The Netherlands Authority for Consumers and Markets has agreed to investigate commercial claims of “social washing” – that is, the use of research and certification to create false perceptions of ethical production – after a new analysis of three Dutch public groups found that fashion brands often make very broad claims that do not always correspond to the truth.
Although clothing companies often make promises such as “no forced labor,” “safe working environment” and “fair wages,” they often rely on business surveys that are not always reliable and can be fraudulent, according to the Center for Research on Large International Organizations (better known by its Dutch acronym SOMO), Consumentenbond and The Clean Clothes.
After reviewing advertisements and statements from many clothing and footwear retailers about working conditions, the organizations found that many rely on third-party audits as a “source of assurance” that their supply chains are free of human rights abuses. But the inspections are “checks” on factory operating conditions that only take a certain amount of time, they said. Years of research by labor activists also show that crime often falls through the cracks, whether it’s intentional or not.
“This is because clothing brands and companies in general are the ones who dictate the audit, which creates a false incentive for the accounting company not to be too bad, so that they will be hired again in the future,” SOMO, Consumentenbond and CCC wrote. “Evaluations are announced in advance, and firms often do their best to portray the situation in a positive light, for example, pressuring their employees to lie about wages and working hours.”
Safety inspectors, for example, failed to spot structural problems at the Rana Plaza building in Bangladesh before it collapsed months later, killing more than 1,130 garment workers and injuring or maiming thousands more. Both Tesco and the inspector it hired have been sued by migrant workers at the supplier in Thailand for negligence and “unfair profiteering” due to unprecedented forced working conditions. A major glove manufacturer in Malaysia kept workers in conditions that met the International Labor Organization’s standards for post-trafficking—including debt bondage, document retention and excessive overtime—despite passing public inspections without issue.
In other words, the report said, there is “good reason to be skeptical” when the brand says the audit gave the factory a clean bill of health.
SOMO, Consumentenbond and CCC presented their findings, including one involving WE Fashion, a Dutch fashion chain that said its factories were following the goal of “no forced labour” in its 2024 sustainability report. Its website also stated that “all industries are audited” and that the seller “guarantees that they comply [the company’s] Code of Conduct.”
A 2023 investigation by the New York nonprofit Transparentem, however, discovered evidence of forced labor at the WE Fashion retailer in Mauritius, where workers were afraid to speak to inspectors about issues such as illegal hiring rates, labor fraud and abusive living conditions. Because many were immigrants from countries like Bangladesh and India, they faced threats of deportation or losing money for making mistakes, getting sick or trying to organize.
WE Fashion said in a statement that it takes Transparentem’s allegations seriously, ordering an independent investigation with other affected customers that resulted in improvements to hiring, housing and food practices, among others. Because the retailer wasn’t willing to “show improvements in the right direction,” however, the brand ended up cutting ties with the firm.
“This highlights that, when faced with signs of serious misconduct, we do not rely only on regular inspections but are willing to conduct thorough investigations and cooperate with special parties,” said WE Fashion. “The management of the international supply chain is increasingly complex and requires balance and continuous cooperation with suppliers, industry initiatives, and local stakeholders. Although not all risks can be completely excluded, we are fully committed to identifying them, dealing with them, and, where possible, reducing them in a timely manner.”
Nike provided another example of a brand that relies on audits to monitor whether retailers are following their code of conduct, the review noted. The footwear industry claims that 87 percent of “strategic” retailers have created “high-quality, safe and healthy workplaces for the people who make our product,” a pattern that suggests public scrutiny is an inappropriate measure of success.
But a 2021 investigation by the Worker Rights Consortium, a Washington-based labor watchdog, found that one such Thai supplier deprived more than 3,300 workers of nearly $600,000 in legally mandated wages after forcing them to sign a form falsely stating they wanted to take unpaid “voluntary” leave. In 2025, the Just Do It firm announced a reform plan for workers, finally accepting the results of the WRC after years of denial.
Nike’s trust in inspections was questioned again in 2025 when Transparentem pointed to signs of forced labor and other abuses – among them illegal wage extraction, high hiring and document retention rates – involving foreign workers at Taiwanese textile suppliers.
The firm, a signatory of the American Apparel & Footwear Association and the Fair Labor Association’s Commitment to Responsible Hiring, has pledged to address issues highlighted by the investigation, such as pressuring the Taiwanese government for changes to its workforce structure and the “zero” hiring model.
However, critics say Nike could have identified the abuse years ago through its own monitoring systems. The brand also faces accusations of not protecting the people who make its clothes from the union. In Cambodia, Indonesia and Vietnam, workers report threats, surveillance and shooting threats to prevent organizing—all tactics that investigations often miss. Nike did not respond to a request for comment.
The shortcomings of voluntary supervision are also shown, according to SOMO, Consumentenbond and CCC, by Puma’s use of the “gold” label from the Leather Working Group to demonstrate environmental and ethical excellence.
In 2025, the independent media platform Dialogue Earth reported hazardous working conditions – including exposure to toxic chemicals – in tanneries in the Indian state of Tamil Nadu that received the same high ranking.
Puma said in a statement that public inspection reports for the leather operations it worked with showed “areas requiring improvement,” such as overtime, fire safety, machine safety, use of personal protective equipment by workers and chemical storage methods. In order to deal with these findings, Puma said it has worked with the company’s management to make a plan to correct the issues.
“We have set a clear timeline for the factory to implement these changes, and we will continue to follow up with management to see if these improvements to worker safety have been made,” the shoemaker said.
The Leather Working Group, for its part, sought to clarify the limits of its certification, noting in a statement that its standards focus on the effects of environmental performance-and the management requirements and the use of chemicals-and that it does not set the social status as part of its evaluation plan. However, the organization added that it “takes these types of complaints seriously and has a process to consider the concerns and information provided” and “used this process in this case.”
SOMO, Consumentenbond and CCC remain unconvinced by these arguments. They said, the fashionable use of public reviews and certificates to “convince” consumers of the true quality of their products, they said, “dangers” for workers and consumers.
The organizations said that although the ACM has established the standards that business performance applications must meet, the agency must take action to prevent “public washing” of benefits. To do so, they said, it must go beyond guidelines and into fines or penalties that produce real legal or financial consequences.
They said: “Employees face a wide range of abuses that are hidden by audit reports produced by the auditing and certification industry that makes huge profits from their positions.” “And consumers are lured into buying things they believe to be responsible by misleading claims and certifications.”
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