In March 2000 the Swiss Clean Clothes Campaign, launched little more than a year before, began a pilot project on independent verification of labor standards with three Swiss companies. The three -- Mabrouc, Migros and Veillon - agreed to adopt the complete CCC model code of conduct, and signed a statement outlying the various duties and obligations of the participants in the project. A director was hired to implement the project, which was scheduled to run until the end of December 2002.

One of the objectives of the pilot project is to make a concrete contribution to efforts to define what an independent verification system should be. After one year of experimentation, the project's director reports that the following appear to be the main principles for any acceptable independent verification system:

- Responsibility: the company has to accept and assume its responsibility for the whole production chain, by adopting a full code of conduct. This means that the implementation and monitoring (internal or external, for example through auditing firms) of labor standards are the responsibility of the company. The existence of a pilot project or, in the future, of an independent verification system will never serve as a substitute for all the necessary steps and measures that a company should take in order to implement its code of labor standards, making it known, understood, and respected throughout the whole production chain.

- No bargaining on code content: An independent verification system verifies compliance with a code of labor standards and therefore companies working with such a system have already agreed to accept the content of the code. A verification system is not a forum for companies to renegotiate code content.

- Participation: people and organisations without any commercial link to the companies whose code compliance is being verified, and therefore who might be potentially critical (such as the CCC) toward them, must take part in the verification process. In countries where garments are produced, individuals involved in the verification process (ex. those who carry out interviews with workers) and concerned organisations (NGOs, trade unions, etc.) have to be included in the decisions, formulation, and implementation of the independent verification process.

- Transparency: this is the keystone of any credible independent system. Transparency is one of the main issues that distinguish external monitoring from independent verification. The CCC cannot call for complete codes of conducts and independent verification if there is no transparency with the public on the results of the process. It is a question of credibility. Also, if there is no transparency toward the "outside", the NGOs and trade unions taking part in the independent verification process would be simply providing an "alibi" for corporate practices. Therefore, it is fundamental to preserve the principle of transparency -- for example by making the verification reports available to interested people -- being aware that the way these reports will be written will be subject to many discussions between companies and the verification body.

- "Second track" verification: given the complexity of the production chain, if any credible independent system is created, it would be fundamental to develop a complaint system for the workers. Such a system would enable workers to denounce violations of the code and set up a procedure to follow up these complaints. The implementation of such a complaint system could mean the establishment of a permanent verification mechanism - in other words a system for workers to report violations of their rights whenever they occur.

The first verification of Mabrouc, Migros and Veillon suppliers in Indian took place in September 2001. Two Indian researchers from a social data gathering institute and an independent woman researcher carried out the interviews of the garment workers from these production sites. The interviews took place several days before the actual visit of the production sites. In some cases, a relationship of trust seemed to develop, especially between the woman workers interviewed by a female researcher. The aim of the pilot project was explained to the workers. None of the interviews were carried out in the presence of management. Some were carried out on site, some off site.

After the interviews, each supplier received unannounced visits by an auditing company. An initial interview with the management was conducted, followed by an inspection of the production site and, when available, the examination of written documents (registers, etc.). Most of the time suppliers said there was no documentation of workers salary, age, attendance, etc. In a final meeting with the management, which took place shortly after the inspection, the auditors conveyed their observations and conclusions, including areas of non-compliance with the code.

Migros, Mabrouc and Veillon now have to meet with their respective suppliers and draw up a corrective action plan, along with an adequate timetable (no more than six months). A second verification visit will be carried out again involving the interview of workers and the inspection of production sites in order to check that corrective measures have been taken. The reports on these second verification visits will be made available to the public.

The Swiss CCC's project on independent verification is just one of the projects the CCC is involved with in an attempt to gather knowledge and experience in relation to the monitoring and verification of codes of labor standards. For more detailed information on the Swiss project and the other CCC initiatives, please see the following website: <http:www.somo.nl/monitoring>.