Students & Scholars Against Corporate Misbehavior (SACOM) has been striving for decent working conditions for toy workers since 2005. Unfortunately, however, we have observed little improvement in the industry over the years. Although the International Council of Toy Industries (ICTI) established the CARE Process, which claims to ensure “safe and humane workplace environments for toy factory workers worldwide,”[1] the foundation rarely lives up to its pledge. Last October, SACOM’s investigative report, Disney, Walmart and ICTI Together Make Worker Rights Violations Normal and Sustainable,[2] shed light on the poor credibility of ICTI’s monitoring system. SACOM’s recent investigations at Dongguan Heng Li Tian Tou Chuang Ying Toys Factory Co. Ltd., Tang Xia Yat Hing Plastic and Metal Manufactory and Hui Zhou Win Merchant Tour Product Co., Ltd., further demonstrate that the CARE Process does not uphold minimum labour standards but rather shields labour violations in the certification system.

ICTI certified Chuang Ying and Win Merchant during SACOM’s investigation. Yat Hing was on probation but was recently certified by ICTI. In its investigations of practices at the three factories, however, SACOM found many labour rights violations to be prevalent, including the denial of employment contracts or falsified contracts, underpayment, excessive and forced overtime, absence of social insurance, and poor health and safety measures. Together with the findings in SACOM’s previous report, these findings reveal that ICTI turns a blind eye to rights violations in its certification system.

The ICTI CARE Foundation is an influential institution. Currently, there are 711 companies, including Mattel, Hasbro and Lego, registered in the Date Certain Process. The brands and retailers concerned will only buy toys at factories that are enrolled in the ICTI CARE Process. Disney, Walmart and Toys ’R’ Us also recognize and support the ICTI CARE Process. As of 2010, over 2300 factories, in which the collective workforce amounts to 1.7 million,[3] participated in the CARE Process. Disappointingly, while the foundation has successfully expanded its membership and sphere of influence, it has systemically neglected to enforce compliance with its own business code and has ignored labour rights violations at factories it certifies. Is the tolerance of labour rights violations the secret of the foundation’s success?

SACOM insists that factories have primary responsibility in correcting labour rights violations. Nonetheless, these exploitations are further promoted by the unethical buying practices of the brands. Within the framework of its certification system, ICTI can put the factories on probation or even terminate their certification. It does not demonstrate a commitment, however, to work with the brands to raise unit prices and prolong delivery times to achieve meaningful structural reforms in the toy industry.

The full report is available here.

[1] A statement from ICTI CARE Foundation website,

[2] Both Sunny Toys (Shenzhen) Co. Ltd. and Dongguan Crown-Ace Toys Company Ltd. are certified by the ICTI CARE Process. Surprisingly, SACOM discovered that labour rights violations were blatant. The report is available at

[3] Figure from ICTI CARE Foundation website.