The Clean Clothes Campaign takes the core labor standards of the International Labor Organization (ILO) and several additional standards (freedom of association, right to collective bargaining, no discrimination of any kind, no forced or slave labor, a minimum employment age of 15, health and safety measures, a maximum work week of 48 hours and voluntary overtime of 12 hours maximum, a right to a living wage and the establishment of an employment relationship) as its guiding principles for acceptable working conditions in the garment industry. The CCC developed a code, called the "Code of Labour Practices for the Apparel Industry Including Sportswear," which sets out these principles. But why was this CCC model code developed? And how is it different, both in content and in purpose, from the codes developed by companies themselves?

The model code was developed because those in the campaign and CCC partners recognized that there was need for a unified standard to campaign around. They felt that there should be consensus and clarity of our demands in relation to labor standards. Coming together behind a common code would demonstrate the broadness and international nature of the support for these standards. It would also provide a challenge to the weak codes that were being developed and promoted by garment and sportswear companies. The CCC saw an opportunity to make monitoring and verification of labor standards part of the discussion (at that time these processes were referred to as "independent monitoring"), by including demands for such systems in the CCC model code. Years of meetings, drafts, and debates took place resulting in a finished CCC model code in 1997, which was presented in early 1998. It was signed by international trade union organizations ITGLWF, ETUC/TCL, WCL), several Asian organizations and networks (from Indonesia, Sri Lanka, Bangladesh, Hong Kong) and all the approximately 250 NGOs and trade unions in the European CCC coalitions. Today it might seem strange that this process was not a global one, but at that time a global consultation process was far beyond the scope of the CCC. The campaign did have contacts in Central America, but by and large these countries were producing for the United States market and therefore had a much stronger link to labor rights organizations in the United States then to those in the European campaigns. Generally, garments in Western Europe came from Asia and Eastern Europe, but Eastern Europe was still "closed territory" in terms of contacts with local groups and knowledge of the industry. (1)

The CCC begins to work with codes 1993: Small-scale international consultation on what should be included in a code of conduct, at that time called a charter 1994: Fair Wear Charter (Netherlands) presented to industry 1995: a declaration of intent to set up a foundation to oversee the implementation and "independent monitoring" of the charter was signed by the industry associations representing the small and middle-sized companies in the garment sector in the Netherlands 1995-1996: deepening of contacts in Asia, CCC spreads throughout Western Europe, joint decision made to develop a model code of conduct Process of meetings, drafts, debates throughout 1997- 1998 The CCC Model Code was finalized in 1998

Though there is a lot of talk about "the proliferation of codes," the model (CCC, ICFTU) and multi-stakeholder codes (ETI) are quite similar when it comes to standards. Those who have developed these codes are still very much involved in debating the way to best implement codes and enforce them. The proliferation of codes comes from industry, which seems far less interested in creating a single standard, despite what they say in public about level playing fields. Companies developed their codes partly as a result of the heightened level of awareness. Along with these in-house codes came corporate-controlled systems of monitoring and verification.

A few of these corporate initiatives are genuine efforts to improve conditions, but many are only public relations tools intended to deflect consumer inquires about workplace conditions and corporate social policies. The standards they contain are weak -- either vague or incomplete -- and there is no commitment to implement, monitor or verify that the standards are applied. In some cases, these company codes make the situation even worse by shifting all the responsibility for complying with labor rights to the supplier level (production countries) without demanding any changes be made at the top of the supply chain -- though it is delivery times and prices set at the highest level of the supply chain which often determine if suppliers can actually meet the standards called for in a code of conduct.

Criticisms of Corporate Codes of Conduct Vaguely defined Incomplete Not implemented and monitored Compliance is not independently verified.

The CCC has made intense use of codes and the associated public attention for them as a campaigning tool, using them as a way to enter the political debate, forcing companies to talk about the notion of a living wage and of job security, and forcing authorities to react to violations of the right to organize. At the same time this tool has enabled campaigns to be much more effective "watchdogs," highlighting the often glaring differences between codes on paper and the actual standards found in the workplace. Many of the urgent appeals cases the CCC works on involve labor rights violations that are also violations of company codes. These cases provide ample evidence of the failure of companies to actually implement the promises made in their codes (in most cases workers are not even informed of the rights articulated in the codes - many codes are only pieces of paper, not translated into the local language, that aren't even posted on a factory wall).

Fuelled by increased reporting on code-standard violations, the debate both within and beyond the CCC network started to shift from the actual labor standards to issues of how to monitor that standards were in place and how to go about verifying the accuracy of such monitoring. Auditing and quality control firms started getting in on the act, and "social auditing and reporting" rapidly became a new service industry.

From the CCC Network During the CCC's international network meeting in March 2001 in Barcelona to evaluate and strategize in the wake of 10 years of campaigning, the following points were made regarding monitoring/verification: Monitoring & verification must include workers, labor NGOs and unions in countries where garments are produced This can be a tool to empower workers if implemented where there is democratic space for organizations to participate Must go beyond the first tier of suppliers (i.e. cover the entire subcontracting chain) There is a risk of shifting costs downwards (ex. current pricing and scheduling practices at the top level of the supply chain continue to prevent codes from being implemented and put disproportionate pressure on suppliers and workers) Regional differences and the need for more interregional sharing on these issues must be recognized In the long term: the CCC should move out of this work and instead carry out a support & watchdog role

Some companies have signed the CCC's code of conduct. In several countries, these companies agreed to participate in projects with the CCC and the CCC model code (or in the case of the UK, with the ETI base code). Specifically, these multi-stakeholder initiatives include the CCC in the Netherlands (Fair Wear Foundation); the UK (the Ethical Trading Initiative); Sweden (the Swedish Project on Independent Verification); France (Ethique sur l'etiquette with French retailers); and in Switzerland (The Swiss CCC Project on Independent Monitoring).(2) In these projects, participants are investigating possible ways in which a good code of conduct could be implemented, monitored, and verified. Just as with the development of the model code of conduct, the CCC believes that to really oppose something, we need to be able to propose something. In terms of monitoring and verification we know that we need to learn more if we're going to be able to propose an alternative to the company controlled and commercial systems of social auditing and reporting that we are opposed to. These pilot projects, as they are referred to, are meant to allow the CCC to better understand the possible ways in which a code of conduct can create space for workers to organize and improve their lives. The projects have similarities and differences in terms of structure and what models are being tested.

Meanwhile, concerns have been raised about the dangers of working with companies on such projects. There are concerns that the campaign might be "co-opted" by corporate interests and that involvement in these projects means that campaigning activities are toned down (so far this has not happened!).

There is a fear that work on codes and monitoring takes up a disproportionate amount of CCC time and resources, and that other possibilities aren't investigated as thoroughly. Capacity problems -- for the European coalition members and those in the South that are involved with these issues -- are serious, so this seems to be a justified fear.

There is also concern that this kind of work legitimizes company codes, promoting "voluntary" processes, and reinforces the withdrawal of the state. Some are concerned that the campaign in a sense is taking on the challenge of solving problems for companies, instead of solving our own.

And in the long term there is a fear that these processes run the risk of creating "good" multinationals and "bad" multinationals, which would serve to legitimize international business practices in general, when only the issue of basic labor standards is being addressed. There are also concerns of international representation - in other words, who has the right to represent who at that the international level?

No final conclusions can be drawn from these projects yet, because all are still underway, except for the Swedish project, which ended and has generated a proposal for a monitoring and verification body. Some early observations have been shared, and can be found on the SOMO (Center for Research on Multinational Corporations) website <http:www.somo.nl/monitoring>. The report on the Swiss project, found in this issue of the newsletter, also shares some insight into what has been learned during the pilot projects. In 2000-2001 the CCC and SOMO were involved in a project to coordinate the exchange of experiences from these projects. It is hoped that in 2002 funding will come through to allow the CCC to continue with this project. Specifically, the CCC and SOMO propose to continue tracking the European monitoring and verification initiatives, with an eye toward harmonizing terminology and methodology, and to develop several monitoring and verification tools.