Canadian corporate ethics watchdog CORE has published its Initial Assessment report after complaints were filed by a coalition of 28 civil society organisations against Ralph Lauren Canada LP (Ralph Lauren Canada) in June last year.

In the complaint, Ralph Lauren is accused of having operations or supply chains in the northeastern Xinjiang region of China, which allegedly engages in forced labour practices.

What is the complaint about?

CORE’s Ralph Lauren Canada Initial Assessment report details the complainants’ allegations that Ralph Lauren Canada has supply relationships with Chinese companies that are currently using or benefiting from the use of Uyghur forced labour.

The complaint alleges that Ralph Lauren has not addressed the issue of forced labour in the early stages of its supply chain.

The complainants refer to the following data related to the “pervasive” use of Uyghur forced labour in the cotton fields and the prevalence of Xinjiang cotton in global garment production:

  • One in five cotton garments in the global apparel market is said to be tainted by Uyghur forced labour
  • Xinjiang (East Turkestan) produces about 19% of the world’s cotton 
  • By 2019, Xinjiang hosted at least 3,500 cotton, textile and garment factories in which Uyghurs were used as forced labourers
  • Approximately two million Uyghur labourers were forcibly placed in state-sponsored enforced labour transfer programmes across nine Chinese provinces
  • China’s export strategy obscures Xinjiang cotton’s origin by transporting cotton, cotton-based yarn and textiles, and semi-finished garments to 53 intermediary manufacturers in third countries which in turn supply to 103 global retailers or brands.

The complainants claim that sourcing from anywhere in China “inevitably” means the presence of Uyghur forced labour in the supply chain.

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In addition to this, the complaint asserts that Ralph Lauren has not addressed the issue of forced labour inputs at early stages of the supply chain.

CORE’s response: Initial Assessment Report

CORE’s report highlights that it is not clear whether the complainants’ mention of “Ralph Lauren” refers to the US parent company Ralph Lauren Corporation (RLC), RLCLP, or to Ralph Lauren as an international brand and retailer, although the complaint specifically alleges that RLCLP uses or benefits from forced labour in its supply chain. 

CORE says that on the basis of the information provided by the complainants, it has decided that the complaint was admissible pursuant to section 6.1 of the Operating Procedures. This means that CORE decided there was sufficient information in the complaint to form a reasonable belief that its three admissibility criteria were met.

During its initial assessment, CORE met with connected parties to learn about their views regarding the allegations, respond to their concerns and questions, and seek their agreement to participate in early resolution or mediation.

However, if the parties do not agree to participate in a consensual dispute resolution process, CORE will decide how to deal with the complaint including whether to begin an investigation.

The Canadian watchdog clarifies that, as outlined in the Initial Assessment report, RLC, responding on behalf of Ralph Lauren Canada, has stated that CORE does not have jurisdiction as Ralph Lauren Canada is a subsidiary and is therefore not responsible for decision-making related to the supply chain concerns highlighted.

In addition, RLC says all operations are overseen by the company’s US headquarters.

Sheri Meyerhoffer, Ombudsperson at CORE, says: “Each complaint is evaluated thoroughly and efficiently. I have decided that the Ralph Lauren complaint warrants an investigation.”

Therefore, as the next plausible step CORE says it will launch an investigation into the complaint regarding Ralph Lauren Canada.

Ralph Lauren did not respond to Just Style’s request for a comment at the time of going to press.

In the last few years, several fashion and apparel brands have been accused of using forced labour in their supply chains either directly or indirectly. This led to a bipartisan group of lawmakers in the US urging a tougher crackdown on goods imported from China and produced by means of forced labour under the Uyghur Forced Labor Prevention Act (UFLPA).

In May, apparel giants including Nike, Adidas, Shein and Temu were collared over Uyghur forced labour concerns in their global supply chains by US senators.

Rep Mike Gallagher and Rep Raja Krishnamoorthi chairman and ranking member of the Select Committee on the Chinese Communist Party penned a letter stating, concerns remain about the companies’ “alleged continued use of Uyghur forced labour in their supply chains despite the 2021 Uyghur Forced Labor Prevention Act (UFLPA) which outlawed this practice”.

From 2024, Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act will require brands, retailers, and importers to identify and prevent human rights violations within their supplier networks.