Report of the Ad-Hoc Committee on Sweatshop Labor

to University President Judith Rodin

(February 28, 2000)


As members of the Ad-Hoc Committee on Sweatshop Labor, we met intensively from February 10 through February 28. We took up the charges of developing a code of workplace conduct for licensees of Penn apparel and considering which monitoring organization or organizations would be best suited to monitor factories making University apparel. The superordinate goal of our deliberations was the promotion of fair labor practices in the manufacture of collegiate apparel. To reach that goal, all members of the committee voted in favor of the following.

We firmly believe that Penn needs a strong code of conduct which will be fully enforced and regularly evaluated for effectiveness. Our proposed code aims to demonstrate Penn's commitment to fair labor practices and to ensure that licensees of Penn apparel are held to very high standards.

We believe that, without question, effective monitoring of licensee factories is crucial to ensuring fair labor practices. With that principle in mind, we believe that both the Fair Labor Association and the Worker Rights Consortium have potential in this regard, but we have a number of concerns about both organizations. Once the organizations agree to address our greatest concern--balanced representation of colleges and universities on their governing boards--we would recommend that Penn join the FLA and the WRC. We would then want to work from within these organizations to address our additional concerns with them.

Code of Conduct:

With a view to stimulating economic growth and development, raising living standards, implementing staffing requirements, and expanding employment opportunities, we recommend and append a Code of Workplace Conduct for University of Pennsylvania Apparel Licensees. The goals of the code are to promote full, productive, and freely chosen employment and to assert that Penn expects its licensees to conduct business in a manner consistent with the high standards in its code. (See the item FOR COMMENT, here)

Evaluation of Monitoring Organizations:

We engaged in thoughtful and thorough deliberations about the question of monitoring organizations which should inspect licensee factories to determine whether they meet the University's code of conduct. We fully recognized that the matter of monitoring organizations has been central to campus discussion about sweatshop labor and we brought all due consideration to the issue. Our goal is to ensure that factories are monitored fairly, effectively, and as quickly as possible.

We studied the Fair Labor Association and the Worker Rights Consortium by reviewing materials on both groups and listening to presentations from their leadership. While we strongly believe that neither organization is sufficiently developed at this time, we have confidence that both, with modifications and time to further evolve, could have a significant effect on working conditions in the apparel industry. Synopses of both organizations follow.

Fair Labor Association: The Fair Labor Association, created in 1998 and formally founded in 1999, is an initiative sponsored by the United States Department of Labor and designed to promote the improvement of working conditions for factory workers who produce apparel. The FLA's purposes are to ensure the inspection and monitoring of factories, to report publicly on factories' compliance with the FLA code of conduct, and to certify brands produced in compliance with FLA standards. The FLA is a non-profit organization which includes labor and human rights groups, apparel companies, and approximately 130 colleges and universities as of January, 2000. The association is headed by a Board of Directors comprised of six industry representatives, six labor/NGO representatives, and one university representative. Charles Ruff, former White House counsel, serves as chair of the FLA Board. The FLA's website is:

Worker Rights Consortium: The Worker Rights Consortium was created in 1999 by United Students Against Sweatshops in consultation with workers and human rights groups; a founding conference is scheduled for April 7, 2000. According to its charter, the WRC aims to verify and inspect conditions in factories producing apparel for colleges and universities through public disclosure, verification of worker complaints, and proactive investigations of regions and companies with a history of violations. A twelve-member governing board will be selected at the founding conference; the current charter states that this board will consist of three students, three university administrators, and six representatives selected from an advisory council with significant expertise in labor standards in the apparel industry. The WRC's website is:


We feel strongly that neither the FLA nor the WRC, in current form, is able to completely serve the University's needs and fully promote fair labor practices among licensees of University apparel. However, we believe that both organizations are committed to the goal of fair labor practices and that, with the following provision met, Penn should affiliate with both organizations.

The current representation of colleges and universities on the governing boards of the FLA and the WRC is unacceptable. Institutions of higher education are at the forefront of the movement for fair labor practices in the apparel industry and must have a voice that is balanced with those of other groups on the governing boards of the FLA and the WRC.

We would like to see Penn re-join the FLA and join the WRC as soon as possible to work from within each organization to resolve our additional concerns with them, as stated below. We recommend that President Rodin write a letter to each group requesting balanced representation and noting that Penn's membership is contingent upon it. When President Rodin receives the responses, we suggest that she charge our Ad-Hoc Committee on Sweatshop Labor or a similar committee to determine next steps. Membership in each organization is contingent on having an adequate response. Our requests will require a very timely response, especially considering that the WRC founding conference is on April 7, 2000. Further, it will be critical for these statements to be followed through fully and quickly. If adequate responses are provided and Penn affiliates with these organizations but they are not implemented, then Penn will withdraw its membership.

Addressing Additional Concerns about FLA and WRC:

If Penn affiliates with the FLA and the WRC, we fully expect that the Committee on Manufacturer Responsibility, which is recommended in the attached code of workplace conduct, will pay careful attention to the progress of both organizations, re-evaluate their effectiveness, and make recommendations to the President accordingly. We would urge the Committee on Manufacturer Responsibility to address the following concerns as soon as possible.


  • Eliminate the conflict of interest apparent in the ability of corporate members to select their own external monitors and permitting pre-announced inspections. We are concerned specifically with the current FLA provision that companies may conduct up to $100,000 of business with firms that they choose as independent monitors. We are concerned, too, that pre-announced inspections are little more than opportunities for quick clean-ups and then a return to business as usual. We advocate unannounced inspections.
  • Institute full public disclosure of all FLA-related factory locations and monitoring reports.
  • Ensure that progressive companies are rewarded and recognized, but that their brands are not certified as compliant with FLA standards, and therefore considered "sweat-free". Certification may be misconstrued as meeting Penn's standards, which are significantly higher than those of the FLA. Also, due to the large number of factories and the severity of their problems, we believe that the two- to three-year period for review and certification suggested by the FLA will not be sufficient to ensure fair labor conditions that meet the University's standards. However, we believe it is appropriate for companies with exemplary labor practices to be rewarded and recognized for their efforts, and that the FLA should develop a system for this.


Our major concern with the WRC is that it is still in its formative stages. We expect that the WRC founding conference, scheduled for April, and Penn's representation at the conference will help address several of the following points, which we feel are critical to our superordinate goal of fair labor practices.

  • Develop a governance structure which can support an effective monitoring system in a timely manner.
  • Ensure that corporate interests are represented in the WRC governance structure. We believe that the promotion of fair labor practices requires bringing all involved parties to the table.
  • Obtain funding sufficient to create and support an effective monitoring system in a timely manner.We recognize that an effective monitoring system is costly. Developing a strategic plan for funding must be a priority of the April founding conference.
  • Demonstrate a commitment to external monitoring and develop an effective plan. We feel strongly that regular, unannounced inspections are as important as a viable way for workers to submit complaints and should be included as part of the WRC charter.
  • We believe it is appropriate for companies with exemplary labor practices to be rewarded and recognized for their efforts.We believe that the WRC should develop a system to accommodate this.

Recommendation for Immediate Implementation:

We strongly recommend that the Committee on Manufacturer Responsibility be formed this semester, as soon as these recommendations have been reviewed and accepted by the President, in order to begin immediate implementation of the code of conduct.

As the members of the Ad-Hoc Committee on Sweatshop Labor, we respectfully submit our recommendations to President Rodin on February 28, 2000.

  • Howard Kunreuther, Cecilia Yen Koo Professor of Decision Sciences and Public Policy, Wharton School, chair
  • Jennifer Baldino, director of external affairs, Office of the President
  • Sue Casey, CGS student and PSAS representative
  • Tina Collins, GSE doctoral student and GAPSA representative
  • Kimberly Colopinto, UA representative
  • Stephen Dunning, professor and chair of Religious Studies, SAS
  • Michael Hearn, SAS sophomore and PSAS representative
  • Amy Johnson, director of external relations, Office of Business Services
  • Brian Kelly, Wharton sophomore and PSAS representative
  • Nancy Nowicki, executive director, external affairs, Office of the Provost
  • Gregory Possehl, professor, Archaeology, SAS; member, Council Steering Comm.
  • Eric Tilles, associate general counsel, Office of the General Counsel
  • Staff: Judi Rogers, director of trustee affairs, Office of the Secretary

See Also:

FOR COMMENT: A Code of Workplace Conduct for Penn Apparel Licensees (Posted 3/2/00)

Comments of the Ad-Hoc Committee on Sweatshop Labor: Regarding its report and proposed code (Posted 2/28/00)

President Judith Rodin's comments (Posted 2/29/00)

Posted 3/2/00