In Paris this week on an official visit, Azerbaijan’s autocratic President Ilham Aliyev has already scored one photo op. Anyone reading yesterday’s Azeri media could see dozens of photos of Aliyev posing with leaders of top French companies, including Airbus, Suez, and Credit Agricole.

Azerbaijan's President Ilham Aliyev (L) shakes hands with his French counterpart Francois Hollande as they visit a local French school under construction in Baku, May 11, 2014.

© 2014 Reuters

Today, President Hollande will receive President Aliyev and host an official dinner at Palais de l’Elysee. Again, Parisian photo ops abound. But amid the flashing cameras, one has to wonder where Azerbaijan’s repression of critics and the jailing of opponents fits in the new relationship between Paris and Baku?

In the past few years, Azerbaijani authorities have aggressively gone after the country’s once vibrant civil society, jailing dozens of activists, journalists, and political opponents. It also adopted draconian legislation making it virtually impossible for independent non-governmental organizations to operate.

One year ago, as Azerbaijan’s economy started to suffer from falling oil prices, several of those detained on political grounds were released. That was an important first step, but hopes for progress were short-lived.

Many of those released face travel bans or obstacles to their activities. Dozens are still locked up on political grounds, including opposition activist Ilgar Mammadov, despite repeated calls by the Strasbourg-based Council of Europe for his immediate release. And more activists have been thrown in jail. Recently, one of the country’s most popular journalists and bloggers, Mehman Huseynov, was sentenced to two years in prison for allegedly defaming the police, in response to his brave public denouncement of the police abuses he suffered.

When visiting Paris, Brussels, or other European capitals, President Aliyev hopes to get more business opportunities and investment in Azerbaijan. But he prefers to ignore that the people of Azerbaijan want human rights protections, transparency, and good governance. Those standing up for these values are routinely exposed to attacks and harassment.

Yet what more clear message that Azerbaijan’s crackdown cannot be ignored by potential investors than last week’s decision by the Extractive Industries Transparency Initiative (EITI), an international coalition promoting better governance of resource-rich countries, to suspend Azerbaijan – precisely because of its actions against civil society.

President Hollande should reject a narrative that only finance and economy matter in Azerbaijan. Human rights should be as central to France’s foreign policy as other topics.

Hollande should publicly call for the release of Ilgar Mammadov and all those detained in retaliation for their activism and criticism. A failure to explicitly support human rights principles would be the worst message to those unjustly waiting behind bars.

Author: Human Rights Watch
Posted: January 1, 1970, 12:00 am

Arvind Ganesan is the director of Human Rights Watch’s Business and Human Rights Division. He leads the organization’s work to expose human rights abuses linked to business and other economic activity, hold institutions accountable, and develop standards to prevent future abuses. This work has included research and advocacy on awide range of issues includingthe extractive industries; public and private security providers; international financial institutions; freedom of expression and information through the internet; labor rights; supply chain monitoring and due diligence regimes; corruption; sanctions; and predatory practices against the poor. Ganesan’s work has covered countries such as Angola, Azerbaijan, Burma, China, Colombia, the Democratic Republic of Congo, Equatorial Guinea, India, Indonesia, the United States, and Nigeria. His recent research has focused on predatory lending practices and governance issues on Native American reservations in the United States. He has written numerous reports, op-eds, and other articles and is widely cited by the media.

Ganesan has also worked to develop industry standards to ensure companies and other institutions respect human rights. He is a founder of the Voluntary Principles on Security and Human Rights for the oil, gas, and mining industries and is a founding member of the Global Network Initiative (GNI) for the internet and telecommunications industries, where he also serves on the board. Ganesan has helped to develop standards for international financial institutions such as the World Bank, and regularly engages governments in an effort to develop mandatory rules or strengthen existing standards such as the Kimberley Process. He serves on the board of EGJustice, a nongovernmental organization that promotes good governance in Equatorial Guinea, and is a member of the International Corporate Accountability Roundtable (ICAR)’s steering committee.

Before joining Human Rights Watch, Ganesan worked as a medical researcher. He attended the University of Oklahoma.

Posted: January 1, 1970, 12:00 am

 

Apparel companies involved in a widely hailed effort to protect garment workers in Bangladesh factories from harm need to take another step to make sure the gains are sustainable. Making that happen depends in large part on workers' ability to organise and to call out dangerous conditions without fear of being beaten or fired, says Aruna Kashyap, senior counsel for the women's rights division of Human Rights Watch.

Global apparel brands were pressed to address worked safety in Bangladesh factories after the Rana Plaza building collapse in 2013, which killed more than 1,100 garment workers. Activists emerged from the ruins with clothes that had brands' tags, showing the world that workers producing for those brands often toiled in factories that were crumbling or firetraps. Worldwide protests followed demanding action by clothing companies to prevent the deaths of more workers in Bangladesh.

Three weeks after the collapse, more than 200 apparel brands signed the Bangladesh Accord on Fire and Building Safety. The legally binding agreement, which will expire in 2018, was a crucial breakthrough for worker safety.  It established a credible system of inspecting factories and developing corrective measures to address fire and building safety concerns. The Accord also built in strong transparency, listing all signatories, supplier factories, and publicly reporting inspection outcomes, corrective actions, and progress over time.

The Accord has helped make many factories safer, but much remains to be done. A March 2017 progress report shows that 77% of the safety hazards identified in initial inspections were reported or verified as having been fixed, but most factories still have substantial additional work to do to be completely safe.

The Accord's training programme on workplace safety has covered 482 factories, educating about 1m workers.

Empowering workers

But there's more to worker safety and rights than just inspections and training. To ensure that the gains are sustainable, even after the Accord is phased out and handed over to the Bangladesh government, it's crucial to empower workers to protect themselves even after inspectors and trainers leave.

The parties to the Accord are negotiating an extension. The Accord should continue its inspections and training, but also move to the next vital step:  enabling workers to report unsafe factories by protecting their right to freedom of association. Independent unions can play an important role as whistleblowers for dangerous factory conditions, and act to protect workers from harm.

No one should forget that some of the workers in Rana Plaza factories saw the cracks in the walls. They didn't want to enter the building that morning but some factory managers threatened them with dismissal if they refused. There were no unions in any of those factories.

Unions can help workers stand up to unjust demands that put their safety and rights at risk. A single worker may be afraid to come forward. But together, in a union, workers can feel confident to raise their voices. In a recent example, in April, unions in two factories in Bangladesh's Ananta Building intervened and ensured that workers were not forced to enter a building they feared was unsafe.

But most Bangladesh factory owners are hostile to unions, viewing them as pesky rabble-rousers tarnishing the factory's reputation. Many factories have retaliated against union organisers with brute force.  Human Rights Watch research uncovered instances of workers being beaten by thugs believed to have been hired by factory managers. To this day, most garment workers in Bangladesh risk being fired or threatened if they dare to form unions.

Recently, I met a woman garment worker who tried to form a union in Bangladesh. She said male factory managers called her into their office, pinned her down by the neck on a desk, gripped her hand, and forced her to sign a blank sheet of paper. Then they fired her.  But they fixed the paper to say she had "resigned." It was the workers' fourth unsuccessful attempt to unionize.

A union leader from another factory bravely persisted despite threats from the production manager: "The company has a lot of money. If they want to have you abducted, they can and you will vanish.  We'll have your hands and legs broken—we can do it inside the factory." Workers from other factories had similar stories—some union leaders were attacked and seriously injured for trying to form a union.

Freedom of association

Bangladesh government authorities have a longstanding crackdown against unions, and the labour laws don't sufficiently protect workers who try to organise. If brands in the Accord want to make Bangladesh's factories safe, they cannot ignore unions' value for ensuring worker health and safety.

The Accord stakeholders should revise its public reporting and complaints mechanisms to include addressing limits on freedom of association. The Accord should include freedom of association as part of corrective action plans linked to fire and building safety and expand its existing complaints system to include grievances related to employer interference with unions.

Without this, the Accord will fall short of delivering true empowerment and protection for workers. More important, it will miss a vital opportunity to make sure that when the Accord expires, workers will be better equipped to raise their voices.

 

About the author: Aruna Kashyap is senior counsel for the women's rights division of Human Rights Watch, a US-founded international non-governmental organisation that conducts research and  advocacy on human rights.

Author: Human Rights Watch
Posted: January 1, 1970, 12:00 am

Dear Mr. Chakrabarti,

We, the undersigned groups, are writing to express our serious concern about your recent statements concerning the EITI and its decision to suspend Azerbaijan.

In a recent interview with Bloomberg News in which you discussed Azerbaijan, portions of which were published on May 4, 2017, you are quoted as saying, “What’s happened on the EITI is very, very unfortunate,” and that “quite a lot of people” were “worried about some of the criteria that are now being used in EITI.”

The EITI board’s decision to suspend Azerbaijan was grounded in a concrete and accurate assessment of the Azerbaijani government’s failure to meet the EITI requirements concerning civil society. The assessment is based on the rigorous EITI validation process, which includes multiple steps of verification, including an independent external review. The criteria and validation process used by EITI apply equally to all EITI members and all members agree to adhere to them as a condition of membership in good standing at EITI. Any changes in those criteria or validation process have been agreed to by all members, including the government of Azerbaijan.

Prior to suspending Azerbaijan this year, the EITI board gave Azerbaijan nearly two years to become EITI compliant and avoid suspension. The EITI board downgraded Azerbaijan to candidate country in April 2015 and established clear requirements for reform to meet the EITI civil society requirements. At its November 2016 meeting, the EITI board gave Azerbaijan yet another opportunity to implement clear and specific reforms. Azerbaijan did not meet those requirements or make meaningful efforts to progress towards doing so. In line with its criteria and procedures, the EITI board suspended Azerbaijan.

Your statements to Bloomberg are also starkly at odds with your previous assessment following your May 2016 visit to Baku, following which the EBRD publicly reported, “President Chakrabarti and civil society representatives agreed that accelerating the work required to restore the country’s full membership of the Extractive Industries Transparency Initiative (EITI) was a priority, an objective shared by the Government of Azerbaijan.”

We are also deeply concerned that your statements appear to undermine the significant role EITI has in holding governments accountable for transparency and accountability in budget revenues and fiscal policy-making, key priorities for the EBRD. The EBRD has publicly stated on its website: “Supporting increased transparency and good governance is one of EBRD’s key priorities across the energy sector.”

Your statements are also inconsistent with the EBRD’s long-standing public support of the EITI and reliance on the EITI as a key indicator of government’s adherence to good governance and transparency. As stated in the EBRD’s Energy Policy: “The Bank is committed to adhere to best governance, transparency and revenue management standards by requiring its clients to implement the principles and requirements of the EITI,” and “the Bank is committed to go beyond the application of the EITI principles and requirements by encouraging endorsement of EITI where governments have yet to do so …. Moreover, the Bank will work closely on the implementation of EITI throughout its countries of operations."

Such transparency and accountability are essential to public confidence in good governance and to investor confidence alike.

In light of Azerbaijan’s suspension from EITI and failure to meet fundamental standards in transparency and accountability, we call on the EBRD to refrain from public lending or lending benefiting the extractives industry, including for the Southern Gas Corridor.

Additionally, we call on you and EBRD staff, you to make clear, in your public statements, in EBRD publications, and in your dialogue with governments and other partners, that the EBRD unconditionally endorses the EITI as an essential platform for ensuring meaningful transparency and accountability in the extractives sector, principles to which the EBRD has committed itself.

We look forward to your response, which can be sent to Jane Buchanan, Associate Director, Europe and Central Asia, Human Rights Watch, on behalf of the undersigned groups.

Sincerely,

ARTICLE 19
BankTrack
Bankwatch
Counter Balance
Crude Accountability
EcoLur Informational NGO
Freedom Now
Green Advocates International
Global Witness
Helsinki Foundation for Human Rights
Human Rights House Foundation
Human Rights Watch
Institute for Reporters’ Freedom and Safety
Netherlands Helsinki Committee
Norwegian Helsinki Committee
Platform London
Public Association for Assistance to Free Economy (Azerbaijan)
Public İnitiatives Center (Azerbaijan)
Publish What You Pay
Rivers without Boundaries International Coalition
Publish What You Pay- Canada
Publish What You Pay- UK
Publish What You Pay- US
Reporters Without Borders
SJ Around the Bay
Ulu Foundation

Posted: January 1, 1970, 12:00 am

A 13-year-old boy digs for gold ore at a small-scale mine in Mbeya Region, Tanzania. “I was digging with my colleague,” he said. “I entered into a short pit. When I was digging he told me to come out, and when I was about to come out, the shaft collapsed on me, reaching the level of my chest … they started rescuing me by digging the pit and sent me to Chunya hospital.” The accident knocked the boy unconscious and caused internal injuries. He remained in the hospital for about a week and still occasionally feels pain in his waist when he sits. After the accident, he was scared of returning to the pits, but he felt he had no choice, explaining: “Whenever my aunt travels is when I go, because I need something to sustain myself.” Companies trading in gold have a responsibility to ensure that they do not cause or contribute to child labor.
 

© 2013 Justin Purefoy/Human Rights Watch

Consumers are increasingly aware that their smartphones and laptops may have components made with minerals mined by children. But tackling child labor in a long and complex supply chain can seem very daunting.

But there’s some good news this week: the Organization for Economic Cooperation and Development (OECD) has launched its “Practical Actions” tool for companies on child labor in mineral supply chains.

It recommends, for example, that companies build child labor clauses into contracts with their suppliers, that refiners and smelters organize independent and credible on-the-ground inspections of child labor, and that all companies report publicly every year about the steps they have taken to prevent child labor in their supply chain.

Child labor in mining is one of the most dangerous forms of child labor, and is an issue I have documented extensively in small-scale mines in Ghana, Mali, Tanzania, and the Philippines. Children have been injured and killed in mining accidents, suffered poisoning from mercury used in gold processing, and developed respiratory disease from exposure to dust. Yet, gold from mines using child labor has entered the supply chain and reached international gold markets, which provide gold to the electronics sector, jewelry, and banks. 

Human Rights Watch has, for years, urged the OECD to outline the steps companies could and should take to tackle child labor in mineral supply chains. Some governments and companies were initially reluctant to embrace the initiative. But ultimately, they came around to supporting it.

Now, they should implement it, something most companies haven’t really done. The 2011 OECD’s flagship standard, the “Due diligence guidance for responsible mineral supply chains from conflict-affected and high-risk areas,” already lists the worst forms of child labor among the abuses it seeks to prevent. But little has been done so far to put the child labor provisions into practice. Many companies claiming to implement the guidance have hardly mentioned child labor as a concern, despite its widespread nature.

Now, the new OECD “Practical Actions” tool shows how companies can and should act to stop child labor. The next question is: Which companies will implement it publicly?

Author: Human Rights Watch
Posted: January 1, 1970, 12:00 am

“Europeans should not wear clothes made by exploiting garment workers,” Lola Sanchez Caldentey, a member of the European Parliament, boldly declared yesterday. She was speaking at an event commemorating the victims of the 2013 Rana Plaza disaster, when the eight-story building collapsed in Bangladesh, killing over 1,100 garment workers. 

As the rapporteur of the European Parliament’s Committee on Development, Sanchez has spearheaded a new report on the EU flagship initiative on the garment sector. Today, the European Parliament voted to accept the report and its recommendations.

Among other things, the report asks the European Commission to “present a legislative proposal on binding due diligence obligations for supply chains in the garment sector.” This means that apparel companies could be legally obligated to take effective steps to identify, prevent, and remedy human rights abuses against the workers in factories around the world who produce their goods.

It was a bittersweet moment for Aminul Haque, president of the National Garment Workers Federation, a leading group of unions in Bangladesh. He, along with other Bangladesh unions and local nongovernmental organizations, have endured the pain and grief of losing colleagues in the Rana Plaza tragedy and watching those injured and traumatized struggle to cope. Many of the Rana Plaza workers, who were part of the supply chain to global brands, were not able to exercise their right to organize and press for their protections.

After the disaster, labor rights activists have pieced together some relief for workers by cooperating on binding initiatives like the Bangladesh Accord on Fire and Building Safety. Haque recalled how he was in Brussels more than a decade ago cautioning that voluntary programs by apparel companies were simply not good enough.

The European Commission has its work cut out in the coming months. As it works to draft the binding legislation, it should remember that a key pillar of corporate accountability is transparency. In a recent open letter, Human Rights Watch and 78 other labor and human rights organizations urged the commission to ensure that publishing supply chain information becomes integral to any such legislative proposal.

Some companies are already ahead of the curve. As part a civil society campaign, Human Rights Watch documented that at least 29 major apparel brands have published information about their supply chain factory names, locations, and other important information. While this is a growing industry trend, far too many European companies have yet to sign up.

Today’s vote was a crucial step toward binding legislation that will protect garment workers’ human rights.

Author: Human Rights Watch
Posted: January 1, 1970, 12:00 am

Open letter to the European Commission

High time for the European Commission to impose transparency in the garment supply chain

Poor working conditions and workers' rights violations are a distinguishing feature of the garment industry. Indeed, over the last decades they have been a pervasive part of this industry's operations across the globe. In addition, the garment industry is characterized by complex and opaque chains of production and responsibility that include many actors at different levels playing a role in production. The lack of public data on the garment supply chain has been a strong barrier to the improvement of working conditions and to securing respect for human rights.

When the Rana Plaza building collapsed on 24 April 2013, identifying the companies that were sourcing from one of the five Rana Plaza factories was crucial in establishing responsibility. This ultimately enabled the delivery of compensation to the injured survivors and killed workers’ families. However, neither the European Union nor its Member States were able to provide such information. This was in sharp contrast to the United States of America and Canada, where labour organizations could identify the companies sourcing from Rana Plaza within hours, due to the existence of detailed import databases. The only way to identify the European companies linked to the disaster was to search through the rubble for labels.

This must change.

The time has come for the European Commission to develop a smart mix of rules that will include binding regulation on human rights due diligence, in accordance with the UN Guiding Principles on Business and Human Rights (UNGP) and the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector. Several Member States – among them the Netherlands, Germany and France – are developing initiatives aimed at making the management of the garment supply more responsible. For these initiatives to be effective, they must be strengthened by enforcement mechanisms at the EU level. At the very least, supply chains must be made transparent so that a garment company can be linked to the different parts of its supply chain.

Supply chain transparency empowers companies in their capacity to identify, assess, mitigate and provide remedy for the actual or potential adverse human rights impacts, as required under the UNGP. It allows stakeholders, such as garment workers, unions, NGOs or shareholders, to be active in the company’s due diligence process. Furthermore, it enables companies to demonstrate that they respect their duty to carry out human rights due diligence.

Some garment companies have voluntarily disclosed supply chain information. This clearly indicates that disclosure does not harm companies' competitive position. Instead, it can have an added value in managing the supply chain in a responsible and sustainable manner. Nevertheless, most companies are still reluctant to disclose where their products are made.

The European Union – as the biggest consumer market in the world – is extremely well-placed to level the playing field. The EU can achieve this by requiring that garment companies in its internal market carry out a strong human rights due diligence, and by creating supportive enforcement mechanisms for existing or emerging initiatives. The widespread labour and human rights violations in the garment supply chains make it a moral duty for the EU to act.

In order to enforce human rights due diligence initiatives and move closer to the actual enforcement of human rights in the garment industry, the undersigned organizations call upon the European Commission to require that companies disclose, on a regular basis, the names, addresses and contact details of all production units and processing facilities in their supply chain. This includes, when applicable, the parent company of the business at the site.

Signatories:

achACT (Belgium)
ACRF (Belgium)
ActionAid France-Peuples solidaires (France)
ACV-CSC (Belgium)
ACV-CSC Metea (Belgium)
Aktive Forbrugere (Denmark)
ASCOFA- Asoc familiar para la Orientación al Consumo (Spain)
Asociatia Nationala a Specialistilor in Resurse Umane - AUR (Romania)
Buy Responsibly Foundation (Poland)
Calcuta Ondoan (Spain)
Campagna Abiti Puliti (Italy)
CCOO Euskadi (Spain)
Christliche Initiative Romero (Germany)
Clean Clothes Campaign (International)
Clean Clothes Campaign Denmark (Denmark)
CNCD-11.11.11 (Belgium)
CNE (Belgium)
CNMS (Italy)
Collectif Ethique sur l’étiquette (France)
Coordinadora Estatal de Comercio Justo (CECJ) (Spain)
Ecoconso (Belgium)
Euskal Kontsumitzaileen Alkartea/Asociación de Personas Consumidoras y Usuarias Vasca (Spain)
Ekumenická akademie (Czech Republic)
Ethical Trade Finland (Finland)
Ev. Kirche von Westfalen (Germany)
European Trade Union Confederation (ETUC) (International)
FAIR (Italy)
Fair Action (Sweden)
Fair Trade Advocacy Office (FTAO) (International)
Fashion Revolution Belgium (Belgium)
Federación Setem (Spain)
FEMNET (Germany)
FGTB CG (Belgium)
FGTB fédérale (Belgium)
FGTB Wallonne (Belgium)
Forum Feminista María de Maeztu (Spain)
FOS (Belgium)
Fundación Paz y Solidaridad (Spain)
Future In Our Hands (Norway)
Gresea (Belgium)
Human Rights Watch (International)
India Committee of The Netherlands (ICN) (The Nederlands)
Industrial Union TEAM Finland (Finland) 
IndustriALL Europe (International) 
INKOTA (Germany) 
International Trade Union Confederation (ITUC) (International) 
International Corporate Accountability Roundtable (ICAR) (International) 
Jesuit European Social Centre - JESC (International) 
Kampagne für Saubere Kleidung (CCC Germany) (Germany)
La marche mondiale des Femmes (Belgium)
Labour Behind the Label (United Kingdom)
LBC-NVK (Belgium)
Le Monde selon les Femmes (Belgium)
Los Martes Al Sol (Spain)
MANI TESE (Italy)
MEDICUS MUNDI ALAVA (Spain)
MOC (Belgium)
Nazemi (Czech Republic)
Netwerk Bewust Verbruiken (Belgium)
Novi sindikat (Croatia)
Observatorio de RSC (Spain)
Oxfam MDM (Belgium)
Oxfam-Solidarité (Belgium)
Plate-Forme pour le Commerce Equitable (PFCE) (International)
Polish Institute for Human Rights and Business (Poland)
Schone Kleren Campagne (Belgium)
Service Union United PAM (Finland)
SETCA (Belgium) 
Solidarité mondiale - WSM (Belgium)
Solidarité socialiste (Belgium)
SOLIDAR (Belgium)
SOMO (The Nederlands)
SÜDWIND (Germany)
Test-Achats (Belgium)
Trade Union Pro (Finland)
Trade Union Solidarity Centre of Finland (SASK) (Finland)
Vereinte Ev. Mission (Germany)
World Fair Trade Organization – Europe (WFTO-Europe) (International)
11.11.11 (Belgium)

Posted: January 1, 1970, 12:00 am

Human Rights Watch Response: Questionnaire on the impact of economic and financial policies on a democratic and equitable international order

1. Human Rights Obligations of the World Bank and other International Financial Institutions (IFIs)

Human Rights Watch believes it is important for UN experts to ground their work on IFIs in the human rights obligations of these institutions. With the exception of the European banks, IFIs often argue that they are bound only by their own internal standards, rather than international human rights standards. In our view it is essential to counter this.

While some have argued that the nonpolitical mandate of the World Bank outlined in its Articles of Agreement precludes it from considering human rights, few argue that the World Bank itself is permitted to violate human rights protected under international law.[1] As an international organization the World Bank derives human rights obligations from customary international law and general principles of law.[2] As a UN specialized agency the World Bank has an obligation to respect and promote human rights and fundamental freedoms for all without distinction as to race, sex, language, or religion.[3] As you know, UN member states are obliged under article 103 of the UN Charter to comply with the Charter over other international agreements in the event of a conflict between the two.[4] The International Bill of Rights, which refers to the combination of the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR) and the International Covenant on Economic, Social, and Cultural Rights (ICESCR), is recognized as the key source used to interpret the rights provisions in the UN Charter.[5]
2. New Environmental and Social Framework: binding commitment to human rights remains absent

Over the course of the four-year drafting process of the Bank’s new Environmental and Social Framework (ESF), Human Rights Watch urged the Bank to commit to respect human rights within the operative text and to ensure that human rights risks and impacts were accounted for in the definition of social risks and impacts.[6] The Bank’s final ESF, however, does not include a binding commitment to the protection of human rights. The Bank snubbed calls from the UN, human rights groups, and many of its shareholder governments in this glaring omission, which, in addition to other remaining problems, leaves the Bank poorly positioned to respond appropriately to the complex human rights challenges many of its projects encounter. Other multilateral development banks and international agencies have recognized that respect for human rights improves development outcomes and have subsequently incorporated human rights commitments and standards into their safeguard policies.[7] The Bank’s rejection of the human rights framework and the suggestion that human rights are merely aspirational undermines decades of progress in international standard-setting that the governments of nearly all World Bank member countries have agreed to respect.[8]

Having missed the opportunity to recognize and implement its human rights obligations in its new ESF, Human Rights Watch recommends that the World Bank Group embark on an inclusive process for drafting a new and separate human rights policy.[9] Such a policy should embody a commitment from the World Bank to integrate human rights into its work by analyzing human rights issues that are relevant to development in the context of its country strategies, to work with governments to comply with their human rights commitments, and to identify and address human rights risks linked to its investments or advice.

3. Commitment to Participatory Development Pales in the Context of Shrinking Spaces for Civil Society

Development banks have increasingly emphasized the importance of public participation for effective development. Meanwhile, in recent years, a growing number of governments have embarked upon broad and sometimes brutal campaigns to shut down the space for civil society activity, in some cases going so far as to criminalize independent human rights work. These abusive measures can prevent people from participating in decisions about development, from publicly opposing development initiatives that may harm their livelihoods or violate their rights, and from complaining about development initiatives that are ineffective, harmful, or have otherwise gone wrong. These broader trends toward repression have profound impacts for development projects. Not only do many community members and activists face an increasing risk of reprisal for speaking out against projects that enjoy government support, independent groups who could otherwise help communities articulate their concerns and perspectives about development projects face similar challenges. The World Bank Group and other IFIs have not taken meaningful steps toward creating an enabling environment for participation and accountability when they finance projects in countries that are closing or have effectively closed civil society space or routinely punish dissent.

Human Rights Watch was one of 169 organizations to draft and support a statement calling on IFIs to assume their responsibility to ensure meaningful and effective participation in development projects.[10] We sent this statement to the World Bank and regional development banks, but we have not seen them meaningfully implement the seven recommendations outlined.

For example, the World Bank, International Finance Corporation, and the Asian Development Bank are invested in, among other sectors, the agriculture sector in Uzbekistan. The Uzbek government continues to deny freedom of speech, association, and assembly, and torture and ill-treatment are endemic to the criminal justice system, which suffers from a systemic lack of due process rights.[11] Many Uzbek citizens risk politically-motivated charges to expose the harsh realities of the government’s forced labor system in the cotton sector and document other human rights abuses. For this, some are routinely harassed, detained, imprisoned, and ill-treated in custody.[12] In this environment, the IFIs have not taken any measures—or pressed the government to take measures—to ensure that community members and independent groups can monitor forced labor and other rights issues in IFI-financed project areas without risk of reprisal. Nor have the IFIs taken steps to ensure that individuals and groups can complain to the institutions or their accountability mechanisms without risk of retaliation.

At a minimum, as Human Rights Watch and others recommended at the time, the IFIs should have included a covenant in the loan agreement allowing independent civil society and journalists unfettered access to monitor forced labor and child labor, along with other human rights abuses within the IFI project areas and to ensure that no one faces reprisals for monitoring human rights violations in the area, bringing complaints, or engaging with monitors.[13] World Bank staff advised in response that their legal advisors had told them such a covenant was not possible.[14]

In Azerbaijan, while the Extractive Industries Transparency Initiative (EITI) has pressed the government to reverse its crackdown on independent civil society, ultimately resulting in its suspension from the initiative on March 9, 2017, IFIs have remained silent with the exception of the EBRD.[15] The World Bank and regional development banks have endorsed the EITI, as well as generally emphasizing the importance of participation, civil society, and accountability. Despite this, the IFIs have continued to fund significant extractives industries projects without working with the government to reverse its crackdown on independent civil society, as documented in Human Rights Watch’s October 2016 report, Harassed, Imprisoned, Exiled.[16]

4. IFIs Do Not Work to Prevent or Respond to Reprisals Against Critics

Linked to the above point, IFIs have done little to prevent or respond to reprisals against critics of projects that they finance. Human Rights Watch’s 2015 report At Your Own Risk: Reprisals against Critics of World Bank Group Projects documents numerous reprisals against individuals and communities critical of World Bank Group projects.[17] It describes how people in Cambodia, India, Uganda, Uzbekistan, and elsewhere have faced reprisals from governments and powerful companies for criticizing projects financed by the World Bank and the International Finance Corporation (IFC). Despite this research, the World Bank Group and other IFIs have done very little to address the very real risk of reprisals. Please see Human Rights Watch’s recommendations to the World Bank Group, which apply equally to other IFIs, attached.

People affected by IFI projects can bring complaints to internal accountability mechanisms, such as the World Bank’s Inspection Panel. In response to the above-mentioned report, several IFI accountability mechanisms are in the process of developing guidelines to prevent, monitor, and respond to reprisals. For example, on March 30, 2016, the Inspection Panel published Guidelines to Reduce Retaliation Risks and Respond to Retaliation During the Panel Process.[18] This is a welcome development, which we encourage other accountability mechanisms and the institutions themselves to build on.

Human Rights Watch urges accountability mechanisms to:

  • Analyze the risk of reprisals and other security risks linked to every complaint received and proactively discuss with complainants;
  • Take all necessary measures to ensure complainants who ask to have their identities be kept confidential are kept so throughout the process;
  • Throughout and following the accountability process, actively monitor for reprisals including by asking each of the complainants whether they or people closely associated with them had any security concerns or had faced any problems whatsoever, particularly following community visits;
  • Work with the institution to develop an early warning system to identify threats or other security issues particularly for those who have filed or are considering filing a complaint or are otherwise critical of a project, to analyze the risks, and to promptly implement protection measures; and
  • Work with IFI management to respond strongly to any reprisals linked to their cases to ensure that the security of complainants and others is restored and maintained, as is their ability to continue their work as human rights defenders, while also using every avenue available to respond to such reprisals directly.

5. IFIs Should Take Proactive Measures to Identify and Address Entrenched Discrimination

Discrimination can both cause poverty and be a hurdle in its alleviation. While disaggregated data is not available with respect to each marginalized group, published data suggests that more than two-thirds of extremely poor people in low-income countries and lower-middle income countries live in households where the head of household is from an ethnic minority group.[19] It also tells us that more than three-quarters of extremely poor people live in rural areas.[20] Furthermor, more than 80 percent of people with disabilities live in developing countries, illustrating both the confluence of poverty and disability and the importance of proactively addressing the needs of people with disabilities in development strategies.[21] Human Rights Watch has also documented discrimination on the basis of political opinion in the distribution of aid.[22] Discrimination limits peoples’ ability to participate in the development of poverty reduction strategies or government policies and limits access to justice, compounding the problem.

The fundamental human rights guarantees of equality and non-discrimination are legally binding obligations and do not need instrumental justifications. There is also a growing body of evidence that human rights-based approaches, which include an emphasis on advancing substantive equality for marginalized groups, can lead to more sustainable and inclusive development results.[23] Eliminating discrimination and ensuring equality may require legislative or administrative reforms to repeal discriminatory provisions or address discriminatory practices by the government or private actors, changes in resource allocation, or educational measures, and may include temporary special measures.[24]

Human Rights Watch urges IFIs to increasingly take proactive measures to identify and address entrenched discrimination, both direct and indirect; to lend their analysis and voice to dismantling discrimination and recognizing it as a hurdle to development; and to avoid and remedy discrimination for which they may be responsible. While the World Bank has moved toward addressing discrimination in the Bank Directive Addressing Risks and Impacts on Disadvantaged or Vulnerable Individuals or Groups, the directive concerningly does not address all forms of discrimination recognized under international law, particularly language, property, birth, political opinion, and race.[25] We encourage IFIs to consistently, privately and publicly, raise concerns with governments when authorities discriminate against people on any prohibited grounds through either laws or practice, when opportunities arise. This would include:

  • Analyzing the environment for discrimination and marginalization in every country partnership strategy or interim strategy note. Articulate forms of discrimination as challenges and risks for development and promote policies designed to realize substantive equality for marginalized and excluded groups.
  • Systematically assessing the environment for discrimination and marginalization, including obstacles to substantive equality, when analyzing the risks related to and the impacts of proposed projects or programs. Throughout all stages of projects or programs, ensure that all members of affected communities have the opportunity to meaningfully participate. Integrate a disability-inclusive approach into existing and future projects and programs, and ensure that Bank staff has the capacity to support this.
  • Articulating any concerns regarding discrimination and marginalization, including obstacles to substantive equality, in both routine and high level meetings with government officials, and draw on evidence indicating that such a non-discriminatory environment leads to more sustainable development results.
  • Strengthening data collection and analysis along grounds of discrimination to increasingly identify barriers to poverty eradication. It may not be feasible to disaggregate data by all potential grounds of discrimination, but at a minimum the IFIs should collect data disaggregated by gender, marital status, demographic group (i.e. ethnic background, language, religion), locale (rural/urban/slum household, state/territory), age, and disability.
  • Ensuring systems for measuring results determine the extent to which projects reach marginalized communities and incorporate their inputs and perspectives, including the most poor, women, indigenous peoples, people with disabilities, gender and sexual minorities, ethnic, linguistic, and religious minorities, and people holding different political and other opinions.

6. IFIs Should Consistently Work to Advance Fiscal Transparency and Accountability

IFIs generally recognize the importance of avoiding corruption and fiscal transparency and accountability. In practice, however, IFIs are selective when they raise these standards. For example, in Egypt, the IMF chose not to raise with the government the lack of transparency and accountability over the military budget when agreeing an US$12 billion loan.[26] The IMF’s Manual on Fiscal Transparency, which provides guidance on the implementation of its Fiscal Transparency Code, recognizes that these standards should apply to military revenue and expenditure, but in practice the institution has not used its leverage to support progress in this area. [27] Other IFIs similarly fall short in this regard.

7. IFIs Should Support Governments in Realizing their Obligations to Regulate Business

Governments have an obligation to regulate the practices of companies to ensure that they do not violate human rights.[28] IFIs should assist governments in this venture, but recognition of governments’ human rights obligations are absent from IFI advice about company regulation. In addition to integrating this into the advice that it provides, the IFC could support improved government regulation by including country-by-country analysis of governments’ realization of this obligation in their annual “Doing Business” report.

 

[1] The World Bank’s articles of agreement state that the Bank “shall not interfere in the political affairs of any member… Only economic considerations shall be relevant to their decisions…” World Bank, “IBRD Articles of Agreement,” June 27, 2012, http://siteresources.worldbank.org/EXTABOUTUS/Resources/IBRDArticlesOfAg... (accessed March 31, 2017), Article IV, Section 10. Language to the same effect appears in Article V, 6 of the IDA Articles of Agreement. World Bank, “IDA Articles of Agreement,” http://siteresources.worldbank.org/IDA/Resources/ida-articlesofagreement... (accessed March 31, 2017).

[2] ILC, “Draft Articles on the Responsibility of International Organizations,” Report of the International Law Commission, Sixty-third session, UNGAOR 66th session, U.N. Doc. A/66/10, http://legal.un.org/ilc/texts/instruments/english/commentaries/9_11_2011... (accessed March 31, 2017), commentary to art. 4 (b), para. 2, p. 14. International Law Association, “Final Report of the International Law Association Committee on Accountability of International Organizations,” 2004, p. 22: “Human rights obligations, which are increasingly becoming an expression of the common constitutional traditions of States, can become binding upon IO-s in different ways: through the terms of their constituent instruments; as customary international law; or as general principles of law or if an IO is authorized to become a party to a human rights treaty. The consistent practice of IO-s points to a recognition of this. Moreover, certain human rights obligations may have attained the status of peremptory norms,” http://www.ila-hq.org/en/committees/index.cfm/cid/9 (Final Conference Report Berlin, accessed March 31, 2017). International Law Commission, “Yearbook of the International Law Commission, Report of the Commission to the General Assembly on the work of its fifty-third session,” Vol. II pt. 2, U.N. Doc. A/CN.4/SER.A/2001/Add.1, 2001, article 26 para. 5: “Peremptory norms that are clearly accepted and recognized include the prohibitions of aggression, genocide, slavery, racial discrimination, crimes against humanity and torture, and the right to self-determination,” http://legal.un.org/ilc/publications/yearbooks/english/ilc_2001_v2_p2.pdf (accessed March 31, 2017). See also the Furundzija case before the International Criminal Tribunal for the former Yugoslavia, where the prohibition of torture was recognized jus cogens: Prosecutor v. Anto Furundzija, ICTY, The Judgement of the Trial Chamber, JL/PIU/372-E, December 10, 1998, http://www.icty.org/sid/7609 (accessed March 31, 2017); See also the related concept of erga omnes obligations (owed by all States to the international community) in the Barcelona Traction case (Belgium v. Spain), ICJ Rep. 1970, paras. 33 and 34, http://www.icj-cij.org/docket/files/50/5387.pdf (accessed March 31, 2017); See also the East Timor case (Portugal v. Australia), judgment of 30 June 1995, ICJ Rep, 1995, p. 90, http://www.icj-cij.org/docket/files/84/6949.pdf (accessed March 31, 2017).

[3] Charter of the United Nations, June 26, 1945, 59 Stat.1031, T.S. 993, 3 Bevans 1153, entered into force Oct. 24, 1945, art. 555, 56. The World Bank is a specialized agency of the UN as a result of an agreement between the Bank and the UN’s Economic and Social Council (ECOSOC) in 1946: Agreement between the UN and the IBRD, entered into force, 1946, 16 U.N.T.S. 346.

[4] Charter of the United Nations, Supra note 44, art. 103: “in the event of a conflict between the obligations of the Members of the United Nations under the present Charter and their obligations under any other international agreement, their obligations under the present Charter shall prevail.”

[5] The UN special rapporteur on the right to food has stated that “[t]he growing consensus is that most, if not all of the rights enumerated in the [UDHR] have acquired a customary status in international law.” Olivier De Schutter, International Human Rights Law: Cases, Materials, Commentary, (Cambridge: Cambridge University Press, 2010), p. 50. See also “Tilburg Guiding Principles on World Bank, IMF and Human Rights,” 2002, http://www1.umn.edu/humanrts/instree/Tilburgprinciples.html, (accessed March 31, 2017): “The Universal Declaration of Human Rights of 1948 is a ‘common standard of achievement for all peoples and all nations’ (Preamble of the Declaration). At the beginning of the new Millennium, the Declaration goes far beyond being merely a moral or political obligation, as large parts of it belong to international customary law, while some rights have developed into jus cogens standards.”

[6] See Human Rights Watch’s submissions: Abuse-Free Development: How the World Bank Should Safeguard Against Human Rights Violations, July 22, 2013, https://www.hrw.org/sites/default/files/reports/worldbank0713_ForUpload.... “World Bank’s Draft Environmental and Social Framework,” April 7, 2015, https://www.hrw.org/news/2015/04/07/human-rights-watch-submission-world-... “World Bank’s Second Draft Environmental and Social Framework,” October 7, 2015, https://www.hrw.org/news/2015/10/07/human-rights-watch-submission-world-... “Overarching Human Rights Provisions in the World Bank's Environmental and Social Framework,” March 15, 2016, https://www.hrw.org/news/2016/03/15/submission-overarching-human-rights-....

[7] In a 2013 World Bank and Organisation for Economic Co-operation and Development

(OECD) publication, the authors considered dozens of development agencies and found

that the majority had adopted human rights policies or were in the process of doing so,

while few agencies had no human rights policies at all. The World Bank and Organisation for Economic Co-operation and Development (OECD), Integrating Human Rights into

Development: Donor Approaches, Experiences and Challenges, 2nd ed. (Washington DC: World Bank, OECD, 2013), pp. 4-6, table 1.1.

[8] More than 90 percent of the World Bank’s 189 member countries have ratified four or more international human rights treaties. Human rights are also protected to varying degrees in most countries’ constitutions or legislation. All but 1 have ratified the International Convention on the Rights of the Child; 183 have ratified the International Convention on the Elimination of All Forms of Discrimination against Women; 172 have ratified the International Convention on the Elimination of All Forms of Racial Discrimination; 170 have ratified the International Covenant on Civil and Political Rights; 161 have ratified the International Covenant on Economic, Social and Cultural Rights.

[9] Human Rights Watch press release, “World Bank: Human Rights All But Absent in New Policy,” July 21, 2016, https://www.hrw.org/news/2016/07/21/world-bank-human-rights-all-absent-n....

[10] Joint Statement, “International Financial Institutions’ Responsibility to Ensure Meaningful and Effective Participation,” July 2016, https://www.hrw.org/news/2016/07/11/responsibility-international-financi.... See also Joint Advocacy Letter to the World Bank, “Safe Space for Participatory Development,” July 2016, https://www.hrw.org/news/2016/07/19/safe-space-participatory-development.

[11] Human Rights Watch, At Your Own Risk: Reprisals against Critics of World Bank Group Projects, June 22, 2015, p. 109, https://www.hrw.org/sites/default/files/report_pdf/worldbank0615_4up.pdf. See also Human Rights Watch, World Report 2017 (New York: Human Rights Watch, 2016), Uzbekistan chapter,

https://www.hrw.org/world-report/2017/country-chapters/uzbekistan.

[12] Ibid. See also Human Rights Watch, “Until the Very End”: Politically Motivated Imprisonment in Uzbekistan, September 25, 2014, https://www.hrw.org/sites/default/files/reports/uzbekistan0914_ForUpload....

[13] Ibid., p. 112. See also Human Rights Watch and the Cotton Campaign, “World Bank: Reconsider Uzbekistan Projects,” June 9, 2014, http://www.hrw.org/news/2014/06/09/world-bank-reconsider-uzbekistan-proj....

[14] At Your Own Risk, p. 112.

[15] EITI, “The Board decided that Azerbaijan did not fully meet the corrective actions related to civil society space,” March 9, 2017, https://eiti.org/BD/2017-15 (accessed April 12, 2017). For the EBRD’s comments on Azerbaijan and EITI, see Svitlana Pyrkalo, “EBRD President visited Azerbaijan,” European Bank for Reconstruction and Development, May 25, 2016, http://www.ebrd.com/news/2016/ebrd-president-visited-azerbaijan.html (accessed April 12, 2017); and Jack Farchy, “Azerbaijan: Aiming to Please,” Financial Times, August 28, 2016, https://www.ft.com/content/d89d55ae-6b73-11e6-a0b1-d87a9fea034f (accessed April 12, 2017).

[16] Human Rights Watch, Harassed, Imprisoned, Exiled: Azerbaijan’s Continuing Crackdown on Government Critics, Lawyers, and Civil Society, October 2016, https://www.hrw.org/sites/default/files/report_pdf/azerbaijan1016_web.pdf.

[17] Human Rights Watch, At Your Own Risk: Reprisals against Critics of World Bank Group Projects, June 22, 2015, https://www.hrw.org/sites/default/files/report_pdf/worldbank0615_4up.pdf.

[18] World Bank Inspection Panel, “Guidelines to Reduce Retaliation Risks and Respond to Retaliation during the Panel Process,” March 30, 2016, http://ewebapps.worldbank.org/apps/ip/PanelMandateDocuments/2016%20Retal... (accessed April 12, 2017).

[19] A. Sumner, “The New Face of Poverty: How has the Composition of Poverty in Low Income and Lower Middle-Income Countries (excluding China) Changed since the 1990s?,” Institute of Development Studies, 408, (2012), p. 2, http://www.ids.ac.uk/files/dmfile/Wp408.pdf (accessed April 12, 2017); A. Sumner, “The New Face of Poverty? Changing Patterns of Education, Health and Nutrition in Low and Lower Middle-Income Countries by Spatial and Social Characteristics of Households, 1998 vs. 2007, IDS Working Paper, table reproduced in ODI, Post-2015: the road ahead,” https://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opini... (accessed April 12, 2017) pp. 6-7.

[20] A. Sumner, “The New Face of Poverty?,” pp. 7.

[21] World Programme of Action Concerning Disabled Persons, “Current situation,” 2006, http://www.un.org/esa/socdev/enable/diswpa04.htm, (accessed April 12, 2017).

[22] Human Rights Watch, Development without Freedom: How Aid Underwrites Repression in Ethiopia, October 19, 2010, https://www.hrw.org/reports/2010/10/19/development-without-freedom-0.

[23] See OHCHR, “Special Rapporteur on the human right to safe drinking water and sanitation,” http://www.ohchr.org/EN/Issues/WaterAndSanitation/SRWater/Pages/SRWaterI... (accessed April 12, 2017).

[24] UN Committee on Economic, Social and Cultural Rights, General Comment No. 20, Non-Discrimination in Economic, Social and Cultural Rights (art. 2, para. 2), U.N. Doc. E/C.12/GC/20 (2009), http://www.refworld.org/docid/4a60961f2.html, para. 39 (accessed April 18, 2017).

[25] President, World Bank, EXC, Bank Directive Addressing Risks and Impacts on Disadvantaged or Vulnerable Individuals or Groups, August 4, 2016, https://policies.worldbank.org/sites/ppf3/PPFDocuments/e5562765a5534ea0b... (accessed April 12, 2017).

[26] IMF, “ARAB REPUBLIC OF EGYPT REQUEST FOR EXTENDED ARRANGEMENT UNDER THE EXTENDED FUND FACILITY—PRESS RELEASE; STAFF REPORT; AND STATEMENT BY THE EXECUTIVE

DIRECTOR FOR THE ARAB REPUBLIC OF EGYPT,” January 18, 2017, http://www.imf.org/en/Publications/CR/Issues/2017/01/18/Arab-Republic-of... (accessed April 18, 2017). See also IMF, “IMF Executive Board Approves US$12 billion Extended Arrangement Under the Extended Fund Facility for Egypt,” November 11, 2016, https://www.imf.org/en/News/Articles/2016/11/11/PR16501-Egypt-Executive-... (accessed April 18, 2017).

[27] IMF Fiscal Affairs Department, “Manual on Fiscal Transparency,” 2007, http://www.imf.org/external/np/pp/2007/eng/101907m.pdf (accessed April 12, 2017).

[28] OHCHR, “Guiding Principles on Business and Human Rights,” 2011, p. 3, http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_... (accessed April 12, 2017).

Posted: January 1, 1970, 12:00 am

An 8-year-old girl sorts and bundles tobacco leaves by hand near Sampang, East Java.

© 2015 Marcus Bleasdale for Human Rights Watch

(London) – British American Tobacco (BAT) should strengthen its processes for identifying and addressing human rights risks in its global supply chain, Human Rights Watch and Swedwatch said today in an open letter to shareholders. At the company’s annual shareholder meeting on April 26, 2017, shareholders will have an opportunity to press the company to take action and to increase the transparency of its efforts.

Human Rights Watch and Swedwatch described the human rights concerns they identified in their research on farms supplying BAT in Indonesia and Bangladesh, respectively. Human Rights Watch has documented child labor and other human rights abuses in tobacco farming in several countries, and since 2014 has urged the largest global tobacco companies, including BAT, to improve human rights protections and monitoring in their supply chains.

“The global tobacco supply chain has serious risks of human rights abuses including child labor, as well as health and safety risks,” said Jane Buchanan, associate children’s rights director at Human Rights Watch. “Shareholders can press BAT to do a better job identifying and addressing human rights abuses to ensure that the company’s profits don’t come at the expense of vulnerable workers.”

In a May 2016 report, Human Rights Watch found that thousands of children in Indonesia, some as young as 8, are exposed to serious hazards while working on tobacco farms, including some that supply BAT. Many child workers mixed or sprayed toxic pesticides and many suffered nausea, vomiting, or other symptoms consistent with nicotine poisoning, a result of absorbing nicotine through their skin.

Human Rights Watch had previously documented hazardous child labor on tobacco farms in the United States, including in areas where a BAT supplier, Reynolds American, was purchasing tobacco leaf. Human Rights Watch has urged BAT and other tobacco companies to prohibit children from all work involving direct contact with tobacco.

The Stockholm-based Swedwatch, in a June 2016 report, found widespread and hazardous child labor, health problems suffered by families involved in tobacco production, and other serious human rights problems in Bangladesh. Interviewees told Swedwatch that children’s work on tobacco farms interfered with their education.

In describing how the company responded to the two reports, BAT Chief Executive Nicandro Durante said, in a March 2017 sustainability report: “We conduct detailed investigations, take appropriate action to address any issues identified, and report transparently on the progress and outcomes.”

The groups raised concerns about the rigor and credibility of BAT’s monitoring practices, and its transparency in publishing details about supply chain audits.

International human rights norms like the UN Guiding Principles on Business and Human Rights state that companies are responsible for identifying and addressing human rights abuses in their global supply chains, and reporting publicly on their efforts.

“Without transparency, human rights abuses go undetected and are not remedied,” said Alice Blondel, director of Swedwatch. “BAT should carry out rigorous internal and third-party monitoring and publish details on the content of the assessments and results.”

Posted: January 1, 1970, 12:00 am

To British American Tobacco Shareholders:

We write on behalf of the nongovernmental organizations Human Rights Watch and Swedwatch to draw your attention to serious human rights abuses we have documented in British American Tobacco’s (BAT) supply chain in the last year. Our research raises questions about whether the company has taken adequate steps to protect the human rights of the people farming the tobacco that goes into its products. At the Annual General Meeting this week, shareholders have an opportunity to ask questions about the company’s human rights due diligence practices, transparency, and accountability.

In recent weeks, BAT released a new sustainability report. The sustainability report stated, “Tobacco remains the most essential part of our product and the farmers who grow it are absolutely crucial to the success of our business.” But we have seen that these very farmers and hired farmworkers face grim realities in countries where BAT purchases tobacco. The farming families BAT describes as “crucial” to its success include young children and adults who get sick from the work. Many have little or no safety training, and lack even basic equipment to protect themselves from the risks of nicotine exposure, including Green Tobacco Sickness.

A report published last May by Human Rights Watch showed how children as young as 8 risk their health working on small-scale tobacco farms in Indonesia, including some that supply BAT. Based on interviews with more than 130 child tobacco workers, the report found thousands of children—maybe tens of thousands, or more—are exposed to nicotine and toxic pesticides while working on Indonesian tobacco farms, and many of them get sick from the work. Half of the children interviewed said they suffered nausea, vomiting, headaches, or dizziness while handling tobacco—common symptoms consistent with nicotine poisoning, which happens when workers absorb nicotine through their skin.

“After too long working in tobacco, I get a stomachache and feel like vomiting,” said one 13-year-old boy interviewed for the report. He likened the feeling to motion sickness: “It’s just like when you’re on a trip, and you’re in a car swerving back and forth.”

Farmers contracted with BAT’s export company in Indonesia did not understand the risks to child workers and could not clearly articulate the company’s expectations on child labor during interviews with Human Rights Watch.

In June, the Stockholm-based organization Swedwatch published a report based on research in three of BAT’s tobacco cultivation areas in Bangladesh. Drawing on direct observations and interviews with over 150 men, women, and children, the report found widespread and hazardous child labor, adverse health impacts on families involved in tobacco production, and other severe human rights problems.

Swedwatch found family poverty put additional pressure on children to do work that could be harmful to their health or interfere with their education. A 16-year-old boy who worked as a day laborer on a farm contracted with BAT told Swedwatch he sometimes worked 15 or 16 hours a day in the high season. “During this time I cannot go to school and I miss many classes,” he said. “This is a very important year for me as I have to sit for the national exams next year. But there is no option for me but to help my parents.” A teacher in one of BAT’s cultivation areas described how work in tobacco farming affects students: “The work in tobacco farming makes the children weak, and even those who are attending school are unable to concentrate on their studies. They lag behind in the class and lose interest to study further."

In its response to Swedwatch’s findings, BAT underlined the benefits of tobacco farming and stated, “we remain of the view that the report as a whole is not representative of the reality on the ground.”

Human Rights Watch had previously documented hazardous child labor on tobacco farms in the United States, including in areas where BAT supplier Reynolds American purchased tobacco leaf. In a 2011 report, the North Carolina-based Farm Labor Organizing Committee and Oxfam documented human rights abuses, including child labor and violations of the rights to freedom of association and collective bargaining on US tobacco farms. FLOC has repeatedly urged Reynolds American and BAT to take additional steps to protect the labor rights of workers in its supply chain, and ensure on-the-ground mechanisms for fair negotiations on tobacco prices and working conditions. BAT and Reynolds American are undergoing a US$49 billion merger this year. 

Our research shows BAT, like many other tobacco companies, has not done nearly enough to identify human rights risks and impacts, and to shoulder its responsibility to remediate violations affecting farmers and workers in the supply chain “most essential” to its product. Under the framework established by the UN Guiding Principles on Business and Human Rights, tobacco companies are responsible for identifying and addressing human rights abuses in their operations. They should report publicly on those efforts.

In its recent sustainability report, BAT acknowledged that, “Agricultural supply chains are particularly susceptible to human rights violations,” and that 60 percent of child labor worldwide occurs in agriculture. Yet in Bangladesh, the company maintained that its own monitoring program found, “zero reported incidences of child labour in tobacco growing,” raising questions about the rigor and effectiveness of its monitoring practices.

BAT makes limited information about its tobacco supply chain monitoring program publicly available.

Under the company’s Sustainable Tobacco Programme, BAT suppliers complete self-assessments annually, where they grade themselves on their own performance on all of the company’s most important human rights and sustainability criteria. Unsurprisingly, BAT suppliers tend to perform extremely well on their own self-assessments. In 2014, for example, BAT’s suppliers in Indonesia got an average score of 90 percent on the child labor section of these self-assessments. The company publishes no detailed information about the specific criteria used, the content of these assessments, or the meaning of these scores.

Every three years, third-party monitors perform an in-country audit and visit a handful of farms to check for abuses. The scope, methodology, and results of the third-party audits are not made public.

In response to the Swedwatch report, the company stated that it had commissioned an assessment of “human rights-related impacts of tobacco growing” at country-level in Bangladesh. In describing how the company responded to our reports on human rights abuses in Indonesia and Bangladesh, BAT Chief Executive Nicandro Durante, said, “We conduct detailed investigations, take appropriate action to address any issues identified, and report transparently on the progress and outcomes.

At this week’s Annual General Meeting, shareholders have an opportunity to push the company to live up to those words, and to examine its human rights policies and monitoring practices, and the transparency and relevance of its public reporting. They deserve clear answers about steps the company is taking to ensure its products are not tainted by human rights abuses. 

British American Tobacco should:

  • Ensure that all contracts and business agreements with suppliers of any size include specific requirements to respect human rights throughout the company’s supply chain, including prohibiting the use of child labor anywhere in the supply chain, specifically any work in which children under 18 have direct contact with tobacco in any form;
  • Collect data and qualitative information about farming communities and farms each season and utilize this information to identify potential human rights risks, including child labor and obstacles to education for children among others;
  • Conduct regular and rigorous monitoring in the supply chain for child labor and other human rights abuses. Human rights impact assessments should include meaningful consultation with stakeholders and vulnerable groups;
  • Engage entities with expertise in human rights and child labor to conduct regular third party monitoring in the supply chain;
  • Publish detailed information about internal and external monitoring in a timely manner. Credible public reporting should include such elements as the terms of reference for the monitors, methodology, indicators used in evaluation, scope of the evaluation (including geography and numbers of farms visited, and the numbers of farmers, family members, including children, and hired workers interviewed), detailed results, and other elements published in a form and frequency consistent with the guidance on transparency and accountability in the United Nations Guiding Principles on Business and Human Rights;
  • Ensure access to remediation when human rights problems are identified. Establish and enforce penalties for suppliers who violate the company’s human rights policy. The penalties should be sufficiently severe and consistently implemented so as to have a dissuasive effect. Discontinue business with suppliers that repeatedly violate the company’s human rights policy;
  • Ensure that all tobacco leaf purchases can be traced to the specific farms where it was grown;
  • Make details on tobacco sourcing available to the public, investors and consumers by disclosing supply countries, suppliers, and size and location of cultivation areas;
  • Continue to engage in collaborative initiatives to address hazardous child labor in global supply chains. Such initiatives are a supplement to, not a replacement for, the company’s individual human rights due diligence across all its global leaf operations.

Shareholders can push BAT to take more meaningful action to protect human rights in its global operations.

For further information, please contact Human Rights Watch in New York (hrwpress@hrw.org; +1-212-216-1832) or London (tilianm@hrw.org; +44 (0) 20-7618-4777), or Swedwatch in Stockholm (jenny@swedwatch.org; +46 (0)8-525-203-75).

Sincerely,

 

Jane Buchanan

Associate Director, Children's Rights

Human Rights Watch

 

Arvind Ganesan

Director, Business and Human Rights

Human Rights Watch

 

Alice Blondel

Director

Swedwatch

 

Posted: January 1, 1970, 12:00 am

Relatives cry for loved ones trapped in the collapsed Rana Plaza building outside Dhaka on April 24, 2013.

(c) 2013 Reuters

“Sometimes I just can’t sleep without pills. I keep remembering how many people died that day.”

Shabana, her name changed to protect her privacy, survived three days buried in the rubble of Rana Plaza, an eight-story building with five garment factories that collapsed in Bangladesh in 2013.

Four years later, Shabana is still struggling to piece her life back together. She has nightmares. Depression hampers her life and ability to work. Setting foot inside a garment factory is unthinkable. She is now a domestic worker.

There was barely any publicly available information about the apparel brands that were using the Rana Plaza factories. Activists searched through the rubble for labels and interviewed survivors.

For decades, such secrecy has been the norm in the garment industry. While a handful of companies, like Adidas, Nike, Levi’s, Puma, and Patagonia, began publishing details more than a decade ago, others have recently joined. By the end of 2016, at least 29 apparel companies were disclosing some information about their source factories. Yet, company commitments to transparency about supplier information are inconsistent, with widely varying standards for what they choose to disclose. Many brands have held out completely.

 

Garment workers in Bangladesh face poor working conditions and anti-union tactics by employers including assaults on union organizers. In the two years since more than 1,100 workers died in the catastrophic collapse of the Rana Plaza factory on April 24, 2013, efforts are underway to make Bangladesh factories safer, but the government and Western retailers can and should do more to enforce international labor standards to protect workers’ rights, including their right to form unions and advocate for better conditions.

Last year, a coalition of labor and human rights organizations endorsed the Transparency Pledge, which sets a minimum standard for publishing supply chain information. The coalition contacted 72 apparel and footwear companies, urging them to carry out the pledge. The pledge reflects existing corporate practices on disclosure, and aims to foster a level playing field in the industry.

Seventeen companies will fully align their disclosure practices with the pledge by the end of 2017. Many others are moving in the right direction. But the industry still has a long way to go. Well-known brands and retailers like Forever21, Urban Outfitters, Walmart, Primark, and Armani are among those yet to embrace transparency.

Supply chain transparency complements other measures for worker safety and rights like the Bangladesh Accord on Fire and Building Safety. Numerous brands are part of the accord and publish their supplier information.

Companies that are reluctant to adopt the Transparency Pledge sometimes claim it is a competitive disadvantage. But increasingly, their competitors are dispelling this myth.

Shabana sewed clothes in a Rana Plaza factory. But she and most other workers didn’t know the brands. “Workers should know about brands so they can tell their true stories,” she says.

 

 

Author: Human Rights Watch
Posted: January 1, 1970, 12:00 am

(Nairobi, April 21, 2017) – Equatorial Guinean authorities should immediately release two men who head the country’s leading human rights organization, seven human rights and transparency organizations said.

The police detained Enrique Asumu and Alfredo Okenve, who head the Center for Development Studies and Initiatives (CEID), on April 17, 2017, and have exceeded the 72-hour period that Equatorial Guinean law permits them to detain a person without charge.

“The authorities have a long history of harassing, arbitrarily detaining, and generally interfering with the work of human rights defenders in Equatorial Guinea,” said Tutu Alicante, executive director of EG Justice, which monitors human rights abuses in Equatorial Guinea. “This latest incident shows the authorities’ willingness to trample on the country’s due process laws to intimidate and silence dissent.”

Alfredo Okenve was a speaker at the International Anti-Corruption Conference held in Panamá in December 2016

The organizations raising their concerns about the detention are Human Rights Watch, EG Justice, Publish What You Pay, Transparency International, the UNCAC Coalition, Amnesty International, and the International Anti-Corruption Conference.

Asumu is the president, and Okenve vice president, of CEID. On April 16, authorities prevented Asumu from boarding a flight from the country’s island capital, Malabo, to the mainland city of Bata, claiming they were acting on the orders of the minister of national security, said a colleague of Asumu’s who was present and Asumu’s lawyer.

The following day, Asumu and Okenye visited the ministry’s offices, which are housed in same building as the Central Police Station in Malabo. The national security minister interrogated the two men in his office for more than five hours, said two colleagues who accompanied them to the meeting and waited outside. After the meeting ended, at about 6 p.m., the authorities prevented Asumu and Okenve from leaving the building, and they continue to hold them there.

The police have permitted the colleagues, as well as family members, to visit Asumu and Okenve, and have allowed them access to their lawyers. But the authorities have not brought them before a judge, which the law requires within 24 hours. Nor have the authorities charged them, which under Equatorial Guinean law must take place within 72 hours.

The Ministry of the Interior ordered CEID to suspend its activities indefinitely in March 2016. Colleagues who have spoken with Asumu and Okenve said that the authorities have threatened to fine them 10 million CFA francs (US$16,000) for violating this order.

The ministry issued the order after shutting down a youth meeting that it contends included statements by participants that constituted incitement, a charge CEID maintains is false and politically motivated. The organization appealed the suspension order, but received no response, a representative from the organization said.

The organization announced that it would resume its activities in September 2016. A representative of the organization contended that the April 2016 suspension of its operations was effective only for three months. Since then, it has organized events attended by representatives from various government ministries.

The government of Equatorial Guinea is applying to join the Extractive Industries Transparency Initiative (EITI), an effort that brings together governments, companies, and nongovernmental groups to encourage better governance of resource-rich countries by fostering open public debate about the use of oil, gas, and mining revenues. The EITI requires member governments to foster “an enabling environment for civil society” and to “refrain from actions which result in narrowing or restricting public debate in relation to implementation of the EITI.”

Equatorial Guinea has been dogged by corruption scandals exacerbated by the lack of transparency related to natural resource revenues. The suspension of the country’s leading organization promoting transparency and respect for human rights, and the detention of its leadership, send the wrong signal about the government’s commitment to combatting corruption, the groups said.

“These detentions make the government’s promises to respect civil society as part of its bid to join EITI ring hollow,” said Elisa Peter, executive director of Publish What You Pay. “They threaten to topple the country’s EITI candidacy and send the message that the government will not tolerate independent voices.”

When CEID resumed its activities in September 2016, it also resumed its role as a member of the national steering committee that involves government officials, oil companies, and civil society as the first stage in applying for EITI membership. The national steering committee last met on April 12, and the minister of mines attended an event the human rights group held on April 14 in celebration of its twentieth anniversary.

“The government works with CEID when it wants to feign respect for civil society, but then keeps this suspension order hanging over it like the sword of Damocles,” said Sarah Saadoun, a business and human rights researcher at Human Rights Watch. “By bullying two of the country’s most respected human rights defenders, the government seems to be trying to silence civil society at a moment of rising anger over the country’s deepening economic crisis.”

Update: Enrique Asumu was released on April 25 and Alfredo Okenve was released on May 3. Both were required to pay an arbitrary fine of 2 million CFA francs (US$3,325) to secure their release.

Posted: January 1, 1970, 12:00 am
 
(London) – More apparel and footwear companies should join 17 leading apparel brands that have aligned with an important new transparency pledge, a coalition of unions and human rights and labor rights advocates said in a joint report issued today. The pledge commits companies to publish information that will enable advocates, workers, and consumers to find out where their products are made.
 
The 40-page report, “Follow the Thread: The Need for Supply Chain Transparency in the Garment and Footwear Industry,” comes just ahead of the fourth anniversary of the Rana Plaza building collapse disaster in Bangladesh. It calls for companies to adopt the Apparel and Footwear Supply Chain Transparency Pledge. Companies that align with the pledge agree to publish information identifying the factories that produce their goods, addressing a key obstacle to rooting out abusive labor practices across the industry and helping to prevent disasters like the Rana Plaza collapse.
 
The coalition contacted 72 companies and asked them to adopt and carry out the pledge. The report details their responses and measures their current supply chain transparency practices against the pledge.
 
 
“A basic level of supply chain transparency in the garment industry should be the norm in the 21st century,” said Aruna Kashyap, senior counsel for the women’s rights division at Human Rights Watch. “Openness about a company’s supply chain is better for workers, better for human rights, and shows that companies care about preventing abuse in their supply chains.”
 
The Rana Plaza building collapse on April 24, 2013 killed over 1,100 garment workers and injured more than 2,000. It was preceded by two large factory fires – one in Pakistan’s Ali Enterprises factory and another in Bangladesh’s Tazreen Fashions factory – that killed more than 350 workers and seriously injured many others. Afterward, labor advocates could not determine which companies’ products were made at these factories and had to hunt for the brand labels from the factory sites and interview surviving workers to determine who was responsible
 
By the end of 2016, at least 29 global apparel companies had published some information about the factories that manufacture their products. To build on this momentum, in 2016, a nine-member coalition of labor and human rights organizations and global unions endorsed the Transparency Pledge. Its aim is to create a level playing field in the industry and move it toward a minimum standard for publishing supplier factory information.
 

 

The coalition consists of Clean Clothes Campaign, Human Rights Watch, IndustriALL Global Union, the International Corporate Accountability Roundtable, the International Labor Rights Forum, the International Trade Union Confederation, the Maquila Solidarity Network, UNI Global Union, and the Worker Rights Consortium.

Coalition members wrote to 72 companies – including 23 industry leaders that were already publishing supplier factory information – urging them to adopt and carry out the Transparency Pledge standards. At the time, many apparel companies, including some that source from countries with persistent labor rights problems, were not publishing any supplier factory information.

Related Content

 
The Transparency Pledge draws upon existing good practices of global apparel companies and sets a floor, not ceiling, for supply chain transparency. It asks apparel companies to publish important information about supplier factories and their authorized subcontractors. These efforts to publish supplier factory information help assert workers’ human rights, advance ethical business practices and human rights due diligence in apparel supply chains, and build stakeholder trust, in line with the United Nations Guiding Principles on Business and Human Rights.
 
Many significant investors have begun to urge apparel companies to make their supplier information public. Most recently, the Corporate Human Rights Benchmark, endorsed by 85 investors representing US$5.3 trillion in assets, score-carded apparel companies’ supply chain transparency, requiring them to publish at least the names of factories that produced for them.
 
“After Rana Plaza and other disasters, human rights groups, unions, and some companies and investors have seen how important transparency is for preventing abuses and for efforts at accountability,” said Ben Vanpeperstraete, lobby and advocacy coordinator at the Clean Clothes Campaign International Office. “Companies need to put transparency into practice to show that they respect human rights and decent working conditions.”
 
Transparency is a powerful tool for promoting corporate accountability for garment workers’ rights in global supply chains, the coalition said. It allows workers and labor and human rights advocates to alert the company to rights abuses in its supplier factories. Information about brands’ supplier factories facilitates faster access to grievance redress mechanisms for human rights abuses.
 
Of the 72 companies that the coalition contacted, 17 will be in full alignment with the pledge standards by December 2017.
 
Many other companies fell short of the pledge standards: five fall just short of the pledge, 18 are moving in the right direction by disclosing at least the names and addresses of cut-make-trim factories, and seven are taking small steps toward publishing supplier factory information – for example, a part of their supplier factories, or at least the names of their supplier factories by country of manufacture, by December 2017.
 
Another 25 apparel companies do not publish information about factories that manufacture their products. Those companies either did not respond or made no commitment to publish any of the information requested.
 
The coalition urges companies that have not aligned with the pledge to do so by December and to help galvanize the apparel industry toward a basic threshold level of supply chain transparency.
 
“Adhering to a minimum level of supply chain transparency in the pledge is important for accountability efforts,” said Judy Gearhart, executive director at the International Labor Rights Forum. “Companies can do more, but they should at least start with this basic step.”
 
Some companies claimed that disclosure would put them at a commercial disadvantage. But that justification is clearly contradicted by the other companies that are publishing such information, the groups said. As Esprit, one of the companies that made a commitment to align with the pledge, said, “[R]eleasing this information is not comfortable for many companies, but the time has come to do it.”
 
Apparel Companies in Full Pledge or Close to Full Pledge Alignment
Apparel companies that had previously published supply chain information and made a commitment to publish additional supplier factory information by December 2017 in full alignment with the pledge standards are adidas, C&A, Cotton On Group, Esprit, G-Star RAW, H&M Group, Hanesbrands, Levis, Lindex, Nike, and Patagonia.
 
Apparel companies that had previously not published any supplier factory information and have made a commitment to publish information in full alignment with the pledge are ASICS, ASOS, Clarks, New Look, Next, and Pentland Brands. These global apparel companies will help break new ground by promoting an industry-wide minimum standard for supply chain transparency.
 
John Lewis, Marks and Spencer, Tesco, Gap, and Mountain Equipment Co-op adhere to transparency practices that fall just short of the pledge standards.
 
In the Right Direction
Coles, Columbia Sportswear, Disney, Hudson’s Bay Company, Kmart and Target Australia, and Woolworths Australia were already publishing the names and street addresses of supplier factories and have not made additional commitments to meet pledge standards. Puma and New Balance were publishing the names and addresses of supplier factories and have made a commitment to add more details to align more closely with the pledge standards.
 
ALDI North and ALDI South, Arcadia Group, Benetton, Debenhams, LIDL, Tchibo, Under Armour, and VF Corporation are taking steps in the right direction and have begun or will begin to publish names and street addresses of at least all cut-make-trim factories in 2017. Fast Retailing published the names and addresses of its UNIQLO brand’s “core factory list” in 2017.
 
Small Steps Toward Publishing Supplier Factory Information
Target USA had previously published the names of their supplier factories with country of manufacture but made no commitment to do more. In 2017, Mizuno, Abercrombie & Fitch, Loblaw, and PVH Corporation have taken steps to publish the names of suppliers, but only with the country of manufacture.
 
BESTSELLER and Decathlon have promised that they will publish supplier factory information in 2017 without specifying precisely what will be included. 
 
No Commitment to Publishing Supplier Factory Information
American Eagle Outfitters, Canadian Tire, Carrefour, Desigual, DICK’S Sporting Goods, Foot Locker, Hugo Boss, KiK, MANGO, Morrison’s, Primark, Sainsbury’s, The Children’s Place, and Walmart did not make a commitment to publish supplier factory information. Inditex declined to publish supplier factory information but makes this data available to IndustriALL and its affiliates as part of its reporting under its Global Framework Agreement.
 
Armani, Carter’s, Forever 21, Matalan, Ralph Lauren Corporation, Rip Curl, River Island, Shop Direct, Sports Direct, and Urban Outfitters did not respond to the coalition and do not publish any supply chain information.
 
Brands that have signed global framework agreements with IndustriALL and publish some supplier factory information:
H&M Group and Mizuno; Tchibo will begin publishing in 2017.
 
Brands that are part of the Bangladesh Accord on Fire and Building Safety and publish supplier factory information:
Accord members that have been publishing supplier factory information are adidas, C&A, Cotton On Group, Esprit, G-Star RAW, H&M Group, Kmart Australia, Lindex, Marks and Spencer, Puma, Target Australia, and Woolworths.
 
Accord members that have begun or will begin publishing some supplier factory information in 2017 are Abercrombie & Fitch, ALDI North and ALDI South, BESTSELLER, Debenhams, Fast Retailing, John Lewis, New Look, Next, LIDL, Loblaw, PVH Corporation, Tchibo, and Tesco.
 
Brands that are part of the German Partnership for Sustainable Textiles (the Textil Bündnis) and publish their supplier factory information:
Adidas, C&A, Esprit, H&M, and Puma; others including ALDI North and ALDI South, LIDL, and Tchibo began or will begin publishing supplier factory information in 2017.
 
 
Current/Anticipated Disclosure by December 31, 2017 vs. Pledge Standards
Company Headquarters Published supplier factory--cut-make-trim (CMT) and subcontractor-- information prior to Pledge Letter? Supplier factory information published meets or will meet Full Pledge by December 2017? Names and street addresses of CMT factories and their subcontractors Worker numbers Product types Parent company information Frequency of disclosures Time Frame to Implement Pledge
Abercrombie & Fitch US None Not full Pledge, but will begin publishing supplier factory information in 2017. Names of tier-1 factories (CMT for woven, denim, knit, sweater, intimates,and accessoroies) with country of manufacture, but without street address. No No No 2 times per year 2017
Adidas Germany Names of all tier-1 factories, including those used by licensees as well as authorized subcontractors, by country and city. Names of all tier-2 wet process suppliers, by country and city. Separate lists of supplier factories used for the Olympic Games. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
ALDI North and ALDI South Germany None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 (CMT) factories but not their subcontractors. No No No 1+ times per year 2017
American Eagle Outfitters US None No commitment to publish supplier factory information. No No No No NA NA
Arcadia Group UK None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 (CMT) factories but disclosure of authorized subcontractors will need more time. No No No 1+ times per year NA
Armani Italy None No response to coalition letter. No No No No NA NA
ASICS Japan None Full Pledge alignment. Yes Yes Yes Yes 1 time per year 2017
ASOS UK None Full Pledge alignment. Yes Yes Yes Yes 6 times per year 2017
Benetton Italy None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 (CMT) factories but not their subcontractors. No Yes No 1 time per year NA
BESTSELLER Denmark None Not full Pledge, but will begin publishing supplier factory information in 2017. Company stated that tier-1 (CMT) factories will be published but did not provide more information about what precisely will be disclosed for each factory. No information No information No information No information 2017
C&A Netherlands Names and addresses of all CMT factories. Excluded: Brazil, Mexico, and processing factories. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Canadian Tire Canada None No commitment to publish supplier factory information. No No No No NA NA
Carrefour France None No commitment to publish supplier factory information. No No No No NA NA
Carter's US None No response to coalition letter. No No No No NA NA
Clarks UK None Full Pledge alignment. Yes Yes Yes Yes 2 times per year A vast majoirity of the supplier factory information will be published in 2017. Five percent of non-footwear accessories to be published in 2018.
Coles Australia Names and addresses of CMT factories, but not subcontractors. Company states that its supplier factories use minimal subcontracting. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of CMT factories, but not subcontractors. Company states that its supplier factories use minimal subcontracting. No No No 1 time per year NA
Columbia Sportswear US Names and addresses of factories from which they directly source and any external subcontractors engaged to perform finishing processes (mostly limited to collegiate suppliers since the others have in-house capacity). No additional commitments to meet Pledge standards; maintaining status quo. Yes No No No 1 time per year NA
Cotton On Group Australia Names and addresses of CMT factories used by top 20 suppliers. Full Pledge alignment. Yes Yes Yes Yes Multiple 2017
Debenhams UK None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 factories which includes all CMT factories; some external processing such as embroidering and washing may not be included. Yes No No No information 2017
Decathlon France None Not full Pledge, but will begin publishing supplier factory information in 2017. Company did not provide more information about what precisely will be disclosed for each factory. No information No information No information No information 2017
Desigual Spain None No commitment to publish supplier factory information. No No No No NA NA
DICK'S Sporting Goods US None No commitment to publish supplier factory information. No No No No NA NA
Disney US Names and addresses of all facilities part of Disney's vertical supply chain and any facility in its vertical supply chains where Disney intellectual property is located, which includes any laundry, printing, embroidery facility if Disney intellectual property is incorporated into that finished product or component. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of all facilities in its vertical supply chain, including subcontractors, where Disney intellectual property is located. No No No 1 time per year NA
Esprit Germany Names and addresses of CMT factoriesand their authorized subcontractors. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Fast Retailing Japan None Not full Pledge, but will begin publishing supplier factory information in 2017. Published name and addresses of "Core Factories"producing for UNIQLO brand, representing 80 percent of the total volume of orders for UNIQLO brand. Plans to publish a list of GU's "major partner factories" in 2017. No clear commitment to publish subcontractors in 2017. No No No 1 time per year 2017
Foot Locker US Previously disclosed names and addresses for suppliers of collegiate apparel line that is currently inactive. No commitment to publish current own-brand supplier factory information. No No No No NA NA
Forever 21 US None No response to coalition letter. No No No No NA NA
G-Star RAW Netherlands Names, addresses, product types, parent company, and worker numbers for CMT factories. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Gap US Names and addresses of CMT factories and their authorized subcontractors. Almost full Pledge alignment. Yes Yes Yes No 2 times per year Gap did not make any new commitments to align with the Pledge by December 2017. The company updated its supplier factory information to be more closely aligned with the Pledge.
H&M Group Sweden Names and addresses of supplier factories and vendors (suppliers), processing factories, and some fabric suppliers. Full Pledge alignment. Yes Yes Yes Yes 4 times per year 2017
Hanesbrands US Names and addresses of collegiate suppliers and owned factories. Full Pledge alignment. Yes Yes Yes Yes 4 times per year 2017
Hudson's Bay Company Canada Names and addresses of some, but not all, supplier factories. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of some, but not all, CMT factories. No No No 1 time per year NA
Hugo Boss Germany None No commitment to publish supplier factory information. No No No No NA NA
Inditex Spain CMT factories not published. Names and addresses of direct and indirect wet processing factories published. No commitment to publish supplier factory information. No No No No NA NA
John Lewis UK None Almost full Pledge alignment. Yes Yes Yes No 2 times per year 2017
KiK Germany None No commitment to publish supplier factory information. No No No No NA NA
Kmart Australia Australia Names and addresses of factories in "high risk" countries. No response to coalition letter. Names and addresses of factories in "high risk" countries. No No No No information NA
Levi Strauss US Names and addresses of CMT factories and authorized subcontractors. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
LIDL Germany None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 factories which includes all CMT, but does not include all processing facilities. No No No 2 times per year 2017
Lindex Sweden Names and addresses of CMT factories. Full Pledge alignment. Yes Yes Yes Yes 1 time per year 2017
Loblaw Canada None Not full Pledge, but will begin publishing supplier factory information in 2017. Names of all factories where they Òsource apparel and footwear directlyÓ with country of manufacture but not street address. No No No 2 times per year 2017
MANGO Spain None No commitment to publish supplier factory information. No No No No NA NA
Marks and Spencer (M&S) UK Names and street addresses, worker numbers, gender breakdown, and product types. Almost full Pledge alignment. M&S will continue with its Plan A disclosure commitments and add processing factories and also make its existing disclosure available in a searchable format. Yes Yes Yes No 2 times per year 2017
Matalan UK None No response to coalition letter. No No No No NA NA
Mizuno Japan None Not full Pledge, but will begin publishing supplier factory information in 2017. Names along with country of manufacture of "Core Suppliers," that is, 125 factories disclosed of 464 tier-1 suppliers as reported on Mizuno website. No Yes No No information Began disclosure in 2017.
Morrison's UK None No commitment to publish supplier factory information. No No No No NA NA
Mountain Equipment Co-op (MEC) Canada Names and addresses of all CMT factories and some processing facilities. Almost full Pledge alignment. Names and addresses of all CMT factories and some processing facilities. Yes Yes Yes 2 times per year Additional details for CMT factories to meet Pledge standards will be published in 2017. Names and other details of authorized printers will be added subsequently.
New Balance US Names and addresses of direct supplier factories, excluding US wholly-owned facilities. Not full Pledge, but will add product type, and update annually in searchable format. Names and addresses of direct supplier factories, excluding US wholly-owned facilities. No Yes No 1 time per year 2017
New Look UK None Full Pledge alignment. Yes Yes Yes Yes At least annual 2017
Next UK None Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Nike US Names, addresses, product category, worker numbers, gender and migrant worker breakdown, and authorized subcontractor. Full Pledge alignment. Yes Yes Yes Yes 4 times per year 2017
Patagonia US Names, addresses, product category, worker numbers, gender breakdown, and parent companies of CMT and authorized subcontractors. Some fabric suppliers indicated. One cotton farm also disclosed. Full Pledge alignment. Yes Yes Yes Yes 1 time per year 2017
Pentland Brands UK None Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Primark UK None No commitment to publish supplier factory information. No No No No NA NA
Puma Germany Name of factory by country, city for tier-1 "core suppliers" and tier-2 material and component suppliers. Almost full Pledge alignment for tier-1 "core suppliers" factories. Names and addresses of tier-1 "core suppliers" amounting to 80 percent of their total business volume. But authorized subcontractors (if any) are not included in the definition of "core suppliers." Yes Yes No 1 time per year 2017
PVH Corporation US None Not full Pledge, but will begin publishing supplier factory information in 2017. Names of CMT factories along with country of manufacture but without street address. No No No 2 times per year 2017
Ralph Lauren Corporation US None No response to coalition letter. No No No No NA NA
Rip Curl Australia None No response to coalition letter. No No No No NA NA
River Island UK None No response to coalition letter. No No No No NA NA
Sainsbury's UK None No commitment to publish supplier factory information. No No No No NA NA
Shop Direct UK None No response to coalition letter. No No No No NA NA
Sports Direct UK None No response to coalition letter. No No No No NA NA
Target Australia Australia Based on information on its website, Target Australia appears to disclose the names and addresses of CMT factories. No response to coalition letter. Names and addresses of CMT factories appear to be disclosed. The coalition has no information about percentage of supplier factories disclosed or other exclusions, if any. No No No Company website says "regular basis." NA
Target USA US Names and countries of CMT suppliers, textile and wet processing factories. No additional commitments to meet Pledge standards; maintaining status quo. Names of CMT factories along with country of manufacture but without street address. No No No 4 times per year NA
Tchibo Germany None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses for CMT factories. Yes Yes No No information NA
Tesco UK Names and addresses of Bangladesh supplier factories only. Almost full Pledge alignment. Yes Yes Yes No 2 times per year 2017
The Children's Place US None No commitment to publish supplier factory information. No No No No NA NA
Under Armour US Only suppliers factories for collegiate apparel. Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses for all CMT factories (but not embellishers or subcontractors). Yes Yes Yes No information Pledge details for CMT factories will be published in 2017.
Urban Outfitters US None No response to coalition letter. No No No No NA NA
VF Corporation US Names of factories by country for all VF brands of all VF-owned and operated, and direct sourced, tier-1 supplier factories. Not full Pledge, but will include street addresses to align more with the Pledge. Names and addresses of all CMT factories but not those used by licensees and subcontractors. No No No Regular 2017
Walmart US None No commitment to publish supplier factory information. No No No No NA NA
Woolworths Australia Names and addresses of all sites in Bangladesh are disclosed, and overall more than 40 percent of the supply chain (for apparel and footwear) is published. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of all sites in Bangladesh are disclosed, and overall more than 40 percent of the supply chain (for apparel and footwear) is published. No No No 4 times per year NA
Posted: January 1, 1970, 12:00 am

Summary

The garment and footwear industry stretches around the world.[1] Clothes and shoes sold in stores in the US, Canada, Europe, and other parts of the world typically travel across the globe. They are cut and stitched in factories in Asia, Eastern Europe, Latin America, or other regions. Factory workers in Bangladesh or Romania could have made clothes only weeks ago that consumers elsewhere are eagerly picking up.

When global supply chains are opaque, consumers often lack meaningful information about where their apparel was made. A T-shirt label might say “Made in China,” but in which of the country’s thousands of factories was this garment made? And under what conditions for workers?

There is a growing trend of global apparel companies adopting supply chain transparency[2]—starting with publishing the names, addresses, and other important information about factories manufacturing their branded products. Such transparency is a powerful tool for promoting corporate accountability for garment workers’ rights in global supply chains.

Transparency can ensure identification of global apparel companies whose branded products are made in factories where bosses abuse workers’ rights. Garment workers, unions, and nongovernmental organizations can call on these apparel companies to take steps to ensure that abuses stop and workers get remedies.

Publishing supply chain information builds the trust of workers, consumers, labor advocates, and investors, and sends a strong message that the apparel company does not fear being held accountable when labor rights abuses are found in its supply chain. It makes a company’s assertion that it is concerned about labor practices in its supplier factories more credible.[3]

The need for information about factories involved in production for global brands has become painfully clear in recent years through deadly incidents that have plagued the garment industry.

A man removes clothing bearing a brand label from the devastated area of the collapsed Rana Plaza building in Dhaka, Bangladesh, on Friday, April 26, 2013.

©2013 Jeff Holt/Bloomberg via Getty Images

The Rana Plaza building collapse in Bangladesh on April 24, 2013 killed over 1,100 garment workers and injured more than 2,000. In the year before the collapse, two factory fires—one in Pakistan’s Ali Enterprises factory and another in Bangladesh’s Tazreen Fashions factory—killed more than 350 workers and left many others with serious disabilities. These were the deadliest garment factory fires in nearly a century.

Until these tragedies occurred, virtually no public information was available concerning apparel companies that were sourcing from the factories involved. The only way to identify these apparel companies and advocate for accountability was to interview survivors and rummage through the rubble afterward to find brand labels.

A system of corporate accountability that requires people to scramble on the ground for brand labels is the antithesis of “transparency.”

Over the past decade, a growing number of global apparel companies have published information on their websites about factories that manufacture their branded products. For more than a decade, adidas, Levi Strauss, Nike, Patagonia, and Puma have been publishing information on their supplier factories. Over time, more apparel companies and retailers with own-brand products joined them,[4] posting some information about supplier factories on their websites.

As more companies adopt supply chain transparency, it is becoming a cornerstone of responsible business conduct in the garment sector. Increasingly, brands and retail chains are beginning to understand that being an ethical business requires them to publish where their own-brand clothes or footwear are being made.

Tracing Supply Chain Transparency in the Garment Industry

Until less than two decades ago, no major apparel company published its global supplier factories network. The companies viewed the identity of supplier factories as sensitive business information, and thought disclosure would put them at a competitive disadvantage.

In the late 1990s and early 2000s, major apparel brands Nike and adidas began disclosing the names and addresses of factories that produced US collegiate apparel.[5] This was a result of a campaign led by a campus network, United Students Against Sweatshops (USAS), in dozens of universities. Universities included supply chain disclosure as part of their licensing agreements with top athletic apparel companies that produced their college logo apparel.

Subsequently, in 2005, Nike and adidas went further by publishing information about all of their supplier factories for all productsnot just collegiate licensed apparel.

Over the past decade, a growing number of other global apparel companies, including North American companies with no connection to the US collegiate apparel sector like Levi Strauss and Patagonia, as well as some European apparel companies, began publishing supplier factory information.

***

Apparel Companies Publishing Supplier Factory Information in 2016

As of December 2016, the following apparel companies were among those that published some supply chain information about their branded products:

adidas, C&A, Columbia Sportswear, Cotton On Group, Disney, Esprit, Forever New, Fruit of the Loom, Gap Inc., G-Star RAW, Hanesbrands, H&M Group, Hudson’s Bay Company, Jeanswest, Levi Strauss, Lindex, Marks and Spencer, Mountain Equipment Co-op, New Balance, Nike, Pacific Brands, PAS Group, Patagonia, Puma, Specialty Fashion Group, Target USA, VF Corporation, Wesfarmers Group (Kmart and Target Australia, and Coles), and Woolworths.

This is not a comprehensive list.[6]

This report takes stock of supply chain transparency in the garment industry four years after the industry disasters in Bangladesh and Pakistan that shook the global garment industry. To build momentum toward supply chain transparency and develop industry minimum standards, a coalition of labor and human rights groups asked 72 companies to agree to implement a simple Transparency Pledge. It also asked that companies declining to commit to the Pledge provide reasons for choosing not to do so.[7] Where companies engaged with the coalition, the coalition also sought additional information about their existing transparency practices. This report explains the logic and the urgency behind the Pledge and describes the responses we received from the companies contacted.[8] Further information about the apparel companies contacted, the reasons for choosing them, and the coalition’s engagement process is outlined in Appendix I.

Supply chain transparency practices vary immensely among companies. Among those apparel companies that embrace transparency, the details they publish are inconsistent.[9] Many other companies refuse to publish supplier factory information at all, or divulge only scant information. Some companies attempt to justify non-disclosure on commercial grounds. But their explanations are belied by the experiences of other similarly situated companies that do publish and have shown that the benefits of disclosure outweigh perceived risks.[10]

Ultimately apparel companies can do far more than implement the Pledge to ensure respect for human rights in their supply chains. Nonetheless, this is one important step in a holistic effort to improve corporate accountability in the garment industry.

Civil Society Coalition on Garment Industry Transparency

In 2016, nine labor and human rights organizations formed a coalition to advocate for transparency in apparel supply chains. Coalition members are:

  • Global unions: IndustriALL Global Union, International Trade Union Confederation, and UNI Global Union.
  • International labor and human rights organizations that focus on the apparel
    sector: Human Rights Watch, Clean Clothes Campaign, Maquila Solidarity Network, Worker Rights Consortium, International Corporate Accountability Roundtable, and International Labor Rights Forum.
  • The coalition endorsed the Transparency Pledge as a minimum standard for supply chain disclosure. The Pledge is based on existing, positive industry practices. See below for more information on the Pledge.

I. The Case for Supply Chain Transparency

Supply chain transparency—starting with publishing names, addresses, and other important information about factories producing for global apparel companies—is a powerful tool to assert workers’ human rights, advance ethical business practices, and build stakeholder trust. Consumers should know where the products they purchase are made. Workers should also know which apparel company’s branded products they are making.

Companies have a responsibility to take steps to prevent human rights risks throughout their supply chains, and to identify and address any abuses that arise despite those preventative efforts. In order to live up to that responsibility, they should adopt industry good practices.

By publishing factory names, street addresses, and other important information, global apparel companies allow workers and labor and human rights advocates to alert apparel companies to labor rights or other abuses in their supplier factories.

An apparel company that does not publish its supplier factory information contributes to possible delays in workers or other stakeholders being able to access the company’s complaint mechanisms or other remedies. Workers and labor rights advocates often expend substantial time and effort trying to collect brand labels or using other methods to determine which companies are sourcing from factories where human rights abuses are occurring. Meanwhile, they lose valuable time and put workers at risk of retaliation and continued exposure to dangerous or abusive working conditions. Such delays reduce the overall effectiveness of grievance redress mechanisms that apparel companies and other parties put in place.

Disclosing names, addresses, and other relevant information about supplier factories helps make it possible to determine whether a brand has sufficient leverage or influence in a particular factory or country to achieve remediation of worker rights abuses.

Supply chain transparency can also help check unauthorized subcontracting, in which factories that contract with apparel companies meet production demands by farming out some of the work, often to smaller, less regulated factories where labor rights abuses are common. This is a persistent challenge in the garment industry. If apparel companies published the names and addresses of all authorized supplier factories and their subcontract facilities, workers and other interested parties would know which factories are authorized to produce for the company and which are not. 

Publishing supplier factory information can also help apparel companies avoid reputational harm. For example, workers may not know that a given apparel company has terminated business with a factory well before labor rights problems arose, and could seek a remedy from the wrong company. Many factories publish information on their websites about their business relationships with major brands that may be outdated and misleading. By publishing supplier factory information themselves, and updating it regularly, apparel companies would reduce the risk that they could be wrongly associated with abusive conditions in factories with which they long before cut business ties.

Moreover, it is difficult for companies to continually identify persistent labor rights problems in specific supplier factories, to detect unauthorized subcontracting, and to regularly verify progress toward corrective action if they limit their sources of information to purely business-led human rights due diligence procedures. These include inspections and labor compliance audits by apparel companies’ own social compliance staff and third-party monitors engaged by them.   

Brand inspectors and third-party monitors—even those that are diligent and professional—are at best able to visit factories periodically and for short periods. The quality and accuracy of third-party monitoring reports depend largely on the methodology used in the assessments, the independence of the assessors from the factory and the apparel company, and the weight given to testimonies from workers and other interested parties. These tools are not sufficient in and of themselves to detect all instances of abuse, unauthorized subcontracting, and other problems. Factory disclosure makes it possible for apparel companies to receive credible information from workers and worker rights advocates between periodic factory audits.

An easily achievable standard of disclosure is for apparel companies to publish on their company websites factory names and addresses (including country, city, and street address). Many leading apparel companies have already done this. In Section III, we describe additional steps apparel companies can and should take to make their supply chains more transparent.

Publishing supply chain information is consistent with a company’s responsibilities under the UN Guiding Principles on Business and Human Rights (UN Guiding Principles), a set of guidelines that lay out steps companies should take to prevent, address, and remedy human rights abuses linked to business operations. The principles state that companies have a responsibility to “identify, prevent, mitigate and account for” adverse human rights impacts of their business operations, and to regularly report on progress made.[11]

The UN Guiding Principles also say that businesses should externally communicate how they address their human rights impacts in “a form and frequency that … are accessible to its intended audiences.”[12] The commentary on the Guiding Principles states that the “responsibility to respect human rights requires that business enterprises have in place policies and processes through which they can both know and show [emphasis added] that they respect human rights in practice.” Further, “[s]howing involves communication, providing a measure of transparency and accountability to individuals or groups who may be impacted and to other relevant stakeholders, including investors.”[13]

In some jurisdictions, companies that publish supplier factory information can also help facilitate compliance with legal obligations under laws like the California Transparency in Supply Chains Act of 2010; “sweat-free” procurement laws adopted in dozens of US cities and a few states; the UK Modern Slavery Act 2015; and the French law on the corporate duty of vigilance, 2017.[14]

The transparency of global supply chains is also increasingly recognized by investors as a metric for evaluating the robustness of business human rights practices. The Corporate Human Rights Benchmark (CHRB), a collaborative effort by business and human rights organizations and investors, developed a public scorecard for the human rights practices of apparel, agricultural, and extractive companies. The benchmark has been endorsed by 85 investors representing US$5.3 trillion in assets.[15] CHRB’s indicators include whether the company publishes supply chain information.

Specifically, the CHRB scorecard assesses whether “[t]he Company maps its suppliers and discloses its mapping publicly [emphasis added].” Apparel companies are given two specific scores depending on whether “[t]he company indicates that it maps its suppliers beyond tier one, including direct and indirect suppliers, and describes how it goes about this” and whether “[t]he Company also discloses the mapping for the most significant parts of its supply chain and explains how it has defined what are the most significant parts of its supply chain.”[16] In order to assess the latter, companies were required to publish at least the names of its supplier factories for the 2016 pilot benchmark.[17]

Kevin Thomas, director of shareholder engagement of SHARE Canada, a nonprofit organization that represents institutional investors in Canadian and other international companies in apparel and other sectors, said that in 2016 at least 20 shareholder resolutions related to supply chains and human rights practices were filed in the US. He said:

[I]nvestors are looking for evidence that demonstrates that the company is effectively identifying human rights risks in its own operations and in the supply chain, and has an effective system to address those risks when they are identified. It’s important that the company not only report on its policies and systems, but also the outcomes of its work – what is it finding, and how is it fixing it. Factory disclosure is a part of that process. [T]he company’s willingness to disclose demonstrates to shareholders that it is confident in its due diligence process. [I]t also assists the company in catching unauthorized subcontracting, as well as developing useful relationships with stakeholders that can assist the company in identifying problem areas and solutions.[18]

II. The Transparency Pledge

The objective of the Transparency Pledge is to help the garment industry reach a common minimum standard for supply chain disclosures by getting companies to publish standardized, meaningful information on all factories in the manufacturing phase of their supply chains. The civil society coalition that developed the Pledge based it on published factory lists of leading apparel companies and developed a set of minimum supply chain disclosure standards. These build on good practices in the industry.

The Apparel and Footwear Supply Chain Transparency Pledge

(“The Transparency Pledge”)

This Transparency Pledge helps demonstrate apparel and footwear companies’ commitment towards greater transparency in their manufacturing supply chain.

Transparency of a company’s manufacturing supply chain better enables a company to collaborate with civil society in identifying, assessing, and avoiding actual or potential adverse human rights impacts. This is a critical step that strengthens a company’s human rights due diligence.

Each company participating in this Transparency Pledge commits to taking at least the following steps within three months of committing to it: 

Publish Manufacturing Sites

The company will publish on its website on a regular basis (such as twice a year) a list naming all sites that manufacture its products. The list should provide the following information in English:

  1. The full name of all authorized production units and processing facilities.*
  2. The site addresses.
  3. The parent company of the business at the site.
  4. Type of products made.**
  5. Worker numbers at each site.***

Companies will publish the above information in a spreadsheet or other searchable format.

The three-month time frame was extended to December 2017 based on the coalition’s engagement with apparel companies. See Appendix I for details.

* Processing factories include printing, embroidery, laundry, and so on.

** Please indicate the broad category—apparel, footwear, home textile, accessories.

*** Please indicate whether the site falls under the following categories by number of workers: Less than 1,000 workers; 1,001 to 5,000 workers; 5,001 to 10,000 workers; More than 10,000 workers.

The Pledge focuses on the “manufacturing phase” of an apparel company’s supply chain, which comprises all factories authorized by the company to produce (that is, cut-make-trim, or CMT) along with others subcontracted by these CMT factories to perform “finishing” processes.[19]

The Pledge aims for consistency in disclosures, which is sorely needed, as shown by an analysis carried out by coalition members of supply chain information published by September 2016 by 23 global apparel companies. In the absence of standards, companies adopt different approaches to transparency, sometimes excluding important information that makes it effective. This analysis informed the content of the Transparency Pledge, as explained in Appendix II.

Why Minimum Standards for Disclosure

Based on an analysis of apparel companies’ disclosure practices, it became clear that without minimum standards, companies’ efforts toward supply chain disclosures suffered from a range of deficiencies:

  • A lack of a common understanding of what constituted the first tier of a brand’s supply chain. For example, not disclosing any information about authorized subcontractors like external printers, embroiderers, and laundries that are essential to producing a finished product, without which it cannot be sold.
  • Publishing only a part of all cut-make-trim supplier factories, without specifying what was included.
  • Omitting factories’ street addresses, making it impossible to know where in a given country or city a factory was located.
  • Excluding names and addresses of factories used by licensees or agents.
  • Not specifying if supplier factory information was published for all or only some brands owned by the apparel company.
  • Not specifying whether the disclosure was for all or only some types of products.
  • Not describing what was being excluded from the disclosure.
  • Not stating what percentage of their total sourcing volume and supplier factories was published, the date the information was last updated, and how frequently such updates were made public.
  • Not publishing this data in downloadable and searchable formats.

Key Pointers for Publishing Supplier Factory Information

When publishing supplier factory information, global apparel companies should pay close attention to the manner in which they provide it. The following guiding points are important to make disclosure effective:

Easy Access

  • Make information easily and freely accessible on their websites.
  • Make information available in formats that have downloadable files and enable machine-readable searches to cut down on the time needed to manually sift through these lists.

Clarity

  • Clearly state what precisely is being published and what definitions are being used. (For example, describe how the company defines terms like “tier-1”; “core manufacturing partners.”)
  • Clearly state whether all authorized subcontractors used by cut-make-trim factories for processes to complete a brand’s products are being published.
  • Indicate the aggregate volume of business that is captured by the disclosure and the percentage of total supplier factories published. (For example, “The factories named represent 80 percent of the factories where the company’s products are manufactured, and are responsible for production of 90 percent of the brand’s products.”)
  • Indicate exclusions from disclosures, if any, and impending plans to expand disclosures. (For example, whether it excludes factories used by licensees, agents, and discloses information for only some or all brands.)

Regular Updates

  • Specify the date when the information was last updated and how frequently the information is publicly updated.

What the Transparency Pledge Does Not Do

The Pledge does not attempt to define the full extent of transparency in the garment industry. It deals with a narrow yet critical part of transparency in apparel supply chains. The full range of transparency practices in the garment industry should be broader and more holistic. Several aspects—ranging from grievance redress procedures and brand efforts to mitigate or remediate human rights problems, including the effectiveness of brands’ compliance programs with respect to worker wages, hours of work, and their freedom of association—stand to benefit from greater transparency.

The Pledge does not set a ceiling, but rather a floor, on what brands should publicly report. The coalition hopes that human rights and environmental advocates, governments, companies, investors, and other stakeholders in the sector will work to deepen and broaden transparency beyond what is included in the Pledge.

Some brands have already taken steps that prove more is possible. They have published more details beyond just a factory name and address, indicating the precise number of workers in the factory, the gender breakdown of the workforce, and other details for every factory disclosed.[20] A very small number of apparel companies have published the textile factories where fabric used in their garments is made and more information beyond the “manufacturing phase” of the supply chain.[21]

 

III. Apparel Company Responses

The civil society coalition that developed the Transparency Pledge contacted 72 apparel and footwear companies asking them to sign on to and implement the Pledge. This section captures responses received as of April 7, 2017.[22]

There were a wide range of responses, which the coalition has grouped into three categories:

  • First, some companies already embrace supply chain transparency and either agreed to add more factory details to meet the Pledge standards or to align their practices more closely with those standards.
  • Second, some companies already publish supplier factory information but declined to add more details to align their disclosure practices with the Pledge standards, or failed to respond to the coalition letter. In the same category are other companies that reported that they intend to begin disclosing more supplier factory information but whose commitments fell far short of the Pledge standards.
  • Third, some companies either did not commit to publishing any supplier factory information or did not respond at all.

These categories are based on commitments made by apparel companies—many of which have promised to begin publishing information for the first time—that they have indicated will be implemented in 2017. An update to this report will be issued in 2018 providing more details about apparel company disclosures and additional responses. Where appropriate the list of companies in each category will be revised, based on the disclosures and commitments that these companies make in the interim period.

Full Pledge or Close to Full Alignment with Pledge

Seventeen apparel companies agreed to publish all supplier factory information requested, meeting all the Pledge standards.[23] Another five companies fell just short of the Pledge standards.

Full Alignment with the Pledge

Apparel companies that previously published supply chain information and committed to publishing additional supplier factory information in full alignment with the Pledge standards are adidas, C&A, Cotton On, Esprit, G-Star RAW, Hanesbrands, H&M, Levis, Lindex, Nike, and Patagonia.

Apparel companies that had previously not published any supplier factory information and have committed to publishing this in full alignment with the Pledge are ASICS, ASOS, Clarks, New Look, Next, and the Pentland Brands.

The commitments of these global apparel companies help break new ground by promoting an industry-wide minimum standard for supply chain transparency.

Just Missing the Pledge Standard

Since its first disclosure in September 2016, Gap updated its information, which now incorporates almost all aspects of the Pledge.[24] Marks and Spencer[25] and Tesco[26] outlined their plans to add more information to their current factory disclosure, which would bring them closer to alignment with the Pledge standard. John Lewis committed to publishing supplier factory information in 2017 in accordance with almost the full Pledge.[27] None of these companies committed to publishing information about parent companies of factories as requested.

Mountain Equipment Co-op added information in accordance with Pledge standards for cut-make-trim factories with a commitment to adding authorized subcontractors in the future.[28]

Some Transparency, More Needed

Some apparel companies (identified in textboxes below) already publish the names and addresses of their supplier factories, but do not disclose other information in line with the Pledge standards, and did not commit to doing more. Others have committed to taking steps to publish supplier factory information but with scant detail or without specifying what precisely they will disclose.

An apparel company should, at the very least, publish the minimum information needed to demonstrate that it “knows and shows” a key part of its supply chain: the names and addresses of all its cut-make-trim factories and authorized subcontractors that undertake processes needed to finish the product.

In the Right Direction

Columbia Sportswear and Disney have been publishing the names and addresses of their cut-make-trim suppliers and authorized subcontractors.[29] But they did not explicitly commit to doing more.[30]

New Balance, which was already publishing factory names and addresses, committed to adding product categories.[31]

PUMA added street addresses, worker numbers, and product categories for all factories it currently publishes.[32]

Coles publishes the names and addresses of its non-food suppliers (not only apparel) from India and China, which the company says includes all supplier factories, but it did not commit to doing more.[33]

Under Armour committed to publishing information for all cut-make-trim factories in accordance with Pledge standards in 2017.[34]

ALDI North and ALDI South published the names and street addresses of their tier-1 suppliers.[35]

LIDL committed to beginning disclosure in 2017, which would list the names and street addresses for all tier-1 factories producing own-brand products.[36]

Tchibo committed to publishing the names, addresses, and product types of cut-make-trim factories in 2017.[37]

VF Corporation committed to adding factory street addresses to its existing publication of owned and operated and tier-1 supplier factory names,[38] but this excludes “licensee and sub-contractor factories.”[39]

Debenhams committed to publishing in 2017 the names and addresses of its tier-1 factories along with worker numbers by gender breakdown.[40]

Benetton published its tier-1 factories in 2017 listing the names, addresses, and product category.[41]

Arcadia Group has committed to publish the names and addresses of all cut-make-trim factories in 2017.[42]

Many Factories Still Missing from Disclosure Lists

The apparel companies named below publish the names and addresses of some factories. But these companies still leave out many cut-make-trim factories and their authorized subcontractor facilities from their factory lists.

Woolworths has suppliers across many countries and responded that it already publishes the names and addresses of all factories in Bangladesh and “overall more than 40 percent” of its apparel supply chain.[43] Their subcontractor facilities are currently only partially disclosed (i.e. for Bangladesh) and the company says it is improving visibility of subcontractors in other countries.[44]

Based on the information given on their respective websites, Kmart Australia appears to publish all apparel factories in “high risk” countries that directly produce Kmart products[45] and Target Australia appears to publish the names and addresses of cut-make-trim factories.[46] But because these companies did not respond to the coalition’s letter, the coalition has no information about the percentage of supplier factories they disclose and whether authorized subcontractors are included.[47]

The Hudson’s Bay Company did not commit to adding more disclosures to its existing factory list, which carries the names and addresses of some, but not all, of its cut-make-trim supplier factories.[48]

Fast Retailing began disclosing the names and addresses of its “core factories list” producing for UNIQLO, the largest of its brands, for the first time in 2017.[49]

Other companies named in the text box below already disclose or have indicated they support some degree of supply chain transparency. But they either disclose or have committed to disclosing only factory names without street addresses. Some have only stated that they plan to begin disclosing in 2017, without indicating what precisely they will disclose.

Beginning to Disclose

Target USA was already disclosing factory names by country and city for manufacturing, textile, and wet-processing factories but did not respond in substance to the coalition’s letter asking for more information to be published about supplier factories.[50]

Mizuno committed to publishing its “core factory list” in January 2017 with “names, location, and product category,” but published the information without including factory street addresses.[51] This list also appears to include only a minority of all Mizuno’s apparel supplier factories.[52] Abercrombie & Fitch and PVH Corporation communicated their decisions to publish all tier-1 factory names by country only.[53] Loblaw similarly committed to publish names of all factories where they “source apparel and footwear directly” and to include the country of manufacture but not the factory address.[54]

Beginning Disclosure, But Details Unknown

BESTSELLER and Decathlon committed to beginning publishing supplier factory information in 2017 but did not specify the details of their disclosure.[55] 

No Commitment to Publish

Some companies gave little or no response to letters requesting information about their disclosure practices or plans, or the Transparency Pledge.

Of the apparel companies and retailers with own-apparel brands who had previously not published any information for cut-make-trim factories, 10 did not send any response to the coalition’s letter.[56] Another 15 did not commit to publish supplier factory information.[57]

No Commitment to Make their Factory List Public

Apparel companies that responded but did not indicate any impending commitment to publishing their supplier factories are American Eagle Outfitters, DICK’S Sporting Goods, Foot Locker,[58] The Children’s Place, Walmart, Canadian Tire, Desigual, MANGO, KiK, Hugo Boss, Carrefour, Morrison’s, Primark, and Sainsbury’s.

Inditex declined to publish supplier factory information but makes this data available to IndustriALL and its affiliates as part of the reporting under its Global Framework Agreement.[59] 

Failed to Respond to Coalition’s Call for Transparency

Armani, Carter’s, Forever 21, Urban Outfitters, Ralph Lauren Corporation, Matalan, River Island, Sports Direct, Shop Direct, and Rip Curl did not send any response to the coalition.

Debunking the So-Called Barriers to Transparency

Competitive Disadvantage

A few brands—KiK, Inditex, DICK’s Sporting Goods, and The Children’s Place—that declined to publish their supplier factory information cited competitive advantage.[60] However, many other large apparel companies and retailers with own-brand apparel products have published supplier factory information for years.[61] Five companies have published this information for more than a decade.[62] Garment industry giants are increasingly choosing to publish their supplier information, proving that transparency can easily coexist with being competitive.

In some cases, supplier factories already openly advertise on their websites the names of brands they produce for, even where a brand does not.[63]

Many apparel companies are also part of initiatives like the Fair Factories Clearinghouse and Sedex, where they voluntarily disclose and share non-competitive information with other brands, including supplier names, audit reports, and so on, even where they do not do so publicly.[64]

Moreover, apparel companies that import products into US markets are subject to the US law, which requires that customs authorities collect information on each shipping container that enters a US port, including the shipper (typically in the case of garments the overseas supplier) and the consignee (typically the apparel company or its agent).[65] Online subscription databases purchase this trade data and market it in searchable formats, allowing users, including competitors, to gather information about suppliers to apparel companies that import goods into the US.[66] But the costs of accessing such subscription-based databases are prohibitive for workers and many civil society organizations. While apparel companies can easily purchase subscriptions, workers and many labor advocates around the world cannot afford them. Despite the availability of these records, some companies are known to use various means of shielding their own names and their suppliers’ names from appearing in this data.

Anti-Competition Law

KiK declined to publish information about their supplier factories, raising anti-competition concerns among others.[67] However, other brands selling products in Germany or other EU countries are governed by the same laws as KiK. They have been disclosing supplier information for many years; and more brands operating there have committed to begin public disclosure. These include companies that already disclose supplier factory information, such as adidas, C&A, Columbia Sportswear, Disney, Esprit, H&M, Levi’s, Nike, Patagonia, and Puma; and others that have committed to beginning disclosure in 2017, such as ALDI North and ALDI South, BESTSELLER, Fast Retailing, LIDL, and Tchibo.

Moving Beyond Private Disclosure

In response to the coalition’s recommendation that brands publicly disclose their supplier information, a few brands declined, citing their participation in other initiatives, like the Bangladesh Accord on Fire and Building Safety or global framework agreements (GFA) with IndustriALL and UNI Global Union.

When implemented effectively, such initiatives serve important human rights due diligence purposes. For example, the Bangladesh Accord requires brands to confidentially disclose their supplier factory information to the initiative’s Steering Committee and staff, which makes public the names of all factories covered by the Accord and their performance on building safety issues, but without disclosing the specific brands that are supplied by each factory. An apparel company’s global framework agreement with IndustriALL typically requires the company to disclose its factory lists to the global union. This creates a basis for the union to engage with the company on the behavior of particular supplier factories.

However, none of these agreements prevent brands from publishing their supplier factory information. A number of brands (named in the text box below) participate in the Bangladesh Accord and publish their supplier factory information. Apparel companies H&M, Tchibo, and Mizuno have shown that private, confidential reporting within the framework of legally binding agreements can and should complement publishing supplier factory information.

Brands that Do Both: Publish Supplier Information and Participate in Other Initiatives

Bangladesh Accord members that have been publishing supplier factory information include adidas, C&A, Cotton On, Esprit, G-Star RAW, H&M, Kmart Australia, Lindex, Marks and Spencer, Puma, Target Australia, and Woolworths.

Accord members that will begin some disclosure in 2017 are Abercrombie & Fitch, ALDI North and ALDI South, BESTSELLER, Debenhams, Fast Retailing, John Lewis, Next, New Look, Loblaw, LIDL, PVH, Tesco, and Tchibo. A number of brands that are a part of the German Partnership for Sustainable Textiles (the Textil Bündnis) publish their supplier information: adidas, C&A, Esprit, H&M, and Puma; others like ALDI North and ALDI South and LIDL began publishing supplier factory information in 2017; Tchibo will also publish its supplier factory information in 2017.

A number of brands that are a part of the German Partnership for Sustainable Textiles (the Textil Bündnis) publish their supplier information: adidas, C&A, Esprit, H&M, and Puma; others like ALDI North and ALDI South and LIDL began publishing supplier factory information in 2017; Tchibo will also publish its supplier factory information in 2017.

MANGO, in response to outreach about the Transparency Pledge, offered an alternative: disclosing only to members of the coalition that spearheaded the Pledge, or to parties that register with the company.[68] These proposals fall short of the level of supply chain transparency needed in the industry. Private disclosure of this type is not sustainable, and does little to improve human rights due diligence in global apparel supply chains.

IV. The Way Forward

Supply chain transparency is an important first step toward more meaningful corporate accountability. As Esprit, one of the global apparel companies that committed to improve its disclosure practices to align with the Pledge, said: “[R]eleasing this information is not comfortable for many companies, but the time has come to do it.”[69]

A number of companies have responded positively to the coalition’s letter committing to add more information in accordance with the Pledge standards. More companies should step out of their comfort zone and join the transparency trend. They should commit to the Transparency Pledge standards.

Multi-stakeholder initiatives should also endorse the Transparency Pledge as a minimum standard for apparel supply chain transparency for their member companies, and publicly scorecard members on transparency practices.

Investors should also endorse the Transparency Pledge as part of broader efforts to promote effective human rights due diligence tools that are industry good practice and in accordance with the UN Guiding Principles on Business and Human Rights.

The Transparency Pledge is an important first step, but is not the end of the story. Far more can and should be done to promote deeper and wider transparency and human rights in garment industry supply chains. 

All global apparel companies, including those acknowledged in this report as committing to the Pledge or close, should periodically review and upgrade their transparency practices.

These efforts should include expanding traceability and transparency beyond the cut-make-trim manufacturing phase to other aspects of the supply chain, including manufacture of yarn, fabric, and other inputs, and the production of raw materials like cotton.

While supply chain transparency is widely recognized as an important pillar on which corporate accountability is built, transparency alone does not result in improved working conditions or accountability. Brands should adopt transparent practices and complement them with other steps to strengthen human rights due diligence in their supply chains.

Countries where global apparel companies do business should pass legislation that promotes mandatory human rights due diligence in the global supply chains of companies, including mandatory publication of supplier information. These should build on the California Transparency in Supply Chains Act, “sweat-free” procurement laws adopted by dozens of local governments in the US, the UK Modern Slavery Act and the 2017 French law on corporate duty of vigilance.[70] Such legislation will go a long way in creating a level playing field in the garment industry.

[The coalition invites additional endorsements from labor and human rights organizations, apparel companies, and investors interested in supporting the move for industry-wide minimum standards for transparency in garment supply chains, starting with the Transparency Pledge. Inquiries may be sent to: transparency@hrw.org or any coalition member.]

Acknowledgments

This report was authored and edited by the following people:

Human Rights Watch: Aruna Kashyap, senior counsel and Janet Walsh, acting director, Women’s Rights Division; Arvind Ganesan, director, Business and Human Rights Division; Chris Albin-Lackey, senior legal advisor; Tom Porteous, deputy program director; and Danielle Haas, senior editor, Program Office.

Maquila Solidarity Network: Lynda Yanz, executive director; and Robert Jeffcott, policy analyst.

Clean Clothes Campaign (International Office): Ben Vanpeperstraete, lobby and advocacy coordinator; and Christie Miedema, campaign and outreach coordinator.

International Corporate Accountability Roundtable: Nicole Vander Meulen, legal and policy associate.

Worker Rights Consortium: Scott Nova, executive director; and Ben Hensler, general counsel and deputy director.

International Labor Rights Forum: Judy Gearhart, executive director; and Liana Foxvog, director of organizing and communications.

International Trade Union Confederation: Alison Tate, director of economic and social policy.

IndustriALL Global Union

A number of people contributed to this collective advocacy effort by coordinating outreach with brand representatives. They include:

  • Clean Clothes Campaign: Ben Vanpeperstraete, Dominique Muller, Laura Ceresna, Deborah Lucchetti, Ineke Zeldenrust, Frieda de Koninck, and Helle Løvstø Severinsen.
  • Human Rights Watch: Aruna Kashyap.
  • IndustriALL Global Union.
  • International Trade Union Confederation.
  • Maquila Solidarity Network: Lynda Yanz and Robert Jeffcott.
  • UNI Global Union.
  • Worker Rights Consortium: Ben Hensler and Scott Nova.

Human Rights Watch also acknowledges the contribution of Shubhangi Bhadada, a consultant who helped with desk research, and Kate Larsen, a former Human Rights Watch consultant.

Alexandra Kotowski and Annerieke Smaak, senior coordinators of the women’s rights division of Human Rights Watch, assisted with brand outreach along with Helen Griffiths, the coordinator of the Children’s Rights Division of Human Rights Watch. Kate Segal, part-time coordinator for the women’s rights division, assisted in the production of this report along with Grace Choi, the design and publications director at Human Rights Watch. 

 

***

Current/Anticipated Disclosure by December 31, 2017 vs. Pledge Standards
Company Headquarters Published supplier factory--cut-make-trim (CMT) and subcontractor-- information prior to Pledge Letter? Supplier factory information published meets or will meet Full Pledge by December 2017? Names and street addresses of CMT factories and their subcontractors Worker numbers Product types Parent company information Frequency of disclosures Time Frame to Implement Pledge
Abercrombie & Fitch US None Not full Pledge, but will begin publishing supplier factory information in 2017. Names of tier-1 factories (CMT for woven, denim, knit, sweater, intimates,and accessoroies) with country of manufacture, but without street address. No No No 2 times per year 2017
Adidas Germany Names of all tier-1 factories, including those used by licensees as well as authorized subcontractors, by country and city. Names of all tier-2 wet process suppliers, by country and city. Separate lists of supplier factories used for the Olympic Games. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
ALDI North and ALDI South Germany None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 (CMT) factories but not their subcontractors. No No No 1+ times per year 2017
American Eagle Outfitters US None No commitment to publish supplier factory information. No No No No NA NA
Arcadia Group UK None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 (CMT) factories but disclosure of authorized subcontractors will need more time. No No No 1+ times per year NA
Armani Italy None No response to coalition letter. No No No No NA NA
ASICS Japan None Full Pledge alignment. Yes Yes Yes Yes 1 time per year 2017
ASOS UK None Full Pledge alignment. Yes Yes Yes Yes 6 times per year 2017
Benetton Italy None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 (CMT) factories but not their subcontractors. No Yes No 1 time per year NA
BESTSELLER Denmark None Not full Pledge, but will begin publishing supplier factory information in 2017. Company stated that tier-1 (CMT) factories will be published but did not provide more information about what precisely will be disclosed for each factory. No information No information No information No information 2017
C&A Netherlands Names and addresses of all CMT factories. Excluded: Brazil, Mexico, and processing factories. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Canadian Tire Canada None No commitment to publish supplier factory information. No No No No NA NA
Carrefour France None No commitment to publish supplier factory information. No No No No NA NA
Carter's US None No response to coalition letter. No No No No NA NA
Clarks UK None Full Pledge alignment. Yes Yes Yes Yes 2 times per year A vast majoirity of the supplier factory information will be published in 2017. Five percent of non-footwear accessories to be published in 2018.
Coles Australia Names and addresses of CMT factories, but not subcontractors. Company states that its supplier factories use minimal subcontracting. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of CMT factories, but not subcontractors. Company states that its supplier factories use minimal subcontracting. No No No 1 time per year NA
Columbia Sportswear US Names and addresses of factories from which they directly source and any external subcontractors engaged to perform finishing processes (mostly limited to collegiate suppliers since the others have in-house capacity). No additional commitments to meet Pledge standards; maintaining status quo. Yes No No No 1 time per year NA
Cotton On Group Australia Names and addresses of CMT factories used by top 20 suppliers. Full Pledge alignment. Yes Yes Yes Yes Multiple 2017
Debenhams UK None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 factories which includes all CMT factories; some external processing such as embroidering and washing may not be included. Yes No No No information 2017
Decathlon France None Not full Pledge, but will begin publishing supplier factory information in 2017. Company did not provide more information about what precisely will be disclosed for each factory. No information No information No information No information 2017
Desigual Spain None No commitment to publish supplier factory information. No No No No NA NA
DICK'S Sporting Goods US None No commitment to publish supplier factory information. No No No No NA NA
Disney US Names and addresses of all facilities part of Disney's vertical supply chain and any facility in its vertical supply chains where Disney intellectual property is located, which includes any laundry, printing, embroidery facility if Disney intellectual property is incorporated into that finished product or component. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of all facilities in its vertical supply chain, including subcontractors, where Disney intellectual property is located. No No No 1 time per year NA
Esprit Germany Names and addresses of CMT factoriesand their authorized subcontractors. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Fast Retailing Japan None Not full Pledge, but will begin publishing supplier factory information in 2017. Published name and addresses of "Core Factories"producing for UNIQLO brand, representing 80 percent of the total volume of orders for UNIQLO brand. Plans to publish a list of GU's "major partner factories" in 2017. No clear commitment to publish subcontractors in 2017. No No No 1 time per year 2017
Foot Locker US Previously disclosed names and addresses for suppliers of collegiate apparel line that is currently inactive. No commitment to publish current own-brand supplier factory information. No No No No NA NA
Forever 21 US None No response to coalition letter. No No No No NA NA
G-Star RAW Netherlands Names, addresses, product types, parent company, and worker numbers for CMT factories. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Gap US Names and addresses of CMT factories and their authorized subcontractors. Almost full Pledge alignment. Yes Yes Yes No 2 times per year Gap did not make any new commitments to align with the Pledge by December 2017. The company updated its supplier factory information to be more closely aligned with the Pledge.
H&M Group Sweden Names and addresses of supplier factories and vendors (suppliers), processing factories, and some fabric suppliers. Full Pledge alignment. Yes Yes Yes Yes 4 times per year 2017
Hanesbrands US Names and addresses of collegiate suppliers and owned factories. Full Pledge alignment. Yes Yes Yes Yes 4 times per year 2017
Hudson's Bay Company Canada Names and addresses of some, but not all, supplier factories. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of some, but not all, CMT factories. No No No 1 time per year NA
Hugo Boss Germany None No commitment to publish supplier factory information. No No No No NA NA
Inditex Spain CMT factories not published. Names and addresses of direct and indirect wet processing factories published. No commitment to publish supplier factory information. No No No No NA NA
John Lewis UK None Almost full Pledge alignment. Yes Yes Yes No 2 times per year 2017
KiK Germany None No commitment to publish supplier factory information. No No No No NA NA
Kmart Australia Australia Names and addresses of factories in "high risk" countries. No response to coalition letter. Names and addresses of factories in "high risk" countries. No No No No information NA
Levi Strauss US Names and addresses of CMT factories and authorized subcontractors. Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
LIDL Germany None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses of tier-1 factories which includes all CMT, but does not include all processing facilities. No No No 2 times per year 2017
Lindex Sweden Names and addresses of CMT factories. Full Pledge alignment. Yes Yes Yes Yes 1 time per year 2017
Loblaw Canada None Not full Pledge, but will begin publishing supplier factory information in 2017. Names of all factories where they Òsource apparel and footwear directlyÓ with country of manufacture but not street address. No No No 2 times per year 2017
MANGO Spain None No commitment to publish supplier factory information. No No No No NA NA
Marks and Spencer (M&S) UK Names and street addresses, worker numbers, gender breakdown, and product types. Almost full Pledge alignment. M&S will continue with its Plan A disclosure commitments and add processing factories and also make its existing disclosure available in a searchable format. Yes Yes Yes No 2 times per year 2017
Matalan UK None No response to coalition letter. No No No No NA NA
Mizuno Japan None Not full Pledge, but will begin publishing supplier factory information in 2017. Names along with country of manufacture of "Core Suppliers," that is, 125 factories disclosed of 464 tier-1 suppliers as reported on Mizuno website. No Yes No No information Began disclosure in 2017.
Morrison's UK None No commitment to publish supplier factory information. No No No No NA NA
Mountain Equipment Co-op (MEC) Canada Names and addresses of all CMT factories and some processing facilities. Almost full Pledge alignment. Names and addresses of all CMT factories and some processing facilities. Yes Yes Yes 2 times per year Additional details for CMT factories to meet Pledge standards will be published in 2017. Names and other details of authorized printers will be added subsequently.
New Balance US Names and addresses of direct supplier factories, excluding US wholly-owned facilities. Not full Pledge, but will add product type, and update annually in searchable format. Names and addresses of direct supplier factories, excluding US wholly-owned facilities. No Yes No 1 time per year 2017
New Look UK None Full Pledge alignment. Yes Yes Yes Yes At least annual 2017
Next UK None Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Nike US Names, addresses, product category, worker numbers, gender and migrant worker breakdown, and authorized subcontractor. Full Pledge alignment. Yes Yes Yes Yes 4 times per year 2017
Patagonia US Names, addresses, product category, worker numbers, gender breakdown, and parent companies of CMT and authorized subcontractors. Some fabric suppliers indicated. One cotton farm also disclosed. Full Pledge alignment. Yes Yes Yes Yes 1 time per year 2017
Pentland Brands UK None Full Pledge alignment. Yes Yes Yes Yes 2 times per year 2017
Primark UK None No commitment to publish supplier factory information. No No No No NA NA
Puma Germany Name of factory by country, city for tier-1 "core suppliers" and tier-2 material and component suppliers. Almost full Pledge alignment for tier-1 "core suppliers" factories. Names and addresses of tier-1 "core suppliers" amounting to 80 percent of their total business volume. But authorized subcontractors (if any) are not included in the definition of "core suppliers." Yes Yes No 1 time per year 2017
PVH Corporation US None Not full Pledge, but will begin publishing supplier factory information in 2017. Names of CMT factories along with country of manufacture but without street address. No No No 2 times per year 2017
Ralph Lauren Corporation US None No response to coalition letter. No No No No NA NA
Rip Curl Australia None No response to coalition letter. No No No No NA NA
River Island UK None No response to coalition letter. No No No No NA NA
Sainsbury's UK None No commitment to publish supplier factory information. No No No No NA NA
Shop Direct UK None No response to coalition letter. No No No No NA NA
Sports Direct UK None No response to coalition letter. No No No No NA NA
Target Australia Australia Based on information on its website, Target Australia appears to disclose the names and addresses of CMT factories. No response to coalition letter. Names and addresses of CMT factories appear to be disclosed. The coalition has no information about percentage of supplier factories disclosed or other exclusions, if any. No No No Company website says "regular basis." NA
Target USA US Names and countries of CMT suppliers, textile and wet processing factories. No additional commitments to meet Pledge standards; maintaining status quo. Names of CMT factories along with country of manufacture but without street address. No No No 4 times per year NA
Tchibo Germany None Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses for CMT factories. Yes Yes No No information NA
Tesco UK Names and addresses of Bangladesh supplier factories only. Almost full Pledge alignment. Yes Yes Yes No 2 times per year 2017
The Children's Place US None No commitment to publish supplier factory information. No No No No NA NA
Under Armour US Only suppliers factories for collegiate apparel. Not full Pledge, but will begin publishing supplier factory information in 2017. Names and addresses for all CMT factories (but not embellishers or subcontractors). Yes Yes Yes No information Pledge details for CMT factories will be published in 2017.
Urban Outfitters US None No response to coalition letter. No No No No NA NA
VF Corporation US Names of factories by country for all VF brands of all VF-owned and operated, and direct sourced, tier-1 supplier factories. Not full Pledge, but will include street addresses to align more with the Pledge. Names and addresses of all CMT factories but not those used by licensees and subcontractors. No No No Regular 2017
Walmart US None No commitment to publish supplier factory information. No No No No NA NA
Woolworths Australia Names and addresses of all sites in Bangladesh are disclosed, and overall more than 40 percent of the supply chain (for apparel and footwear) is published. No additional commitments to meet Pledge standards; maintaining status quo. Names and addresses of all sites in Bangladesh are disclosed, and overall more than 40 percent of the supply chain (for apparel and footwear) is published. No No No 4 times per year NA

 

[1] The terms garment industry, apparel industry, and garment and footwear industry are used interchangeably in this report. All references to the garment or apparel industry also include the footwear industry.

[2] This report uses the phrase “global apparel companies” or “apparel companies” to refer to companies, retailers, and supermarkets that sell their branded clothing and footwear products. Many global apparel companies, including adidas, H&M, Levi Strauss, and VF Corporation, own multiple brands.

[3] The phrase “supplier factory” refers to a factory engaged in the production of apparel and footwear. This term is distinct from “suppliers,” which some apparel companies use to mean “vendors.”

[4] Retailers and supermarkets typically sell apparel and footwear belonging to a number of different brands, only some of which they own. For example, a shoe retail chain may sell its own-brand shoes as well as other name brands, like adidas, Nike, and Puma.

[5] William McCall, “Nike Discloses Factory Locations,” Washington Post, October 8, 1999, http://www.washingtonpost.com/wp-srv/aponline/19991008/aponline182943_000.htm (accessed March 21, 2017).

[6] Apart from information compiled by advocacy groups, there is no centrally available public repository that tracks which apparel companies are publicly disclosing information about their supplier factories. This list incorporates the latest information released by Fashion Revolution about the names of brands that make their supplier factory information public: Fashion Revolution, “Transparency is Trending,” March 2017, http://fashionrevolution.org/transparency-is-trending/ (accessed March 20, 2017).

For information about US companies licensed to produce collegiate apparel and making these supplier factory names public, see Worker Rights Consortium, “Factory Database,” http://www.workersrights.org/search/ (accessed April 1, 2017); and International Labor Rights Forum, “Tracking Corporate Accountability in the Apparel Industry,” April 5, 2017, http://laborrights.org/apparelcompanychart (accessed April 6, 2017).

[7] For more information, see Section III, “The Transparency Pledge.”

[8] Ibid. See also Section IV, “Apparel Company Responses.”

[9] See Section III, Transparency Pledge, and Appendix III (available online).

[10] See Section IV, “Debunking the So-Called Barriers to Transparency.”

[11] United Nations, UN Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework (UN Guiding Principles), 2011, http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf (accessed February 10, 2017).

[12] Ibid, p. 23.

[13] Ibid, p. 24.

[14] The California Transparency in Supply Chains Act of 2010, http://www.leginfo.ca.gov/pub/09-10/bill/sen/sb_0651-0700/sb_657_bill_20100930_chaptered.pdf (accessed February 18, 2017); for a list of US cities with sweat-free procurement policies and codes of conduct, see Sweatfree Purchasing Consortium, “Resource Library,” http://buysweatfree.org/resource_library (accessed March 28, 2017); UK Modern Slavery Act 2015, http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted (accessed February 18, 2017); the French law on corporate duty of vigilance, http://www.assemblee-nationale.fr/14/ta/ta0924.asp (accessed March 2. 2017).

[15] Corporate Human Rights Benchmark, 2016, https://business-humanrights.org/en/corporate-human-rights-benchmark (accessed February 18, 2017). The benchmark was developed by a steering committee comprised of six organizations. These include Aviva Investors, Calvert Investments, The Dutch Association of Investors for Sustainable Development (VBDO), and Vigeo Eiris, a group that also advises on responsible investment.

The benchmark is endorsed in the UN Guiding Principles Reporting Framework Investor Statement, http://www.ungpreporting.org/early-adopters/investor-statement/ (accessed February 18, 2017).

[16] Corporate Human Rights Benchmark, Corporate Human Rights Benchmark Pilot Methodology 2016, March 2016, https://business-humanrights.org/sites/default/files/CHRB_report_06_singles.pdf (accessed February 18, 2017), p. 97.

[17] Email communications from Eniko Horvath, senior researcher, Business and Human Rights Resource Center, to Human Rights Watch, March 27 and March 28, 2017. The Business and Human Rights Resource Center is one of the organizations that is part of the CHRB’s Methodology Group.

[18] Email communication from Kevin Thomas, SHARE, to Human Rights Watch, February 24, 2017.

[19] The Pledge does not use the first and second tier terminology to avoid confusion because different brands define tiers differently. Where a CMT factory does not have the in-house capacity to undertake printing, embroidery and other embellishments, laundry, and related processes without which a product cannot be readied for shipment, typically the factory outsources these functions to other specialist factories. These authorized subcontractors should also be disclosed.

[20] For example, Nike, “Nike Manufacturing Map,” http://manufacturingmap.nikeinc.com/ (accessed August 23, 2016). For every factory disclosed, Nike publishes information about number of workers, percentage of female workers, and percentage of migrant workers; Marks and Spencer (M&S), “M&S Supplier Map,” https://interactivemap.marksandspencer.com/ (accessed August 23, 2016). For every factory disclosed, M&S publishes information about product type, number of workers, and percentage of male and female workers; Patagonia, “The Footprint Chronicles,” http://www.patagonia.com/footprint.html (accessed August 23, 2016).

[21] H&M Group, “Supplier List,” http://sustainability.hm.com/en/sustainability/downloads-resources/resources/supplier-list.html (accessed August 23, 2016). H&M disclosed a number of fabric and yarn mills that supplied the factories producing apparel. Patagonia, “The Footprint Chronicles.” Patagonia disclosed a number of textile mills in its supply chain as well as one cotton farm.

[22] For information after this date, visit the brand website for any new developments.

[23] In evaluating company responses to the Pledge, the coalition has opted for flexibility on frequency of updates to supplier factory lists. As explained in more detail in Appendix II, this decision was based on its discussions with companies.

[24] Email communication from Gap to the coalition, March 22, 2017.

[25] Email communication from Marks and Spencer to the coalition, December 20, 2016. Marks and Spencer did not commit to additional disclosures in response to the Pledge. They informed the coalition that their existing plans already intended to extend disclosures in January 2017. This will add “[B]eauty suppliers and Homeware suppliers, which will complete the public transparency of … entire first tier product Global clothing and home supply chains.” Marks and Spencer also stated that its representatives were “[a]lready in discussions of how to improve and increase the level of transparency. This includes adding 2nd tier processing sites and some raw materials and we will keep you posted throughout 2017 on these plans.”    

[26] Email communication from Tesco to the coalition, March 16, 2017.

[27] Email communication from John Lewis to the coalition, November 1, 2016.

[28] Mountain Equipment Co-op committed to adding all details as requested in the Pledge for all its “first tier” factories whose names and addresses it was already disclosing. It also noted that it was collecting information about external printers used by its authorized cut-make-trim (CMT) factories. But these would be disclosed as part of its ongoing efforts to deepen supply chain transparency and will happen over the next three years.

[29] Letter from Columbia Sportswear to the coalition, December 20, 2016 (on file with the coalition). Even though Columbia did not commit to additional disclosures in response to the Pledge, it stated that the company was “[c]ommitted to continuously improving transparency … and were open to further dialogue … about it.” Email communication from Disney to the coalition, December 21, 2016. Disney declined to add more details or commit to the full Pledge, stating that “Disney’s facility list is the largest list published to date, with over 6,000 facilities identified,” but said they “remain open to further dialogue about transparency practices.”

[30] Ibid.

[31] Email communication from New Balance to the coalition, February 22, 2017.

[32] “Puma Global Core Factory List 2017,” http://about.puma.com/damfiles/default/sustainability/supply-chain/manufacturing-map/PUMA-Global-Core-FTY-List-2017_final.pdf-dfb64160fd36df1141c4cac5d3ad248d.pdf (accessed April 7, 2017). Letter from Puma to the coalition, December 19, 2016; email communication from Puma to the coalition, March 21, 2017. Puma’s core factory list covers 80 percent of its business volume for tier-1 suppliers but also tier-2 material and component suppliers. However, it does not include tier-1 subcontractors (if they exist) since those do not fall under Puma’s definition of “core supplier.”

[33] “Coles non-food suppliers,” https://www.coles.com.au/about-coles/ethical-sourcing/non-food-suppliers (accessed April 1, 2017). Email communications from Coles to the coalition, December 6, 2016 and March 16, 2017. Coles stated that the majority of its production was done in-house by its cut-make-trim suppliers and that reliance on subcontractors was minimal. All subcontractors were not disclosed. 

[34] Email communications from Under Armour to the coalition, December 20, 2016 and March 7, 2017.

[35] Email communication from ALDI North and ALDI South to the coalition, December 20, 2016. ALDI North and ALDI South stated that the companies were taking measures to restructure their supply chain and “aim to set internal goals regarding increased supply chain transparency,” and subsequently published their factory lists. ALDI North Factories List, http://www.aldi-nord.de/print/01_verantwortung/ALDI_Nord_Hauptproduktionsstaetten_Lieferanten.pdf (accessed April 1, 2017); ALDI South Factories List, https://unternehmen.aldi-sued.de/de/verantwortung/lieferkette/transparenz-in-der-lieferkette/ (accessed April 1, 2017). Email communications from ALDI North and ALDI South to the coalition, March 20 and March 29, 2017. ALDI North and ALDI South defined tier-1 “mainly as CMT factories (of which many do have processes like laundry, printing, embroidery, etc.).”

[36] LIDL, “Disclosure of main production facilities for textiles & footwear worldwide,” https://www.lidl.de/de/transparenz-in-der-lieferkette/s7376023 (accessed April 1, 2017). Email communications from LIDL to the coalition, November 21, 2016 and February 28, 2017. LIDL includes within its definition of tier-1 manufacturing stages depending on vertical integration or contractual arrangement. These may include some processes like printing, washing, and so on, but not all authorized subcontractors.

[37] Email communication from Tchibo to the coalition, March 30, 2017.

[38] Email communication from VF Corporation to the coalition, February 20, 2017.

[39] See VF Corporation, “Factory List,” http://responsiblesourcing.vfc.com/factories-list/ (accessed February 27, 2017).

[40] Email communications from Debanhams to the coalition, November 7, 2016 and March 17, 2017. Debanhams defined tier-1 as cut-make-trim factories including those with in-house capacity to perform processes like laundry, printing, etc. 

[41] “Benetton Supplier List 2016,” http://static.benettongroup.com/wp-content/uploads/2015/06/Benetton_Supplier_List_2016.pdf (accessed April 4, 2017).

[42] Email communication from Arcadia Group to the coalition, April 7, 2017.

[43] Email communication from Woolworths to the coalition, March 3, 2017.

[44] Ibid. In response to a clarification asking whether all manufacturing and processing sites were disclosed, the company said: “Partially - we have good visibility of this in Bangladesh and are focused on improving this in other markets.” Email communication from Woolworths to the coalition, January 30, 2017. Woolworths committed to exploring whether Pledge standards can be integrated into its ongoing review of its ethical sourcing strategy, but the company did not provide a time frame for when this review is expected to be completed.

[45] Kmart Australia, “Factory List,” http://www.kmart.com.au/ethical-factories (accessed March 5, 2017). Kmart Australia says on its website that its factory list includes “all apparel and general merchandise factories in high risk countries [emphasis added] that directly produce [emphasis added] Kmart Australia products.”

[46] Target Factory Partner List, https://www.target.com.au/company/about-us/ethical-sourcing/factory-list (accessed March 5, 2017).

[47] At time of writing, Kmart Australia and Target Australia had not responded to the coalition’s letter.

[48] Letter from the Hudson’s Bay Company to the coalition, November 4, 2017 (on file with the coalition).

[49] Email communications from Fast Retailing to the coalition, March 22 and March 27, 2017. Fast Retailing stated, “Though not an exhaustive list of UNIQLO factories, it does indeed show all of the factories that UNIQLO currently engages in a long-term, continuous nature, accounting for the vast majority of our production.” In 2017, the company will be expanding its factory list to include another brand, GU’s “major partner factories.”

[50] This is based on information provided by Target USA on its website. “Global Factories List (as of March 24, 2017)” https://corporate.target.com/_media/TargetCorp/csr/pdf/Target-Global-Factory-List-Q1-2017.pdf (accessed April 7, 2017). On its website, Target states, “Target publishes a list of all factories, as well as textile and wet processing facilities producing Target owned-brand products.… This list is subject to change and updates will be provided on a quarterly basis.” Target USA began publishing supplier factory information before the coalition wrote to the company. The company did not respond to the coalition’s letter.

[51] Letter from Mizuno to the coalition, November 14, 2016 and email communication from Mizuno to the coalition, January 31, 2017 (on file with coalition).

[52] “Mizuno Core Factory List as of January, 2016,” http://media.mizuno.com/~/media/Files/com/csr/partner/17_0131_en.pdf (accessed January 31, 2017). Mizuno’s disclosure list has 125 factories, while their website says that there are “240 factories, which constitute … main contract manufacturing,” and further that Mizuno has “464 factories that are Tier 1 suppliers.” The definition of Tier 1 is not included on its disclosure page.

[53] Email communication from Abercrombie & Fitch to the coalition, November 6, 2016; email communication from PVH Corporation to the coalition, April 4, 2017.

[54] Email communication from Loblaw to the coalition, November 7, 2016; “Loblaw Apparel Supply Chain Disclosure, February 2017,” http://www.loblaw.ca/content/dam/lclcorp/pdfs/Responsibility/LCL%20Apparel%20Supply%20Chain%20Disclosure%20V1%20EN%20(Feb117)FINAL.pdf (accessed March 20, 2017).

[55] Email communication from BESTSELLER to the coalition, February 24, 2017. The company committed to disclosing all “tier one” suppliers and said, “Tier 1 are CMT,” excluding authorized subcontractors from within its scope. The company did not have more details about what precisely would be disclosed about its CMT suppliers. Email communications from Decathlon to the coalition, November 3, 2016 and February 14, 2017.

[56] Emails acknowledging receipt of the coalition’s letter with a preliminary response that the company is discussing the letter without a clear indication of the company’s position on supply chain transparency have been counted as not having responded.

[57] Details of company responses sent on company letterhead are available as an Annex online.

[58] Letter from Foot Locker to the coalition, November 4, 2016 (on file with the coalition). Foot Locker has previously disclosed the names and addresses of its cut-make-trim supplier factories that produced goods licensed by US colleges and universities and did not commit to adding more information about factories that produce its other own-brand products. This information was made publicly available on the website of the Worker Rights Consortium, http://www.workersrights.org/search/index.asp?search=results&licensee=Team+Edition+Apparel (accessed April 6, 2017). It appears, however, that Foot Locker is no longer marketing this line of apparel, and, relatedly, no longer discloses any supplier factory information.

[59] Letter from Inditex to the coalition, November 7, 2016 (on file with the coalition). Inditex publishes its direct and indirect wet processing supplier list, https://www.wateractionplan.com/documents/186210/199857/6.1.INDITEX+SUPPLY+CHAIN_WET_PROCESS_v1May2016.pdf/90f1e765-5ca2-4cc3-9215-88e0f1cc12a4 (accessed April 1, 2017). See below for more information about brands like H&M, Mizuno, and Tchibo that have global framework agreements with IndustriALL and publish or have committed to publishing supplier factory information.

[60] Letter from KiK to the coalition, November 7, 2016; letter from Inditex to the coalition, November 7, 2016 (on file with the coalition); email communication from DICK’s Sporting Goods to the coalition, March 6, 2017; email communication from The Children’s Place to the coalition, March 20, 2017.

[61] See Text Box in the Summary for a list of apparel companies that publish supplier factory information.

[62] adidas, Levi’s, Nike, Puma, and Patagonia.

[63] For example, Rupashi Group, http://rupashigroup.com/ (accessed March 3, 2017 and screenshot on file with Human Rights Watch). The group states on its website that it produces for Forever 21, Zara, and other brands that do not publish their supplier factory information; Ha-Meem Group, http://www.hameemgroup.net/ (accessed March 3, 2017 and screenshot on file with Human Rights Watch). The group states on its website that it produces for Zara, Mango, and American Eagle Outfitters among other brands that do not publicly post information on their websites. 

[64] Fair Factories Clearinghouse, “Benefits of Membership,” http://www.fairfactories.org/Home/Benefits-of-Membership (accessed February 23, 2017); Sedex, http://www.sedexglobal.com/ (accessed February 23, 2017).

[65] 19 US Code § 1484, Entry of Merchandise, https://www.law.cornell.edu/uscode/text/19/1484 (accessed March 21, 2017).

[66] Subscription databases exercise rights under the US Freedom of Information Act to purchase trade data from US Customs and market it in searchable formats to users, including competitors’ apparel companies. See for example, Import Genius, “Our Clients,” https://www.importgenius.com/how-it-works/our-clients (accessed February 18, 2017). Import Genius lists sourcing professionals as part of its clientele and says: “Hundreds of importers use our service to view the U.S. shipping history for overseas suppliers in any industry.… They can search by company name or product keywords to identify the manufacturers already supplying their competitors, from world-class brands to small-time importers.” In fact, Import Genius clearly says that it serves “competitive intelligence analysts,” providing “unrivaled access into the supply chain activities of … major competitors.” Panjiva, https://panjiva.com/ (accessed February 18, 2017). Panjiva advertises that one of the database’s advantages is to “[u]nderstand [the] market share by seeing where … competitors source their goods, and which entities are involved in the shipment of goods.”

[67] Letter from KiK to the coalition, November 7, 2016 (on file with the coalition).

[68] Email communication from MANGO to the coalition, November 24, 2016. MANGO said it was developing a system to create a username and password upon request to its CSR department through which supplier information can be accessed by “any organisation that may be interested, as long as they do not have any competitive conflict.”

[69] Letter from Esprit to the coalition, November 23, 2016 (on file with the coalition).

[70] See for example, ITUC, “Closing the loopholes—How legislators can build on the UK Modern Slavery Act,” https://www.ituc-csi.org/IMG/pdf/uk_modern_slavery_act.pdf (accessed March 7, 2017).

Author: Human Rights Watch, Human Rights Watch
Posted: January 1, 1970, 12:00 am