor: Background document pre- pared for the Oslo International Conference on Child Labour (Geneva: International Labor Organization, 1997) 2.

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3 World Footwear Markets (United Kingdom: SATRA Footwear Technology Center, 1997) v [hereinafter World Footwear Markets].

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4 Globalization of the Footwear, Textiles, and Clothing Industries at 16. For example, in 1995, China, India, Vietnam, and Thailand all saw their footwear industries grow, while South Korea and Taiwan experienced decreased footwear production, a fact discussed further in World Footwear Markets at 1.

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5 World Footwear Markets at v.

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6 Current Highlights of the Nonrubber Footwear Industry (Washington, DC: Footwear Industries of America, April 1, 1997) 1.

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7 The Art & Science of Footwear Manufacturing (Washington, DC: Footwear Industries of America, 1993) 1 [here- inafter The Art & Science of Footwear Manufacturing].

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8 Priceline Imports/ Exports 1996 (Washington, DC: Footwear Industries of America, 1997). According to the U. S. International Trade Commission, in some leather footwear categories,
imports constitute 90- 95 percent of domes- tic consumption. Nonrubber Footwear Statistical Report, 1996 (Washington, DC: U. S. International Trade Commis- sion, 1997) iii.

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9 ShoeStats (Washington, DC: Footwear Industries of America, 1996) 30.

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10 Id. at 35.

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11 Recent Developments in the Leather and Footwear Industry (Geneva: International Labor Organization, 1992) 13 [hereinafter Recent Developments].

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12 The Art & Science of Footwear Manufacturing at 9.

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13 For a more detailed description of this process, see The Art & Science of Footwear Manufacturing at 10- 12.

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14 Id. at 12.

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15 Globalization of the Footwear, Textiles, and Clothing Industries at 76; Diagnóstico do Trabalho Infantil at 79; IPEC in India (1992- 1995): Looking Back , (New Delhi: International Labor Organization, 1996) 1.

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16 Jack Epstein, "International Concern Over Underage Workers," San Francisco Chronicle (September 4, 1995) A1.

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17 Irandi Pereira and Raquel Licursi Benedeti Rosa, Child Labor in the Footwear Industry in Franca (Geneva: International Labor Organization, 1993) 30. [Informal translation into English from Portuguese version] [hereinafter Child Labor in the Footwear Industry in Franca].

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18 Recent Developments at 33.

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19 Child Labor in the Footwear Industry in Franca at 30.

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20 Id. at 30.

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21 Recent Developments at 33. The ILO has also reported children working in cleaning and production activities in leather tanneries.

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22 Globalization of the Footwear, Textiles, and Clothing Industries at 75.

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23 Id. at 75.

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24 Some reports state that as competition has forced firms to reduce costs and make production more flexible in the 1990s, the practice of subcontracting or outsourcing has grown. See Crianças que Estudam e Trabalham at 35. According to a union leader in Franca, virtually all of the manufacturing operations required to produce leather footwear can be outsourced to home-based or small workshops. Interview with Paulo Afonso Ribeiro, Union of Shoeworkers of Franca, by U. S. Department of Labor officials (June 25, 1997). Relevant child labor legislation in Brazil is set forth in the 1988 Federal Constitution and 1990 Law on the Protection of the Child and Adolescent Rights. The Constitution states that the legal age for entry into the labor market is 14, but an exception is made for children involved in apprenticeship programs who are able to begin these programs between the ages of 12 and 14. The Constitution also prohibits nocturnal, dangerous, and unhealthy employment for individuals below the age of 18. Lucilia Tremura of the Ministry of Labor notes that labor laws are not applied to small, family run production sites. If no labor is hired from outside of the family, Ministry of Labor inspectors are not permitted to inspect homes or family farms for the use of child labor. In the case of dangerous work or lack of school attendance, however, Brazilian civil law is employed to protect the safety of the child and guarantee mandatory school attendance. Telephone interview with Lucilia Tremura, Brazil- ian Ministry of Labor, by U. S. Department of Labor officials (July 9, 1997).

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25 Diagnóstico do Trabalho Infantil. This is a preliminary study which has not been fully reviewed by the ILO Office in Brazil; some of the information contained in the study may be modified upon final review.

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26 Crianças que Estudam e Trabalham.

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27 Diagnóstico do Trabalho Infantil at 60- 62.

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28 Diagnóstico do Trabalho Infantil at 61; Crianças que Estudam e Trabalham at 74.

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29 Iolanda Huzak and Jo Azevedo, Crianças de Fibra , Editora Paz e Terra S. A. (Brasilia, 1994) 116 [hereinafter Crianças de Fibra]. This book quotes the mayor's office of Franca as estimating that 60 percent of leather footwear suppliers operate in clandestine conditions.

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30 Crianças que Estudam e Trabalham at 45.

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31 Crianças de Fibra at 130.

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32 Interview with Eliete Maria Neves Silva, Tutelary Council of Franca, by U. S. Department of Labor officials (June 26, 1997). Tutelary Councils are public entities that oversee the
implementation of child welfare policies in the municipalities of Brazil.

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33 Diagnóstico do Trabalho Infantil at 80. This survey also indicated that most child workers had a very high incidence of repeating grades in school. Diagnóstico do Trabalho Infantil at 55- 56.

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34 U. S. Department of Labor officials visited two complementary school programs in Franca (one sponsored by the Pro- Child Institute and another jointly- sponsored by UNICEF and the
Mayor's Office) and one in Novo Hamburgo (an ILO/ IPEC project).

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35 Crianças que Estudam e Trabalham at 28- 30.

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36 During conversations with home workers and an owner of a small workshop in Franca, U. S. Department of Labor officials were informed that children are still working in small workshops and household production of footwear (June 23- 24, 1997).

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37 A newspaper article dubbed the city of Franca as Brazil's "capital of child labor." "Latin Town's Child Labor Tarnishing its Image," The Orlando Sentinel (September 10, 1995) A9. During interviews conducted in Brazil by U. S. Department of Labor officials in June 1997, a number of local business leaders, NGOs, union leaders, and government officials indicated that there has been a significant reduction in the number of child workers in Franca in the footwear industry. However, no recent study has been conducted in Franca to ascertain the scale of this trend.

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38 Diagnóstico do Trabalho Infantil at 32- 33. This report notes that in 1994, more than 20,000 footwear workers were dismissed because of closures and bankruptcies in the footwear industry of Rio Grande do Sul. A recent newspaper article noted that "In recent years, close to 7,000 [formal sector] jobs have disappeared from [Franca's] footwear factories. This number represents 50 percent of the total number of jobs in Franca's footwear industry at the beginning of the decade." Luciana Cavalini, "Franca grows and fears unemployment," Folha de São Paulo (March 9, 1997).

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39 Interview with Miguel Heitor Baettarello, Sindicato da Indústria de Calçados de Franca, by U. S. Department of Labor officials (June 13, 1997).

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40 Efforts of the Abrinq Foundation and the Pro- Child Institute have been important, for example, in organizing the private sector to combat child labor and creating programs to address some of the causes of child labor in the area. In addition, Franca was nominated as the nation's first "Child- Friendly Municipality" by the Abrinq Founda- tion, and the mayor's office has been active in creating educational opportunities and other programs to eradicate child labor. The local union of footwear workers also provided an important impetus to efforts in Franca by calling attention to the child labor situation through two reports in the early 1990s.

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41 Interview with Izielma De Luca Andrade, Regional Delegation of the Ministry of Labor, by U. S. Department of Labor officials (June 20, 1997).

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42 The union of shoeworkers in Franca is currently seeking funding to update the 1994 survey on child labor in Franca.

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43 Guy Thijs, Briefing Note on IPEC Activities in China (Bangkok: International Labor Organization International Programme on the Elimination of Child Labor, May 29, 1997) [hereinafter IPEC Activities in China].

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44 Rapid economic growth may hamper the ability of government officials to regulate new industrial establish- ments and enforce labor laws.

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45 Two Hong Kong human rights groups that had been monitoring factories in China since 1995, recently reported workers' allegations that Wellco, a company producing shoes for Nike in Dongguan, employs children ages 13- 15 in the sewing, handwork and cutting departments. "Working Conditions in Sports Shoe Factories in China Making Shoes for Nike and Reebok" (Hong Kong: Asia Monitor Resource Centre and Hong Kong Christian Industrial Committee, September 1997) 7 [hereinafter Working Conditions in Sports Shoe Factories in China]. Nike has challenged the veracity of this report and issued a rebuttal to its claims.

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46 IPEC reports that Chinese government educational data show that in 1993, 2.61 million school- age children did not enroll in primary school, representing about 2 percent of the country's school-age children. Other figures show that in 1993 there were about 10.66 million minors out of school. IPEC Activities in China. Under Chinese law the use of child labor is prohibited. Child labor is defined as "labour performed for economic reward by a child or a youth under the age of 16 in a working relationship with a work unit or individual, or on his or her own account." The law also provides for nine years of compulsory education and all children who reach the age of six, irrespective of age, nationality and race are required to enroll in school.

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47 As discussed earlier, a team of U. S. Department of Labor officials visited China in June 1997. The team interviewed a number of footwear manufacturers and industry associations. Chinese government officials met with the U. S. Department of Labor team in Beijing, Wenzhou, Hangzhou, and Guangzhou.

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48 In a 1995 Report on the Implementation of the Convention of the Rights of the Child, the Chinese government stated that "in recent years, child labour has emerged in individual regions as a result of the growth of small- town and private industry and individual businesses. A preliminary analysis shows it to be fairly marked in the southern coastal cities, largely because the southern coastal regions have been growing fast and the comparative wealth of job opportunities exerts a strong attraction on households and minors in some poor districts." Convention on the Rights of the Child, U. N. Committee on the Rights of the Child, U. N. Doc. CRC/ C/ 11/ Add. 7, August 21, 1995, 47. For a critique of China's submission to the U. N. Report, see "Child Workers: China's Hidden Agenda," in China Labour Bulletin , Issue No. 25 (Hong Kong, April 1996).

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49 Anita Chan, "Boot Camp at the Shoe Factory," The Washington Post (November 3, 1996) C1.

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50 Working Conditions in Sports Shoe Factories at 2.

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51 The Status and Problems of Leather Workers and Their Future Growth Perspective (New Delhi: Institute of Applied Manpower Research, 1995) [hereinafter The Status and Problems of Leather Workers].

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52 Id.

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53 American Consulate- Mumbai, unclassified telegram no. 2199 (July 29, 1997).

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54 The Small Hands of Slavery at 90- 92.

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55 The Status and Problems of Leather Workers.

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56 American Consulate- Chennai, unclassified telegram no. 794 (May 1, 1997).

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57 Child Worker News (Royapuram, India: Center for Street and Working Children, vol. 2, no. 3, January- March 1995) 5.

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58 American Consulate- Chennai, unclassified telegram no. 794 (May 1, 1997).

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59 Interview with Father Jesu, Street Elfin Education and Development Society, by U. S. Department of Labor official (June 9, 1997).

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60 Telephone interview with Matthew Moffett, reporter for The Wall Street Journal , by U. S. Department of Labor official (April 7, 1994).

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61 International Child Labor Hearing , U. S. Department of Labor (April 12, 1994) (Statement of Defense for Chil- dren International- USA).

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62 U. S. Department of Labor interviews with government, industry, labor union, and NGO representatives in June 1997. Except for safety and health provisions, the Mexican Federal Labor Law does not apply to the "Family Industry" or home production. (Mexican Federal Labor Law, Chapter 15, Article 352).

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63 Only one of the shoe manufacturers interviewed, in Guadalajara in the State of Jalisco, indicated that he subcontracted the stitching of uppers to one of the few factories which provides stitching of uppers service. Interview with Ing. J. Arturo Márquez González, President of Calzados Gali, by U. S. Department of Labor official, (June 10, 1997). The other manufacturers visited subcontract the stitching of uppers to household producers.

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64 "Action to End Child Labor Urged," International Textile, Garment and Leather Workers' Federation Newsletter, no. 1 (1994).

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65 An Innovative Approach to Non- formal Education at 2.

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66 Interview with Fawad Usman Khan, Representative, Sudhaar, by U. S. Department of Labor official (June 13, 1997).

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67 Interview with Fawad Usman Khan, Representative, Sudhaar, by U. S. Department of Labor official (June 13, 1997). In a visit to the Moonshine School for former child workers in Kasur, the main concern raised by the children was the pollution problem caused by the leather tanneries. Tannery refuse has polluted air and water, and threatens livestock and human health. This is a major concern to residents, workers, government officials and activists in Kasur.

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68 Fawad Usman Khan, "Child Protection from Exploitative and Hazardous Labour" (Kasur, Pakistan: November 1996) 5 [hereinafter Child Protection from Exploitative and Hazardous Labour].

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69 Presentation at National Child Labour Seminar, Fawad Usman Khan, Representative, Sudhaar, Islamabad, Paki- stan, October 14, 1995 [on file]. In a separate study, Mr. Khan noted that of a population of 40 million children, 28 million children are currently out of school; 16 million children have no access to schools. Child Protection from Exploitative and Hazardous Labour at 2.

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70 Interview with Mohammed Akram, Director of Exports, Service Industries, Ltd., by U. S. Department of Labor official (June 11, 1997).

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71 Human Rights Commission of Pakistan, Child Labour in Pakistan (Lahore: Human Rights Commission of Paki- stan Rights of the Child Series, no. 9, 1995) 18- 19.

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72 The most recent child labor law, enacted in 1991, prohibits employment of minors of less than 14 years of age in a number of industries and production processes that use certain inputs, including tanneries. Exception is made for children working at home under the supervision of the parents. Shoe manufacturing is not one of the industries enumerated in the labor law. The Factory Act of 1934 prohibits the employment of children in any factory with more than 10 workers.

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73 U. S. Embassy- Rome, unclassified telegram no. 2420 (March 18, 1997).

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74 Id.

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75 U. S. Embassy- Rome, unclassified telegram no. 2420 (March 18, 1997). To date, the Italian Association of Leather Manufacturers and the textile and leather working unions have established a joint committee to develop guidelines for the mark or labeling program. The committee is currently trying to obtain funding from the European Union to support this program. Interview with John LaMazza, Labor Attache, U. S. Embassy- Rome, by U. S. Department of Labor official (September 18, 1997).

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76 Entrepreneurial Mobilization for the Eradication of Child Labor in Brazil (São Paulo: UNICEF, December 1996) 9 [hereinafter Entrepreneurial Mobilization].

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77 The Abrinq Foundation does not receive funding from the Brazilian government.

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78 Interview with Abrinq Foundation representatives by U. S. Department of Labor officials, (June 9, 1997).

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79 Entrepreneurial Mobilization at 16.

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80 Entrepreneurial Mobilization at 16- 17; interview with Caio Magri, Director of the Child- Friendly Company Program, Abrinq Foundation, by U. S. Department of Labor officials (June 9, 1997); telephone interview with Caio Magri by U. S. Department of Labor officials (July 8, 1997).

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81 Consultations with public officials include oral and/ or written communications with the Municipal Councils for the Rights of Children and Adolescents, Public Attorneys, and the Regional Office of the Ministry of Labor. These consultations are the only type of government involvement in the certification and labeling program.

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82 Use of the label in the product or promotional material must be approved by the Abrinq Foundation. To date, no cases of label counterfeiting have been reported or investigated.

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83 Interview with Caio Magri, Director of the Child- Friendly Company Program, Abrinq Foundation, by U. S. Department of Labor officials (July 8, 1997). Although Yakult provides financial support to the Abrinq Founda- tion, it does not participate in the Child- Friendly Company program. In 1996, the operational cost of the Child- Friendly Company program was $130,000, which covered staff salaries, equipment, mailing and travel expenses.

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84 Most of the Child- Friendly companies in the footwear sector also participate in another labeling program sponsored by the Pro- Child Institute. This labeling program is described in the following section.

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85 Abrinq Foundation for Children's Rights, Empresa Amiga da Criança Information Booklet (São Paulo, Brazil) [on file]. Examples of some the social programs include: the American Chamber of Commerce in Brazil has established the Institute for Quality in Education ( Instituto Qualidade no Ensino ) which provides financial and technical assistance to four public schools in the state of São Paulo to improve math and language skills among underprivileged children; Calçados Azaléia, a footwear company in Rio Grande do Sul, provides its workers with daycare and health services, college scholarships, and technical training programs. Abrinq also encourages companies to participate in and donate 1 percent of their corporate income tax to the Municipal Fund for the Rights of Children and Adolescents, which is administered by local municipal councils and is comprised of community activists and professionals.

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86 Abrinq's "network of partners" includes labor unions, employers associations, NGOs, and public officials.

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87 Interview with Valdir Luis Barbosa, Administrative Director, Empresa Municipal para o Desenvolvimento de Franca, by U. S. Department of Labor officials (June 14, 1997).

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88 Interview with Arbrinq Foundation representatives by U.S. Department of Labor officials (June 9, 1997).

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89 Instituto Pro- Criança, Manual da Empresa Credenciada (Manual for Certified Companies) (Franca, 1996) 3.

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90 Interview with Miguel Heitor Bettarello and other representatives of the Footwear Industry Association of Franca (Sindicato da Indústria de Calçados de Franca) by U. S. Department of Labor officials (June 13, 1997).

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91 Telephone interview with Maurilo Casemiro Filho, Managing Director, Pro- Child Institute, by U. S. Department of Labor officials (July 22, 1997).

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92 Some of the rehabilitation projects sponsored by the institute receive public funding and are conducted in partnership with government entities.

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93 "Uma Nova Realidade de Atuação Empresarial na Comunidade" (Franca: Pro- Child Institute, January 1997) 24. Many of these companies are also members of the Abrinq Foundation Child-Friendly Company Program.

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94 These companies are large and medium- sized manufacturers that produce both for the domestic and export markets. According to the Industry Association, of the 360 footwear companies in Franca, about 200 companies belong to the Association.

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95 These procedures are outlined in the Manual da Empresa Credenciada (Manual for Certified Companies) provided to each company by the Pro- Child Institute.

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96 Given the lack of current reliable data on child labor in Franca's footwear industry, Cassiano Pimentel, Vice- Mayor of Franca, illustrated the positive impact of the Pro- Child Institute labeling program by citing an increase in school enrollment. According to Mr. Pimentel, the number of children attending school has increased by 17 percent over the last three years. Interview with Cassiano Pimentel, Vice- Mayor of Franca, by U. S. Department of Labor officials (June 13, 1997).

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97 Telephone interview with Maurilo Casemiro Filho, Managing Director, Pro- Child Institute, by U. S. Department of Labor officials (July 22, 1997).

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98 The statement defines business partners as contractors and suppliers who provide labor and/or materials utilized in the manufacturing and finishing of member products. "Statement of Guidelines on Practices of Busi- ness Partners," Athletic Footwear Association (August 31, 1993).

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99 The guidelines define a child as less than 14 years of age or younger than the compulsory age to be in school. In the event of any willful non- compliance with these guidelines, AFA member companies may terminate or refuse to renew their supply agreements with business partners based on the business partner's awareness of these guidelines. "Statement of Guidelines on Practices of Business Partners," Athletic Footwear Association (August 31, 1993). Greg Hartley, Executive Director of the Association, reiterated that these are voluntary guidelines and the Association does not monitor or enforce the guidelines. Telephone interview with Greg Hartley, Executive Director, Athletic Footwear Association, by U. S. Department of Labor officials (August 13, 1997).

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100 The European Confederation of the Footwear Industry (ECFI) and the European Trade Union Committee of Textiles, Clothing and Leather (ETUC: TCL) jointly adopted a Charter on Child Labour within the European social sectoral dialogue meeting held on March 7, 1995. Among other things, companies and affiliated trade unions would "not employ children under the age of 15 or below the age of compulsory schooling, either directly or indirectly." The companies will also support the development of in- house apprenticeship programs to provide for the training of young workers. The Employment of Children - A European Social Partners' Charter for the Foot- wear Industry (Brussels: European Confederation of the Footwear Industry and the European Trade Union Committee of Textiles, Clothing and Leather, March 7, 1995)

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101 "President Clinton Announces Apparel Industry Partnership Agreement," White House press release (April 14, 1997). The Apparel Industry Partnership Agreement calls for the
implementation of a code of conduct and independent monitoring systems that will assure consumers that the clothes and shoes they buy are made under "decent and humane working
conditions." The participants also agreed to develop an independent association to assure compliance with the Code and to inform consumers about which companies comply with it. The footwear companies currently participating in this effort are Nike, Reebok and Phillips- Van Heusen.

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102 For a more detailed discussion of codes of conduct, see The Apparel Industry and Codes of Conduct: A Solution to the International Child Labor Problem? (Washington, DC: U. S. Department of Labor, 1996).

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103 "FY 1995 Profile: Personal Consumer Products & Retailing," in Profile Highlights (Atlanta: Kurt Salmon Associates, July 1996).

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104 International Child Labor Hearing , U. S. Department of Labor (April 28, 1997) (Written statement of Peter T. Mangione, President, Footwear Distributors and Retailers of America).

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105 Information about U. S. importers of Brazilian footwear was provided by the Footwear Industry Association of Franca, to U. S. Department of Labor via facsimile (July 21, 1997).

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106 Interview with representatives of the Footwear Industry Association of Franca, by U. S. Department of Labor officials (June 13, 1997). The Association representatives noted that U. S. importers who source footwear from a number of different countries may not be willing to participate in country- specific labeling programs because of concerns regarding how similar products may be manufactured in other countries.

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107 In addition to provisions on child labor, most of the companies' policies also include other labor provisions addressing issues such as forced or prison labor, safety and health, and
discrimination. Footstar indicated that it has a company policy prohibiting child labor that is communicated to each factory and supplier in a memorandum from the President and CEO; the memo must be countersigned by the factory or vendor. Footstar did not provide a copy of the memorandum.

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108 Interview with Miguel Heitor Bettarello, Calçados Agabê, by U. S. Department of Labor officials (June 13, 1997).

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109 Interview with Celeste Cornelli, Director, Ocean Exports, by U. S. Department of Labor officials (June 18, 1997). Ms. Cornelli also added that she believes that Nine West Headquarters was in the process of developing a code of conduct but that it had not yet been implemented.

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110 Interview with Enio Lucio Schein, Director, Calçados Paquetá, by U. S. Department of Labor officials (June 18, 1997).

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111 Interview with Andy Chuang, Senior Manager, and William Chou, Manager, Nority, Ltd., by U. S. Department of Labor officials (June 17, 1997).

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112 Interview with V. L. Javid Ahmed, General Manager, India Shoes, by U. S. Department of Labor official (June 9, 1997).

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113 Interview with K. Areen- Ur- Rahman, Chairman, KAR Group, FlorInd Headquarters, by U. S. Department of Labor official (June 10, 1997).

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114 Interview with Abdul Rahman, General Manager, Chevro Shoes, by U. S. Department of Labor official (June 11, 1997).

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115 Interview with M. Mohamed Hashim, Chairman, K. H. Group, by U. S. Department of Labor official (June 11, 1997).

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116 Interview with Sudrep Singh Chadra, Manager, Tej Shoe, by U. S. Department of Labor official (June 13, 1997).

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117 Although generally unfamiliar with U. S. importers' codes of conduct, representatives of the American Chamber of Commerce in Mexico, the National Conference of Chambers of Industry, and other industry representatives stated that conceptually codes of conduct and labeling programs are good ideas that could help them market Mexican footwear in the United States. Similarly, the representatives of the Guanajuato State Shoe and Leather Industry Workers Union stated that they were not aware of codes of conduct or labeling programs for the industry but noted that the union has placed a no- child labor provision in its collective bargaining agreements.

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118 The Footwear Distributors and Retailers of America (FDRA) developed a standard form or manufacturers certificate to aid its member companies in addressing the U. S. prohibition of imported goods made with forced or prison labor. In 1993, FDRA added a no-child labor provision to this form. According to the president of FDRA, this form is widely used by many of the member companies; however, FDRA is not responsible for the enforce- ment of the child labor provision. Telephone interview with Peter Mangione, President, Footwear Distributors and Retailers of America, by U. S. Department of Labor official (August 13, 1997).

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119 Interview with Nairton Santana Soares, Human Resources Manager, Calçados Samello, by U. S. Department of Labor officials (June 13, 1997). U. S. Department of Labor officials did not visit the Samello factory and therefore were not able to observe whether the signs were posted. However, during interviews with Samello workers, they confirmed that signs were posted.

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120 Interview with Amaury Rosenberg, President, Adidas Brazil, by U. S. Department of Labor officials (June 12, 1997).

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121 Interview with Ignacio Celis, General Director, Calzados Celis, by U. S. Department of Labor official (June 9, 1997).

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122 Interview with Celeste Cornelli, Director, Ocean Exports, by U. S. Department of Labor official (June 18, 1997); Interview with Mr. Miguel Heitor Bettarello, Calçados Agabê, by U. S.
Department of Labor official (June 13, 1997).

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123 Interview with Thomas Wu, Chairman and CEO, and Jerry Hu, Business Manager, Pegasus International Hold- ings, Ltd., by U. S. Department of Labor officials (June 19, 1997).

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124 Interview with Abdul Rahman, General Manager, Chevro Shoes, by U. S. Department of Labor official (June 11, 1997).

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125 Interview with Sudrep Singh Chadra, Manager, Tej Shoe, by U. S. Department of Labor official (June 13, 1997).

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126 Interview with M. Mohamed Hashim, Chairman, K. H. Group, by U. S. Department of Labor official (June 11, 1997).

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127 Interview with Celeste Cornelli, Director, Ocean Exports, by U. S. Department of Labor officials (June 18, 1997).

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128 In practice, most companies work to correct the violation or may reduce orders until the situation is rectified.

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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