Working conditions in the supply chain and environmental concerns may have been the primary CSR hotspots for the clothing sector in recent years, but this year has brought into clear relief the level of public concern over the commercialisation and sexualisation of children.

Such has been the tenor of campaigner and public sentiment in the UK over the commercialisation and sexualisation of children that the incoming government instituted a wide-ranging review of the issue late last year.

The review, conducted by Reg Bailey, chief executive of the Mothers Union, was published in June. Bailey's report, 'Letting Children be Children,' looked at cultural influences on children and children as consumers but particularly significant for the clothing sector was its examination of clothing, products and services for children.

The report stated that the marketing of "sexualised and gender-stereotyped clothing, products and services" for children were "the biggest areas of concern for parents and many non-commercial organisations contributing to the review."

In the industry's defence, the report pointed out that the issues were "rarely clear-cut, with a fine balance on a number of points - taste, preference, choice, affordability, fashion and gender preferences."

It also said that retailers were aware of the issues and sensitivities and were responding. But the review called for clothes to be "explicitly and systematically family-friendly, from design and buying through to display and marketing."

Such a review is not unprecedented. In 2008, the Australian government conducted an inquiry into similar issues following the publication in 2006 of a hard-hitting report by the Australia Institute entitled Corporate Paedophilia, though campaigners have bemoaned a lack of action on the part of government and industry since then.

In contrast, the UK retail industry has responded promptly to the concerns raised in the report.

Concerted industry action
As the report was published, the British Retail Consortium (BRC) unveiled a set of guidelines governing the design, commissioning and marketing of clothing ranges for children under 12 years old.

The recommendation that a retail code of good practice be set up was the sole recommendation in the report relating to the sale of inappropriate clothing, products or services. Therefore, the early publication of the BRC guidelines must be viewed as positive for the industry's corporate responsibility effort.

While some sceptics may see the immediate publication of the guidelines as almost too slick, possibly smacking of calculated media management, this would be harsh. Had the guidelines not been in place, those same sceptics may have been demanding why.

Jane Bevis, director of public affairs at the BRC, says the fact that its guidelines were published so quickly reflects how the industry had engaged with Bailey during the review. "We had been working very closely with Reg Bailey and his team," Bevis explains, adding that the BRC had been able to demonstrate that there was "a lot of good practice" already in evidence among retailers.

Bevis says it was during these conversations that the idea of pulling the best practice already being observed by companies together into one set of guidelines had emerged. In addition, the BRC also engaged with the influential grassroots campaign group, Mumsnet, which has been a key participant in this debate, not least through its own 'Let Girls be Girls' campaign. "It was a really collaborative process," says Bevis.

The nine original signatories to the code were Argos, Debenhams, George (Asda), John Lewis, M&S, Next, Peacocks, Sainsbury's and Tesco, which were subsequently joined by Pumpkin Patch and TK Maxx.

The guidelines detail specific requirements on the styling, sizing and labelling and marketing of children's clothes.

In particular, they cover some key areas of concern, such as the use only of age-appropriate slogans and imagery, necklines, skirt lengths, and the design and decoration of underwear, particularly first bras. The guidelines specify that first bras should be designed "to provide comfort, modesty and support but not enhancement".

Potential weaknesses
The BRC could not put a figure on what percentage of the UK children's clothing market was represented by signatories to the guidelines. Among the major retailers not yet signed up are Top Shop and Primark.

Bevis remains hopeful that others will join in due course. "It's fantastic we've got 11 retailers signed up now. We still have aspirations to bring other people on board so we are talking to a number of other retailers who are positive in principle but are working out how it fits with their business at the moment."

As is often the case with such initiatives, the degree to which the BRC can bring other companies into line will be critical. Bevis says the retailers that worked on the guidance in general had a "good track record on making the right decisions". But this could suggest that these companies may not have been the primary problem.

Indeed, the Bailey report states that the BRC "should continue its work in this area as a matter of urgency and encourage non-BRC members to sign up to its code."

Another possible criticism the BRC may face is that it has chosen to focus on clothes marketed for children under 12 years, whereas the Bailey review classified children as under 16. Bevis explains that the BRC did not dispute that there were issues to address in the 12-16 age bracket but it had taken this decision because of the way the retailers segment their businesses, with different departments for children's and teen fashion.

"It's not that we are saying we only need to worry about the under-12s; it's just that fitted with the way most retail businesses are set up." Bevis adds that there will be "slightly different concerns" in the older age group and that the guidelines can be taken as "a starting point" for everyone working in this area.

Some will suggest the way companies organise their buying departments was not an insurmountable problem. However, in focusing on under-12s the BRC is clearly concentrating on what appears to be the primary area of concern among the public, and this arguably makes good sense from a corporate responsibility standpoint.

Where perhaps the BRC response is more exposed to criticism is in regard to monitoring and complaints. In fairness, the stipulation in the Bailey report was for a code of practice. Requirements regarding monitoring and compliance procedures were not specified in the review.

"We have not got a separate monitoring process from the usual customer complaints processes that those retailers have in place," Bevis says. "Clearly though people know where to find us. We don't have a consumer-facing role; we're a trade association. But if something was brought to our attention we would share that with the retailer concerned."

However, she adds that it is a "very public commitment" that the companies have made to which customers would be able "to hold them to account".

Campaigner reaction
A system which essentially just waits for complaints is a very different model from an ethical code which is backed up by a monitoring process, even more so if there is no central complaints procedure at all, and this is simply handled by the companies concerned. It also offers far less precision in measuring progress.

Indeed, the lack of a formal complaints or monitoring procedure was one of the few negative observations made by Claude Knights, director of children's charity Kidscape. "This is absolutely a concern. How do you decide after 18 months that it is working or it is not working?" she asks.

Monitoring was also an issue raised by the National Society for the Prevention of Cruelty to Children (NSPCC). "We're pleased that the BRC has put in place good practice guidance for stores selling children's clothing," an NSPCC spokesperson told just-style. "However, the code will only be effective if those retailers who sign up are monitored to ensure they stick to it."

Knights is also concerned about the fact that the BRC guidelines only cover under-12s, but on the whole sees the BRC guidelines as a positive move. Interestingly, like Bevis she alluded to the fact that the guidelines reflect a lot of good practice that these retailers had already put in place, sometimes in response to previous criticism.

However, by signing up to the code, Knights says the retailers have made an even more public commitment and raised the reputational stakes. "I anticipate any breach by one of the 11 would then make headline news." She believes having one set of standards to which they have all committed will improve matters. "They'll be watching each other and that gives strength to the whole issue."

The BRC guidelines also received positive feedback from Mumsnet. Co-founder Carrie Longton said: "It's great that the industry as a whole, through the British Retail Consortium, has recognised its responsibility and drafted its own guidelines to encourage more responsibility up and down the high street."

Looking ahead
The fact that campaigners have generally been positive about the BRC move is undoubtedly a good sign. However, there is a strong feeling among NGOs that the proof of the pudding will be in the eating. They are sure to be scrutinising the effectiveness of the guidelines very closely.

Bevis says the BRC will review how its guidelines are working in a year's time "not just in light of comments we receive from parents and other stakeholders but also because the world of fashion keeps moving on and something that we've not encountered yet will suddenly raise itself as an issue."

Given that the guidelines are to be voluntary and some notable companies are yet to sign up, the jury would appear to be out on how much impact the BRC action will have both in helping to allay concerns over the commercialisation and sexualisation of children and in deflecting criticism away from the clothing sector.

So the 18-month review stipulated in the Bailey report will be a critical juncture both for campaigners and politicians looking for improvement, and for the industry's hopes of showing that it can be part of the solution.