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Sandler, Travis & Rosenberg, P.A. > Labor & Corporate Social Responsibility >

Codes of Conduct and Compliance


When sourcing products from abroad, it is no longer sufficient to rely on foreign authorities to enforce labor laws. If a problem in a factory is missed or, as is often the case, domestic labor authorities are understaffed and under-trained, a brand may become associated with unacceptable working conditions. That is why many companies have adopted codes of conduct on the working conditions in the factories producing for them.

There are legal compliance requirements for child labor and forced labor implemented by U.S. Customs that can affect the ability to enter merchandise into the United States. In addition, there are legal requirements with regard to selling any product to the Federal Government where forced child labor may have been used.

A viable compliance program must support a code of conduct. Companies follow many different approaches towards compliance. Determining the best compliance approach requires asking the right questions. What is the chain of production? Who is responsible for implementation of a code of conduct? Are people adequately trained to minimize the risks of violations? What type of monitoring is appropriate? What is to be done if a problem is found? What is the best strategy to remedy violations?

ST&R helps identify strategies related to code of conduct and compliance issues.