Transparentem’s new report flags forced labour risks in Taiwan’s textile industry. The investigation primarily focuses on apparel companies and is backed by strong evidence, including third-party audits and worker testimonies. However, Transparentem maintains that brands must address labour issues at suppliers’ suppliers, even when they do not supply materials for their products – a position that is not aligned with the OECD Guidelines and UNGPs.
- Transparentem’s report, Following the Thread – Labor Abuses in Taiwan’s Textile Industry, published in February 2025, focuses on forced labour abuse of migrant workers in the Taiwanese textile industry. The report presents strong evidence of forced labour risks in Taiwan’s textile industry including high recruitment fees, coercive employment practices, and passport confiscation. Transparentem is a US-based NGO that investigates environmental and human rights abuses in global supply chains.
- Findings in the report were based on interviews conducted in 2021-2023 with more than 90 migrant workers from Vietnam, the Philippines, Indonesia, and Thailand across 13 factories operated by nine suppliers. Interviews were conducted off-site by Transparentem investigators, sometimes in collaboration with local labour rights groups. Findings were triangulated against information from brand-commissioned audits conducted by Dignity in Work for All (DIWA) in April 2024 and Verité in July-August 2024. Findings of ILO forced labour indicators were identified in all 13 factories. We have provided a breakdown of the key findings per ILO forced labour indicator below.
- Transparentem recommended that brands take measures to ensure remedy is provided to the impacted workers in their supply chain and to prevent recruitment fees and other forced labour indicators in the future, and this is aligned with due diligence standards. However, we do have a fundamental issue with Transparentem’s position on where brand responsibility lies and ends in relation to a brand’s suppliers’ suppliers, when these do not feed into a brand’s supply chain. We’ve provided further analysis on this below.
Buyer-supplier responsibility for remediation
- Transparentem maintained that brands were responsible for addressing forced labour issues in the Taiwanese suppliers, even where those suppliers were not providing materials and fabrics that were used in the brands’ products.
- For example, according to Transparetem’s report, in the case of Levi Strauss and Co (LSCO), five suppliers from Taiwan supplied fabric to an LSCO tier 1 manufacturer in Vietnam. The Vietnamese manufacturer used fabric from China for LSCO products, and not the fabric from the Taiwanese suppliers. LSCO declined to participate in remediation efforts at the Taiwanese suppliers due to this.
- Despite this, Transparentem’s position was that “Best practice dictates that a buyer should address reports of forced labor that occur at its supplier’s supplier, even if the buyer believes the materials manufactured by the supplier’s supplier do not enter the buyer’s products.” It stated “abuses beyond the first tier will only be prevented if buyers take responsibility for abuses in all suppliers to their tier one suppliers.”
- This is not in line with international due diligence guidance. Under the OECD due diligence guidance, a company, in this example LSCO, would not be required to address the impacts in the five Taiwanese suppliers, as they are not part of its supply chain. LSCO would be expected to verify that fabrics were indeed supplied by its Chinese fabric supplier, but beyond this, would not hold a responsibility for impacts at the Taiwanese suppliers. The OECD Secretariat has previously clarified this point in a 2014 publication.
- Transparentem and other civil society organisations have disagreed, stating that this approach hampers collective action on due diligence, and that prudent due diligence should extend to suppliers’ suppliers, even when these suppliers are not part of the brand’s supply chain, particularly where transparency of material suppliers is limited.
- At a broader industry level, the American Apparel and Footwear Association (AAFA) and Fair Labor Association (FLA) have launched an initiative, as part of the Commitment to Responsible Recruitment, to improve conditions for migrant workers in Taiwan. The initiative, supported by 50+ companies, their suppliers, and the Taiwan Textile Federation, aims to eliminate recruitment fees, ensure workers retain control of their travel documents, enhance supply chain transparency, and promote systemic labour reforms.
Findings
- A summary of key findings by ILO indicator is below:
ILO INDICATOR | FINDING |
Abuse of Vulnerability (Recruitment Fees) | Migrant workers all reported paying recruitment fees, sometimes up to $6,000 to agents in their home countries, creating debt bondage. Some workers paid additional deposits ($500-$1,000) to prevent them from leaving before contract completion. Although some suppliers had no-fee policies in place, interviewed workers reported they had not been reimbursed for fees that were paid prior to the introduction of the policies. |
Debt Bondage | Workers paid $50-$60 per month in “service fees” to Taiwanese labour brokers, adding up to over two months’ wages per contract. These fees trapped workers in exploitative conditions, as they could not afford to leave. |
Coercion & Menace of Penalty | Workers at some sites were blocked from leaving mid-contract. Supervisors and brokers pressured workers to renew contracts or threatened deportation. |
Threats of Reprisal | Workers at some sites reported threats from supervisors and brokers. Infractions such as tardiness or phone use resulted in pay deductions, forced cleaning duties, or repatriation. |
Control over Workers | Some suppliers held passports of migrant workers. This prevented workers from leaving employment freely. |
Isolation | Workers at some factories faced nighttime curfews and restrictions on leaving factory premises. |
Involuntary Work through Long Hours | Overtime at some factories exceeded legal overtime limits. Some pay slips showed illegal overtime. |