Key findings included:

• Wage reduction and wage theft remain the most reported allegations (linked to over half (55%) of cases), followed by unfair dismissal (linked to 42% of cases) and inhumane work rates and forced (and often unpaid) overtime (linked to 42% of cases).
• Gender-based violence and harassment, including verbal, psychological and physical abuses, and pregnancy discrimination, are widespread. The Tracker recorded multiple instances of women being threatened and unfairly dismissed for not meeting production targets.
• Attacks on garment workers’ civil liberties take various forms, including attacks on freedom of association in the workplace (linked to 26% of allegations) as the crackdown on trade unions continues. The Tracker also documents employer-military collusion (linked to 15% of allegations), whereby employers call the military into factories to intimidate workers, and the military regime is able to enter workplaces to target pro-democracy activists.
• Amid this crackdown on freedom of association, apparel brands are disproportionately relying on alternative forms of stakeholder engagement; from multi-stakeholder and industry initiatives, to communication through worker voice technology and Workplace Coordinating Committees (WCCs); the latter of which are tacitly condoned by the military regime as trade unions are persecuted.

Key recommendations to apparel brands and retailers:

1. Maintain a fully up to date and publicly available list of all direct and indirect suppliers in Myanmar; publicly and in detail outline their business decision and approach in Myanmar.
2. Engage closely with workers and their trade union representatives in all processes of risk identification and assessment, remediation and evaluation of the impacts of their business or divestment activities on workers.
3. To continue sourcing from Myanmar, brands must demonstrate their adherence to the highest requirements of human rights due diligence. This means brands must ensure that the process is transparent and risk-based. As labour rights frameworks in Myanmar are outdated and the rule of law is non-existent, brands should protect workers’ fundamental rights, including the rights to decent wages and collective bargaining, through responsible purchasing practices and international human rights instruments.
4. Where heightened human rights due diligence is not possible, brands must plan to responsibly end sourcing from Myanmar. Companies must make publicly available plans for a responsible exit, following existing guidance by IndustriALL Global Union, and in close collaboration with trade unions inside and outside of Myanmar to minimise the risk of adverse human rights impacts pre- and post-exit.

Key recommendations to governments:

1. Develop comprehensive mandatory human and environmental due diligence legislation, with specific reference to companies’ responsibility in high-risk contexts, such as Myanmar.
2. With specific reference to the European Union institutions, ensure the final Corporate Sustainability Due Diligence Directive:
   • Requires a transparent and risk-based approach to due diligence, meaning companies report on their activities in high-risk contexts such as Myanmar.
   • Compels companies to engage fully and effectively with stakeholders, and defines stakeholder as explicitly including workers and trade unions.
   • Places the burden of proof on companies, rather than victims of corporate abuse, to demonstrate whether due diligence has been adequately conducted.

Key recommendations to investors of fashion companies:

1. Conduct a thorough country, sector and company level risk assessment to better understand the human rights risks and potential harms linked to investment in Myanmar.
2. Consider all investment and engagement tools at their disposal to influence and seek to mitigate the crisis in Myanmar.
3. Perform targeted divestment and engagement regarding corporate operations in the region. Either individually, or as a collective, increase the frequency of company engagement on human rights risks i.e., focusing on reducing and remediating risks to individuals or communities, as opposed to risks to the business. Consider divestment in cases where companies are not demonstrating sufficient action.
4. Increase public policy engagement and publicly condemn the violence in Myanmar, e.g. by aligning with statements from the Investor Alliance for Human Rights.