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Examining human rights protections for Syrian refugees in Turkish garment supply chains
It is estimated that of the 3.4 million Syrian refugees registered in Turkey, 650,000 have found work in the manufacturing sector, which includes the thriving leather-textile-garment industry. Most of them, however, are informally employed in the sector. In January 2016, the Turkish government introduced work permits to enable Syrian refugees to gain formal employment and work under the same rights and protections as their Turkish counterparts.
However, very few work permits have been applied for and issued in the industry. By the end of 2016, 13,298 work permits had been issued to Syrian refugees, rising to 20,600 in 2017, leaving the overwhelming majority in informal employment and vulnerable to exploitation in the garment sector, including in the factories producing for international brands.
This post draws on the latest findings from a longitudinal and comparative research project led by the Business and Human Rights Resource Centre that explores what leading European garment brands have been doing to prevent and remedy risks for Syrian refugees and ensure that they can access decent employment in their Turkish supply chains, as well as a multi-stakeholder roundtable held in Oxford to discuss the findings.
In the last 30 years, the Turkish leather-garment-textile industry has developed a fast, high-quality and relatively low-cost mode of production enabling Turkey to become the 5th exporter of textiles in the world in 2016. This rapid development has been possible thanks to a dense, vertical and complex network of small factories and workshops that bigger manufacturers often subcontract to complete specialised tasks and meet the high volume and fast turnover orders of global garment brands retailing in Europe and the US. This competitive advantage is also facilitated by a huge labour force constituted of 1 million formal workers and an equivalent number of informal workers. Working in the informal economy means being undeclared and therefore more vulnerable to abuses such as exploitative work conditions, low wages, and long hours, while they cannot join trade unions and organise, and thus have little recourse to protection and remedy.
The problems of informality and exploitation in the Turkish garment industry are not just problems for Syrian refugees. However, the media focus on the situation of Syrian refugees has shone a light on labour abuses in the sector and tackling the risk of exploitation of Syrian refugees could be a first step towards addressing this broader issue in Turkey.
To explore this issues, between July and September 2017 we conducted fieldwork and interviews with local Turkish stakeholders (business associations, trade unions, the UNDP, NGOs, academics and the Ministry of Economy), and analysed 30 responses to a survey of 37 European high-street retail labels, including among others: Adidas, Aldi, ASOS, C&A, Debenhams, Esprit, GAP, H&M, HUGO BOSS, Inditex (Zara Group), Marks & Spencer, Mothercare, New Look, NEXT, Nike, Primark, Tesco, White Stuff, Burberry, Lidl, and Sainsbury’s.
The research also included a multi-stakeholder roundtable at St Edmund Hall, Oxford University, to discuss the findings, and identify core issues and solutions that can be addressed in the short to medium term, including: purchasing practice and subcontracting; transparency and the informal sector; the role of government and international institutions; and shared responsibility and remedy. The findings are contained in the briefing ‘What’s changed for Syrian refugees in Turkish garment supply chains? A survey & analysis of company action to address exploitation & abuse’, the project’s third report.
Our conversations with Turkish industry stakeholders in 2017 show a greater level and willingness to engage with the projects, conferences, and training that have been developed to inform stakeholders about the work permit legislation, labour rights and skills training/job matching for refugees by international brands and Multi-stakeholders Initiatives (MSIs, such as the Fair Labour Association (FLA); Ethical Trading Initiative (ETI) and Amphori – formerly Foreign Trade Association) since work permits for Syrian refugees became a legal requirement and the process of application was simplified. As 98% of refugees work informally without work permits in the industry, such programmes and work permit legislation pave the way for legal employment for refugees.
Furthermore, the survey also shows increased positive action and commitment from brands to provide decent work for Syrian and Turkish workers alike since late 2015. Some garment brands that conduct human rights or modern slavery risk assessments as part of their human rights due diligence and reporting under the UK Modern Slavery Act have identified exploitation of Syrian refugees in Turkey – and other garment-producing host countries around Syria – as a salient risk. The majority of international brands surveyed have adopted a specific policy to guide their suppliers on the employment of Syrian refugees in Turkey and prohibit discrimination and exploitation. We also found new auditing approaches, including several brands that have expanded their local auditing teams and conduct unannounced and night audits in supplier factories in Tiers 2 and 3, where exploitation is widespread. Some brands have also developed CSR programmes to provide humanitarian support to Syrian refugees and/or encourage their employment in their supply chains.
Nevertheless, very few brands report having identified Syrian refugees in their supply chains and, as noted, the number of applications for work permits remains extremely low. These findings are surprising as they do not align with the high number of Syrian refugees estimated to be informally employed in the industry.
A major challenge in Turkey is therefore to find ways to support the legalisation/formalisation of the refugee workforce and encourage employers to apply for work permits on behalf of their refugee employees. On the one hand, this requires overcoming political, legal and procedural barriers that still hamper access to work permits. MSIs’ engagement with and lobbying of relevant government authorities and international institutions can go some way towards this. On the other hand, it also demands that brands provide real incentives to their suppliers who are reluctant to (formally) employ Syrian refugees because of the higher labour cost that comes with formalisation and the difficulty of finding employees with the required skills.
The reluctance of employers to formally hire Syrian refugees, however, reflects a broader issue in the industry. According to Turkish employer associations, international brands play an important role in reproducing the industry’s structural problems, including informal labour and child labour, and associated issues such as the low level of application for work permits for Syrian refugees. Specifically, they criticise the purchasing practices of international brands. One representative explained that ‘if brands want Turkish suppliers to employ refugees and pay the living wage to all employees, brands should take this into account in their purchasing prices. If suppliers don’t earn their living wage, how can they pay the living wage to their employees?’
This highlights underlying contradictions between the expectations set out by sustainability-CSR departments and the practices of buying departments: the former want suppliers to invest in social compliance and support the employment of disadvantaged groups, while the latter insists on lowering prices and production costs. A number of brands surveyed have started to address this issue by joining the ACT initiative on living wages and are going through an assessment of the impact of their purchasing practices on living wages.
As discussed in the report and at the roundtable, addressing purchasing practices would be a first step toward profound changes in the industry’s business model. The current model of fast, cheap and volume fashion leads to precarious and exploitative labour conditions by driving prices down and shifting responsibility and accountability down the supply chain. Fundamentally, it would require a change in the relationship between brands, their suppliers and other industry stakeholders to give more voice to workers and their associations as well as suppliers. Human rights due diligence by brands and collaborative and collective approaches involving these various stakeholders could assist in setting fair prices, driving transparency about when and why there is a need for subcontracting and about risks and ethical issues in factories, and ensuring that the rights of all workers are protected.
These processes are critical at a time when private investors and companies, including garment brands, are increasingly incentivised and relied upon to invest and create jobs in refugee hosting countries as part of international migration management programmes geared to keeping displaced people near their countries of origin.
This blog is based on the findings of the research for and multi-stakeholder roundtable event organised by the Business & Human Rights Resource Centre between July and October 2017. More details about these can be found here.
 An estimated 98% of refugees in the textile/garment/leather/shoe industries work informally. Erol, Ertan; Akyol, Ayla Ezgi; Salman, Cema et.al. (2017) Suriyeli Sığınmacıların Türkiye’de Emek Piyasasına Dahil Olma Süreçleri ve Etkileri: İstanbul Tekstil Sektörü Örneği, Birleşik Metal İş Yayınları, Haziran 2017.
 Dogan, N. and Palamutcu, S. (2013) ‘Tekstil ve Hazır Giyim Sektöründe Nitelikli İş Gücü Yetiştirme Programları’, 2023e 10 kala 3. Sanayi Surasi, TC Bilim, Sanayi ve Teknoloji Bakanligi.
Informal employment accounts for 33% of the Turkish economy; this percentage varies and is higher in the textile and construction sectors.
 Transnational corporations rank their suppliers as Tier 1, 2 and 3 based on the commercial distance in the relationship between the corporation and its suppliers. Tier 1 companies are direct suppliers of corporations whereas, in general, Tier 2 and 3 companies are suppliers to tier 1 suppliers.
 ACT (Action, Collaboration, Transformation) is an agreement between global brands and retailers and trade unions to transform the garment and textile industry and achieve living wages for workers through industry-wide collective bargaining linked to purchasing practices.
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