CHOICE's toy industry survey

Our survey that safety is only part of the complex issues we face when buying toys for our children.
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  • Updated:6 Jun 2008

06.Codes of conduct

CSR initiatives are most commonly implemented through corporate codes of conduct. Three of our 17 survey respondents (Coles, Hasbro and Lego) have their own code and seven are sourcing all or some their toys from ICTI Care Process factories --- follow this link for the details.

The table below shows how these codes compare to the Ethical Trading Initiative (ETI) Base Code. (We also included Disney’s code of conduct because it’s a major company.) ETI consists of retailers, brands, trade unions, charities and campaigning organisations that work together to tackle the complex questions posed by ethical trade. Its Base Code sets minimum requirements for labour standards. While none of these codes fully meets the minimum requirements of the ETI Base Code, the companies that have a code or ethical trading guidelines in place ought to be commended for at least having these issues on their agenda.

Ahead of the competitors

 The Lego Group seems to be well ahead of its competitors in terms of engaging with and understanding the complexity of the issues. However, only 3% of its toys are made in China, the rest in Denmark and the Czech Republic, where it might be easier for Lego to ensure acceptable conditions and a robust regulatory environment exists. Lego is also the only company in our survey that’s a signatory to the UN Global Compact, which asks companies to “embrace, support and enact, within their sphere of influence, a set of core values in the areas of human rights, labour standards, the environment and anti-corruption”.

One point all codes fail to address sufficiently is ‘regular employment’, which is of particular concern in China where migrant workers are all too often employed on temporary contracts. Most codes (all but Lego’s) also fail to actively engage with the critical issues of working hours and appropriate wages that meet basic needs. They either make recommendations that have no teeth, or refer to law. Many employers, however, circumvent the law, using ‘bonuses’ for extra hours worked.


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  Does the code equal or exceed the ETI Base Code on the following issues?
Code (in alphabetical order) Forced labour Child labour Health and safety Wages and benefits Working hours No discrimination Regular employment Harassment and abuse Freedom of association and collective bargaining
Coles Ethical Sourcing Code Yes Partly Mostly Partly Partly Mostly No Yes Mostly
Disney Code of Conduct Yes Partly Partly No Partly Yes No Yes Partly
Hasbro Global Business Ethics Principles Yes Partly Partly No Mostly Mostly No Mostly No
ICTI Code of Business Practice (A) Yes Mostly Mostly No Partly Partly No Yes Yes
Lego Code of Conduct Yes Yes Yes Mostly Mostly Yes No Yes Partly

Table notes

(A) This code is used by the following survey respondents: Funtastic, Hunter Overseas, Kids II Australia, Moose Enterprise, Russ Australia, Woolworths and, at times, by Hasbro and Lego instead of their own code.