In July 2020, Top Glove retained Impactt as an independent consultant specialising in ethical trade practices, human rights and labour practices with specific experience of remedying forced labour in Malaysia to:
- Conduct a forced labour investigation on the Top Glove Group (the “Group”) to assess the presence of forced labour by reference to the ILO’s 11 Forced Labour Indicators
- Propose corrective action plans to improve the Group’s labour practices
- Monitor the Group’s implementation of the corrective action plans
The Group has also engaged Impactt to perform quarterly verification for a year until August 2021 to monitor the Group’s ongoing implementation of the corrective action plans and other remedial steps. The corrective action plans included Top Glove implementing Impactt’s recommendation to make remediation payments to its foreign workers who paid recruitment fees to their recruitment agents and/or sub-agents.
Based on these verifications and as at January 2021:
- Impactt found that the following Forced labour Indicators were no longer present among the Group’s direct employees: abuse of vulnerability, restriction of movement, excessive overtime and withholding of wages.
- Impactt found that further progress had been made with regard to the following Forced labour Indicators among the Group’s direct employees: retention of identity documents, abusive working and living conditions, deception, debt bondage, physical and sexual violence and intimidation.
- In Impactt’s opinion, as at January 2021, and considering the Group’s ongoing actions, these findings do not amount to systemic forced labour.
Impactt’s opinion does not extend to a part of Top Glove’s operations where foreign workers are indirectly employed by outside contractors, which as at January 2021 comprised six workers employed via third party agencies providing canteen services on the Group’s premises. Twenty seven such workers were in scope during the initial investigation in August 2020, and are included within the remediation payment schedule referred to above.