Cotton Campaign Recommendations to Brands and Retailers on their Policies for Sourcing Cotton Products from Uzbekistan
July 2022
The Cotton Campaign has issued the following recommendations, following the lifting of the Uzbek Cotton Pledge.
While Uzbekistan ended state-imposed forced labor in the harvest of cotton, human rights risks remain, including civic space restrictions, constraints on freedom of association and expression, and low capacity for independent monitoring, exacerbated by continuing restrictions on independent groups to register and operate.
If you and your suppliers are interested in sourcing cotton products from Uzbekistan, we invite you to join the Cotton Campaign Framework for Responsible Sourcing. We launched the Framework to ensure that companies and their suppliers can begin responsibly sourcing yarn, fabric, and finished goods from Uzbekistan. The Framework establishes robust mechanisms for monitoring, capacity building, grievance and remedy, accountability, and traceability for sourcing consistent with the UNGPs, the OECD Guidelines, and national laws governing human rights due diligence, supply chains, and imports. Through these mechanisms, the ongoing human rights risks will be addressed at the producers you begin working with. Brands play a key role in developing these mechanisms and working with the Uzbek industry, government, and civil society to create a sustainable cotton industry.
The Framework was developed in consultation with the Cotton Campaign coalition members, including Responsible Sourcing Network (RSN), the American Apparel & Footwear Association (AAFA) and the United States Fashion Industry Association (USFIA), as well as civil society partners. It also reflects the Cotton Campaign’s ongoing engagement with the government of Uzbekistan, Uzbek cotton producers, and global brands and retailers.
The Framework encourages brands to make investments on the long term in Uzbekistan and practice responsible sourcing to ensure labor rights are protected in their Uzbek cotton supply chain. The implementation of the Framework will provide full transparency about labor practices and protection of labor rights at all tiers, including the cotton farms (Tier 5), gins (Tier 4), yarn spinners (Tier 3), fabric mills (Tier 2), and manufacturing units (Tier 1)
For more information, please contact Raluca Dumitrescu, Cotton Campaign Coordinator, at coordinator@cottoncampaign.org.
Recommendations
All brands should:
1. Assess whether sourcing Uzbek yarn or cotton goods meets their human and labor rights commitments and legal obligations to not use forced and exploitative labor in their supply chains.
Each company looking to source from Uzbekistan must evaluate whether it has the means and capacity to effectively implement human rights due diligence and mitigate human rights risks in its Uzbek supply chain.
2. Inform their sourcing agents, first-tier manufacturers, and textile suppliers about the ongoing human rights risks in cotton production in Uzbekistan and require them to conduct human rights due diligence to ensure that adverse human rights impacts are identified, prevented, and mitigated throughout the entire supply chain. To achieve this, fabric manufacturers could/should be conformant with the YESS Standard for Textile Mills. If the fabric mills are sourcing yarn or fabric from Uzbekistan, they can meet the YESS requirements by sourcing from Uzbek sub-suppliers that are YESS-conformant and are participating in the Cotton Campaign Framework for Responsible Sourcing (See recommendation 5).
3. If you are a member of Better Cotton (BC), engage with the BC Council and BC Secretariat to ensure that they:
Consult with the Cotton Campaign and independent civil society organizations in decision-making about the development and implementation of the Better Cotton program in Uzbekistan.
Prior to licensing farms in Uzbekistan, conduct comprehensive due diligence, including a risk analysis and assessment of the enabling environment for labor rights both at the producers in question and overall, at the national level. Ensure that BC implements the recommendations issued by the Task Force on Forced Labor and Decent Work (2020) and that BC Principle Six on Decent Work is effectively implemented at the covered farms, including that workers’ rights to freedom of association and collective bargaining are protected year round and that there is no forced labor used in the harvest of cotton.
Use their influence in Uzbekistan to advocate for broader reforms to enable civil society organizations to formally conduct their activities and achieve an enabling environment for labor rights.
If they decide to begin sourcing from Uzbekistan, brands should:
4. Exercise human rights due diligence in all aspects of their interactions with the Uzbek textile industry, from evaluating its commercial attractiveness to establishing and maintaining commercial relationships with Uzbek suppliers.
The vertical integration of the Uzbek supply chain requires brands to conduct human rights due diligence to identify, prevent, mitigate, and account for adverse human rights impacts at all levels of production, including at the cotton farms controlled/contracted by the supplier clusters, their gins, yarn spinners, fabric mills, and cut-make-trim units.
5. Engage in good faith with the Cotton Campaign and explore the possibility of sourcing through the Cotton Campaign Framework for Responsible Sourcing. Brands can nominate Tier 1, Tier 2, or Tier 3 suppliers in Uzbekistan to become covered under the Cotton Campaign’s program for responsible sourcing.
The Framework was designed to ensure that brands can begin sourcing from Uzbekistan in a manner consistent with their human rights due diligence requirements and legal obligations.
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A co-governed Board with equal representation of brands, labor, and textile clusters;
Implementation of ILO standards at all levels of the textile supply chain;
Independent grievance mechanisms and access to effective remedy;
Independent and ongoing monitoring;
Accountability at both supplier & buyer levels;
Capacity building and contributing to an enabling environment for labor rights, including freedom of association.
6. Actively commit to furthering freedom of association and collective bargaining. Support the establishment and functioning of democratically-elected, independent, farm and factory-level trade unions and worker organizations.
7. Adhere to responsible purchasing practices that enable those involved in all tiers of the supply chain to offer decent work, including offering employment contracts, and paying a living wage to their workers.
Responsible purchasing practices across all levels of the cotton supply are essential to ensure decent work for cotton workers. These cover business relationships between brands and their direct suppliers, and between suppliers and their sub-suppliers, all the way to the cotton farmers and farm workers.
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Fair contractual terms;
Fair prices based on fair and ‘open costing’;
Mutual agreement between buyer and supplier on production planning and lead times;
Reasonable payment terms;
No unilateral suspension or cancellation of contracts;
Transparency about purchasing practices and costing methodologies. Contracts between buyer and supplier should not contain clauses that deny parties the right to publicly disclose such information.
8. Ensure that the producers they work with:
Do not directly, or through the involvement of local officials, exploit farmers by requesting them to sign blank contracts, delay payments, or renege on contractually agreed terms.
Commit to fair recruitment practices for workers at all levels of the supply chain - including cotton pickers and workers in production facilities - in accordance with the ILO General principles and operational guidelines for fair recruitment and definition of recruitment fees and related costs. This means ensuring that prospective workers receive correct information on their working and living conditions; that workers are not asked to make advance payments; and that workers are formally registered at the relevant administrative authorities.
Provide all workers with written employment contracts and monthly payslips in a format that workers can understand.
Pay all categories of workers, from apprentices to skilled workers, a wage that enables them to cover their basic needs and have a discretionary income.
9. Publicly support the farmers’ efforts to create an independent association that promotes and protects their interests.
10. Sponsor (or become a member once available) Responsible Sourcing Network’s initiative YESS: Yarn Ethically & Sustainably Sourced. YESS utilizes the OECD risk-based due diligence approach to identify and eliminate forced labor from cotton production. Brands should also require the fabric mills and yarn spinners in their supply chains to be conformant with the YESS due diligence standards. If the fabric mills are sourcing yarn or fabric from Uzbekistan, they can meet the YESS requirements by sourcing from Uzbek sub-suppliers that are YESS-conformant and are participating in the Cotton Campaign Framework for Responsible Sourcing.
