Example in Action: Top Glove WRO and Subsequent Modification

• The demand for personal protective equipment (PPE) saw a large uptick in 2020 due to the COVID-19 pandemic. As governments and health care providers scrambled for PPE, rubber glove manufacturers gained international attention as they sought to meet unprecedented demand for disposable rubber gloves. In turn, the labor practices of companies like Malaysia-based Top Glove, the world’s largest rubber glove manufacturer, came under new scrutiny.
• Forced labor practices at Top Glove had occurred prior to the pandemic. An investigation into the UK’s National Health Service supply chains by The Guardian in 2018 found that migrant workers at Top Glove had experienced exploitative conditions, including excessive overtime, passport confiscation, withholding of wages, and other indicators of forced labor. During the pandemic, rising demand for PPE, restriction of movement to contain the spread of the virus, and the cessation of in-person audits exacerbated the long-standing labor abuses.
• DOL added rubber gloves produced in Malaysia to its List of Goods Produced by Child Labor or Forced Labor in 2020. On July 15, 2020, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) that banned Top Glove-produced rubber gloves from import into the United States because the gloves were made by forced labor. Under the WRO, CBP seized several shipments of disposable gloves that originated in Malaysia.
• Soon after the release of the WRO, Top Glove retained Impactt Limited*, a UK-based independent consultancy firm specializing in human rights and ethical trade practices, including the remediation of forced labor. Top Glove hired Impactt to assess the presence of the ILO’s forced labor indicators within their operations, propose Corrective Action Plans (CAPs), and monitor Top Glove’s implementation of the CAPs on a quarterly basis from August 2020 to August 2021. The CAPs included making remediation payments to migrant workers who had paid recruitment fees to third-party agents to work at Top Glove.
• In March 2021, Impactt released its first statement on Top Glove’s status as of January 2021, which found that forced labor indicators were no longer present among Top Glove’s direct employees.
• In April 2021, Impactt released an updated statement that outlined findings at the third quarterly verification. These reports indicated that Top Glove had made progress in eliminating indicators of systemic forced labor in its direct operations and confirmed the repayment of recruitment fees totaling over $36.3 million to 12,676 current and eligible former workers. In addition, from September 2020 to July 2021, Impactt implemented a helpline for workers to verify remediation actions and raise any other concerns in a confidential manner.
• On September 9, 2021, CBP issued a modification of its forced labor findings on Top Glove, allowing imports to resume. In the press release, CBP affirmed that Top Glove had issued “more than $30 million in remediation payments to workers and [is] improving labor and living conditions at the company’s facilities,” which is consistent with Impactt’s final statement released in October 2021. The transparency of Top Glove’s remediation process—swift implementation of Impactt’s recommendations, including payments to migrant workers directly employed by Top Glove, an independent grievance mechanism, and continuous and effective public reporting of corrective actions—was instrumental in remediating an identified forced labor issue.
• This example details general events and is informed by public information relative to this case and should not be considered an indication of likely outcomes in other cases. CBP is responsible for issuing, modifying, and revoking WROs. For more information, see https://www.cbp.gov/trade/forced-labor/withhold-release-orders-and-findings.
• Companies should encourage suppliers to be honest if they cannot complete an order without violating the terms of the company’s code of conduct, and companies should consider implementing financial incentive structures for suppliers that remediate labor rights violations identified in their supply chains, rather than simply moving their business to another supplier.
• Corrective Action Plans (CAPs) are plans of action for remediation of all violations found in a particular audit.
• It is good practice to provide opportunities for worker and community input into a CAP.
• See ILAB’s Forced Labor Remediation Guide for examples of specific remediation actions that could be taken when indicators of forced labor are found. In all cases, issues should be documented and tracked, and management systems should be updated to prevent recurrence:

DOL welcomes examples of good practices
to address child labor and forced labor.

Email us at GlobalKids@dol.gov.