This overview describes Transparentem’s initial investigation, which began in 2022, followed by our engagement with companies starting in 2023 and the companies’ efforts to remediate the problems as of January 2025.  

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Ravi (a pseudonym) has worked since he was 10 years old. At the time of his interview, at age 45, poverty and illness had forced him to borrow money from his employer and work off his debt on a nine-acre cotton farm connected to the supply chain of Pratibha Syntex, one of the cotton suppliers who sourced from farms investigated by Transparentem. The debt bound him to his employer, Ravi said. “What [the farmer] says is, ‘You have taken debt from me, so I will not allow you to go and work at anybody else’s place whether there is work on my [farm] or not.’” A full day of farm labor earned him 200 rupees (about $2.42). “We can’t even ask for a wage hike,” Ravi said, “as we have taken debt from [the farm owner]…. How can we live off only 200 rupees?” Ravi asked. “So, we also take the children to work.”

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Due diligence efforts often fall short when addressing labor abuses beyond the first tier of the supply chain—that is, the suppliers’ suppliers. Transparentem’s investigation into conditions on Indian cotton farms, which represent the raw material level of the apparel supply chain, uncovered alarming indicators of forced labor as defined by the International Labor Organization (ILO). Transparentem also found instances of child labor, including, in some cases, the worst form of child labor. Some children were exposed to hazardous pesticides and some directly handled these toxic substances.

Through our investigation, Transparentem linked investigated farms to the supply chains of one of three different suppliers, either directly or indirectly. These three suppliers were then linked to 60 global brands. Transparentem shared its findings with the suppliers and buyers, prompting many of them to initiate remediation efforts. We continue to engage with these suppliers and buyers to advance meaningful remediation strategies.

Buyers’ and suppliers’ responsibilities extend across all levels of their supply chains. By extending robust social compliance efforts to the raw materials level, companies can safeguard vulnerable workers in the cotton sector from exploitation. Achieving this goal requires a collaborative approach involving workers, farm owners, suppliers, governments, and NGOs. This approach can sustain improvements in working conditions and children’s meaningful access to education.

For an in-depth analysis of these findings and related insights, please see the detailed report.  Summary information is provided below.

Investigation Findings

Between June 2022 and March 2023, Transparentem conducted an extensive investigation into labor conditions on 90 cotton farms in the Khargone and Barwani districts of Madhya Pradesh, India. This investigation revealed troubling practices, including the use of child labor and widespread labor violations such as debt bondage, abusive working conditions, and other indicators of forced labor, as defined by the ILO[1]. Among the concerning findings, children were found handling pesticides or working in environments where pesticides were used.

In addition to these critical labor concerns, the investigation uncovered potential issues related to the organic integrity of the cotton produced on farms connected to the supply chain of Pratibha Syntex.

Below are further details on the abuses and concerns revealed in our investigation. It is important to note that these violations were not found across all farms connected to the supply chains of all three suppliers; some were identified only on farms associated with one or two suppliers.

Child Labor and Pesticide Exposure: Investigators documented numerous cases of children younger than 14 working on cotton farms despite Indian laws prohibiting it. Some children worked alongside their parents to repay family debts and some missed school to work. Some children and adolescents were exposed to health risks from handling pesticides or working on farms after pesticides had been sprayed. Several experienced health issues such as respiratory problems, nausea, and skin irritation due to pesticide exposure.

Transparentem’s findings highlight how economic hardship forces many children to miss or abandon school to support their families, perpetuating cycles of poverty. Adult workers expressed concerns about their children’s futures, acknowledging the importance of education but feeling trapped by financial constraints—a reflection of broader issues in rural, low-wage economies.

Debt Bondage: Debt bondage is an ILO indicator of forced labor and, according to the United Nations, is a practice similar to slavery. Offering advance payments or loans is a customary method cotton farm owners use to secure labor for the entire season. These arrangements, however, can bind workers to employers for unspecified and often long periods, making it very challenging for workers to complete repayment. If a family continues to experience economic challenges and requires further advances and loans, they may become trapped in cycles of debt bondage.

Debt bondage emerged as a widespread issue on the farms investigated by Transparentem. Families were bound to work to repay advances or loans from employers. Charging workers high interest rates can prevent them from repaying their debts timely and may put them at higher risk of becoming trapped in cycles of debt. One worker who said the employer charged interest said it could take two to three years to repay a debt.

Wage Violations and Poverty-Level Wages: Low, unpredictable wages—often below the legal minimum—left workers vulnerable to experiencing forced labor indicators. These conditions severely limited their ability to escape debt.

Transparentem, using World Bank data, estimates that workers earning the state’s minimum wage may have still lived in poverty, as their income was insufficient for an average-sized family to rise above the poverty line. Some workers might have even experienced extreme poverty.

Further, several workers from three different farms that sold raw cotton to ginning mills that supplied cotton bales to Maral Overseas said that the farm owner sometimes withheld their wages for unpredictable amounts of time. Most of them were also in debt to their employer. Withholding wages can compel workers to remain working for their employer while they wait to receive what they are due. Given that workers were in an extremely precarious economic condition, unpredictable payment frequencies and unpaid wages could also exacerbate risks of debt bondage and child labor.

Abusive Working Conditions and Health Hazards: Workers reported abusive treatment, with some farm owners shouting and threatening to send them home without paying them their full wages if they made mistakes, arrived late, worked too slow, or sat down. Many workers faced grueling hours in extreme heat, risking heatstroke and exhaustion. Although many workers said that they had access to drinking water on the farm, reports by the Indian government and media suggest that safety concerns related to a lack of proper toilet facilities often lead women to withhold drinking water, amplifying the risk of dehydration associated with farm work in hot climates. Transparentem’s investigation found that none of the farms connected to the supply chains of the three suppliers had bathrooms or any type of sanitary facility that granted privacy to workers.

Inadequate protective gear and exposure to hazardous pesticides among adult workers led to health issues. Transparentem’s investigation highlighted that hazardous working conditions and lack of safety measures were consistent issues on cotton farms, placing the health and well-being of workers, particularly children, at substantial risk.

Other Findings: Transparentem’s investigation revealed potential issues with the integrity of organic cotton in Pratibha Syntex’s supply chain and the Vasudha Swaraj program. (Transparentem did not find evidence of organic integrity concerns on investigated farms connected to the supply chain of Remei India.). Evidence suggests that genetically modified seeds and synthetic pesticides may have been used, and organic cotton might have been mixed with conventional varieties. Pratibha Syntex asserted that it upholds organic integrity through strict procedures and monitoring, with Vasudha Swaraj inspecting over 16,000 farms twice annually and downgrading non-compliant farms. Transparentem recommended that Pratibha Syntex, Vasudha Swaraj, and their buyers investigate these concerns further and remediate them if confirmed.

Transparentem’s findings underscore the need for stronger verification processes and adherence to organic standards to ensure compliance with environmental and ethical commitments in cotton production.

Brand and Supplier Progress Toward Remediation

Full details of corporate responses begin on page 47 of the report. A summary table of the responses from brands to Transparentem’s investigation, detailing brands who have acted and those who have yet to engage or provide a response, begins on page 48.

By reviewing company documents and interviewing farm owners, Transparentem traced cotton supply chains from the investigated farms in Madhya Pradesh to Pratibha Syntex and Remei India—two major suppliers of cotton yarn, textiles and apparel—and to several ginning mills. Transparentem then connected the ginning mills to the supply chain of a third supplier of cotton yarn, textiles, and apparel: Maral Overseas. Transparentem leveraged publicly available information and third-party shipping data, to trace the suppliers’ supply chains to multiple global brands and retailers. In late 2023, Transparentem contacted the three suppliers and 60 of the brands and retailers to share our findings and recommendations for remediation, providing them the opportunity to address the issues uncovered during our investigation.

Many brands and retailers were already participating in initiatives focused on labor rights, organic production, and traceability, but most lacked full visibility into the origins of their cotton at the farm level. This lack of visibility hindered their ability to conduct effective due diligence. Interviews with workers also revealed that they did not know about any grievance mechanisms, highlighting a critical need for improved access to complaint channels. These findings underscore the importance of expanding social compliance efforts beyond the first tier of production to safeguard workers at the raw material level.

After learning of Transparentem’s findings, all suppliers and over half of the contacted buyers formed working groups or began individual efforts to address labor concerns within their supply chains. When communicating with buyers, Transparentem emphasized the importance of constructive engagement with suppliers, advising against cutting business ties, which could harm vulnerable workers and fail to address past harms.

Harvesting the Future Initiative with Fair Labor Association: In early 2024, 26 brands that purchased goods from Maral Overseas and Pratibha Syntex partnered with the Fair Labor Association (FLA) to develop a remediation roadmap to address labor issues, establish traceability, and improve working conditions on cotton farms in Madhya Pradesh. An initial eight-month scoping study conducted by FLA gathered input from local stakeholders, including farmers, community members, and government officials, to guide the remediation efforts.

In September 2024, buyers and their suppliers—Maral Overseas and Pratibha Syntex—designated the FLA to lead the Harvesting the Future (HTF) – Cotton in India project, which focuses on 32 villages in Khargone and Barwani districts, encompassing over 7,500 cotton farm owners. The three-year roadmap for the project combines human rights due diligence, community-level interventions, and an area-based approach to child protection. The plan aims to establish Child Labor Free Zones, improve grievance mechanisms, and enhance access to government schemes. It also seeks to boost farm owners’ earnings, ensure payment of legal minimum wages, and implement supply chain mapping and capacity-building initiatives, with activities set to begin in 2025.

Transparentem commends the important effort undertaken by FLA and these 26 buyers to collaborate in developing a solution that holds promise for addressing systemic issues by placing workers and communities at the center of the response. The novel potential for creating visibility to the cotton farm level in conventional cotton gives this region of India an opportunity to become a very attractive market for ethical sourcing of cotton.

Still, some improvements to this effort are needed. While the FLA reports having received sufficient funding commitments to cover the first two years of the Harvesting the Future project plan, no buyers have disclosed the amounts of their financial contributions to support the initiative. Transparentem has expressed concern over the project’s slow progress; the scope of remediation, which is limited to just 32 villages in three years; and the lack of public transparency around budget details, which prevents stakeholders from effectively evaluating each company’s role in the project’s impact. More buyers and suppliers whose supply chains are connected to cotton farms in Madhya Pradesh must join in this and similar efforts to achieve systemic change.

Remei’s Study and Commitment to Traceability: Remei informed Transparentem that Remei India collaborates directly with smallholder farmers in Madhya Pradesh to promote transparency, uphold human rights due diligence, and support organic farming. Transparentem commends Remei’s efforts and its full farm-level visibility, which allowed Transparentem to more easily connect investigated farms directly to Remei. Remei also told Transparentem that it has processes in place to remediate identified cases of abuse, which it could not activate because Transparentem did not provide access to the evidence gathered during the investigation nor the specific locations of investigated farms. (Transparentem’s confidentiality policy does not provide for disclosure of such information, to protect sources from potential retaliation.)

In response to the investigation, Remei and its buyers initiated a baseline study with a university research center and a local NGO to assess labor conditions and address systemic issues in its supply chain. By September 2024, the study’s first phase had reviewed 970 organic and 80 conventional farms, with the second phase set to cover another 1,000 farms during the delayed cotton harvest, pushing completion to February 2025. Remei has not shared the results of the first phase of the study publicly nor with Transparentem. Remei shared its child labor remediation plan, which is aligned with Transparentem’s recommendations. Remei noted that its study found that the structural risk factors for child labor had not changed significantly since 2005. Thus, improvements to policies and processes to monitor risks and address root causes are likely needed. Remei plans to involve farm workers in training to raise awareness of their rights and connect them to government benefits.

Additional Actions by Individual Brands and Retailers: Many companies, including several that are also participating in group action, reported planning and implementing additional actions to assess conditions, improve their policies and practices, or enhance traceability.

Buyers Who Did Not Respond or Ceased Communication with Transparentem: The buyers listed below either did not respond or ceased communication with Transparentem regarding any actions to address critical issues in the cotton supply chain.

Call to Action

Over a year has passed since Transparentem shared findings with buyers and suppliers regarding child labor, forced labor indicators, and other abuses on cotton farms linked to their supply chains. Despite some progress by many companies that Transparentem engaged, several other companies have failed to respond or engage in meaningful remediation. All buyers and suppliers must take responsibility across all tiers of their supply chains, extending social compliance efforts to the raw material level. Collaboration with NGOs, farm owners, governments, and workers is vital to achieving effective due diligence and accountability.

Transparentem is encouraged by efforts from some buyers and suppliers and acknowledges the potential challenges to addressing systemic issues identified in the investigation. However, progress remains too slow, leaving many workers in the dire situations found during our investigation.

Transparentem calls on buyers and suppliers to expedite due diligence and remediation to set a global precedent for ethical sourcing in Madhya Pradesh. All companies sourcing from this region must act to eliminate child labor, forced labor, and other abuses. Together, these efforts can transform Madhya Pradesh into a preferred ethical sourcing region.

[1] https://www.ilo.org/sites/default/files/wcmsp5/groups/public/@ed_norm/@declaration/documents/publication/wcms_203832.pdf