Four of the eight cases highlighted above—Lido, Confecciones Ninos, Anthony Fashions, and Tainan—involve export companies. In each case, the company reportedly entered into business relationships with U.S.-based corporations and, in some cases, other Salvadoran exporters during the time period when the alleged workers’ human rights abuses documented by Human Rights Watch occurred.
States have the primary responsibility to promote and protect workers’ rights, “including ensuring that transnational corporations and other business enterprises respect human rights.”403 Nonetheless, as reflected in the U.N. Norms, as well as the U.N. Global Compact404 and the Organization for Economic Cooperation and Development Guidelines for Multinational Enterprises (OECD Guidelines),405 there is an international consensus that corporations have a duty to uphold workers’ human rights. The Commentary on the Norms on the Responsibilities of Transnational Corporations and Other Business Enterprises with Regard to Human Rights (Commentary on the U.N. Norms) elaborates:
There is also an emerging consensus, evidenced in various corporate codes of conduct and instruments, such as the OECD Guidelines407 and the U.N. Norms,408 that corporations have a responsibility to take meaningful steps to ensure that labor rights are respected not only in their directly owned facilities but throughout their supply chains.
When countries, such as El Salvador, do not effectively enforce labor laws or lack sufficient legal protections to guarantee workers’ human rights, the government fails to fulfill its duty under international law to protect labor rights. These governmental acts of omission enable employers to commit labor rights violations with impunity.
These local employers may produce goods for licensees that bear the labels or logos of licensing corporations. They may contract directly with corporations to produce their trademarked corporate goods for export. Or these local employers may manufacture their own brand name products and hire corporations to distribute those goods abroad. When these financial or contractual relationships are forged, the exporting, distributing, licensing, and licensee corporations have financial influence that they can exert to demand respect for labor rights in local workplaces. When they fail to do so, in some cases contravening their own codes of conduct or ethical standards, they facilitate and benefit from the labor rights violations because they export, distribute, or obtain royalties from goods produced under abusive conditions. Human Rights Watch believes that in such cases, all four kinds of companies—exporting, distributing, licensing, and licensee—have a fundamental responsibility to demand respect for labor rights in local workplaces that supply them and may be complicit in the violations that occur when they fail to do so.
Human Rights Watch has sent letters to each corporation that, according to information we have received, did or is doing business with Lido, Confecciones Ninos, Anthony Fashions, and/or Tainan. The letters seek to confirm the alleged contractual relationships. They also inquire as to the labor policies and practices of each corporation regarding respect for workers’ human rights throughout its supply chain, pose questions specific to the alleged labor rights violations in each case, and ask whether a corporate representative audited or visited the relevant local factory during the period in question.
At this writing, we have received seven replies, reproduced in the appendix, to the sixteen letters we sent. The responses varied widely. One company simply reiterated, in general terms, its standards of engagement, failing to answer most of the specific questions posed in the letter. Another also did not discuss the case-based questions, asserting generally that, as a licensing company, it has no contractual relationship with local factories. Similarly, a U.S.-based distributor claimed to have no information regarding respect for workers’ rights in the cited supplier facility. Four corporations described conducting worksite inspections of the local operations, three deciding to go ahead with or continue placing orders and the fourth finding conditions unacceptable and allegedly severing the business relationship. Five corporations also confirmed their business relationships with the local suppliers during the time period at issue; one responded that it had severed its relationship prior to that time period; and another did not respond to the question. These diverse responses and the companies’ codes of conduct and ethical standards are described below.
Human Rights Watch has been informed that Lido contracts with a Maryland-based firm—Rio Grande Food Products, Inc. (Rio Grande Foods)—to distribute its bread and dessert products in the United States.409 As discussed, since January 2002, Lido has reportedly violated workers’ right to freedom of association by engaging in anti-union dismissals, pressuring union members to renounce their membership, and requiring illegally fired union members to tender resignations and sign liability waivers prior to collecting their severance pay—thereby circumventing Labor Code trade union protections.
On July 7, 2003, Human Rights Watch mailed and faxed a detailed letter of inquiry to Rio Grande Foods. On July 11, 2003, Rio Grande Foods responded with a letter acknowledging that the company has been distributing Lido’s products “since approximately September 2002 to the present.” The letter continued, “While everyone at Rio Grande Food Products, Inc. respects the rights of all workers in every region of the world, we do not have any information to provide on our suppliers’ policies on this matter.”410
Under the Commentary on the U.N. Norms, however, corporations like Rio Grande Foods “have a responsibility to use due diligence in ensuring . . . that they do not directly or indirectly benefit from abuses of which they were aware or ought to have been aware” and, in fulfilling this responsibility, “shall inform themselves of the human rights impact of their principal activities.”411 As stated above, Human Rights Watch believes that distributor corporations such as Rio Grande Foods have a responsibility to use their financial influence to demand respect for workers’ human rights throughout their supply chains. When, as in the case of Rio Grande Foods, they fail to do so, they benefit from, facilitate, and are complicit in labor rights violations that may occur in those supplier facilities.
Between January 2001 and March 2002, Confecciones Ninos reportedly supplied casual clothing to U.S.-based Wal-Mart Stores, Inc.; JC Penney Company, Inc.; Perry Manufacturing Company and its Salvadoran subsidiary, Primo, S.A. de C.V; Kellwood Company and its subsidiary, Koret of California, Inc.; Kahn-Lucas-Lancaster, Inc.; and Kmart Holding Corporation and to Salvadoran-based Lenor Industries, among others.412 During that period, Confecciones Ninos allegedly engaged in illegal anti-union discrimination, failed to pay overtime and legally mandated annual bonuses, delayed salary payments, denied legally mandated paid vacations, and limited workers’ use of restroom facilities.
To Human Rights Watch’s knowledge, three of these corporations have policies governing corporate responsibility for labor conditions in supplier facilities: JC Penney, Kellwood, and Wal-Mart. While Kmart has adopted the “Kmart Code of Business Conduct,” it does not address labor conditions in supplier factories but, instead, confines its treatment of a “respectful workplace” to non-discrimination and harassment policies at Kmart facilities.413
Each of the three policies enumerates labor rights, discussed below in relevant part, with which supplier factories are required to comply. All three establish principles governing wages and benefits and require suppliers to comply with local laws on the issue, with Wal-Mart adding that suppliers shall also meet local industry standards. While only Kellwood explicitly includes freedom of association as a right that must be respected, all three require their suppliers to comply with the legal requirements of doing business in the countries in which they operate.414 JC Penney phrases its policy as follows:
Thus, despite JC Penney’s and Wal-Mart’s failure to include the right to freedom of association among the standards to be upheld by suppliers, their monitoring of Salvadoran worksites should cover workers’ right to organize, as the right is established in Salvadoran law. Human Rights Watch believes, however, that all codes, principles, or standards governing workplace conduct should explicitly require respect for workers’ right to organize.
Human Rights Watch sent letters to the six U.S.-based corporations on June 20 and to Lenor Industries on July 1, seeking comment on the situation. As of this writing, we have received one reply.
On July 9, JC Penney responded to Human Rights Watch and enclosed with its letter a document titled, “The JC Penney Supplier Legal Compliance Program.” The company confirmed that “in early 2001, one of our suppliers, Perry Manufacturing, . . . contracted with Confecciones Ninos to produce three Liz Baker items we had ordered from Perry. The production took place between February and May of that year.” According to JC Penney, “In 2000, having been advised of Perry’s potential use of the factory to produce apparel for JC Penney, our inspectors conducted quality assurance and legal compliance inspections of the factory. The factory passed both inspections.” The company added, however, that it “never contracted with the factory” directly and has “no other record of the factory’s use by any of our suppliers.”416
Between November 2001 and December 2002, when the events in the Anthony Fashions case described above unfolded, the company allegedly supplied U.S.-based Liz Claiborne, Inc., through its U.S.-based licensee Leslie Fay.417
To Human Rights Watch’s knowledge, Leslie Fay has not published an internal workplace code of conduct for its directly-owned and supplier facilities. Liz Claiborne, however, established a code of conduct in 1994 and is a member of the Fair Labor Association (FLA).418 While the company has explicitly excluded all licensees, including Leslie Fay, from its FLA obligations,419 Human Rights Watch believes that the FLA should not permit such licensee exclusions, as corporations have a responsibility to ensure respect for workers’ human rights throughout their supply chains, including when licensees contract with local facilities to produce goods with the corporate label. Liz Claiborne’s own code of conduct does not distinguish between licensees and other suppliers,420 however, and is still applicable in this case.
Liz Claiborne’s code of conduct addresses a number of workers’ human rights and requires, in relevant part, that suppliers “observe all applicable laws of their country” and, specifically, “recognize and respect the right of employees to freedom of association and collective bargaining” and “provide legally mandated benefits.” The code also demands that “every employee . . . be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological, or verbal harassment or abuse.”421 As detailed above, however, between November 2001 and December 2002, Anthony Fashions managers reportedly verbally abused workers; deducted pension and social security payments from their salaries without turning those monies over to the government, preventing workers from accessing free ISSS health services; and failed to pay legally mandated year-end bonuses, severance pay, and, in some cases, salaries.
On June 20, 2003, Human Rights Watch mailed and faxed letters of inquiry to Leslie Fay and Liz Claiborne. On July 3, 2003, Liz Claiborne responded. The letter attaches the company’s “standards of engagement” and asserts, “We cannot offer a guarantee that somewhere, at some time, our standards are not being violated but we can assure you that we are working hard to uncover these situations where they exist and rectify the problems, where possible.” Addressing Liz Claiborne’s reported contractual relationship with Anthony Fashions, the letter asserts that while Liz Claiborne “has never worked directly with Anthony Fashions . . . , we believe that a former licensee—Leslie Fay made dresses at this factory.”422 The letter clarifies:
A report prepared by two Salvadoran labor inspectors on January 7, 2003, however, suggests that Leslie Fay continued sourcing from Anthony Fashions through the end of 2002. According to the report, Anthony Fashions’ director, Jorge Paz, and head of human resources, Jermías Antonio Reyes, told labor inspectors that the labor suspensions initiated in December 2002 were “due to the fact that the Leslie Fay company, the only client, cancelled the production contract with [Anthony Fashions].”424 Leslie Fay remained a Liz Claiborne licensee until June 30, 2003.425 If Leslie Fay was still doing business with Anthony Fashions until shortly before the company closed, as the inspectors’ report suggests, and ordered Liz Claiborne dresses from the factory until that time, it is likely that Liz Claiborne dresses were produced between November 2001 and December 2002 under conditions that violated workers’ human rights and the company’s code of conduct.
To Human Rights Watch’s knowledge, five of these corporations have internal corporate codes of conduct or ethical standards or have ratified external workplace codes that set forth principles governing workers’ human rights in their supplier facilities: Kellwood, Kohl’s, Target, Dress Barn, and The Gap. The codes and standards vary, as do monitoring systems in place to oversee their implementation, yet all articulate a range of labor rights, discussed in relevant part below, with which supplier facilities are required to comply.
With the exception of Target’s “Standards of Vendor Engagement,” all the above-mentioned codes and standards reference workers’ right to freedom of association. As previously discussed, Human Rights Watch believes that all such codes should include this fundamental right. Three demand that the right be respected—the “Kellwood Code of Conduct,” “Kohl’s Ethical Standards and Responsibilities,” and “The Gap Code of Vendor Conduct.” One, Dress Barn’s “Standards of Engagement,” commits the corporation to “favor” those suppliers that respect this right. In a letter to Human Rights Watch, however, Dress Barn clarified that the company’s Global Human Rights Policy, “which applies to all factories with which we do business,” contains Policy Guidelines with “a questionnaire to be completed by the factory prior to the issuance of a Letter of Credit” that includes the question, “ Do workers have the right to have a union if they wish?”427
Each set of principles also addresses wage and benefit payments, with Kellwood and Dress Barn requiring suppliers to comply with local laws on the issue; The Gap demanding that “[w]orkers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater”; Kohl’s asserting that it “will only do business with suppliers whose workers . . . are fairly compensated”; and Target seeking suppliers that share its stated commitment to “the betterment of wage and benefit levels that address the basic needs of workers and their families.” As a catch-all provision, all five assert that they will only do business with suppliers that abide by the local laws of the countries in which they operate.428 Based on this provision alone, all should have verified that Tainan abided by local labor laws, including those governing freedom of association, and should have monitored compliance.
Nonetheless, as detailed above, between February 2001 and April 2002, Tainan allegedly violated workers’ right to freedom of association and local laws on payment of wages and worker suspension—reportedly failing, in early 2002, to comply with an order from the Labor Inspectorate to pay illegally suspended workers their wages due.
On June 20, 2003, Human Rights Watch faxed and mailed the aforementioned letters of inquiry to these five corporations, as well as Cherokee and Foot Locker. In addition to the standard questions articulated above, in the letters to these seven corporations that reportedly engaged in business with Tainan between February 2001 and April 2002, Human Rights Watch also inquired as to the companies’ roles, if any, in facilitating or supporting the negotiation of the November 2002 agreement between representatives of Tainan Enterprises Company and the Union of Textile Industry Workers in response to the April 2002 closure of Tainan El Salvador. Only The Gap and Dress Barn answered these additional questions, as noted above. At this writing, Cherokee, Target, Dress Barn, and The Gap have responded to the letters.
On June 25, Human Rights Watch received a two-sentence response from Cherokee, stating that “[we] support human rights” but “are a licensing company and do not manufacture or purchase any products or have any contractual relationship with any factories.” Cherokee neither confirmed nor denied that Tainan produced its label during the relevant time period.429 As explained above, Human Rights Watch believes that licensing companies also have a responsibility to exert their financial influence to ensure respect for workers’ human rights in local workplaces where goods, bearing their company names and earning them royalties, are produced.
Target responded to Human Rights Watch on July 8 and enclosed with its letter the company’s “Standards of Vendor Engagement” (Standards), which it states are used for the selection of Target vendors. Target confirmed that between February 2001 and April 2002, at Tainan, it had “one supplier that produced a limited amount of product for Target Corporation.” The company clarified, however, that it owns no manufacturing facilities, and, therefore, “must rely upon careful selection and education of our vendor base to meet these principles in the sourcing and production of the merchandise sold in our stores.” Target claims to investigate “any and all specific allegations that vendors are violating [the Standards]” and has established a “corporate compliance organization” with “auditors who visit factories where our merchandise is manufactured to measure compliance with our Standards.”430
In a July 21 letter to Human Rights Watch, The Gap confirmed that the company “performed its initial compliance assessment of the Tainan El Salvador facility in August 2000 and production took place between February 2001 to April of 2002.” According to the letter, during this period, over which the workers’ human rights violations described above occurred, the company’s senior vice-president of sourcing, vice-president of global compliance, and senior director of global compliance for the Americas were “actively involved in ongoing issues.” In addition, The Gap states that it “continued to monitor the facility on an ongoing basis” and “engaged an independent NGO to monitor the facility and the findings were made publicly available.”431 The public findings, however, are contained in a report along with the findings of monitoring visits to three other Salvadoran companies supplying The Gap in early 2002, each of which is identified only with a letter—A, B, C, or D.432 Human Rights Watch asked The Gap whether another monitoring report, specifically naming Tainan and clearly identifying factory-specific findings is available. It is not.433
Dress Barn confirmed in a July 17 letter to Human Rights Watch that “[i]n February, 2001 Dress Barn placed an order with Tainan El Salvador, S.A. de C.V. for 21,000 pairs of ladies shorts. That was the only purchase of goods purchased from Tainan el [sic] Salvador.” According to the letter, on October 24, 2000, prior to this one-time purchase, a Dress Barn agent asked Tainan’s production control manager whether “workers have the right to have a union if they wish,” to which he responded, “‘yes.’” In its letter, Dress Barn also noted that, prior to purchasing product for export, “its agents visit the factories with which it does business and meet with workers to verify that they receive all payments,” inspect the facilities, and complete an “assessment document.”434
402 Norms on the Responsibilities of Transnational Corporations and Other Business Enterprises with Regard to Human Rights, U.N. Doc. E/CN.4/Sub.2/2003/12/Rev.2 (2003), sec. A(1). The U.N. Norms were approved unanimously by the U.N. Sub-Commission on the Promotion and Protection of Human Rights on August 13, 2003. They are the most authoritative guide to corporate social responsibility and provide the most comprehensive set of international human rights standards intended to regulate business conduct. The U.N. Norms restate or interpret legally binding and non-binding international instruments adopted by international bodies, such as the ILO and the Organization for Economic Cooperation and Development (OECD), and reflect principles already embodied in many corporate codes of conduct. In the upcoming years, other superior U.N. bodies are expected to adopt and recommend implementation of the U.N. Norms. See Responsibilities of transnational corporations and other business enterprises with regard to human rights, U.N. Sub-Commission on the Promotion and Protection of Human Rights, resolution 2003/16, U.N. Doc. E/CN.4/Sub.2/2003/L.11 at 52 (2003).
403 U.N. Norms, sec. A(1).
404 United Nations, The Global Compact, January 31, 1999, http://www.unglobalcompact.org/gc/unweb.nsf/content/thenine.htm (retrieved August 1, 2001). The Global Compact is not a regulatory instrument nor a code of conduct. Instead, it identifies nine “universal principles,” including freedom of association, and asks companies to act on these principles in their own corporate domains, become public advocates for the principles, and participate in the activities of the Global Compact, including thematic dialogues. Participating companies are asked to post, at least once a year, on the Global Compact website concrete steps they have taken to act on any of the nine principles and the lessons they learned from doing so. Global Compact Office, The Global Compact: What it is, January 17, 2001,http://www.unglobalcompact.org/gc/unweb.nsf/content/whatitis.htm (retrieved August 23, 2001).
405 The Organization for Economic Cooperation and Development Guidelines for Multinational Enterprises: Text, Commentary and Clarifications, DAFFE/IME/WPG(2000)15/FINAL, October 31, 2001. The OECD Guidelines are “recommendations addressed by governments to multinational enterprises” that “provide voluntary principles and standards for responsible business conduct.” Ibid., Preface, para. 1. These voluntary principles include “the right of . . . employees to be represented by trade unions and other bona fide representatives.” Ibid., Employment and Industrial Relations, para. 1(a).
406 Commentary on the Norms on the Responsibilities of Transnational Corporations and Other Business Enterprises with Regard to Human Rights, U.N. Doc./E/CN.4/Sub.2/2003/38/Rev.2 (2003), sec. A(1)(b).
407 The OECD Guidelines state that enterprises should “[e]ncourage, where practicable, business partners, including suppliers and sub-contractors, to apply principles of corporate conduct compatible with the Guidelines.” OECD Guidelines, General Policies, para. 10.
408 The U.N. Norms state, “Each transnational corporation or other business enterprise shall apply and incorporate these Norms in their contracts or other arrangements and dealings with contractors, subcontractors, suppliers, licensees, distributors, or natural or other legal persons that enter into any agreement with the transnational corporation or business enterprise in order to ensure respect for and implementation of the Norms.” The Commentary on the U.N. Norms explains further that “[t]ransnational corporations and other business enterprises shall ensure that they only do business with (including purchasing from and selling to) contractors, subcontractors, suppliers, licensees, distributors, and natural or other legal persons that follow these or substantially similar Norms.” U.N. Norms, sec. H(15); Commentary on the U.N. Norms, sec. H(15)(c).
409 E-mail message from Gilberto García, director, CEAL, to Human Rights Watch, July 3, 2003.
410 Letter from Josue Alvarado, president, Rio Grade Food Products, Inc., to Human Rights Watch, July 11, 2003.
411 Commentary on the U.N. Norms, sec. A(1)(b).
412 Elena Chávez Ramírez, labor inspector, inspection report, October 23, 2001; Dorys Inglés, “Plisar la tela es labor de Nino”; “Protesta sindical por cierre de maquila”[“Union protest for maquila closure”], El Diario de Hoy, n.d.; e-mail messages from Elias Misael Caceres, secretary of organizing and statistics, FEASIES, to Human Rights Watch, March 1 and May 6, 2003.
413 Kmart Holding Corporation, 2003 Code of Business Conduct, February 2003, http://www.kmartcorp.com/corp/story/general/code_of_conduct.stm (retrieved July 9, 2003).
414 JC Penney Company, Inc., The JC Penney Supplier Legal Compliance Program, n.d.; Kellwood Company, Kellwood Company Code of Conduct,n.d., http://www.kellwood.com/corporate/policies/code_of_conduct.asp (retrieved May 13, 2003); Kellwood Company, Highlights of Kellwood Contractor Compliance Program, n.d.,http://www.kellwood.com/corporate/policies/code_of_conduct.asp (retrieved May 13, 2003);Wal-Mart Stores, Inc., Standards for Suppliers, n.d., http://www.walmartstores.com/wmstore/wmstores/Mainsupplier.jsp (retrieved July 9, 2003); Wal-Mart Stores, Inc., 2001 Report on Vendor Standards: Report on Supplier Standards, n.d., http://www.walmartstores.com/wmstore/wmstores/Mainsupplier.jsp (retrieved July 9, 2003).
415 JC Penney Company, Inc., The JC Penney Supplier Legal Compliance Program.
416 Letter from Peter M. McGrath, president, JC Penney Purchasing Corporation, to Human Right Watch, July 9, 2003.
417 Inspection report from Ada Cecilia Lazo Gutiérrez, supervisor of labor inspectors, Department of Industry and Business Inspection, and Jairo Felipe Cruz Damas, labor inspector, to Edmundo Alfredo Castillo, head, Department of Industry and Business Inspection, January 7, 2003; CEAL, Trabajadores textiles sin protección del Estado [Textile workers without protection of the State], n.d., http://www.rel-uita.org/maquilas/trabajadores_textile.htm (retrieved February 25, 2003).
418 Letter from Daryl Brown, vice president of human rights compliance, Liz Claiborne, Inc., to Human Rights Watch, July 3, 2003. The Fair Labor Association is self-described as a “non-profit organization combining the efforts of industry, non-governmental organizations (NGOs), colleges and universities to promote adherence to international labor standards and improve working conditions worldwide.” The FLA was founded “as an independent monitoring system that holds its participating companies accountable for the conditions under which their products are produced.” FLA, Welcome, n.d., http://www.fairlabor.org (retrieved July 9, 2003).
419 FLA, Participating Companies and Licensees, n.d., http://www.fairlabor.org/all/companies/index.html (retrieved August 19, 2003); see also Human Rights Watch telephone interview, Auret van Heerden, executive director, FLA, August 19, 2003.
420 Liz Claiborne, Inc., Standards of Engagement, n.d.
421 Ibid.; Liz Claiborne, Inc., Our Policies to Promote a Fair and Just Workplace, n.d., http://www.lizclaiborne.com/lizinc/rights/conduct.asp (retrieved May 13, 2003).
422 Letter from Daryl Brown, vice president of human rights compliance, Liz Claiborne, Inc., to Human Rights Watch, July 3, 2003.
424 Inspection report from Ada Cecilia Lazo Gutiérrez, supervisor of labor inspectors, Department of Industry and Business Inspection, and Jairo Felipe Cruz Damas, labor inspector, to Edmundo Alfredo Castillo, head, Department of Industry and Business Inspection, January 7, 2003.
425 Liz Claiborne, Inc., Liz Claiborne Inc. Announces Licensing Agreement with Kellwood’s Halmode Division to Manufacture Women’s Dresses and Suits, March 19, 2003, http://www.corporate-ir.net/ireye/ir_site.zhtml?ticker=LIZ&script=460&layout=0&item_id=392664 (retrieved October 2, 2003).
426 Table of Tainan shipping records, November 30, 1999-March 20, 2002; letter from Deanna Robinson, senior director of global compliance, The Gap, Inc., to Stephen Coats, director, U.S. Labor Education in the Americas Project, April 30, 2002; e-mail message from Gilberto García, director, CEAL, to civil society representatives, February 27, 2002.
427 Letter from Christopher J. McDonald, vice president and corporate counsel, Dress Barn, Inc., to Human Rights Watch, July 17, 2003.
428 The Gap, Inc., The Gap Code of Vendor Conduct, n.d., http://www.itcilo.it/english/actrav/telearn/global/ilo/code/gap.htm (retrieved July 9, 2003);Kellwood Company, Kellwood Company Code of Conduct; Kellwood Company, Highlights of Kellwood Contractor Compliance Program; Kohl’s Corporation, Kohl’s Ethical Standards and Responsibilities, n.d., http://www.kohlscorporation.com/InvestorRelations/pdfs/CodeOfEthics022003.pdf (retrieved July 8, 2003); Dress Barn, Inc., The Dress Barn, Inc. and its Subsidiaries Standards of Engagement, n.d., http://www.itcilo.it/english/actrav/telearn/global/ilo/code/dressbar.htm (retrieved July 3, 2003); National Federation of Retailers, Statement of Principles on Supplier Legal Compliance, n.d., http://www.sweatshops-retail.org/nrf%20website/nrf.htm (retrieved July 8, 2003); Target Corporation, Standards of Vendor Engagement, n.d., http://www.targetcorp.com/targetcorp_group/about/engagement.jhtml (retrieved July 8, 2003).
429 Letter from Howard Siegel, president, The Cherokee Group, to Human Rights Watch, June 25, 2003.
430 Letter from Erica C. Street, president, Target Brands, Inc., to Human Rights Watch, July 8, 2003.
431 Letter from Deanna Robinson, senior director of global compliance, The Gap, Inc., to Human Rights Watch, July 21, 2003.
432 Independent Monitoring Group of El Salvador, Verification of compliance with Salvadoran labor law and the Gap Inc. Code of Conduct in four companies in El Salvador: Report corresponding to the third set of visits held between March and April 2002, May 2002.
433 Human Rights Watch telephone interview, Deanna Robinson, senior director of global compliance, The Gap, Inc., August 27, 2003.
434 Letter from Christopher J. McDonald, vice president and corporate counsel, Dress Barn, Inc., to Human Rights Watch, July 17, 2003.