4 Implementation of codes of conduct In Bangladesh buyers have been implementing codes of conduct since 1996/1997. This section is based on interviews with three Bangladeshi firms and seven retailers importing from Bangladesh, all of which have implemented codes of conduct. The section also draws on an interview with ETI. We will go through the different stages of the codes implementation process, seen from the different points of view. The implementation process includes: how the importers adjust their codes of conduct to the local laws; how they present their codes; how they do the auditing of the companies; and how they make sure that corrections of noncompliance are made.
4.1 Integrating local legislation into the codes The importers always incorporate the local legislation of the country they are sourcing from into their codes of conduct. This means that they base criteria such as minimum wages, overtime payment and number of holidays on the national law. Sometimes the codes of conduct are presented as a document which denotes both the local legislation and the company’s code. Most of the importers say that when local legislation sets a lower standard than their own codes of conduct, they aim for the higher standard. The Bangladeshi firms felt that if they can comply with the existing labour laws then buyers’ compliance is not a problem. It can sometimes be problematic to find out what the local law says on these specific issues, and to keep updated on changes in the law. The importers have different methods for dealing with this. Some were using local solicitors, and some were registered with the relevant Ministry in Bangladesh to get the information they needed. Information could also be found in a handbook compiled by the BGMEA. Some importers said the suppliers could provide them with information, and that the internet was also useful. One British importer said ETI was helpful in giving out information about different countries’ local legislation. None of the interviewed importers said they used their respective countries' development agencies (DFID or SIDA) in order to get hold of this kind of information. Companies that use external revision do not have to use time and resources on legislation, since the auditing companies are usually up to date on both Bangladeshi and international legislation. Similarly, importers that hire codes of conduct inspectors in Bangladesh will leave the legislation work with them, since the inspectors have contacts and will check for changes in the law. Another problem with the integration of local legislation into the codes of conduct is that the local laws are sometimes vague and so interpretation is problematic, as was mentioned in section 3. In the EPZs the laws are more streamlined and the standards are monitored. But the workers do not have the right to unionize, which they should have according to most of the buyers’ codes of conduct. We will later see what the interviewed importers' policy is concerning trade unions.
4.2 Presentation of codes The importers normally inform the factories about their codes of conduct early in the process of purchasing. Usually they are presented in a written form together with quality requirements. When representatives of the importing company meet with the supplier, they
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