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There is a complementary relationship between export incentives and domestic activists in improving workers’ rights in global supply chains. Governments will repress labour in order to boost export competitiveness; resistance is then sporadic, ineffective, and dangerous. If governments anticipate economic rewards, they may reduce labour repression; but domestic activists must simultaneously mobilise for substantive reforms. I demonstrate this by exploiting within-case variation in Bangladesh and Vietnam, showing what happened before the introduction of export incentives; in their presence; and after they subsided. Vietnam liberalised labour laws in order to join the Trans-Pacific Partnership; and Bangladesh did likewise in order to salvage its reputation after Rana Plaza. Activists became less fearful once Bangladeshi politicians had announced reforms. They registered unions, demonstrated en masse, and secured a 77% increase in the minimum wage. In Vietnam, party reformists were crucial in persuading their conservative colleagues that TPP would help strengthen the regime’s hold on power, while pushing for genuinely independent unions. This paper explicates the synergies between export incentives and domestic mobilisation by connecting protagonists’ motivations to macro-level reforms, via process-tracing and in-depth qualitative research.
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Alice Evans
There is a complementary relationship between export incentives and domestic mobilisation in improving
workers’ rights in global supply chains. Governments will repress labour in order to boost export
competitiveness; resistance is then sporadic, ineffective, and dangerous. If governments anticipate
economic rewards, they may reduce labour repression; but domestic activists must simultaneously mobilise
for substantive reforms. I demonstrate this by exploiting within-case variation in Bangladesh and Vietnam,
showing what happened before the introduction of export incentives; in their presence; and after they
subsided. Vietnam liberalised labour laws in order to join the Trans-Pacific Partnership; and Bangladesh
did likewise in order to salvage its reputation after Rana Plaza. Activists became less fearful once
Bangladeshi politicians had announced reforms. They registered unions, demonstrated en masse, and
secured a 77% increase in the minimum wage. In Vietnam, party reformists were crucial in persuading their
conservative colleagues that TPP would help strengthen the regime’s hold on power, while pushing for
genuinely independent unions. This paper explicates the synergies between export incentives and domestic
mobilisation by connecting protagonists’ motivations to macro-level reforms, via process-tracing and in-
depth qualitative research.
Keywords: workers’ rights; global supply chains; trade; Free Trade Agreements (FTAs); Vietnam;
I am extremely grateful to my Vietnamese and North American participants (who shared their reflections
with me, explained complex political dynamics, and provided useful comments on earlier drafts). This article
has greatly benefited fantastically insightful, thoughtful, and constructive criticism from Matt Amengual,
Tim Bartley, Susanna Campbell, Greg Distelhorst, Kim Elliott, Alisha Holland, Naomi Hossain, Dan
Honig, Genevieve LeBaron, Axel Marx, Ken Opalo, Elke Schüßler, and editing by Pseudoerasmus; together
with feedback at the APSA Annual Meeting, the Harvard Kennedy School, Center for Global
Development, London School of Economics, and Ho Chi Minh City University of Law. Fieldwork was
financed by the Development Leadership Programme (DLP), and the Effective States and Inclusive
Development (ESID). The debts are many, deficits mine, and critique is very welcome.
(1) Introduction
Labour repression is endemic in global supply chains. This is widely recognised (Anner, 2015; Bartley, 2018).
Less known and more contested is how to abate it (Berliner et al, 2015a). This paper improves our
understanding of how to improve workers’ rights in global supply chains by examining the impact of export
incentives for pro-labour reforms in Vietnam and Bangladesh.
The Government of Vietnam announced it would permit independent unions in order to join the Trans-
Pacific Partnership (TPP). Labour reforms were a condition for TPP membership and increased market
access. The Government of Bangladesh loosened constraints on trade unions in order to salvage its
reputation after the Rana Plaza tragedy. In this case, labour reforms were required to preserve access to
existing markets. In both countries, domestic reformists and activists were legitimised and emboldened by
export incentives. Then they could safely advance their pre-existing agenda, including higher wages.
However, when export incentives weakened so did pro-labour reforms. After Trump’s election, the USA
withdrew from TPP. The Government of Vietnam then stalled legislative change and cracked down on
dissent. In Bangladesh, the Government saw that buyers had neither fled nor mandated labour reforms,
but were squeezing prices. Therefore both governments ceased to regard labour repression as an
impediment to exports and ramped up repression.
This paper contributes to the literature in the following ways. First, it demonstrates two complementary
conditions: export incentives and domestic mobilisation. Only when export incentives shifted did pro-
growth governments reduce labour repression. Crucially then, emboldened reformists mobilised for
substantive change. Second, it shows this by exploiting within-case variation in Vietnam and Bangladesh:
charting what happened before pro-labour export incentives, in the presence of incentives, and once they
subsided. In the absence of export incentives, domestic mobilisation is sporadic/ dangerous/ ineffective.
Third, this paper connects protagonists’ motivations with macro-level changes via careful process-tracing
and in-depth qualitative research (60+ interviews). To understand why governments reduce labour
repression, we need to focus on protagonists’ motivations. Fourth, by establishing common effects in two
very different case studies (Vietnam and Bangladesh), this paper indicates a broader phenomenon.
(2) Literature Review
This section synthesises what we know about how to reduce labour repression in global supply chains, and
what kind of research is needed to further our understanding
We know that domestic politics matters. Workers have more rights in countries with higher union density,
stronger political democracy, and more representation by left-wing political parties in the executive and
legislature (Berliner et al, 2015b; Mosley, 2010; Ronconi, 2012). Organised labour has played a crucial role
by publicising and decrying abuses; striking and disrupting production; campaigning for reform; and
securing concerted increases in the minimum wage (Ashraf and Prentice, 2019; Harrison and Scorse, 2010;
Siddiqi, 2009; Trn, 2007; Yoon, 2009). Workers’ organisations can also buttress state capacity through co-
enforcement of regulation (Amengual and Chirot, 2016; Amengual and Fine, 2017). Stronger civil society
is associated with regulatory enforcement (Distelhorst et al, 2015; Toffel et al, 2015).
But organised labour is severely threatened - by dismissals, blacklisting, hired thugs, and brutal police. Fear
deters collective organising. Low unionisation thwarts their prospects. Never seeing successful mobilisation,
workers become even more despondent, and reluctant to organise collectively. In the absence of strong
independent labour movements, workers struggle to overturn repressive laws. This perpetuates a negative
feedback loop, which inhibits collective organising, pro-labour laws, and higher pay. The feedback loop is
sustained by workers’ perceived interests in job security and their expectations of ineffective unionism.
Labour repression is exacerbated by export incentives. Governments in low- and middle-income countries
repress labour to keep costs low and maintain export competitiveness. Competition is especially fierce in
low-end supply chains, where there are large pools of cheap labour, few barriers to entry, and multiple
suppliers (Anner, forthcoming). Buyers set prices, and credibly threaten to source from cheaper alternatives
(Anner, 2015; Bartley, 2018). As footloose buyers scour the world for the lowest price point, exporters cut
costs by increasing work intensity, cutting corners on safety, curtailing labour inspectorates, and neutering
trade unions (Anner, forthcoming; Berliner et al, 2015a).
Export competition in low-end supply chains reinforces a ‘race to the bottom’ in labour rights. When one
government quashes workers’ freedom of association and collective bargaining rights, other countries tend
to follow suit in order to remain competitive (Wang, 2018). The Cambodian Prime Minister Hun Sen told
workers: ‘Employers wont stay if the price of labour is expensive. Theres no way they could endure to stay
if the minimum wage continues to increase. Be reasonable for your employers because if they go bankrupt,
they will move to another location’ (Barrie, 2018, cited in Anner, 2019).
Over time, this ‘race to the bottom’ is associated with trade openness (Blanton and Blanton, 2016; Mosley
and Uno, 2007). There is also a strong correlation between unit prices and workers’ rights among the top
twenty garment exporters to the USA. When prices fall, workers’ rights worsen (Anner, 2013).
Manufacturers who are squeezed by prices tend to oppose labour regulation (Amengual et al, 2017). Unable
to negotiate prices with buyers, they lower unit cost by increasing work intensity, e.g., through piece-rate
incentives, mandatory overtime, and no weekend breaks (Ashraf and Prentice, 2019).
If governments increase labour repression when export competitiveness is determined by costs, we might
expect them to reduce repression in the presence of pro-labour export incentives. Indeed, countries that
export to places with stronger labour rights also tend to reform their labour laws (Greenhill et al, 2009;
Adolph et al, 2017; Newman et al, 2018). Similarly, Vietnamese manufacturers expressed greater willingness
to improve wages and working conditions in order to enter high value foreign markets (Malesky and
Moseley, 2019).
Labour reforms could also be incentivised by preferential trade agreements (PTAs) with strict labour
conditionalities. For example, the desire for increased market access motivated otherwise reluctant
Caribbean and Central American governments to reform their labour codes (Frundt, 1998). In response to
US trade threats, the Government of the Dominican Republic revised its labour code, improved
enforcement, and used industrial policy to motivate firm compliance (Schrank, 2013; see also Hafner-
Burton, 2013).
However, pro-labour provisions in PTAs are seldom enforced. Importing country governments often
ignore violations, prioritising diplomatic or commercial relations (Frundt, 1998; Giumelli and van
Roozendaal, 2017; Greenhill, 2010; Hafner-Burton et al, forthcoming; Kim, 2012). Even if importing
country governments did prioritise workers’ rights, they would struggle to monitor and sanction non-
Moreover, the broad consensus in the literature is that external conditionalities are insufficient for
substantive reform (Andrews et al 2017; Krasner and Weinstein, 2014). One reason for this may be that
conditionalities do not necessarily incentivise exporting governments to enforce reforms. If a regime is not
already doing X, external incentives do not create the desire to do X, only the façade of X. Without a
countervailing force on the ground to reveal non-compliance, the façade persists (Hafner-Burton, 2013;
Neumayer, 2005). This is evident in the aforementioned study by Greenhill et al (2009): countries that
export to places with stronger collective labour rights do tend to follow suit with legislation, but the
association with labour practices is much weaker.
Another hypothesis is that PTAs and other forms of global integration motivate pro-labour reforms, not
through incentives, but through socialisation. Perhaps countries join international institutions, revise their
internalised ideologies, and then embrace labour rights intrinsically (Greenhill, 2010). Others speculate that
trade deals improve outcomes by strengthening capacities (Aissi et al, 2018). Quantitative research struggles
to test these different mechanisms (ideologies, incentives, capacities), as their hypothesised effects are
identical (as noted by Mansfield and Milner, 2012:176).
In order to understand the drivers of pro-labour reforms, we need to connect protagonists’ reasons for
acting with their changing domestic and international circumstances.
First, we must examine exporting country governments’ motivations. Typically, they have been portrayed as
passive subjects of ‘external pressure’: forced to be good’, ‘trade partners don’t want human rights’ (Hafner-
Burton, 2013: 118; Trn et al, 2017). This narrative urgently requires revision, because the effectiveness of
trade sanctions depends on why exporting country governments enter PTAs in the first place. Their
motivations may include market access, geopolitical security, international reputations, and entrenching
domestic reforms. The literature’s passive framing obscures these priorities and clouds our understanding.
Second, we need to get inside the black box of domestic politics - in order to understand what strengthens
pro-labour reformists and how they use international mechanisms to further their agendas. Research on
trade-labour conditionalities often treats countries as units and obscures internal divisions. This echoes the
methodological nationalism of classic International Relations theory.
Meanwhile, many studies of
Contentious Politics construct a monolithic ‘state versus society’. Yet demands for reform do not
exclusively come from political rivals or social movements. Reformists within the party-state were critical to
economic liberalisation in East Asia (Breslin, 2003; Fforde et al, 2017; Malesky, 2008; Vu-Thanh, 2017).
Within any governing coalition there is always a diversity of ideologies and interests (as shown in Figure 1).
‘Reaching consensus is possible, but it is always fragile and transitory [in Vietnam]. Politics in this collective-
leadership system is perpetual renegotiation’ (Elliot, 2012:12). Given such contention, decision-makers may
use preferential trade agreements to lock-in their pre-existing objectives for domestic reform (Baccini and
Urpelainen, 2014; Eckhardt and Wang, forthcoming). As argued in a recent Annual Review, ‘research
should continue delving into the micro-politics of preferential trade liberalisation’ (Baccini, 2019).
Figure 1: Trajectories of Vietnam’s Policy Currents, represented in the Politburo
Source: Vuving, 2017: 428
Third, studies on the impact of labour conditionalities in trade agreements reveal positive impacts in some
but not other contexts. This heterogeneity likely reflects the diversity of perceived interests and expectations
within exporting countries including the reasons for seeking PTAs in the first place, and the perceived
risks of non-compliance. For instance, most governments improved workers’ de jure rights before signing a
PTA with the USA, but Latin American countries bucked this trend (Kim, 2012). Perhaps they believed
that the US prioritised the formation of a regional economic bloc and did not see sanctions for labour
repression as a credible threat (ibid:717). Hence in order to understand the heterogeneous impacts of PTAs,
we need to trace exporters’ expectations and perceived interests.
Fourth, cross-country regressions of PTAs, FDI, and trade openness do not tell us the precise mechanisms
by which national reforms take place, nor the relative importance of international and domestic factors, nor
the mechanism by which domestic politics is influenced by international integration. Is it due to
international socialisation or incentives? Instead of regressing measures of international integration, we need
to understand protagonists’ motivations. Qualitative research - ideally comparative and/or exploiting
Research on PTAs increasingly emphasises domestic politics (Milner, 1997). Curiously though, this focus is not always shared by the sub-set of literature on trade-
labour conditionalities.
within-case variation - can help us understand why specific governments choose to reduce labour
Fifth, we must understand interactions between export incentives and domestic mobilisation. International
economic incentives appear to motivate de jure reforms and enable activists to mobilise for de facto change.
For example, the Government of Indonesia permitted independent trade unions partly in order to benefit
from increased market access and international financing (in the wake of the Asian financial crisis) (Caraway,
Once labour repression subsided, workers mobilised for higher wages, and secured incremental
gains (Caraway et al, 2019; Panimbang and Mufakhir, 2018). Cross-national research on trade-labour
conditionalities in Central America also suggests the crucial role of local activism (Frundt, 1998). After post-
Soviet states ratified international human rights treaties to secure economic benefits, canny activists then
capitalised on these ‘insincere commitments’ to hold their governments accountable (Smith-Cannoy, 2012;
see also Simmons, 2009 for broader trends).
Each of these cases reveals synergies between domestic
mobilisation and external incentives respectively, PTAs, foreign aid, and EU accession.
In sum, we do not know how to abate labour repression in global supply chains. We do know that strong,
independent labour movements are critical for workers’ rights, yet they are violently repressed. Such
violence intimidates workers, perpetuates hopelessness, and deters unionisation. Without organising
collectively, workers struggle to secure wage hikes and contest anti-union legislation. This negative feedback
loop is perpetuated by domestic politics and global competition for price-sensitive buyers. Intuitively, we
might expect governments to reduce repression in the presence of pro-labour incentives. But this has not
yet been shown. There is an urgent need for a political economy of labour reforms that links international
incentives with domestic actors’ motivations.
(3) Theoretical Framework
My analysis of why labour reforms are adopted by export-orientated low/middle-income countries is rooted
in protagonists’ reasons for acting. This includes their ‘perceived interests’ and ‘norm perceptions’ (their
expectations of what others will laud or condemn). This methodological individualism is important, because
countries are not unitary actors, with homogenous motivations. We must examine internal conflicts,
contestations, and coalitions.
Governments promote exports for different reasons depending on their composition, collective
capacities, domestic mobilisation and norm perceptions. Governments beholden to capitalist interests
(either as factory-owning parliamentarians or their patronage networks) promote exports to further
capitalists’ objective material interests. These profit-maximising politicians seek to maintain power via
patronage networks, which fracture the working class and inhibit mobilisation for pro-labour reforms. So,
whatever promotes the interests of the ruling business elite becomes their governing strategy. If there are
new opportunities to maximise profits (such as if global buyers or trade partners revise the criteria for
export growth), their strategy shifts. If export-growth is contingent on low costs, then labour repression is
intensified. If exports require some labour reforms, then repression is relaxed to further capitalists’
material interests. This is straight-forward. For such cases, an ideational analysis would be co-extensive with
a materialist one.
Business interests do not always reign supreme. They may be disciplined, at the service of authoritarian
control. But even if all party leaders prioritise political control, they may disagree about strategy. Some may
champion export-growth (with corollary gains in jobs-creation, domestic legitimacy, regional prestige and
geopolitical security). Some may support labour repression (either to remain internationally competitive, or
to quash political dissent and maintain dominance). Others may favour pro-labour reforms (believing this
will strengthen domestic legitimacy). For authoritarians (hell bent on political control), their governing
It was also partly motivated by mass protests, and ongoing democ ratisation.
Echoing my findings in Vietnam, Smith-Cannoy (2012) details how post-Soviet states ratified UN human rights treaties, in ord er to secure economic assistance, but
without the intention of implementation. Activists then leveraged these mechani sms. This evidence of a two-step process (export incentives motivating de jure reform,
followed by activists mobilising strategically for substantive change) counts against the idea of monolithic ‘norm diffusion’ .
There is less evidence of synergies in non-democracies, where civil society is weak or dependent on government (Hafner-Burton , 2013; Neumayer, 2005).
strategy depends not on the objective material interests of business, but on contestation and coalitions. So,
even if there are new opportunities to maximise business profits (such as if global buyers or trade partners
revise their criteria), the governing strategy does not necessarily shift. Even amongst single-party East Asian
states, industrial relations differ, and have changed over time (China is arguably much more repressive than
Vietnam Chan, 2019). To understand these differences, we must attend to protagonists’ perceived
interests (which are subjective, and unknowable a priori). These may be revised with shifts in export
incentives and domestic mobilisation.
This paper also attends to ‘norm perceptions’ (individuals’ expectations of what others laud or condemn).
Reformists may privately favour pro-labour reforms or greater international economic integration, yet stay
silent if they see dissidents being arrested and replaced by loyalists. Their proclivity to vocalise their
perceived interests is conditional on their norm perceptions: anticipation of wider support, open-minded-
debate, or sanctions for sedition. Norm perceptions are developed through observation and interaction:
reading party decrees, listening to radio broadcasts, hearing media coverage of un/successful strikes,
witnessing mass arrests, and being evaluated at work. Politicians, civil servants, factory owners, unionists,
and workers see which ideas and activities are celebrated or chastised, then anticipate similar treatment.
Fearing backlash, they may prefer to self-censor (Chen, 2002; Perry, 2012; Stern and Hassid, 2012).
If governments brutally repress labour (either to promote exports or thwart dissent), they inhibit domestic
mobilisation, and perpetuate negative feedback loops. These operate via perceived interests and norm
perceptions (as shown in Figure 2). First, workers and party-state insiders may be reluctant to strike/ speak
out if they anticipate harsh penalties such as job loss, beatings, or incarceration. This motivates quiet
conformity (as in China - Franceschini and Nesossi, forthcoming). Collective defiance may also be deterred
by pervasive patron-clientelism (proffering jobs and services, in exchange for political docility). Second, if
workers and party-state insiders never witness critique, they may underestimate support for reform, and
miscalculate the opportunity cost of resistance. This is called ‘pluralistic ignorance’. Pluralistic ignorance is
amplified by authoritarianism, given the costs of dissent. It is less common within governments serving
business elites, since these parliamentarians share an objective material interest in capitalist accumulation.
People only revise their norm perceptions upon seeing widespread critique, mass behavioural change,
regime responsiveness, or top-down authorisation (Evans, 2018; Lohmann, 1994). But persistent repression
deters open dissent, reinforces hopelessness, and deters public critique. Organising remains sporadic,
dangerous, and ineffective. Labour repression persists in a negative feedback loop, perpetuated by
potential dissenters and ruling governments’ perceived interests and norm perceptions.
This negative feedback loop could be interrupted if there is a change in domestic mobilisation or export
incentives. Endogenous domestic mobilisation is extremely unlikely, for the reasons highlighted above. But
domestic mobilisation could occur in the presence of pro-labour export incentives as explained below.
If governments serving business elites anticipate that global buyers or trade partners will reward pro-labour
reforms, they have an economic interest to do so. By contrast, governments prioritising political control
may be reluctant, in need of reassurances from party-state insiders that this will boost growth and strengthen
legitimacy, without jeopardising political control. In both cases, export incentives would only be sufficient
for de jure reforms, i.e. the mere announcement of glasnost (since buyers and trade partners struggle to
monitor conditions on the ground).
Once governments signal glasnost, workers and party-state reformists may become less fearful, and mobilise
for substantive reforms. This shift in interests might catalyse domestic mobilisation, enabling a positive
feedback loop (as shown in Figure 2). When workers and reformists see peers openly challenge labour
repression, they revise their norm perceptions, and become more confident in the possibility of political
change. These shifts in interests and norm perceptions foster more domestic mobilisation, which if
sustained could overcome repressive laws, police brutality, and low pay.
This theoretical framework explicates multiple equilibria in two different political economies of labour
repression, as mediated by shifts in perceived interests and norm perceptions (as shown in Figure 2). But
what counts as evidence for ideational theories? Some argue that decision-makers’ beliefs and perceived
interests only ‘matter’ if they are not reducible to material features of the case (Jacobs, 2014). However,
there is no logical reason why the default explanation should be materialist. Even if our beliefs are perfectly
accurate, they still shape how we process information and make behavioural choices. Beliefs and perceived
interests are thus a necessary part of the causal story, even if not exogenous.
In these ways, this paper offers a novel theoretical approach: seeing people’s reasons for acting as the
underlying drivers of change. By correlating people’s beliefs and expectations with specific events, this
paper helps explain why, how, and when export incentives result in successful labour reforms.
Figure 2: Multiple Equilibria
(4) Case Study Selection and Methodology
Vietnam and Bangladesh are ideal comparisons because they both experienced short-lived export incentives
to reduce labour repression. With all else constant, and only one variable changing, we can examine what
happened before, during, and after incentives subsided. Within-case variation enables us to get at causation.
Vietnam and Bangladesh share basic similarities. Both governments prioritise export-led growth and have
been remarkably successful - with soaring exports, factories, and jobs. Between 2012 and 2017, Bangladesh’s
exports have increased by 8% a year, from $26.8 to $ 39.2 billion. Vietnam’s export growth has been even
faster: 13.5% a year, increasing from $116 billion in 2012 to $220 billion in 2017 (OEC, 2018).
Yet Vietnam and Bangladesh also exemplify the two different political economies of labour repression
described in the theoretical framework. The Government of Bangladesh is a hybrid regime, largely captured
by private business interests. Over the past five decades, it has prioritised export-growth, to advance the ruling
business elites’ material interests, and moderated labour repression accordingly. Since 1991, power has been
transferred between parties, under competitive clientelism. Vast networks of patronage structure political
and economic relationships, impeding horizontal associations of the poor. The ruling party has recently
consolidated political control (Ahmed et al, 2014; Lewis, 2011; Lewis and Hossain, forthcoming;
Moniruzzaman, 2019). Meanwhile, the Communist Party of Vietnam (CPV) prioritises political control. In 1986,
CPV initiated doi moi. Party conservatives were anxious: accepting slow, incremental economic reforms
(conditional on their belief that this would boost growth, create jobs, reduce poverty, strengthen legitimacy,
and thereby cement political control); but resisting rapid liberalisation (for fear of political instability). They
proceeded cautiously, unsure whether international economic integration would further their perceived
interests. Conservatives have become more supportive of economic integration, seeing it as instrumental
to continued dominance. Bangladesh and Vietnam thus exemplify the two different political economies of
labour repression described in theoretical framework. With this case selection, we can examine how
different regimes respond to shifts in export incentives for labour repression.
Methodologically, this paper draws on in-depth interviews with 60+ participants in Hanoi, Ho Chi Minh
City, and Washington, D.C, over five months in 2017, 2018, and 2019. They include senior and junior
government officials; domestic business associations; foreign investors; trade union leaders; International
Labour Office advisors; international non-government organisations; trade negotiators; international
brands; factory managers; and workers. This paper also explores parallels in Bangladesh. This secondary
case helps check the argument.
To understand participants’ perspectives and priorities, I always asked open questions: never leading the
discussion by mentioning possible influences. To gauge perceived interests, I inquired about individual and
organisational goals, conflicting interests, top-down performance metrics, and their consequences. I also
asked how others would react, and how that had changed over time.
Only by listening to protagonists on the ground can we really understand what they perceive as ‘incentives’.
I triangulated interviews with a broad range of actors and institutions, engaged in different aspects and
levels of reform. This helped corroborate and nuance diverse perspectives. Interviews were recorded,
transcribed, and manually coded using emerging themes. I deliberated sought out and assessed wider data
and alternative explanations, to strengthen rigor. To preserve anonymity, names have been changed and
organisations obscured. To understand the macro-trends observed by domestic activists and reformists,
this paper also includes quantitative data on large-scale dynamics.
(5) Before Export Incentives for Pro-Labour Reforms
This section explores what prevailed before export incentives for pro-labour reforms. It details how mass
strikes secured economic but not political concessions over the 2000-10s. Governments in both Vietnam
and Bangladesh raised minimum wages, but continued to thwart independent labour movements. This
constrained workers’ capacity to obtain further economic concessions.
In Vietnam, enterprise-level strikes are permitted as long as they are not coordinated or violent, and pose
no challenge to the Communist Party of Vietnam (CPV). But the Government prohibits independent
labour unions to prevent public critique and protect regime legitimacy.
The Vietnam Confederation of Labour (VGCL) is the only representative of workers permitted, but is
subordinated to the CPV. Therefore, it is not an independent voice of workers. Furthermore, independent
activists are beaten, detained, and arrested (Pham, 2017: 23; Vu-Thanh, 2017). In the absence of a strong,
independent labour movement, private regulation scarcely improves workers’ pay and conditions (Anner,
Within these constraints, Vietnamese factory workers have organised strikes to improve wages and working
conditions. Given tightening labour markets in industrial zones, strikes generally secure material gains.
Norm perceptions can also be traced through quantitative research. To track norm perceptions, surveys can ask respondents to estimate wider support in their
enterprise/ community/ country; or how they expect governments to respond, and their anticipation of repression. could be tra cked over time. As an example of
quantitative work on norm perceptions see Bursztyn et al (2018). This contrasts with surveyors’ tendency to focus on internalised ideologies: “Do you want/believe
200,000 striking workers secured a 30% increase in the minimum wage in 2006, and mandated inflation-
adjusted nationwide annual increases thereafter. In the garment industry specifically, monthly real wages
increased by 40%, between 2001-2011 (WRC, 2013).
These strikes have been publicised by pro-labour journalists. Media reports of successful activism shift
norm perceptions: workers learn that they can improve their conditions by mobilising (Chan, 2011; Do,
2011; Kerkvliet, 2011: 175; Lee, 2006; Siu and Chan, 2015; Tran, 2007). Although garment wages increased,
in 2011 they were still only 29% of a living wage (WRC, 2013).
The Government fears that strikes will jeopardise production, foreign direct investment, social stability, and
their legitimacy as guardians of the workers’ interests (Chan, 2019; Do and van Broek, 2013). The
Government could have violently quashed the strikes and suppressed media coverage (as in Bangladesh and
China), but instead it has tried to pre-emptively address workers’ concerns through trade union reform –
at least at enterprise and provincial levels. This reflects concern for legitimacy, and growing recognition that
workers’ concerns cannot be resolved through the top-down union structure, with management
representation at enterprise level.
So, to prevent strike escalation, some provincial authorities have
supported bottom-up union organising; bypassed enterprise unions; social dialogue; collective bargaining;
and coordinated wage adjustments. However, these remain quiet, careful, subnational experiments (Do,
2011; 2017; Evans, forthcoming).
Within the national leadership, there has always been some support for trade union reform. In 1988, some
senior party and VGCL leaders supported a more autonomous VGCL, accountable to workers (Pham,
2017:23). But in the wake of Tiananmen Square and USSR’s collapse, the CPV leadership became fearful
that critical, independent unions might undermine their hegemony, legitimacy, and credibility.
After a relentless strike wave in 2009, the National Assembly initiated industrial relations reform. Proposals
included the establishment of labour councils at national and enterprise levels, which could be either
VGCL-affiliated unions or workers’ independent representatives. The Ministry of Labour (MOLISA)
specified that they would ‘not replace enterprise unions’. But VGCL reacted angrily by running aggressive
newspaper articles and condemned MOLISA as trying to undermine the working class, the union
movement, the party leadership, and the nation as a whole. MOLISA conceded, and reform stalled (Do,
2011:292). Although the first draft of the 2012 Labour Code originally allowed workers to organise
independently and bargain collectively inside enterprises without VGCL representation, these clauses were
later rescinded. (Pham, 2010: 367).
In sum, some workers, provincial authorities, and senior officials in Vietnam challenged the status quo, but
were rebuffed by a party leadership that prioritised political control. Party-state officials either fell in line,
or were demoted. Interviewed civil servants emphasised the dangers of calling for independent unions.
Anticipating backlash, career-minded civil servants prefer to self-censor. As a VGCL official explained,
some people within VGCL really want to change it. They see the weakness of the union. They see it’s not suitable in the
market economy, but being a fighter [i.e. a singular, dissenting voice] cannot do, one has to get approval from the
organisation’. Without seeing successful resistance, reformists underestimate wider support, and remain
despondent. These norm perceptions of condemnation affect their perceived interests in speaking out,
motivating quiet compliance, which in turn reinforces norm perceptions about the dearth of peer support.
This perpetuates a negative feedback loop.
In Bangladesh, successive governments have sought to boost export-competitiveness by minimising labour
costs. Strategies include under-staffing labour inspectorates, permitting industry self-regulation, repressing
independent labour movements with restrictive legislative and police brutality, while co-opting more
acquiescent trade union leaders. Having competed for political patronage and resources, trade union leaders
are seen as self-interested, corrupt, subservient to political parties, and internally divided (ITUC et al, 2016;
Union leaders are often employed as factory managers (Anner, 2017; Do, 2011; Kerkvliet, 2011: 173; Lee, 2006: 422; Pham, 2017).
Khanna, 2011; Rahman and Longford, 2012; Zajak, 2017). Such clientelism thwarts bottom-up pressure
for regulatory enforcement.
Trade unions were banned in the 1970s under martial law. Even after they were legalised, the registration
of unions still required support from 30% of workers in each enterprise, which is difficult to accomplish in
large factories. Trade unions are prohibited in export-processing zones (which are also exempted from
national labour legislation - Khanna, 2011). 400,000 EPZ workers are thus protected neither by unions nor
labour law (Bair et al, 2018). Conditions are little better outside EPZs: minimum wages and regulations are
rarely enforced, and non-compliance is seldom penalised (Rahman and Longford, 2012).
Minimum wages
in Bangladesh remain the lowest among the major apparel-exporting countries, at USD 0.39 per hour
(Anner, forthcoming).
Labour repression is sustained by regulatory capture and elite ideologies. 56% of politicians have business
backgrounds and thus have a vested interest in business autonomy, deregulation, labour repression, and
low wages (Alam and Teicher, 2012; Berliner et al, 2015b; Hassan and Raihan, 2017; Jahan, 2015). Neither
of the main political parties court organised labour, and both champion free-markets. Ideologically
neoliberal, many politicians may regard deregulation as conducive to exports (rather than an impediment
to labour productivity). They have eschewed alternatives, such as heavily investing in infrastructure and
training (to increase productivity, or reduce delays at ports) (Ahmed and Nathan, 2016).
For their part, manufacturers thwart unionism with hired thugs, intimidation, threats, blacklisting,
dismissals, and false criminal complaints (Ashraf and Prentice, 2019; HRW, 2015; 2017; ILO, 2016).
Surveyed manufacturers explicitly identified low labour costs as key to international competitiveness (above
all other factors, like technology, productivity, market access) (Alam and Natsuda, 2016). Many also bitterly
resent and oppose trade unions (James et al, 2019).
Despite these obstacles, garment workers have militantly demonstrated for higher wages - in 2006, 2010,
and 2014. During the large-scale violent protests of 2006, for example, workers struck at 4000 factories,
burnt down 16 factories, and damaged 50 others. In the aftermath, the employers and the Government
accepted workers’ demands including: the release of arrested workers and the withdrawal of criminal cases;
the reopening of closed factories; better union rights and collective bargaining; a minimum wage hike;
weekly day off; and maternity leave. The Government further established a Minimum Wage Board and
Bangladesh Labour Act (Government of Bangladesh, 2006; Khanna, 2011).
However, many factories chose to disregard reforms agreed after the 2006 unrest, because they rightly did
not perceive sanctions from understaffed, uninterested labour ministries as credible threats (Ahmed et al,
2014; Khanna, 2011; Rahman and Longford, 2012; Siddiqi, 2009). Indeed, the unskilled minimum wage
was only raised to 1,662 taka (then USD$24), not the originally agreed 3,000 taka. Worker mobilisation was
outright banned in 2007, during a state of emergency. Protests that erupted in 2008, 2009, and 2010 were
met with police brutality, which saw the use of rubber bullets, tear gas, water cannons, arrests, and torture
(Khanna, 2011). Workers’ fear of violent reprisals may explain extremely low unionisation rates (ILO, 2014).
Outsiders have supported unions with financial and technical aid. But competition for transnational support
may actually compound union divisions and rivalry, while deterring membership recruitment, democracy,
and accountability (Zajak, 2017:1119; Hossain, 2019). Moreover, workshops do not lessen the reality of
police brutality. And despite the minimum wage increases, the real monthly prevailing wages in the garment
industry actually fell by 2.4% between 2001 and 2011. Prevailing wages were just 14% of the living wage in
Bangladesh. This was true in both 2001 and 2011 (WRC, 2013).
Over the 2000-10s, in Bangladesh, mass strikes did not abate labour repression. Dismissals and detention
deterred further resistance. Onlookers seldom saw successful resistance and thus underestimated wider
support and the possibility of political liberalisation. Norm perceptions, together with the high costs of
The ILO has repeatedly urged Bangladesh to permit unionisation in export processing zones, remove bureaucratic obstacles, and the 30% high membership
threshold requirement (ILO, 2017:50) - to no avail.
unilateral deviation, motivated quiet conformity. This negative feedback loop thwarted workers’ capacities
to realise further economic gains (Anner, 2017; Anner et al, 2018; Locke, 2013).
(6) Export Incentives: Emboldening Domestic Reformists
This section details how both governments introduced pro-labour reforms in response to export incentives
after 2013.
‘The CPV and its government have undergone significant ideological changes evolv[ing] gradually yet
consistently towards further economic liberalisation’ (Thu, 2018:256). CPV leaders have come to believe
that political control is best assured by economic growth, foreign direct investment, international economic
integration, and geopolitical alliances (Elliot, 2012). This shift in perceived interests over the past three
decades is evident from discourse analysis of CPV Congresses, Central Committee, and Politburo
resolutions (Thu, 2018). It reflects two key dynamics. First, by cautiously liberalising markets, Vietnam has
achieved soaring GDP growth and nearly eradicated extreme poverty (World Bank, 2016: 152; 2018).
Export-led industrialisation has strengthened CPV’s legitimacy and control (it has not fuelled working or
middle-class dissent). Given these norm perceptions, CPV leaders increasingly perceive international
integration as furthering their interests. Such cautious, incremental, learning-by-doing is called ‘crossing the
river by feeling the stones’ - in both Vietnam and China. Second, by the early 2010s, there was a pan-Asian
proliferation of FTAs. Constantly comparing themselves to regional peers, CPV leaders feared being left
behind (Thu, 2018:242). Accordingly, they sought to expand and deepen international integration.
The Trans-Pacific Partnership (TPP) and EU Trade Agreement (EVTA) promised greater access to global
markets, stronger international partnerships, and military security. Through TPP, Vietnam was estimated
to gain 8-10% in GDP, a 28% increase in garment exports, and a 14% increase in real wages for unskilled
labourers by 2030 (World Bank, 2016). However, the US Congress insisted upon pre-ratification reforms,
including the freedom of association for labour. The EVTA also called for labour reforms, though less
stringently. These export incentives made it politically acceptable for party-state members to openly discuss
independent trade unions, which had hitherto been regarded as seditious or even as agents of US
imperialism. When the ILO cautiously convened discussions on ‘international labour standards’,
within Vietnam were able to present ‘independent unions’ as a matter of international integration.
But CPV conservatives remained nervous that independent trade unions might threaten regime legitimacy
and stability. They resisted TPP as ‘premature and too far-reaching(Ebbighausen, 2016; Pham, 2017).
Then, in 2014, China deployed an oil rig in a disputed region of the South China Sea, triggering widespread,
violent anti-China protests throughout Vietnam. Reformists exploited this geopolitical threat and domestic
discontent in order to persuade their conservative colleagues that Vietnam must diversify and deepen
international relationships in order to offer a bulwark against China (see also Do, 2016; Hoang, 2015; Pham,
2017: 18; Vuving, 2017).
The Vietnamese party-state has always included partisans of a Vietnamese ‘glasnost’. Within the National
Assembly, the Ministry of Labour, and the VGCL reformists had long privately favoured independent
unions but been too scared to speak openly. TPP incentivised, legitimised, and emboldened open
discussions. In a televised interview, VGCL President Dr Dang Ngoc Tung expressed VGCL’s readiness
to work with new unions. This top-down authorisation alleviated reformists’ reluctance to speak out. As
more reformists spoke out openly, others realised wider support, and became emboldened to express
support. This fostered a positive feedback loop. Anticipation buzzed on Facebook and online forums;
interviewed Vietnamese activists thought this might be a stepping stone to democratisation. Reformists
became increasingly more vocal, and some official trade union leaders excitedly reimagined themselves as
the leaders of new independent unions.
These themes are highlighted below, in five separate interviews:
ILO Convention 98 on the Right to Organize and Collective Bargaining; and Convention 87 on Freedom of Association and Protection of the Right to Organize.
‘The idea for change is here already, for many years… There are many people who want the labour code to move in
this direction [independent unions]. The idea for trade union renovation has been here for a long time. TPP just
provides an excuse for the group who wants those things to happen to move forward senior civil servant.
‘When TPP wrapped up, everyone in VGCL was so eager for change’ retired VGCL leader. ‘Everyone?’, I
sceptically interjected. ‘The technical departments were all very happy within independent unions, because at least
it brings change into the trade union system’.
‘There were many good initiatives to reform VGCL, but the top leaders didn’t prioritise that. They didn’t think it
was necessary. That’s partly because the Central Committee assess VGCL leaders based on their ability to serve the
party… But people who prioritise the national interest were happy about TPP, and independent unions’ - senior,
retired VGCL official [translated].
‘The idea first came from TPP, it’s very clear... People don’t pressure… People will follow the law, they will not
demand for the law to change VGCL official (who privately supports independent unions).
Without the TPP, the (labour) reforms would have taken place only after 2020 Deputy Minister (Viet Nam
News, 2016).
A new consensus emerged, now supported party conservatives. Indeed, the new General Secretary Nguyen
Phu Trong (elected in 2011, re-elected in 2016, then elected President in 2018) has a track record of being
anti-Western, pro-China, pro-state control (Ives, 2016; Vuving, 2017). As Trong outmanoeuvred Prime
Minister Dũng (who sought closer ties with the USA), some observers predicted an ‘era of counter-
reformation(Brown, 2016). But, as Trong has always stressed, his primary objective is regime preservation
(Vuving, 2017). He and other party conservatives came to perceive TPP as furthering their interests. Thus,
at the closing meeting of the 14th plenum of the XIth Party Central Committee, Trong declared,
‘With the country’s experience from 30 years of doi moi (renewal), and global economic integration along with the
creativity, efforts and united resolve of the entire Party, people, army and business community, we are confident that
we can overcome any challenges, and seize opportunities afforded by the TPP agreement for rapid and sustainable
development’ (Vietnam News, 2016).
This statement reflects a common theme in my interviews: conservatives were confident that the potential
rewards outweighed the risks. Their norm perceptions and perceived interests have changed with
experience and debate. In 1986, CPV’s Central Committee feared the unknown effects of international
integration. But in 2015 they voted in support of TPP. Government Decision No 2528/QD-TTg ordered
the ratification of ILO core conventions. In February 2016, ‘the United States-Vietnam Plan for the
Enhancement of Trade and Labour Relations’ was agreed, permitting independent unions within both
enterprises and as a national federation. This included an enforcement mechanism for penalising non-
compliance (USTR, 2016). On 6th November 2016, the Central Committee issued Party Resolution 6 on
international integration, permitting ‘workers’ organizations not affiliated to the Vietnam General
Confederation of Labor’. All participants attributed this to TPP.
Resolution 6 was only a de jure, not de facto, change. CPV conservatives merely sought to placate the USA,
while hobbling ‘independent’ unions, according to my participants.
Yet this announcement was still
important for lessening fears of repression; motivating open discussions; enabling reformists to realise
wider support; and thereby overcoming coordination problems. This echoes economic liberalisation (doi
moi) four decades ago. The Sixth Party Congress gave prominence and legitimacy to Southern reforms by
This statement may overstate support for reform. It is impossible to know what proportion of party-state leaders and cadres privately supported independent trade
unions. But the point that open critique was deterred by desire for career progression (which was contingent upon party loyalty) was widely reiterated in my sample.
A remarkably similar process occurred in 2006. Just before acceding to the World Trade Organisation, the Governmen t of Vietnam briefly tolerated the existence
of independent unions, though did not announce any policy changes, and the international incentive to do so was not sustained (HRW, 2009).
See also Slater and Wong, 2013 on Asian authoritarians ceding multipartyism believing they could maintain control.
providing a ‘green light to open discussion’; and enabling ‘fence breakers’ to share rather than conceal their
improvisations (Elliot, 2012:51; Malesky, 2008).
Export incentives similarly motivated pro-labour reforms in Bangladesh. The horrifying collapse of the
Rana Plaza factory complex in 2013 (which killed over a thousand garment workers) was a global front-
page horror story.
Consumers, campaigners, union federations, international institutions, and trading
partners expressed grave concerns. ‘Following the disaster, domestic stakeholders feared that foreign buyers
would abandon the country en masse’ (Bair et al, 2018). This was a huge threat as the garment industry
accounted for 87% of Bangladesh’s exports and 4 million jobs (ibid). Nervousness about export-growth
spawned openness to reform.
[T]he way media had been publicizing the image of the industry, there had been assumptions that the industry would
not survive without global compliance measures, so we were supportive and positive about the enactment of the
agreements - industry representative (quoted in Alamgir and Banerjee, forthcoming:18; see also
Hossain, 2019; Khan and Wichterich, 2017).
‘[A]fter Rana Plaza, the Bangladesh Garment Manufacturers and Exporters Association proudly claimed the
industry has eliminated any bars to forming trade unions inside factories. Amid mounting pressure from international
retailers for ensuring safety compliance and worker rights, some factories opened door to labour unions to keep the
business growing’ (Hammadi, 2015).
The EU and USA urged the Government of Bangladesh to improve safety and permit freedom of
association. The EU
threatened trade sanctions: ‘we will put a fire under their feet a little bit’ (FT, 2013).
After concerted campaigning from Democrats and labour unions, the Obama administration announced it
would suspend Bangladesh’s trade privileges, for ‘insufficient progress by the Government of Bangladesh
in affording Bangladeshi workers internationally recognized worker rights’ (USDOL, 2013).
To salvage its reputation, the Government hastily announced pro-labour reforms. It agreed to revise the
Labour Act, uphold workers’ rights, improve occupational health and safety, stipulate safety committees,
and strengthen the national labour inspectorate. Workers could unionise without disclosing their supporters
to factory owners. The Government also permitted the re-registration of the Bangladesh Center for Worker
Solidarity, and withdrew criminal charges against its leaders (Rahman and Longford, 2014). Criminal charges
were filed against the building owner and five factory owners. The Government and the Bangladesh
Garment Manufacturers and Exporters Association (BGMEA) sought to reassure buyers that factories were
safe (Ashraf and Prentice, forthcoming; Hossain, 2019).
However, the Government did not change the 30% threshold for union formation, or EPZs’ exemption
from labour laws. Bangladesh remained non-compliant with ILO core labour standards. Many reforms
were performative promises intended to placate the international community. There is little evidence of
genuine commitment or increased government funding for pro-labour reforms.
Rana Plaza also triggered domestic outcry and politicised garment workers. According to interviewed trade
union leaders, the Rana tragedy strengthened the class consciousness of Bangladeshi garment workers,
angered and horrified that their very lives were now imperilled by factory conditions (Hossain, 2019). One
Likewise in China, protestors tactfully adopt official language, to signal compliance, while pushing for reform (Distelhorst 2017; O’Brien and Li, 2006; Perry, 2012).
Two factories in the complex had just been audited, against the Business Social Compliance Initiative (Donaghey and Reinecke, 2018:22).
The EU accounted for 61% of Bangladesh’s garment exports (BGMEA, 2014). It threatened to suspend Bangladesh’s duty free and q uota free access to the EU
(FT, 2013)
The suspension of U.S. trade privileges signalled grave consternation, but was not in itself materially significant (as these did not previously cover garments).
Likewise in 2004, US officials threatened to revoke trade preferences unless the Government of Bangladesh rescinded its ban o n trade unions in Export Processing
Zones. This move was publicly supported by Bangladeshi labour activists, though US insistence subsided, and in 2008 the gover nment expressly prohibited organising
in EPZs (Siddiqi, 2009).
labour organiser called Rana Plaza hotyakando (an incident of mass murder) (ibid). Protesting garment
workers also gained public sympathy (ibid).
But domestic outcry was not the primary driver of reform. Reforms were introduced specifically to placate
the international community and restore business confidence. Government and BGMEA made huge efforts
to reassure foreign buyers and governments (ibid). In announcing labour reforms, the Chairman of the
Bangladeshi Parliamentary Sub-Committee on Labour Reforms stated, ‘I am hoping this will assuage global
fears around this issue’ (Reuters, 2013, emphasis added). Bangladeshi labour activists and opposition
parliamentarians explicitly criticised the government ‘for enacting the law in a hurry to please foreigners’
(ibid). That is, activists who might want to take credit for these reforms instead rebuked them.
Although pro-labour reforms were introduced in response to external incentives, Bangladeshi activists
could now mobilise for further change and registered 228 new unions in 2013-2014 (Anner, forthcoming).
We do not know how many of these unions represented workers’ interests. Some of these may have just
been ‘yellow unions’ (Hossain, 2019). But Zajak (2017:1017,1120) finds that soaring registrations were
‘much more than just a paper exercise’. Unions strengthened their organisational skills by recruiting new
members, securing their trust, collecting fees, strengthening internal democracy, and experimenting to
overcome management repression. Interviewed women union leaders anticipated a more responsive, non-
violent state. Feeling ‘hopeful’, over 50,000 workers went on strike and secured a 77% increase in the
minimum wage (from USD 39 to 68 per month, Alamgir and Banerjee, forthcoming).
Very reluctantly, the Government also permitted ‘the Bangladesh Accord on Fire and Building Safety’
[hereafter The Accord’]: a five-year, legally-binding, multi-stakeholder agreement between international
trade union federations, 180 lead buyers, and seven Bangladeshi trade unions. Buyers committed to finance
major repairs. Manufacturers committed to building safety inspections, remediation, public disclosure,
elected worker-management Health and Safety Committees, as well as safety training programmes (Accord,
2015). Again, this was only permitted in order to preserve export markets. The BGMEA and Government
both preferred ‘the Alliance’: an alternative multi-stakeholder agreement, without worker representation
(Donaghey and Reinecke, forthcoming).
The Accord improved building safety. Since 2013, the Accord has inspected 1,600 factories; identified
132,000 high-risk fire, structural, and electrical concerns; and corrected 97,235 of these findings. Accord
inspectors called for the immediate evacuation of 50 buildings - preventing another Rana Plaza (Anner,
2018). Participating factories must also establish democratically-elected worker-manager Health and Safety
Committees and complaint mechanisms. As of March 2018, 197 worker complaints had been resolved
(Donaghey and Reinecke, forthcoming). Importantly, this intervention was enabled by and contingent upon
a shift in export incentives.
(7) Reversing Export Incentives; Reversing Pro-labour Reforms
Three days after the Communist Party of Vietnam issued Resolution 6 , permitting independent trade
unions, Trump was elected President and withdrew from TPP.
The National Assembly removed the
Labour Code revision from the legislative agenda. Party leaders no longer anticipated that the USA would
reward pro-labour reforms with increased market access. Progress stalled.
In 2018-19, Vietnam signed two further trade agreements: TPP minus the USA (CPTPP) and the EU-
Vietnam Trade Agreement (EVTA). Party leaders perceived both economic and geopolitical gains from
trade (Viet Nam News, 2018), but they no longer believed that such rewards were contingent upon labour
reforms, at least not immediately.
In 2018, a senior Vietnamese negotiator explained, there is no specific
Clinton may have done the same, as promised in her presidential campaign.
For full details, see Chapter 13 on “Trade and Sustainable Development” This
reflects a difference between US and EU trade deals more broadly, with the former typically requiring stricter labour conditionalities - Leeg, 2018. In June 2019,
commitment on ILO Convention 87: no specific pressures, no specific requirements, nothing like TPP’. Furthermore,
parties to CPTPP have signed side letters stipulating that Vietnam will not be sanctioned for non-
implementation of labour clauses over the next five years.
The withdrawal of pro-labour export incentives bitterly disappointed Vietnamese activists.
If the EU don’t demand it, the Vietnam Government will just leave it there… The right approach is for international
partners to be very loud, very aggressive, while local partners are quietly supportive. If the EU is soft and local
partners are loud, it is counter-productive and very dangerous for us.
In 2018, CPV’s leadership was keen to centralise control and cracked down on dissent, no longer having
TPP’s strong economic incentive to do otherwise. Vietnam joined the Belt and Road initiative and re-
affirmed geopolitical and economic ties with China. The 2018 Cyber Security Law is very similar to China’s:
authorising the removal of seditious expression; and mandating service providers disclose user data to
authorities (Trinh, 2017). In July 2017, the Information and Communications Minister reported that
‘Google and Facebook had removed 3,367 clips with bad and poisonous content after being requested to
do so by the Ministry of Information and Communications. Facebook removed more than 600 accounts
that have violating content’. The Government has also mobilised over 10’000 online propagandists (just as
in China). In June 2018, people were arrested for demonstrating against the draft law on special economic
zones. Independent activists and bloggers are harassed, intimidated, assaulted, and detained (Human Rights
Watch, 2019a).
In 2018, Vietnamese NGOs struggled to gain government approval for their existence, activities, and
events (as also noted by HRW, 2019a). Without such permits, NGOs cannot receive international funding
(as per Decree 93 - an old policy, now stringently enforced). Vietnamese human rights activists detailed
increased police intimidation, in separate interviews:
The scrutiny of CSOs has increased. The Government delays their projects. We have to go through several ministries
to get approval, and ministries delay. Projects [approval] are hard, and heavily controlled by government… We need
approval for every activity. We need a license to operate from the government. It’s very difficult for us to operate...
Everything is a negotiation, with public security and government. We try not to be too confrontational, and we know
they might cancel our event, e.g. force the venue owner to cancel the contract, or cut off the electricity… The political
environment is more difficult now, because TPP ended.
Under TPP, it was very open, people were prepared to talk about it [Freedom of Association]. Only now it’s become
How can NGOs bring cases to the higher level? At the country level, we cannot do anything. There is no
mechanism… The expert meeting is very closed... ‘Freedom of Association’ is out of the discussion.
Disturbed by the repression in Vietnam, Members of the European Parliament (MEPs), who must approve
the treaty, called for EVTA negotiations to mandate independent trade unions (Human Rights Watch,
2019b; Tremosa, 2018; Kirton-Darling, 2019). This resurgence in export incentives may help explain why
Vietnam’s National Assembly amended the labour code in November 2019. This code ostensibly allows
workers to join or form a representative organisation of their own choosing at enterprise level; prohibits
anti-union discrimination and interference; and clarifies collective bargaining. The Government also ratified
ILO Convention 98, prohibiting management interference in unions.
Vietnam ratified ILO Convention 98, but this only precludes manageme nt interference in VGCL unions. Only in 2023 has Vietnam pledged to ratify Convention 87:
allowing workers to establish and join unions of their own choosing.
As global outrage subsided and Bangladeshi products were never boycotted, the government regained
confidence in the efficacy of labour repression as a tool of export-orientated development. The perceived
interests of Bangladeshi politicians and manufacturers reverted to their original pre-Rana state.
The Government deliberately delayed implementation of the revised Labour Act; intimidated trade unions;
interfered with their elections; and increasingly refused registration (Bair et al, 2018; ILO, 2016). By 2016,
the Government was rejecting nearly half the trade union applications in Dhaka and three quarters of those
in Chittagong Division (ILO, 2017:49; Zajak, 2017). Even when local authorities do register unions,
factories may seek a court injunction and freeze union activity for several months (ibid). Thousands of
workers went on strike in December 2016 calling for the minimum wage to be tripled. 1,600 garment
workers were fired. Invoking the 1974 Special Powers Act, the Government arrested and detained 35 labor
organisers and workers.
In January 2019, one garment worker was killed and another 50 injured after
police fired rubber bullets, water cannons, and tear gas at 5,000 demonstrators, protesting the wage
structure. Factory managers have since dismissed 11,600 workers (as estimated by IndustriALL, 2019).
Faced once again with labour repression, workers came to anticipate rejections, and ceased trying to
unionise (see Figure 3). ‘[I]n the current climate, there was little point in attempting to register a union’ (Bair
et al, 2018). As a result, only 4% of surveyed workers said there was a trade union in their factory. Seldom
seeing successful unionising, only 12% of surveyed workers valued the right to unionise (Kabeer, Huq, and
Sulaiman 2019). Without a strong independent labour movement, real wages have fallen by 6.5%, since
December 2013 (Anner, forthcoming).
Figure 3: Trade Unions in Bangladesh’s Garment Sector
Source: Solidarity Center, Bangladesh; presented in Anner, forthcoming.
Government commitment to building safety also appears to have waned. The national regulatory body has
not overseen proficient inspections, remediation, enforcement against non-compliant factories,
transparency, or fair resolution of workers’ safety complaints (according to EU, 2018:5,34; ILO, 2019; see
also Daily Star, 2017). The Committee observed that many of the changes it has been requesting for a
number of years had either not been addressed or addressed only partially’ (EU, 2018:11). Remediation
rates are low. And the government has sought to terminate the Accord. ‘We don’t need them anymore’ –
insisted the Commerce Minister (Daily Star, 2018).
The Government only agreed to release the workers and organisers because five image-conscious brands threatened to boycott the 2017 Dhaka Apparel Summit
(Ashraf and Prentice, 2019).
Bangladeshi politicians and employers have backtracked on reforms, precisely because none of their fears
about a global backlash against Rana has materialised. To the contrary, international buyers have continued
to source from Bangladesh and even stepped up their financial pressure on suppliers.
First, despite brutal police crackdowns in 2016 and 2019, European and US firms never curtailed purchases
from Bangladesh (Ahlquist and Mosley, 2018; UNComtrade, 2019). Consequently, exports actually grew in
the wake of the Rana Plaza tragedy: from 2013 to 2017, they increased from $24.5 to $31.4 billion
(UNComtrade, 2019).
Second, those international buyers who joined the Accord never made good on their commitment to co-
finance safety upgrades to factories. Thus Bangladeshi garment manufacturers, now burdened with the full
costs of complying with the buildings requirements of the Accord, were unwilling to foot the bill (Alamgir
and Banarjee, forthcoming; Khan and Wichterich 2015; Rahman and Rahman, 2018). The BGMEA sought
to terminate the Accord (Bair et al, 2018; James et al, 2019).
Third, despite the 2013 minimum wage hike, lead European EU and American US buyers have continued
to pressure Bangladeshi factories for cost reductions. Since Rana Plaza, they have paid suppliers about 9-
10% less per unit in all major product categories (Anner, forthcoming); and between 2011 and 2015, the
lead times required by international buyers fell by 8%. Fashion buyers are also increasingly asking for
smaller orders and varied styles. All these trends contributed to a 13% fall in Bangladeshi manufacturers’
profit margins in 2011-16 (ibid).
In compensation, Bangladeshi manufacturers increased overtime and work intensity; outsourced
production to unsafe factories; and generally became less compliant in labour standards (ibid; Berik, 2017).
‘Our buyers continue to threaten us, saying, if you don’t want to take our orders, we will go elsewhere cheaper. But
factories cannot produce cheaper without cutting corners on workers’ rights explained by the BGMEA (quoted
in James et al, 2019).
‘The factories bear all the brunt of additional expenses while the signatory brands keep on bargaining for cheaper
prices. It is as if owners alone are responsible for improving the workplace conditions while the buyers will not spend
a single penny for the purpose’ – a factory owner complained (Daily Star, 2018).
Figure 4: Bangladesh: Labour Rights in Practices and Prices
Source: Anner, forthcoming.
The actions of international buyers have reinforced the dominant narrative amongst Bangladeshi politicians
and manufacturers that their garment industry thrives by being the ‘cheapest’ (Alam and Natsuda, 2016;
Dhaka Tribune, 2019). This perceived interest predominates in the absence of countervailing (pro-labour)
incentives. Indeed, in 2016, Bangladesh exported more t-shirts than its three closest competitors by
achieving the lowest unit cost (Anner, forthcoming).
(8) Conclusion
This paper has argued that domestic activists and reformists can harness export incentives to improve
workers’ rights in global supply chains.
To recall, many governments repress independent labour organisations to keep costs low and maximise
exports. Domestic mobilisation remains sporadic, ineffective, and dangerous. Never seeing successful
mobilisation, activists and reformists remain despondent, doubting wider support and responsive
governance. These norm perceptions reproduce quiet conformity, notwithstanding private critique.
Without organising collectively, workers struggle to secure wage hikes and contest anti-union legislation.
This negative feedback loop is perpetuated by export incentives for labour repression and norm perceptions
of ineffective mobilisation. But, governments (that prioritise export-growth) may reduce repression given
pro-labour export incentives. Domestic reformists may then speak out more openly (as in Vietnam), and
activists take to the streets (Bangladesh). Through mobilising en masse, activists and reformists realise wider
support, become emboldened, secure pro-labour concessions, revise their norm perceptions, and agitate
for further substantive reforms. They overcome the negative feedback loop (Figure 2).
The alternative hypothesis (export incentives alone) is not consistent with the available evidence. Despite
the lure of increased market access, Vietnam’s ratification of TPP was not inevitable. Party conservatives
strongly resisted TPP for fear that independent unions would jeopardise regime control. Risk-averse party
conservatives did not perceive export incentives as in their interests, so were strongly opposed. But, given
the potential economic gains, they did permit more open discussions on international labour conventions.
Reformists within the party-state became less fearful of repression, voiced support for independent unions,
and realised wider approval. They revised their norm perceptions, and overcame pluralistic ignorance. Now
emboldened, they convinced conservative colleagues that regime stability was best secured by broadening
geopolitical alliances, boosting jobs through exports, and international integration. Through internal debate,
conservatives came to see export incentives as furthering their perceived interests. This case suggests that
we cannot predict whether governments will be swayed by export incentives, outcomes are contingent upon
domestic debate and mobilisation (which may shift expectations and perceived interests). To misquote
Blyth (2003), export incentives do not come with an instruction sheet. Meanwhile in Bangladesh, export
incentives only motivated de jure reform. Mass strikes ensured a 77% hike in the minimum wage.
The other alternative hypothesis (domestic activism alone) is also not consistent with the evidence. First,
domestic activists and reformists had long challenged labour repression, but had been unsuccessful. Second,
regulatory bodies in Bangladesh had long been captured by the manufacturers, and the activists were unable
to gain political influence prior to the policy reforms. In Vietnam, the leadership had been more centralising
and conservative from January 2016, before they announced support for independent unions. Third,
interviewees (including those directly engaged in policy) attributed reform to export incentives. Fourth and
most importantly, when export incentives were reversed, both Bangladesh and Vietnam resumed labour
repression. The resumption of labour repression also counts against alternative hypotheses that trade
improves human rights through persuasion and emulation, i.e. exporters adopting new beliefs about
appropriate labour standards (Greenhill, 2010). Taken together, these four types of evidence strongly
suggest that Vietnamese and Bangladeshi leaders only implemented pro-labour reforms to promote exports.
This paper’s comparative approach was crucial to testing the alternative hypotheses and revealing the
shared, underlying causal mechanisms. If one focused on Vietnam, one might infer that the key driver was
the pre-FTA ratification reforms. By looking at Vietnam and Bangladesh in tandem, we realise the
significance of export incentives, in general. And by connecting macro-level changes to protagonists’
motivations, this paper explicates the full causal chain. Effective domestic mobilisation (whether by labour
activists or party-state reformists) is conditional on pro-labour export incentives from trade partners. By
contrast, qualitative research on labour activism often treats national political economies as closed systems,
or only considers transnational relations in relation to firms and social movements not trade partners
(Brookes, 2019; Zajak et al, 2017). There seems scope for further analysis of the evolving synergies between
domestic mobilisation, government export strategies, and geopolitics.
One cautionary note. Even if pro-labour export incentives had endured over a twenty-year period, we
cannot assume that a tiny smattering of weakly organised activists/ party-state reformists could have
secured substantive change. Major obstacles remained. First, the Bangladeshi textile industry competes by
keeping prices low. Without higher productivity, improved quality, or shorter delays at ports, exporters
would still have strong incentives for labour repression to maintain low-cost production. Second, the
Communist Party of Vietnam maintains control by containing public critique. Even if the US had stayed in
TPP, CPV leaders would still have strong incentives to hobble a strong, independent union federation. Third,
across the Asian region, authoritarianism is on the rise. This may sap reformists’ hopes and expectations of
Importantly, even if workers’ rights did improve in targeted countries, this would not demonstrate the
efficacy of trade-labour conditionalities in improving labour rights in the global aggregate. The underlying
problem of labour repression in global supply chains is that buyers prioritise low costs, which incentivises
cost-cutting at the expense of labour. Threatening one country with trade sanctions may just lead global
buyers to source from another in a global game of whack-a-mole.
Thus the net effect of targeting a single
country may be to improve rights in one country but worsen them in another.
Therefore, this paper has only shown the causal impact of export incentives in specific countries and
situations, not how they should be designed in the long-term. Going forward, we need to understand why
and how high-income countries might entrench pro-labour export incentives in all global supply chains
(without accelerating automation and jeopardising jobs). Corporate accountability is one option - making
companies liable for abuses in their supply chains. This might incentivise more scrupulous sourcing. Labour
repression could then cease to be an economically competitive export strategy.
Countries are more likely to democratise if their neighbours do so (Gleditsch and Ward, 2006; Haggard and Kauffman, 2016).
After the EU threatened Cambodia with trade sanctions, Bangladesh’s exports soared. Buyers may have shifted, to avoid tariffs and maximise profits (Apparel
insider, 2019).
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... Інституційні передумови результативності економічних досягнень В'єтнаму проаналізовано в роботі Красноперова П. [2], суперечливий вплив глобалізації та індустріалізації на стан ринку праці у В'єтнамі відображено в праці Angie Ngoc Tran та Irene Nørlund [3]. Відповідь на питання щодо соціальної ціни забезпечення експортоорієнтованості в'єтнамського бізнесу отримано в дослідженні Alice Evans [4]. Результати багаторічних спостережень щодо впливу якості інституційного середовища на інноваційну спроможність малого бізнесу В'єтнаму відображені в нещодавніх роботах Vu Hoang Nam та Hoang Bao Tram [5]. ...
... в систему захисту прав працівників. Так, В'єтнаму довелося лібералізувати власне трудове законодавство, щоб приєднатися до Транс-Тихоокеанського партнерства [3][4]. ...
... Much like the Accord, ad hoc initiatives such as these created spaces where the government, brands, NGOs, and trade bodies could work together to implement certain activities. Between 2012 and 2017, despite some anticipations that Bangladesh may eventually lose the apparel market due to several industrial accidents, its exports have increased by 8% a year, from $26.8 to $ 39.2 billion (Evans 2020). ...
The paper discusses how a key post-Tazreen/ Rana Plaza initiative, namely the Accord on Fire and Building Safety in Bangladesh (Accord), a transnational/ multisectoral initiative meant to address worker's health and safety at the Ready-Made Garments industry has gone into a transformation and nationalized in Bangladesh. The transformation indicates not only friction between the Accord and the local business elite but also a clear collaboration between the government and the local business elite when it comes to questions of governance of Bangladesh's garments sector. Through reviewing newspaper reports and analyzing some government statements, and other secondary sources, the paper builds around an increasingly important set of literature on neoliberal global order and its forging of global connections and import in the global south.
Despite a sizable literature on the labor market effects of maternity leave regulation on women in developed countries, how these policies affect women’s work in developing countries with a large informal sector remains poorly understood. This study examines how extending the maternity leave requirement affects women’s decision to work in the informal or formal sector in Vietnam. We use a difference-in-differences approach to evaluate the 2012 Amendments to the Vietnam Labor Law, which imposes a longer maternity leave requirement than before. We find that the law increases formal employment and decreases unpaid work among women. This is driven by women switching from agricultural household work to employment in the private formal sector, especially in the manufacturing industry and among the middle-skilled occupations such as plant and machine workers, craft and related workers, as well as clerks.
Full-text available
After the economic success of East Asian economies such as Japan, South Korea, Hong Kong and Taiwan, many countries in the region copied the economic formula of developing export-oriented manufacturing industries, attracting foreign direct investment (FDI), integrating into and moving up global value chains (GVCs) with strong technological progress. Unfortunately, none of these ‘following’ countries in Asia have achieved the level of economic success of the original four East Asian ‘tigers’.
Full-text available
The manufacture of ready-made garments (RMG) for global markets took hold in Bangladesh in the 1980s because the country had wage levels among the lowest in the world and a huge reserve army of labour available for exploitation, and its policymakers were averse to introducing labour standards and allowing unionization of this sector because of a fear of losing foreign currency earnings. The Bangladeshi public’s perception of the existing union movement as corrupt was used to justify the resistance to further unionization. Consequently Bangladesh soon became a preferred manufacturing location for many outsourcing transnational apparel companies (Dannecker, 2002; Kabeer, 2004; Rock, 2001a; Siddiqi, 2004). Here we see an illustration of the race-to-the-bottom thesis of globalization. The ruling elites in Bangladesh were able to pursue such policies effectively because of their control of an overdeveloped State, a product of colonialism (Alavi, 1979). By 2010/11 there were 5,150 garment factories in Bangladesh employing 3.6 million people (see table 5.1). Yet labour unions in Bangladesh largely ignored the RMG sector in the 1980s and efforts at unionization since 1990 have had very limited success. This chapter explains why labour unions have failed Bangladesh’s garment workers over the past 30 years. It is based upon a review of the historical literature, extensive documentary research, and in-depth interviews with labour union officials, industrial relations experts and garment workers conducted by the first author in Dhaka in 2007.
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Since the beginning of the 21 st Century we have witnessed a proliferation of Preferential Trade Agreements (PTAs) in the Asia Pacific. China has been at the forefront of this development. Initially, China's PTAs were very shallow and mainly aimed at building friendly relationships with developing countries. However, over time China has started to negotiate deeper PTAs with developing and developed countries alike. This notable shift has thus far been understood to result from three broad motivations: China's desire to access key export markets; the facilitation of regional production networks; to address resource security concerns; and/or to further geostrategic interests and political influence. We propose that these motives are not sufficient to fully account for China's new generation trade agreements. We suggest that China is increasing its integration into the world economy to push for domestic marketization and reform by credibly committing to trade liberalization through PTAs. Deep and comprehensive PTAs tie a country's hands and constrains it to obey a set of rules that permit little leeway for violating commitments. In order to successfully implement and enforce PTA commitments, China has also gradually strengthened its regulatory state by investing in regulatory capacity and capability in the field of trade policy. We test the plausibility of our argument through an in-depth analysis of China's PTAs signed since 2000 and find evidence that China's PTAs are indeed in part driven by a desire to lock-in domestic economic reform and that this has gone hand in hand with a strengthening of its regulatory state
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Most research on private governance examines the design and negotiation of particular initiatives or their operation and effectiveness once established, with relatively little work on why firms join in the first place. We contribute to this literature by exploring firms’ willingness to participate in two recent, high-profile private initiatives established in the aftermath of the Rana Plaza disaster in the Bangladesh ready-made garment (RMG) sector: the Accord on Building and Fire Safety and the Alliance for Worker Safety in Bangladesh. Using novel shipment-level data from U.S. customs declarations, we generate a set of firms that were “eligible” to join these remediation initiatives. We are able to positively attribute only a minority of US RMG imports from Bangladesh to Accord and Alliance signatories. Firms with consumer-facing brands, publicly-traded firms, and those importing more RMG product from Bangladesh were more likely to sign up for the Accord and Alliance. Firms headquartered in the USA were much less likely to sign onto remediation plans, especially the Accord.
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During the past decade Bangladesh has shifted from a competitively clientelistic two‐party system towards a dominant‐party democracy. This article analyses how the ruling party has consolidated partisan political control at the local level. Using qualitative field data from 2004 and 2016, and drawing on a post‐structural analysis of the state, it shows how this extension of power has been achieved locally through interaction between formal and informal political initiatives. Four main types of informal activity are documented, through which the extent of local political competition has been reduced: circumvention, capture, brokerage and the creation of new organizations. These insights into the changing nature of Bangladesh's long‐standing partisan politics highlight how the state's capacity to deliver local services, allocate resources and maintain stability has been enhanced through the ruling party's control of local government structures, its elimination of political opposition, and its reshaping of local patronage arrangements.
We study the effects of Fair Trade (FT) certification of coffee on producers and households in Costa Rica. Examining the production dynamics of all Costa Rican coffee mills from 1999–2014, we find that when global coffee prices are lower and the FT guaranteed minimum price is binding, FT certification is associated with a higher sales price, greater sales, and more revenues. We also find that certification reduces the probability of a mill closing down and exiting the industry. Looking at households, we find that certification is associated with higher incomes for farm owners. Part of this is due to a transfer of incomes from intermediaries whose incomes decrease due to FT. We find no effect of FT on unskilled workers, who are the more disadvantaged group within the coffee sector.
Bangladesh’s garments workers have served as both an emblem of that country’s rapid social and economic progress, and of the precarities of labour in global value chains. Based on an understanding of how disaster politics have played out in Bangladesh’s history, this article explores whether and how the Rana Plaza disaster has been a critical juncture in the politics of the sector, resulting in a shift in power relations that empowers workers to demand and secure their rights. Drawing on a framework developed by Mark Pelling and Kathleen Dill for the analysis of the politics of natural disasters, the article explores the aftermath of the 2013 factory collapse in which 1,134 factory workers were killed. The article examines changes in workers’ own agency and resources, and in their relationships to the state and transnational actors. The article concludes that while the disaster was a turning point in key respects, it has not – unlike previous major disasters in Bangladesh – generated an elite consensus over the priority of workers’ rights and in particular of trade unions. Workers are more empowered than in the past but have yet to fully reverse their historical associational and structural disempowerment.
This paper re-examines why global collective action problems persist, and how to overcome them. Drawing on 140 interviews with campaigners, politicians, and businesses in 10 European countries, it suggests that many activists are stuck in a despondency trap. Never seeing radical reform, they lower their ambitions, and invest in more feasible but sub-optimal alternatives. This creates a negative feedback loop, in which the dearth of radical reform becomes self-fulfilling. But if reformists see advances at home and abroad, they may become more optimistic about collective mobilisation and break out of their despondency trap. This is shown by tracing the drivers of ground-breaking legislation. From 2018, large French firms must mitigate risks of environmental and human rights abuses in their global supply chains, or else be liable. This bill – the world’s first of its kind – was vociferously contested by businesses. But French campaigners and politicians persisted for four years, because they saw reasons for optimism. These include growing international support; public outcry; the French political culture (state intervention, and distrust of multinationals); together with a Centre-Left Government. Optimism galvanised relentless mobilisation. Legislative success in France then delivered a positive shock to activists across Europe, who were emboldened to launch similar campaigns and escape their despondency trap.