This overview describes Transparentem’s initial investigation, which began in 2022, followed by our engagement with companies starting in February 2024 and the companies’ efforts to remediate the problems as of February 2025.

“I came to work to pay my family’s debt but received another debt.”

– Far Eastern migrant worker

Modern manufacturing’s long and complicated supply chains make labor abuses hard to see and harder to fix when they are discovered. Ending labor abuses that occur before the final stage – or beyond the first tier – of production requires coordination and collaboration.

Transparentem aimed to catalyze this type of action in Taiwan, an important production hub for outdoor and athletic apparel fabrics. Transparentem recently investigated labor abuses there, affecting migrant workers employed by deeper-tier textile suppliers. This report details outcomes as of February 2025 and the work that remains.

Transparentem’s Investigation

In 2022 and 2023, Transparentem investigators interviewed more than 90 migrant workers from Vietnam, the Philippines, Indonesia, and Thailand employed by textile and textile-related suppliers in Taiwan. These workers reported paying recruitment fees as high as $6,000, among the highest identified by Transparentem across its investigations in multiple countries. In addition to other abuses, our investigation found evidence of conditions that the International Labour Organization (ILO) has defined as indicators of forced labor[1]. According to the ILO, finding at least one of these indicators points to the possible presence of forced labor.

In March 2024, Transparentem sent confidential reports to more than 40 buyers[2] with possible supply-chain connections to nine Taiwanese suppliers operating beyond the first tier of production. The reports presented evidence of labor abuses and recommended actions that buyers should take to correct or remediate the harm.

Transparentem sent reports to buyers who named investigated suppliers on their public lists of factories that manufacture their products. Transparentem also sent reports to buyers who, according to shipping data, bought finished products from manufacturers who bought materials from investigated suppliers. In both cases, Transparentem’s position was that buyers were responsible for taking corrective action at the investigated suppliers.

Transparentem argues that abuses beyond the first tier will only be prevented if buyers take responsibility for abuses in all suppliers to their tier one suppliers.

Company Responses

Many, but not all, of the buyers who received Transparentem’s investigation findings took a narrower view of corporate responsibility. In a submission to Transparentem, they argued that their obligation to respond to reports of abuse does not extend to all suppliers to their tier one suppliers but only to those workers who produce the specific materials that end up in their products. As a result, many buyers chose to act at only some of the suppliers to which Transparentem had connected them. Still, other buyers took helpful actions regarding their suppliers’ suppliers, contributing to an important precedent. Only a very small number of buyers were either totally unresponsive or declined to take any action.

Indeed, nearly all buyers opted to take some action toward addressing the problems Transparentem found. A dozen buyers stepped forward to lead remediation efforts at specific suppliers. At facilities run by eight of nine investigated suppliers, buyers commissioned audits that broadly confirmed Transparentem’s findings. At the time of drafting this report, corrective action plans (CAPs) had been created at all but one supplier, and in many cases, buyers and suppliers had already begun corrective actions. (The ninth supplier—Lucky Unique—initially declined buyers’ request for an audit but later consented to a remediation process beginning with a third-party assessment, expected to take place in February 2025.)

American Apparel and Footwear Association (AAFA) played an important role in coordinating buyers and advised Transparentem that additional buyers beyond those engaged by Transparentem had joined in supporting some remediation activities. In January 2025, largely as a result of Transparentem’s investigation, the AAFA and Fair Labor Association (FLA) announced the formation of a new coalition of global apparel companies working to promote responsible recruitment and employment in Taiwan’s textile industry.

However, at the time of finalizing this report, important details remained unclear about remediation at the investigated suppliers, including who would fund repayments to migrant workers who had paid high recruitment fees to secure their jobs and which workers would qualify for such reimbursement.

Asked in November 2024 to respond to Transparentem’s findings, one supplier did not reply, another declined to comment, and the remaining suppliers said they were working toward improvements at their facilities. Some suppliers later sent further feedback, including disputing some of Transparentem’s investigation findings.

Government Engagement

Transparentem was not aware of any substantive steps the government had taken to address concerns raised by civil society and the private sector as a result of Transparentem’s investigation.

As Transparentem had recommended, many buyers began engaging with the Taiwanese government to advocate for stronger regulatory protections for migrant workers. As a result of Transparentem’s investigation, more than 50 apparel brands signed a letter in September 2024 urging the government of Taiwan to implement specific regulatory and legal reforms to increase protections for migrant workers. The signers included 32 of the buyers that Transparentem had identified as possibly connected to the investigated suppliers. The AAFA and the Fair Labor Association (FLA) organized the letter. Also in September 2024, Transparentem and more than 20 individuals and local and international civil society organizations sent a similar advocacy letter to the Taiwanese government.

In December 2024, many buyers participated in follow-up advocacy meetings and workshops in Taiwan organized by the AAFA and FLA.

Transparentem also plans to contact national governments that may have supply chain connections to the investigated suppliers via their public procurement processes.

Call to Action

While promising steps forward were in motion at the time of this report’s publication, more timely action is needed to ensure that migrant workers in Taiwan are protected from labor abuses.

Buyers and suppliers must follow through on their plans for remediation and corrective action, including the full reimbursement of all recruitment fees paid by all workers, no matter when they were hired. Suppliers that have not yet converted to ethical recruitment practices and ensured that no migrant workers pay to work in their factories must do so. Buyers and industry groups must implement corporate responsibility commitments at all factories farther upstream in their supply chains. All actors must ensure that migrant workers have real access to independent grievance mechanisms and can meaningfully exercise freedom of association. The government of Taiwan must enact reforms, including prohibiting all worker-paid recruitment fees and so-called “service fees” that migrant workers pay monthly to local labor brokers.

These steps will not only benefit migrant workers. They will also help ensure the competitiveness of Taiwan’s economy at a time of increasing expectations of human rights due diligence extending even beyond the first tier of production.

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

[2]In this report, the term “buyer” means a company that bought material directly from at least one investigated supplier or from another company that bought material from at least one investigated supplier, regardless of whether that material entered the buyer’s products.