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“No forced labour”, “a safe working environment”, and “fair pay”: these are promises clothing brands readily use in advertisements to reassure consumers seeking clean clothing. But what are these claims based on? A new analysis by SOMO, the Dutch consumers’ association Consumentenbond, and Clean Clothes Campaign (CCC) shows that clothing brands regularly make overly general statements that are not always accurate. These statements frequently rely on commercial audits that are known to be unreliable. SOMO, Consumentenbond, and CCC have shared our findings with the Netherlands Authority for Consumers and Markets (ACM). The ACM has agreed to investigate how “social washing” – the use of audits and certifications to create a misleading impression of responsible production – can be tackled.
SOMO, Consumentenbond, and CCC examined advertisements and statements made by dozens of clothing brands about working conditions in (online) stores, on social media, and on websites. Many of these advertisements refer to commercial audit companies as a source of assurance that there are no human rights abuses in their supply chains. An audit is a spot check of the working conditions in a factory, but years of research by civil society organisations(opens in new window)
, including SOMO and CCC(opens in new window)
, have shown that labour rights violations are often not detected during such inspections. This is because clothing brands and factories are generally the ones commissioning the audit, creating a perverse incentive for the audit company not to be too negative, so that they will be hired again next time. Audits are announced in advance, and factories also often do everything they can to present the situation in a favourable light, pressuring their workers to lie about wages and working hours, for example. The final inspection report is sent to the client and is not made public, meaning workers, trade unions, and civil society organisations cannot check what it says.
There is, therefore, good reason(opens in new window)
to be sceptical when a brand claims that audits have shown that everything is fine at their factories. This is also illustrated by several specific examples from our investigation. For example, WE Fashion reported in its 2024 sustainability report(opens in new window)
that its factories were 100% compliant with the goal of “no forced labour”. Additionally, on its (Dutch) sustainability webpage, WE Fashion advertises that “all factories are checked” and that WE Fashion “guarantees that they comply with [the company’s] Code of Conduct”.
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However, in a 2023 investigation(opens in new window)
, the NGO Transparentem had indeed found evidence of forced labour at a WE Fashion supplier in Mauritius. Here, too, workers did not dare to speak freely during the commercial audit. When contacted by Consumentenbond, WE Fashion stated that it takes signals such as those from Transparentem seriously and does not rely solely on audits to verify labour conditions in its supply chain. Regarding the specific situation of the supplier in Mauritius, WE Fashion admitted that its claims around forced labour “could have been clearer”, and eventually terminated the relationship with the supplier in July 2025.
Another example is Nike. On its Responsible Supply Chain webpage(opens in new window)
, the company states that it is committed to building a responsible supply chain monitored through audits. It also reports that 87% of its strategic suppliers have developed “world-class, safe and healthy workplaces,” presenting audits as assurance of responsible production(opens in new window)
.
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However, independent investigations documented serious labour rights violations at supplier factories in earlier and subsequent periods. A 2021 investigation(opens in new window)
by the Worker Rights Consortium found that a Thai supplier of Nike deprived more than 3,300 workers of nearly US$600,000 in legally mandated wages through a scheme of coerced “voluntary” unpaid leave. And a 2025 investigation(opens in new window)
by Transparentem identified indicators of forced labour and other abuses affecting migrant workers at Taiwanese textile factories supplying Nike.
A third example concerns Puma, whose sustainability page(opens in new window)
states that human rights are embedded across its suppliers and that compliance is monitored through regular audits(opens in new window)
. The company also states(opens in new window)
on its sustainability site that its leather products support responsible production by sourcing from Leather Working Group-certified tanneries, and advertises its products as such.
However, in 2025, an investigation by the environmental journalism organisation Dialogue Earth(opens in new window)
documented hazardous working conditions and exposure to toxic chemicals at tanneries supplying global footwear brands that had received “gold” certification from the Leather Working Group, raising serious concerns about the reliability of such certification schemes.
This system, in which brands use social auditing and certifications to convince consumers that their products are produced responsibly, disadvantages both workers and consumers. Workers face multiple forms of abuse that are concealed by audit reports produced by an auditing and certification industry that profits handsomely from their situation. And consumers are lured into making purchases they believe are responsible through slick adverts and certification seals. As the Dutch consumer authority, this is something from which the ACM should protect consumers. The ACM has already developed guidelines setting up the criteria that corporate sustainability claims must meet. It should now act to curb “social washing”. The ACM has indicated that it will investigate measures to prevent social washing, meaning that in the future, brands caught social washing could face significant sanctions or fines. This would be a welcome and much-needed development.
WE Fashion, Nike, Puma, and the Leather Working Group were all contacted for a response. Only Nike did not respond. The responses are found in the footnotes.
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