The Netherlands Authority for Consumers and Markets has agreed to investigate corporate “social washing” claims—that is, the use of audits and certifications to create a misleading impression of ethical production—after a new analysis by three Dutch civil-society groups found that fashion brands often make overly broad attestations that don’t always jibe with reality.
While clothing companies frequently tout promises such as “no forced labor,” “a safe working environment” and “fair pay,” they often rely on commercial audits that aren’t always reliable and can be prone to deceptive practices, according to the Centre for Research on Multinational Corporations (better known by its Dutch acronym SOMO), Consumentenbond and the Clean Clothes Campaign.
After poring through advertisements and statements from dozens of apparel and footwear purveyors about working conditions, the organizations found that many lean into third-party audits as a “source of assurance” that their supply chains are free of human rights abuses. But audits are “spot checks” of working conditions at a factory that capture only a specific moment in time, they said. Years of research by labor activists also show that violations frequently fall through the cracks, whether intentionally or not.
“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,” SOMO, Consumentenbond and CCC wrote. “Audits are announced in advance, and factories also often do everything they can to present the situation in a favorable light, pressuring their workers to lie about wages and working hours, for example.”
Safety inspectors, for instance, failed to detect structural issues in Bangladesh’s Rana Plaza building before it came crashing down months later, killing more than 1,130 garment workers and injuring or maiming thousands more. Both Tesco and the auditor it hired are being sued by migrant workers at a supplier in Thailand for negligence and “unjust enrichment” over alleged forced labor conditions that went undetected. A major glove manufacturer in Malaysia kept employees in conditions meeting International Labour Organization criteria for modern slavery—including debt bondage, retention of identity documents and excessive overtime—despite having passed social audits without issue.
In other words, the report said, there’s “good reason to be skeptical” when a brand claims an audit has provided a factory with a clean bill of health.
SOMO, Consumentenbond and CCC provided case studies of their own, including one involving WE Fashion, a Dutch fashion chain that claimed its factories were 100 percent compliant with the goal of “no forced labor” in its 2024 sustainability report. Its website, too, claimed that “all factories are checked” and that the retailer “guarantees that they comply with [the company’s] Code of Conduct.”
A 2023 investigation by New York nonprofit Transparentem, however, uncovered evidence of forced labor at a WE Fashion supplier in Mauritius, where workers feared speaking to inspectors about issues such as illegal recruitment fees, employment deception and abusive living conditions. Because many were migrants from countries like Bangladesh and India, they also faced threats of deportation or loss of income for making mistakes, falling ill or attempting to organize.
WE Fashion said in a statement that it took Transparentem’s allegations seriously, commissioning an independent investigation with other involved buyers that resulted in improvements in recruitment practices, housing and meal provisions, among others. Because the supplier was unwilling to “objectively substantiate improvements,” however, the brand ended up cutting ties with the factory.
“This highlights that, when faced with signals of serious misconduct, we do not rely exclusively on regular audits but are prepared to conduct in-depth investigations and collaborate with specialized parties,” WE Fashion said. “International supply chain management remains complex and requires continuous balancing and collaboration with suppliers, industry initiatives, and local stakeholders. Although not all risks can be completely excluded, we are fully committed to identifying, addressing, and, where possible, structurally reducing them in a timely manner.”
Nike offered another example of a brand that relies on audits to monitor suppliers’ compliance with its code of conduct, the analysis noted. The footwear giant claims that 87 percent of “strategic” suppliers have developed “world-class, safe and healthy workplaces for the people making our product,” a framing that suggests that social audits are an unqualified measure of success.
But a 2021 probe by the Worker Rights Consortium, a Washington labor watchdog, found that one of the brand’s Thai suppliers deprived more than 3,300 workers of nearly $600,000 in legally mandated wages after forcing them to sign a form falsely stating they wanted to take “voluntary” unpaid leave. In 2025, the Just Do It firm announced a remediation plan for the workers, finally acknowledging WRC’s findings after years of denial.
Nike’s faith in audits was questioned again in 2025 when Transparentem identified indicators of forced labor and other abuses—among them illegal wage deductions, exorbitant recruitment fees and document retention—affecting migrant workers at the brand’s Taiwanese textile suppliers.
The firm, a signatory of the American Apparel & Footwear Association and the Fair Labor Association’s Commitment to Responsible Recruitment, pledged to address the problems highlighted by the investigation, such as by lobbying the Taiwanese government for structural labor reforms and a “zero-fee” recruitment model.
Even so, critics say Nike should have pinpointed these abuses years ago through its monitoring processes. The brand also regularly faces accusations of failing to protect the people who make its clothes from union-busting. In Cambodia, Indonesia and Vietnam, workers report intimidation, surveillance and firing threats to suppress organizing—all tactics that audits routinely miss. Nike did not respond to a request for comment.
The limitations of voluntary oversight are further illustrated, according to SOMO, Consumentenbond and CCC, by Puma’s use of “gold” certification from the Leather Working Group to signal environmental and ethical excellence.
In 2025, independent journalism platform Dialogue Earth documented hazardous working conditions—including exposure to toxic chemicals—at tanneries in India’s Tamil Nadu region that received the same sterling rating.
Puma said in a statement that social assessment reports for the tannery it worked with showed “areas which require improvements,” such as excessive overtime, fire safety, machinery safety, use of personal protective equipment by workers and chemical storage practices. To address these findings, Puma said, it worked with the factory’s management to develop a corrective action plan.
“We have set a clear deadline for the factory to implement these changes, and we will regularly follow up with the management to check that these improvements to workers’ safety have been made,” the shoemaker said.
The Leather Working Group, for its part, sought to clarify the limits of its certification, noting in a statement that its standards focus on operational environmental impacts—with requirements on the management and use of chemicals—and that it does not set a social standard as part of its audit framework. Still, the organization added that it “takes complaints of this nature seriously and has a process in place to consider concerns and any information provided” and has “applied that process in this case.”
SOMO, Consumentenbond and CCC remain unconvinced by these arguments. Fashion’s use of social audits and certifications to “convince” consumers of their products’ ethical bona fides, they said, “disadvantages” both workers and consumers.
The organizations said that while the ACM has already developed criteria that corporate sustainability claims must meet, the agency must now act to nip “social washing” in the bud. To do so, they said, it must move beyond guidance and toward sanctions or fines that create genuine legal or financial consequences.
“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,” they said. “And consumers are lured into making purchases they believe are responsible through slick adverts and certification seals.”