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
consider whether they could increase their technical assistance to
help assure that the smaller companies in the industry can achieve
- 2. All parties should consider whether there would be any
additional benefits to adopting more standardized codes of
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
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.