Report of the Ad-Hoc Committee on Sweatshop Labor
to University President Judith Rodin
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
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: www.fairlabor.org.
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: www.workersrights.org/.
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
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
- Gregory Possehl, professor, Archaeology, SAS; member, Council Steering
- Eric Tilles, associate general counsel, Office of the General Counsel
- Staff: Judi Rogers, director of trustee affairs, Office of the