German Businesses Should Cut Ties with Turkmenistan’s Textile Industry [Cotton Campaign Correspondence with German Business Association]
Doing business with the textile industry in Turkmenistan plays a major role in supporting the state-imposed forced labor system in cotton production
Employees of state water supply company picking cotton in Dashoguz region, October 2022. Photo by Turkmen.News.
In advance of the German-Turkmen Investment Forum hosted in Düsseldorf on June 27, 2023, the Cotton Campaign called on all German business associations, consultancies, multi-stakeholder initiatives, and supply chain actors to cut ties with Turkmenistan’s textile industry to avoid benefitting or profiting from forced labor.
Public workers picking cotton in Turkmenistan. September 2022. Photo by Turkmen.News.
On this page, we present the Cotton Campaign’s correspondence with VDMA, one of the co-hosts of the event in Düsseldorf and a business association representing German machinery and equipment manufacturers. We outline why German business associations, instead of promoting investments in Turkmenistan’s textile industry, should in fact protect their members from doing business with the Turkmen textile industry and becoming complicit in Turkmenistan’s forced labor system.
School and kindergarten teachers arrived to a cotton field in the back of a truck. Dashoguz region, October 2022. Photo by Turkmen.News.
On June 20, 2023, the Cotton Campaign wrote letters to the leadership of all seven German organizations co-hosting the event.
On June 27, 2023, the day of the Investment Forum, the Cotton Campaign issued a press release.
On June 12, 2023, VDMA President Karl Haeusgen responded to the Cotton Campaign’s letter. VDMA sent the same communication to the Business and Human Rights Resource Center (BHRRC), which had published the Cotton Campaign’s call to German businesses to cut ties with Turkmenistan’s textile industry.
On July 25, 2023, the Cotton Campaign responded to VDMA’s letter. Our communication can be downloaded here and has also been published on BHRRC’s website as rejoinder.
On July 28, 2023, VDMA responded to the Cotton Campaign that it had nothing to add to its original communication. It is extremely concerning that VDMA will continue encouraging business with the textile industry of Turkmenistan, thus supporting the perpetuation of the state-imposed forced labor system in Turkmenistan cotton production.
School and Kindergarten Teachers submit cotton to be weighed, Dashoguz region, October 2022. Photo by Turkmen.News. October 2022. Photo by Turkmen.News.
Key points highlighted by the Cotton Campaign in its response to VDMA
Turkmenistan: state-imposed forced labor in cotton production
All cotton originating in Turkmenistan is produced by the state with the systematic and widespread forced labor of hundreds of thousands of teachers, healthcare workers, other state employees, and sometimes children.
There is a well-documented record of reporting and communication from international expert bodies, finding that Turkmenistan has made insufficient progress to end its state-imposed forced labor system in cotton, including from the ILO Committee on the Application of Standards and the UN Human Rights Committee.
Turkmenistan does not import cotton, which means that all cotton used in the textile industry in Turkmenistan is produced with state-imposed forced labor.
Doing business with the textile industry in Turkmenistan plays a major role in supporting the state-imposed forced labor system in cotton production
Doing business with the textile industry in Turkmenistan and providing machinery and equipment to cotton ginneries, spinning mills, fabrics mills, sewing units, and other production units in the textile manufacturing industry of Turkmenistan plays a major role in supporting the state-imposed forced labor system in cotton production.
The German companies that sell machines and equipment for usage in the Turkmen textile industry benefit from the forced labor system.
They also support the perpetuation of the forced labor system and, by facilitating the production of forced labor Turkmen cotton into finished and semi-finished products, they facilitate Turkmen cotton entering global supply chains, in violation of import ban regulations and legal and ethical obligations on companies not to use goods made with forced labor.
Terminating business with Turkmenistan’s textile industry is the only responsible course of action to avoid benefitting or profiting from forced labor
In accordance with the OECD Due Diligence Guidance for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights , when entering new markets, companies must identify and assess actual and potential adverse impacts associated with their operations, products, and services. A robust due diligence process requires conducting a risk assessment associated with all business relationships the company has. In the case of Turkmenistan, there is extensive evidence, documented over more than a decade by independent labor monitors, that the government uses state-imposed forced labor to harvest cotton. To avoid benefitting or profiting from forced labor, German companies should not enter into business relationships with Turkmen textile producers and should terminate any such existing relationships.
While the OECD standards encourage lead firms to work with suppliers towards continuous improvement, the standards also account for situations where mitigation is not feasible or because of the severity of the adverse impact, where the only responsible course of action is disengagement, such as contexts of state-imposed forced labor. This is due to the inability to conduct due diligence on the ground and the fact that no company has or will have enough leverage to work towards any improvement in practice. In situations of state-imposed forced labor, such as in Turkmenistan, businesses are unable to prevent or mitigate human rights abuses. There are no valid means for companies to verify that any cotton picked in Turkmenistan is free of forced labor, nor can companies take action to prevent the use of forced labor in the Turkmen cotton harvest. Companies cannot even enter the country to conduct their own due diligence.
Even if companies could, theoretically, interview workers, worker interviews, which are essential to the methodology of any labor or human rights investigation, cannot generate reliable information in state-imposed forced labor contexts. No worker can speak candidly to auditors or investigators about forced labor or other human rights issues without placing themselves and their families at risk of brutal retaliation. Furthermore, meaningful remedy for directly affected individuals is not possible. Therefore, in such cases, urgent disengagement is the only responsible way to ensure businesses do not contribute to such abuses. We further note that these disengagement standards are included in the amendments adopted by the European Parliament on the EU’s proposed Corporate Sustainability Due Diligence Directive, which extends due diligence obligations, including regarding disengagement, across a company’s full value chain.
Human and labor rights must be respected within the framework of EU-Turkmenistan relationships
The VDMA letter notes that “the European Union supports economic cooperation with the country and regularly reviews the human rights situation in direct talks with Turkmenistan”. In fact:
The European Parliament has not approved the EU-Turkmenistan Partnership and Cooperation Agreement (PCA) because of strong concerns about human rights violations committed by the government of Turkmenistan. In 2019, the Parliament adopted a resolution setting out concrete human rights benchmarks that it expects to see sustainable progress on by Turkmenistan before giving its consent to the PCA.
Furthermore, the EU report of the EU-Turkmenistan Human Rights Dialogue from 2022 shows that state-imposed forced labor is ongoing in the cotton harvest in Turkmenistan and despite the government accepting to begin engagement with the ILO, the ILO Committee on the Application of Standards’ Conclusions issued in July 2023 note that the Committee “deplored the persistence of the widespread use of forced labor in relation to the annual state-sponsored cotton harvest in Turkmenistan and the Government’s failure to make any meaningful progress on the matter since the Committee discussed the case in 2016.”
There is an urgent need for collective action. Supporting the textile industry in Turkmenistan undermines efforts to end forced labor in Turkmenistan cotton
Supporting the textile industry in Turkmenistan, and therefore the perpetuation of the state-imposed forced labor system in Turkmen cotton, undermines all the efforts by responsible companies and investors, policy makers, enforcement agencies, and civil society to take action to eliminate Turkmen cotton from supply chains and to increase the pressure on the government of Turkmenistan to end its forced labor system.
Collective and consistent action by companies, civil society, international organizations, and governments played a critical role in pressuring the government of Uzbekistan to end the forced labor system there.
The Cotton Campaign welcomes the opportunity to meet with VDMA, its members, and other German business associations and consultancies, supply chain actors, and government representatives, to address the issue of state-imposed forced labor in Turkmenistan cotton and coordinate efforts to increase compliance with national laws governing human rights due diligence, supply chains, and imports, including the Germany Supply Chain Act, requiring companies to eliminate forced labor from their supply chains.
To coordinate such a meeting with the Cotton Campaign coalition, please reach out to Raluca Dumitrescu, coordinator@cottoncampaign.org.
